CABINET BOUCHARA • AVOCATS Spe c lallstes en Droit de I a Proprlete l ntellectuelle

Bv Registered Letter : RK 00 128 367 4 FR

Cease and desist letter

Ell Complaints Monsieur Matthew Chan P.O. Box 6391 Columbus, GA 31917 United States

Paris, December 19th, 2016

Subject: GETTY IMAGES I EXTORSIONLETTERINFO.COM

Sir,

I am the legal adviser of the company GETTY IMAGES.

The company GETTY IMAGES is the biggest global database. Its main activity is the supply, development and worldwide distribution of onl ine images, videos and music under which many communication professionals made use.

Indeed, it enjoys an established reputation both domestically and internationally.

However, my cl ient found many comments which seriously jeopardize its practice on your web site www.extortionletterinfo.com, and more precisely at the following addresses:

http://www. extortionletterinfo. com/ http://www. extortion letteri nfo. com/how-to-get -he I p-with-yo u r -extortion-letter/ http://www.extortionletterinfo.com/eli-phone-support-call-with-matthew-chan/ http://www. extortion lette ri nfo. com/attorney-oscar -m ichelen-expla ins-his-getty­images-defense-letter-program/ http://www.extortionletterinfo.com/2012-update-expansion-of-attorney-oscar­michelens-defense-letter-program/

Indeed, the combination of the words « GETTY IMAGES » and « extortion » or «arnaque» (fraud) on the search engine Google bring us directly to your web site.

17. rue du Colisee 75008 Pans- Tel : 01 42 25 42 30- Fax : 01 42 25 42 31 mfo@ cabmetbouchara.conJI················

Furthermore, the regularity of the methods and of the proceedings used by our client had also been questioned, which have been described as « legalized extortion» and« Extortion Letter Scheme».

Please find bellow some of the litigious statements :

Welcome to ExtortionLetterlnfo.com (Ell) Mission Statement

"ExtortionLetterlnfo.com (ELl) is dedicated to reporting information and providing commentary on Getty Images (and other stock photo) Settlement Demand Letters. ELl is a privately-owned and privately-managed website. Every effort is made to provide factual information and professional opinions regarding Getty Images' (and the respective companies~ "practice" of issuing "Settlement Letters" that we consider 111egalized extortion". As Lead Contributors of this website, we believe what they are doing is technically legal but ethically and morally questionable. "The Letter" bullies and preys upon the legal ignorance of the letter recipients. This website attempts to discover, report, and comment on the facts in a civil and orderly way. This website also provides assistance in defending unaware and unintended victims of this Letter."

Why is This Being Called "Legalized Extortion" and an "Extortion Letter Scheme"?

"This is a descriptive and colloquial term for Getty Images' deliberate, malicious, bullying, and presumptuous letter campaign that engages in what is tantamount to legalized extortion. The letter in its entirety is both well-worded and well-constructed. It has been clearly been well thought out. Because of the deliberate construction and planning that goes into this letter campaign, it qualifies as a Scheme.

The Letter automatically presumes guilt of the recipient. The letter recipient is expected to provide proof of their innocence. In effect, the letter recipient is presumed guilty unless they prove their innocence.

Although the letter does provide for the possibility that the letter recipient was unaware and unintended of the alleged infringement, the Letter takes a heavy-handed and unforgiving approach of stating that they are responsible for all alleged "damages and liability". The Letter automatically presumes Getty Images has been "damaged" whether or not that is actually true or proven.

Because this scheme relies heavily on the letter recipients ignorance of due legal process and people's inherent fear of legal conflict as a result of that ignorance, it is considered by many as legalized extortion.

Given the overall assessment of the situation, the term "legalized extortion" was coined to better describe Getty Images very aggressive

letter campaign."

How to Get Help With Your Extortion Letter October 29, 2016 Matthew Chan Ell Premium Support, General Q

"Since 2008, we've had thousands of readers discover the ELl website and ELl Forums after they have received a Getty Images, Masterfile, Corbis, or some other stock photo agency's or photographer's "extortion letter". Over the years, many have attempted to contact us through phone and email asking for help. Early on, we tried to help but eventually there were just too many requests for help and the help being requested overstepped reasonable time boundaries. So, we are unable to provide free one-on-one help. However, we have provided several help and support options. If you get an extortion letter, this is what you need to do:

1. The very first thing you need to do is to CALM DOWN and TAKE A BREATH! Tens of thousands of these extortion letters have gone out over the years. You are far from being alone. Getting an extortion letter from out of the blue is upsetting but not the end of the world. Your credit will not be ruined, you will not have to file for bankruptcy, and (most of the time) you won't be sued. For most people and their situation, the bark is much worse than the bite.

