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Sc-Lite Rccfing Prcducts, Inc. -5- March 7, 2DDl
unccmmcn practice fer ccrpcrate defendants in unfair ccmpetiticn
litigaticn tc file a bankruptcy petitien after being fcund liable
fer substantial damages, yen shcnld anticipate that Skyline wculd
name Sc-Lite's ccrpcrate cfficers as individual defendants tc
enhance the prcbability sf ccllecting the damages awarded by a
ccurt. The list cf defendants wculd alsc include sc—Lite*s sales
representatives whe disseminated the false statements enumerated
abcve, as well as Sc-Lite's distributnrs er dealers whc were
similarly invclved.
Q; SKYLINE'§ PEE-LIIIQ&[IQN DEMANDS
Skyline demands that Sc-Lite prcmptly ccnsult with a trial
attcrney familiar with the false advertising and unfair
ccmpetiticn ccncepts set fcrth abcve and prcvide Skyline with a
prcmpt meaningful written respcnse, including as a minimum:
1} assurance that each act cf unfair ccmpetiticn set
fcrth abcve will be premptly terminated;
2} An enumeratisn sf the specific steps te be
implemented by Sc-Lite te destrey its existing -
inventsry cf advertising materials such as
Exhibits 1 and 2 as well as any inventcry
currently in the hands nf S¤·Lite's distributcrs
cr dealers; and
3} Prcviding ccpies cf mcdified sc-Lite
advertisements fcr use in publicaticns such as the
Exhibit 3 and 4 magazines where all false and
misleading statements have been deleted.
2; EUM ARY AND CONQLUSIQN
The ccnduct cf sc-Lite, its cfficers, sales representatives
and distributcrs as identified abcve has repeatedly vielated 35
U.S.C. 5 292 and 15 U.S.C. 5 1125{a}. Skyline demands a
meaningful written respcnse frcm Sc-Lite‘s trial ccunsel by nc
later than Friday, March 3D, EDO1 addressing each cf the issues }
presented abcve. `
After receiving that letter, Skyline's president will
ccntact yen tc schedule a face-tc-face meeting at the Phcenix,
Arizcna cffices cf its trial ccnnsel. Ycur trial ccunsel shculd
plan tc attend that meeting.
The cutccme cf that meeting will determine whether Sc—Lite,
its president, its sales representatives and selected Sc-Lite
r Case 2:O3—cv-OOO67—SI\/II\/I D0cument131-7 Filed O4/28/2006 Page10f2

Sc-Lite Rccfing Prcducts, Inc. -6- - March T, 20mi
dealers will be sued fcr unfair ccmpetiticn in the Phcenix,
Arizcna Federal District Ccurt.
Very truly ycurs,
CAB SUTTé§\& THOMAS, PLC
1 1
1 { '__.-·" I · * F' { ·'•·
I ‘-*‘ -·i I-.-
G. Watkins III
YEiQcm
TGW:lSbd
encls.
cc: Skyline Manufacturing, Inc.
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Case 2:03-cv-00067-SMM

Document 131-7

Filed 04/28/2006

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Case 2:03-cv-00067-SMM

Document 131-7

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