AI Cease & Desist Letter

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED

April 5, 2026

Marcus Williams
1421 Harbor View Drive
Seattle, Washington 98101

Re: CEASE AND DESIST — Unauthorized Use of Copyrighted Photographs

Dear Mr. Williams:

This letter is sent on behalf of Jennifer Rodriguez of 500 Pine Street, Suite 1200, Seattle, Washington 98101. We write to demand that you immediately cease and desist from the unauthorized use of Ms. Rodriguez's copyrighted photographic works.

STATEMENT OF FACTS

Ms. Rodriguez is a professional commercial photographer holding valid copyright registrations for her "Pacific Northwest Series" and "Urban Landscapes Collection" (U.S. Copyright Reg. Nos. VA 2-301-445 and VA 2-301-446), protected under the U.S. Copyright Act, 17 U.S.C. § 101 et seq.

It has come to Ms. Rodriguez's attention that you have, without authorization, license, or consent: (1) reproduced and publicly displayed at least fourteen (14) of her registered photographs on your commercial website; (2) used those photographs to commercially promote your real estate business; and (3) implied ownership or licensing rights you do not possess. These unauthorized uses were first discovered on or about March 15, 2026, and have been ongoing since approximately January 2026.

LEGAL BASIS

Your actions constitute copyright infringement in violation of 17 U.S.C. § 501. Ms. Rodriguez holds the exclusive rights under 17 U.S.C. § 106, including the exclusive right to reproduce, distribute, and publicly display her works.

Under the Copyright Act, Ms. Rodriguez is entitled to: (a) actual damages and profits attributable to infringement; or (b) statutory damages of up to $30,000 per infringed work, or up to $150,000 per work for willful infringement (17 U.S.C. § 504); plus attorneys' fees and costs (17 U.S.C. § 505).

DEMANDS

You are hereby DEMANDED to, within fourteen (14) days of this letter:

1. Immediately and permanently remove all of Ms. Rodriguez's copyrighted photographs from your website, social media, marketing materials, and all other platforms;
2. Provide written confirmation to the undersigned that all infringing content has been removed and will not be republished;
3. Preserve all records, communications, and documents relating to your acquisition and use of the photographs;
4. Provide a full accounting of all revenue derived from or business attributable to use of Ms. Rodriguez's works.

RESERVATION OF RIGHTS

Ms. Rodriguez expressly reserves all rights and remedies available under the Copyright Act and applicable law, including injunctive relief, monetary damages, and attorneys' fees. Nothing herein constitutes a waiver of any right or remedy.

Failure to comply with these demands within the specified timeframe will result in Ms. Rodriguez pursuing all available legal remedies, including filing suit in the United States District Court for the Western District of Washington without further notice.

Govern yourself accordingly.

Sincerely,

[Attorney Name]
[Law Firm Name]
[Address | Phone | Email]

cc: Jennifer Rodriguez