Join the GIGO Family: Exclusive Opportunity for Wholesalers

Ref: U.S. Certificate Serial No. 88848448 | USTF10166556
CC: Buyer, Block Party Store – 8853 Santa Monica Blvd, West Hollywood CA
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Dear Ms. Cañas and Mr. Van Rossem,

This letter is issued on behalf of TIGERXHORSE LLC, regarding the continued and unauthorized use and distribution of our registered short design, protected under U.S. Certificate Serial No. 88848448 | Ref: USTF10166556.

Despite your prior assurances dated August 28, 2024, affirming that all infringing garments had been destroyed, we have obtained clear evidence that these designs continue to be marketed and sold in the United States, in direct violation of U.S. intellectual property laws.

We have officially notified our legal counsel, Dennemeyer & Associates LLC (Chicago), and we are prepared to proceed with immediate legal action should full compliance not be met.

Violations and Required Actions:

1. In-Store Infringement – Block Party (8853 Santa Monica Blvd):
- On April 2, 2025, infringing shorts identical to our protected design — including back flap and strap details — were discovered for sale at Block Party, West Hollywood.
- These shorts were removed immediately, and the store’s buyer has been cc’d on this correspondence.

2. Unauthorized Distribution by Agent (Mr. Richard Van Rossem):
- Mr. Van Rossem, you are hereby instructed to:
– Cease all wholesale, retail, and trade show activity involving TIGERXHORSE designs.
– Immediately discontinue offering or promoting any infringing styles at events such as MAGIC Las Vegas or to any U.S./international retailers.
– You are not authorized to sell or distribute any TIGERXHORSE or derivative product.

3. Digital Infringement – Website & Social Media:
- You must immediately remove all infringing designs from:
– Company websites
– Instagram and Facebook platforms
– Online retail or promotional listings
- Please note:
– We have already filed copyright takedown requests through Meta (Instagram/Facebook).
– We are also preparing a formal complaint to your website hosting provider to request full removal of infringing content.

- 🔴 Cease & Desist:
Immediately halt all production, promotion, and sale of infringing garments.

- 📸 Proof of Destruction:
Provide dated photo or video evidence that all remaining units have been destroyed, including warehouse stock or third-party inventory.

- 📍 Retailer Disclosure:
Submit a full list of all U.S.-based retailers or partners who received these products.

- 📨 Customer Communication Evidence:
Provide proof of communication with these accounts regarding product withdrawal.

- ✍️ Signed Legal Acknowledgment:
Confirm in writing that:
– You acknowledge the infringement
– You guarantee all further production of this design has ceased
– You commit to future compliance with U.S. and international IP law

The unauthorized sale of counterfeit shorts at $40 USD severely undermines TIGERXHORSE’s brand integrity and pricing model, and damages our relationships with authorized retail partners.

Failure to comply by 5:00 PM PST, April 10, 2025 will result in the following immediate actions:

- Filing for injunctive relief and damages in U.S. Federal Court
- Initiating U.S. Customs seizure orders for any future inbound infringing shipments
- Coordinating takedowns through Meta, your hosting provider, and payment platforms

This is your final legal notice. We expect your full cooperation and compliance without delay.

Sincerely,
Cathy R.
Senior Legal Counsel
TIGERXHORSE LLC
contact@tigerhorse.com.au
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On Sep 3, 2024, at 3:41 PM, Tiger X Horse | Contact <contact@tigerhorse.com.au> wrote:

Dear Ms. Cañas,

Thank you for your prompt response and for acknowledging the issue regarding the unauthorized use of our design. We appreciate your cooperation in resolving this matter.

However, given the seriousness of the infringement and the fact that these products were produced and distributed without our authorization, we must ensure that all remaining units are permanently removed from circulation. As such, we require the following:

1. Proof of Destruction: Please provide documented proof (such as photographs or certificates) that all remaining units of the infringing shorts, including any in your inventory, have been destroyed.

2. Details of Communication with U.S. Customers: Kindly provide evidence that you have contacted any customers in the United States who received these garments, and any steps you have taken to retrieve or destroy the remaining units.

3. Confirmation of Compliance: We also request a formal written confirmation that no further production or distribution of the infringing design will occur, and that any future designs will be fully compliant with intellectual property laws.

We believe that these steps are necessary to ensure that this matter is fully resolved. We look forward to receiving the requested documentation within ten (10) business days of this email.

Please do not hesitate to contact us should you require any further clarification.

Sincerely,
Cathy.r
Legal
TIGERXHORSE LL

On 28 Aug 2024, at 8:35 am, Gigo Underwear <info@gigo.com.co> wrote:

Good morning TIGERXHORSE LLC /GLOBAL,

We apologize if we caused any inconvenience; it was not our purpose, just a customer sent us a reference to make a similar design and we did not see any inconvenience, because we used different fabrics, and we changed the design, although we did use the 4 buttons on the handles (which I understand was the biggest inconvenience).
The production we got from that reference was 40 units per color distributed in 7 sizes, for a total of 145 units of total production

SANDLER MATERIAL S M L XL 2XL 3XL TOTAL
SHORT CARGADERAS – NEGRO 10 10 10 5 3 2 40
SHORT CARGADERAS – VERDE 10 10 10 5 3 2 40
SHORT CARGADERAS – BEIGE 5 5 5 5 3 2 25
SHORT CARGADERAS – AZUL 10 10 10 5 3 2 40
145
and most of the production was sold to the client who suggested the design because he needed them for a party in Bogota, Colombia.
Some units were sent to customers in the United States, but they were very few and the customers should no longer have them.
We will follow up on the garments with customers in the United States and let them know what is possible.

