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Winter Carnival 2024

Yubani Noriega,
Supervising Legal Assistant - Copyright Enforcement Division
Law Firm of 

Higbee & Associates
February 17th, 2023

Yubani,

Thanks for the email. It was nice talking to you. You asked me to send you my best offer. Before I do that let me explain something first. 

I asked Brian Ayer if he had checked out our website at West St Paul Antiques . He say YES and he also assured me that your law firm wouldn't be peppering West St Paul Antiques with lawsuits. So with that in mind I made an offer to save time and money. The offer was for $4200 which I thought was a fair offer at the time. He rejected the offer within days of making it.. So I took my offer off the table for good. Brian then said that he would be sending it to litigation. I believed him. So I started preparing for litigation.  Now you are asking me for my best offer. In my opinion that was my best offer. So if I was going to make your law firm a second offer, it would definitely be less than the original offer made. So with that in mind can you tell me what you would accept. 

I am puzzled by something that Brian Ayer said. I asked Brian a question around the middle of January. The question was about your case, Claim Number: 516719 dated September 19th, 2018 against West Saint Paul Antiques. This is why I am so puzzled, he blew me off. He answered so quickly it's  like he had  prepared a statement. He said "Oh you were closed so we didn't pursue it." Not true, we were open then. We closed due to Covid on March 14th, 2020 and we remained closed for 15 months. So I can get this straight, so I'm clear about this, all I have to do is close to have your law firm not pursue these cases. Was Brian not telling me the whole truth at that time.  I'm curious so can you respond to this issue and clarify this for me.

There are many issues with these cases. I'll bring up one more in this email today. PicRights did not make several efforts to resolve these copyright matters with West St Paul Antiques.  As stated in your claims. The several attempts to resolve a case was in 2017 not in these cases. Compare all the cases. PicRights reference Number: 1447-7737-5436 attempts made to resolve that case were made on November 15th & December 13th, 2017 & January 3rd, 2018 before sending the case to your law firm. The first letter I received  from Higbee & Associates was on September 19th, 2018 for that case. Your Claim Number: 516719. In these cases 6PEEMQ,  XQVVPY, L60051, N5MMOZ & OQ993N RicRights sent all these letters on June 20th, 2022. I received those letters several days later. On all of those letters it reads: " We would like to resolve this time-sensitive issue as soon as possible and request that you respond within 14 days from the date of this correspondence." I received your firm's  first letter dated July 6th, 2022 followed by four additional letters dated the 7th, 13th, and two on them July 26th, 2022. Draw your own conclusions on that. I already have.

 I'll look forward to hearing back from you. If you have any questions for me don't hesitate to send me an email or call me at your leisure. 

Think over what it would take to resolve these issues so I don't have to spend a lot more of my time on it.  I can send you a link to the work that I've done so far. If you would like me to send this link just let me know. Keep in mind that this is not the final draft, it's a work in progress for me. This would show you and your associates things that bother me about these cases.

I hate to sound like a broken record, but all the images / photos / exhibits in question by PicRights and your law firm are all informational and educational images / photos with no profit or gain by myself or West St Paul Antiques.  Send me a reasonable offer after you review all the facts in the link below with your associates, so that we can stop dancing around and resolve these issues.

Have a great day and thanks for all your time in this matter.

Sincerely,

Floyd Ruggles,
On behalf of West St Paul Antiques

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This website contains, in various sections, portions of copyrighted material not specifically authorized by the copyright owner. This material is used for educational purposes only and presented to provide understanding or give information for issues concerning the public as a whole. In accordance with U.S. Copyright Law Title 17 U.S.C. Section 107, the material on this site is distributed without profit. More Information

Information presented based on medical, news, government, and/or other web based articles or documents does not represent any medical recommendation or legal advice from myself or West Saint Paul Antiques. For specific information and advice on any condition or issue, you must consult a professional health care provider or legal advisor for direction.

I and West Saint Paul Antiques can not be responsible for information others may post on an external website linked here ~ or for websites which link to West Saint Paul Antiques. I would ask, however, that should you see something which you question or which seems incorrect or inappropriate, that you notify me immediately at floyd@weststpaulantiques.com  Also, I would very much appreciate being notified if you find links which do not work or other problems with the website itself. Thank You!

Please know that there is no copyright infringement intended with any part of this website ~ should you find something that belongs to you and proper credit has not been given (or if you simply wish for me to remove it), 
 just let me know and I will do so right away.

Website Terms and Condition of Use Agreement
also known as a 'terms of service agreement'

By using this website, West Saint Paul Antiques . Com, you are agreeing to use the site according to and in agreement with the above and following terms of  use without limitation or qualification. If you do not agree, then you must refain from using the site.

The 'Terms of Use' govern your access to and use of this website and facebook pages associated with it. If you do not agree to all of the Terms of Use, do not access or use the website, or the facebook sites. By accessing or using any of  them, you and any entity you are authorized to represent signify your agreement to be bound by the Terms of Use.

Said Terms of Use may be revised and/or updated at any time by posting of the changes on this page of the website. Your continued usage of the website, or the facebook site(s)  after any changes to the Terms of Use will mean that you have accepted the changes. Also, any these sites themselves may be changed, supplemented, deleted, and/or updated at my sole discretion without notice; this establishes intellectual property rights by owner (myself).

It saddens me to include a Terms of Use for West Saint Paul Antiques . Com, but we all realize it is something that is necessary and must be done these days. By using the website, or facebook for West Saint Paul Antiques, you represent that you are of legal age and that you agree to be bound by the Terms of Use and any subsequent modifications. Your use of the West Saint Paul Antiques sites signify your electronic acceptance of the Terms of  Use and constitute your signature to same as if you had actually signed an agreement embodying the terms.