Dear Mr. Turber:
My law firm represent Joy Enterprises. Joy Enterprises had asked us to make you and your associate cease certain improper actions which have been directed at my clients employees. To that end, we are prepared to pursue any necessary legal remedies in the state of Florida and we have arranged for local counsel to be prepared to seek appropriate legal remedies in Nevada. We have also been hired to bring appropriate legal action against you for libel and interference with my clients business.
You and Mr. James have harassed my clients female employees at various shows, including most recently at the Shot Show in Orlando, Florida. You have insulted my clients employees, harassed them and made improper sexually harassing comments and gestures. Additionally, your agents have violated the rules and regulations of the shows by photographing my clients wares and then denying to the show operators that you took photographs.
You have wrongfully and improperly stated that Joy Enterprises has violated U.S. patent laws by selling knives which you claim are protected by the patent laws. You verbally threatened my clients female employees with criminal violations in order to try to obtain some sort of business advantage. Your threats may constitute a crime in the state of Florida, depending on the language used and the threats made.
Since the show, you have maliciously threatened my client and its principals of a crime with the specific stated purpose of forcing them to refrain from selling their legal products, telling them that they must get rid of your inventory. You have threatened them with harassment and followed through with your threat. In so doing, you have committed a felony under Florida Statutes Section 836.05. This has been reported to the authorities and has been assigned case number 03-0644.
You have also maliciously slandered and libeled my client and its principals. You have called them thieves and accused them of knocking off other peoples designs. Those statements are false and were intended to harm my clients reputations and business.
You have specifically claimed that my client has improperly copied your model number 21688, the Mini-Raptor. Nothing could be further from the truth. My client did not copy any design and in fact Kevin Tan designed the particular knife my client sells while David Winch designed the knife you sell. A copy of Mr. Tans design is enclosed. Mr. Tans design designation is TG003" and has nothing to do with your product. You have claimed that your design is patented; my clients have never seen any design, registration or patent on your Mini-Raptor. I invite you to forward anything you have directly to me.
There was some questions raised about other products of my client referred to in our catalog as TG002", TG004" and G001". None of these designs were copied from anyone but are the work of Mr. Tan. Copies of Mr. Tans design criteria for these products is also included.
Although you have apparently denied it, you violated the rules of the Orlando trade show by taking photographs of my clients products and display area. This will be reported to the show operators.
The company you claim you own in Florida, World of Weapons, Inc., is not an active corporation listed with the state of Florida. The company was dissolved by the State of Florida because the proper filings have not been made for over four years. You are not listed by the State as an officer or director of any active company with the name WOW in it.
At any future shows, you are instructed as follows:
A. Your people will not come to the display booth operated by Joy Enterprises;
B. Your representatives will never again harass or talk to my clients employees;
C. Your representatives will stop taking photographs in violation of the shows rules; and
D. Any correspondence or communication concerning this matter shall be directed to me and not to my clients.
We have engaged local counsel, John Ryan, Esquire, who is prepared to take immediate and emergency steps should you appear at and act improperly at the Las Vegas show.
Your behavior is that of a schoolyard bully and I assure you that the courts in Florida and Nevada will not tolerate it. You have already greatly damaged my clients and you should stop now to avoid even more severe repercussion.
Sincerely,
John L. Bryan, Jr.