Regards,

Luza Cañas
GIGO / FETICHE
Cell Phone: (+57) 3105522063
info@gigo.com.co
www.GIGO.com.co

El jue, 22 ago 2024 a las 17:47, Tiger X Horse | Contact (<contact@tigerhorse.com.au>) escribió:
19 august 2024

Richard Van Rossem
Brands 2 Con-nect

Luza /producer &exporter
C.I.ZIG ZAG WEAR S.A.S.
NIT-900 .363 932-1
CARRERA 70 #30 A 144 medellin Colombia.
57-4 3007864050

RE: IMMEDIATE CEASE AND DESIST – WILLFUL COPYRIGHT INFRINGEMENT AND BREACH OF DESIGN RIGHTS UNDER GLOBAL INTELLECTUAL PROPERTY LAWS

VIA REGISTERED MAIL AND EMAIL

Dear Miss Liza @.GIGO / MrRichard Van Rossem ,

1. INTRODUCTION AND PURPOSE OF LETTER

I act for TIGERXHORSE LLC,TIGERXHORSE AUSTRALIA ,TIGERXHORSE GLOBAL, the registered owner of Design Registration No. 201416360, which pertains to the original and distinctive design known commercially as the “Romey Strap Shorts.” This letter is to formally demand that you and all entities associated with Brands 2 Connect and GIGO C.I.ZIG ZAG WEAR S.A.S. immediately cease and desist from all activities that infringe upon my client’s exclusive intellectual property rights. This includes, but is not limited to, the unauthorized reproduction, distribution, marketing, and sale of any garments or products that incorporate any elements of the protected design.

2. DESCRIPTION OF INFRINGING ACTIVITY

It has been brought to my client’s attention that your company continues to engage in the unlawful production and sale of products that are materially identical, or substantially similar, to the “Romey Strap Shorts,” despite previous notifications of infringement. These products replicate my client’s original design features, including but not limited to the unique yoke structure, front block design, and distinctive strap mechanisms. The continued production and distribution of these infringing products constitute a clear and unequivocal violation of my client’s intellectual property rights, specifically under the provisions of the Berne Convention and the Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS), both of which impose obligations on your company as a participant in international commerce.

3. LEGAL GROUNDS AND CONSEQUENCES

Your actions represent a willful infringement of my client’s design rights and copyright, as protected under the aforementioned international agreements and relevant domestic intellectual property laws. Willful infringement is treated with particular severity under the law, as it demonstrates an intentional and deliberate disregard for the intellectual property rights of others. As a consequence, you and your company are exposed to a range of legal liabilities, including but not limited to:

- Statutory damages: Under applicable law, my client is entitled to recover statutory damages for each instance of infringement, which may be significantly increased in cases of willful infringement.
- Actual damages and disgorgement of profits: My client is also entitled to recover any actual damages incurred as a result of your infringing activities, as well as any profits that you have unlawfully obtained through the sale of the infringing products.
- Injunctive relief: My client will seek injunctive relief from the courts to prevent any further production, distribution, or sale of the infringing products.
- Legal fees and costs: You may also be held liable for my client’s legal fees and costs associated with enforcing their intellectual property rights.

4. DEMANDS

In light of the foregoing, you are hereby directed to comply with the following demands within ten (10) business days of receipt of this letter:

1. Immediately cease and desist from the production, distribution, marketing, and sale of any products that infringe upon my client’s design rights and copyright, specifically those resembling the “Romey Strap Shorts.”

2. Permanently remove all infringing products from all points of sale, including but not limited to physical retail locations, online stores, and third-party platforms.SHOWINGS.

3. Provide a full accounting of all sales, profits, and inventory related to the infringing products, including detailed records of quantities produced, sold, and currently held in inventory.

4. Deliver up for destruction all remaining inventory of the infringing products under your control.

5. Provide written confirmation of your compliance with the above demands and a legally binding undertaking that you will refrain from any future infringement of my client’s intellectual property rights.

5. CONSEQUENCES OF NON-COMPLIANCE

Failure to comply with these demands within the specified timeframe will leave my client with no alternative but to pursue all available legal remedies, including initiating formal legal proceedings against you and your company. Such proceedings may include, but are not limited to, claims for damages, injunctive relief, and an account of profits. My client will also seek an award of legal fees and costs associated with such proceedings.

Please be advised that should litigation become necessary, your continued willful infringement may result in enhanced damages being awarded against you, potentially amounting to treble the actual damages, as well as an injunction preventing further infringement.

6. RESERVATION OF RIGHTS

This letter is not intended as a full and exhaustive statement of all the facts and matters relevant to this dispute, nor is it a waiver of any of my client’s rights or remedies, all of which are expressly reserved. My client reserves the right to take any further action they deem necessary to protect their intellectual property rights.

I look forward to your prompt and full compliance with the demands set out in this letter.

Yours sincerely

Cathy.r.

HR LEGAL
TIGERXHORSE LLC /GLOBAL

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