VANOPHEM IP LAW PLC

1585 S HICKORY RIDGE ROAD

MILFORD, MICHIGAN 48380-1519

JOHN VANOPHEM
john@vanophemiplaw.com
OFFICE: 248-817-8913
FAX: 248-817-8915
April 22, 2021

VIA US MAIL
VIA EMAIL TO: HAMMAD@HSWSUPPLY.COM

Mr. Hammad Ahmad

HS Wholesale Limited
511 South Vista Avenue
Addison, IL 60101

RE: Counterfeit and Infringing Mr. Vapor Products

Dear Mr. Ahmad:

I write on behalf of Mr. Vapor Wholesale, LLC (“MVW”), the owner of the trademark
rights in the name, MR. VAPOR and the MR. VAPOR logo and product. MVW recently learned
that HS Wholesale is manufacturing, distributing, and/or selling counterfeit MR. VAPOR
products (“Counterfeit Product”). This letter is to demand that HS Wholesale immediately cease
and desist from manufacturing, selling, offering for sale, marketing, and / or distributing the
Counterfeit Product.

HS Wholesale’s activities regarding the Counterfeit Products is likely to cause, and has
caused, consumers to erroneously believe that the Counterfeit Products are either real MR.
VAPOR products of MVW or are otherwise sponsored by, affiliated with or somehow connected
to MVW’s MR. VAPOR trademarks. The likelihood of confusion that is inevitable by HS
Wholesale’s continued use of the MR. VAPOR trademarks puts MVW’s reputation at risk of
irreparable harm and injury because MVW has no ability to control the quality of the products
which incorporate MVW’s MR. VAPOR trademarks offered by HS Wholesale.

HS Wholesale’s unauthorized use of the MR. VAPOR trademarks in connection with the
sale of a unauthorized and counterfeit products constitute trademark counterfeiting, trademark
infringement, false designation of origin, and unfair competition in violation of the United States
Trademark Act of 1946, 15 U.S.C. §1051 et seq. (the “Lanham Act”). Given the egregious
nature of these apparently willful violations of the Lanham Act’s provisions, MVW will be
seeking to obtain an order for temporary and/or permanent injunctive relief, actual damages, to
disgorge profits, statutory damages, treble damages for sale of a counterfeit product and/or
MVW’s attorney’s fees.
Mr. Hammad Ahmad
HS Wholesale Limited
January 16, 2020
Page 2

MVW hereby demands that HS Wholesale, and all those associated with HS Wholesale,
immediately cease and desist from manufacturing, selling, marketing, and/or distributing the
Counterfeit Products. MVW further demands HS Wholesale provide an accounting of all
Counterfeit Products manufactured, marketed, distributed and/or sold by HS Wholesale and that
all Counterfeit Products remaining in HS Wholesale’s possession, custody or control be
quarantined and set aside for destruction. MVW further demands that if HS Wholesale is not the
manufacturer of the Counterfeit Products, that you immediately notify us of the name, address
and contact information of the entity from which HS Wholesale obtained the Counterfeit
Products.

MVW have instructed me to immediately prepare and file a complaint pursuing the
claims and remedies set forth above against all responsible parties and individuals. You should
immediately provide this letter to your attorneys.

Regards,

VANOPHEM IP LAW PLC

s/John VanOphem/

By: John VanOphem

cc: Mr. Vapor Wholesale, LLC