GJD Enterprises LLC d/b/a Pedal Chile
Michael D. Lancaster
1408 Willow Road
Hendersonville, NC 28739

CopyCat Legal PLLC
3111 N. University Drive
Suite 301
Coral Springs, F L 33065


This response is to your cease and desist letter and settlement communication
received on the 18 th day of January, 2023. Thank you very much for notifying us of
this apparent infringement on the plaintiff’s alleged copyright. Please note that we
use the term “alleged” not to be disrespectful of the claim, but to point out that
simply the image is in fact correctly registered with the Register of Copyrights, or
that the original artist has consented to, and continues to consent to CopyCat Legal
representation. We dutifully respect and support the rights of the artist in such cases
and understand that knowing copyright infringement is not to be
taken lightly. However, we would be foolish to simply send you monetary
compensation toward this claim without having complete access to all of the facts

involved. We assure you that any unauthorized use of said image on our website was
an oversight.
I lived in Telluride for 4 years. Most of the photographs on the website were mine and
from one of my friends. I grabbed some of the photographs off of his Facebook page.
For the image in question, I saw it on his page and I assumed it was one of the many
photographs he took since the widely shared photograph had no watermarks or ID
Our company has no insurance as we have run ZERO tours, especially as we were
founded right around covid, even before Covid, Chile experienced mass civil unrest
due to proposals for a new constitution. Therefore, the photograph was only viewed
by a handful of people associated with our business since the website does not run
As a result of receiving your letter, we have taken steps to ensure that all other
images used on our website are our own images or licensed for our use. In response to
your claim, we immediately removed the image in question from our site. Please note
that our immediate removal of the image in question is in no way an admission of
knowing infringement on our part. We have removed the image in good faith and in
respect of the original artist’s rights. We feel that this immediate removal of the
image in question completely fulfills part (a) of your demand to “cease and desist from
any and all unauthorized uses of the image”. As for part (b) of your demand, to “pay the
retroactive license fee noted in the demand claim”, we take issue with the amount you
calculated for this retroactive license fee.

We are open to some form of settlement as again, we are acting in good faith, and we
understand that our unknowing infringement of your alleged copyright does not
absolve us of negligence in the event that you can supply all supporting
documentation to back up your claim.
The “retroactive license fee” noted in the demand claim is for $30,000.00 US. We
understand that under law CopyCat Legal must bear the burden of defending its
copyrights and spends a certain amount of time and money to search for and
prosecute unauthorized use of its copyrighted images. With this in mind, we
are willing to offer in good faith a settlement to CopyCat Legal client without
demanding further proof of the terms in this claim.
If we assume CopyCat Legal exclusive copyright status is in good standing, and that
the original artist is still contracting CopyCat Legal to manage the rights for the
image, we are willing to offer CopyCat Legal, in good faith, a settlement of
$1000.00 US for this claim. Our LLC, GJD Enterprises, has lost thousands of dollars
since its inception.
CopyCat Legal will have ten (10) days to supply an updated claim demand invoice in
the amount of $1,000.00 US for the retroactive license fee associated with the use of
image “20120928_colora_1077”.Receipt of said invoice, and subsequent payment by
preferred mode of payment will conclude this matter. If CopyCat Legal does not wish
to comply to these terms and offer of good faith settlement, please
note that will consider this matter closed and any good faith assumptions held in this
letter will be retracted. CopyCat Legal will be held to a much higher burden of proof
if it wishes to pursue the terms of its original claim. Please understand that this offer

of settlement is not an admission of any wrong doing on the part of GJD Enterprises
LLC d/b/a Pedal Chile.
This is not an agreement to the terms of your claim. We are simply acting in good
faith in the interest of the rights of the artist involved. Please also understand that
nothing in this reply should be construed as a waiver of any of the rights of GJD
Enterprises LLC d/b/a Pedal Chile, remedies, or protections under law.
Again, thank you very much for your notification of this alleged infringement, for your
time, and for your understanding in this matter.
Michael D. Lancaster,
GJD Enterprises LLC d/b/a Pedal Chile.

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