2. This is one is a no-brainer. You should immediately remove ALL copies of the allegedly infringing images from your web server. Even the "hidden" ones. If it is anywhere on your web server, you are at risk. Also, if you have other images you don't have receipts for or authorization to use, you should remove those as a precautionary measure. If you can get one extortion letter, you get more. And unfortunately, we know plenty of people who have received a few extortion letters."

Ell Phone Support Call with Matthew Chan October 29, 2016 Matthew Chan Ell Premium Support£

"Some of the more notorious copyright extortionists and settlement demand letters I have personally researched, reported, and consulted on include:

• Getty Images • Picscout • License Compliance Services (LCS) • Masterfile • Garbis • Vincent K. Tylor I J. Stephen Street • Photo Attorney I Leslie Burns I Carolyn Wright • BWP Media I Sanders Law • Higbee & Associates (Mathew Higbee) • Adlife Marketing & Communications • DeBoer IP • lmageRights International • Woolf, Gafni & Cirlin • Linda Ellis I Linda's Lyrics I John W Jolin (Dash Poem) ."

Update & Expansion of Attorney Oscar Michelen's Defense Letter Program October 29, 2016 Matthew Chan Ell Premium Support, General Q

"One of the ongoing goals of the Defense Letter Program is to efficiently serve many people as cost-effectively as possible. Because of Oscar's extensive experience gained from the last 8 years of representing stock photo extortion letter clients, I am happy to announce, on Oscar's behalf, the Expansion of the no-frills Defense Letter Program to include legal representation against the following extortion letters:

• Getty Images Settlement Demand Letters • Picscout Settlement Demand Letters • License Compliance Services (LCS) Settlement Demand Letters • Masterfile Settlement Demand Letters • Photo Attorney Settlement Demand Letters • Superstock Settlement Demand Letters • Garbis Settlement Demand Letters • Vincent K. Tylor Settlement Demand Letters • Hawaiian Art Network Settlement Demand Letters • Linda's Lyrics (Dash Poem) Settlement Demand Letters • Sanders Law Settlement Demand Letters • DeBoer IP Settlement Demand Letters • Adlife Marketing & Communications Settlement Demand Letters

lmageRights Settlement Demand Letters • And man others . "

According to the judgment given by the First Civil Division of the French Supreme Court on the 12th of July 2012, this is particularly intolerable and reprehensible.

Those acts of gross disparagement seriously damage GETTY IMAGES' image.

This article discredits the services offered by my client. Moreover, it calls into question its seriousness and honesty by accusing it, in a totally unfunded manner, to be the author of dubious proceedings.

According to a judgment given by the Commercial Division of the French Supreme Court on the 15th of December 2009, disparagement is to discredit someone by spreading criticisms and malicious information about it or its business methods.

Moreover, on the 5th of June 2002, the Paris District Court ruled that interactions between web users on discussion forums which comments obviously contain fraud imputations and questionable practices exceed the limits of the liberty of expression. Indeed, it reaches denigration which impair the honor and do not respect the dignity to whom it is directed.

Thus. as the registrant of the web site in question. you are responsible for the information disclosed on it, notably regarding their reliability, veracity or completeness.

Under the judgment given by the First Civil Division of the French Supreme Court on the 5 th of July 2006, you shall observed the most elementary prudence concerning the content of the comments disclosed.

Yet, in this case, those statements have undeniably exceeded the right to criticize.

Furthermore, those statements incite to violate GETTY IMAGES' rights, which is particularly intolerable.

As a result you shall withdraw every indication disparaging my client on your website.

If you do not comply with this letter of formal notice within 8 days from the date of its receipt and, in any case, before the 27th of December, I had been instructed to initiate all appropriate action against you.

We truly hope we will not go that far, and that we will quickly manage to settle this matter.

Pursuant to our professional rules, we are available to discuss this case with your usual adviser.

Yours sincerely,