Shea Porr, President of the Camarilla, Jan. 15, 2002
Sent to the membership of the Camarilla via e-mail

To the members of the Camarilla,

As many of you will have seen across various lists today, White Wolf Publishing, under the guidance of it's new President, has taken the unusual steps of claiming the right to manage an independent organization over which they have no legal claim : The Camarilla.

The Camarilla is an independent non-profit organization, incorporated in Utah, USA, which is managed by a volunteer board of directors, and made possible because of the hard work of you - the members, coordinators and storytellers who put so much effort into this fantastic organization. We will not allow an outside organization to claim ownership of The Camarilla and take it over as part of their marketing department. This is not in the best interest of the organization, and based on feedback we've received in the past few days, is not what the membership wants.

For some time we have tried to negotiate a contract which was in the best interests of the organization. In the time we have been undertaking these negotiations White Wolf has rejected a number of key compromises and remained firm on their view of this club. It is clear that they have a different view as to the purpose and direction of The Camarilla to that of it's own members and founders. Because of this difference, it is unlikely that an agreeable contract will be reached in the near future.

White Wolf has never had any part in the running of this organization, nor will "White Wolf will manage the club directly". Our club will continue to run as it has done so in the past. In the mean time we are consulting with our attorneys to ensure that we have explored every possible option open to us.

To be clear :
* Coordinators, if they were sending their reports to White Wolf, are to stop doing so immediately.
* No membership list will be presented to White Wolf.
* Our chronicle will not be shut down, re-set, altered or otherwise effected in the immediate future.
* Memberships will continue to be handled in the current manner.
* The Camarilla will continue operations as normal.

We will keep you updated as to the resolution of this issue as it develops.

Thank you,
Shea

**********
Shea Porr, 9509-075
President
The Camarilla (r)

---Letter # 2-----

Shea Porr, President of the Camarilla, Jan. 21, 2002
Sent to the membership of the Camarilla via e-mail

Hello,

I'd like to say a couple of things before I get into the meat of this update. First, I apologize for the delay in posting this response. Things have been very hectic this week and I wanted to have some answers for you, better answers than "We're looking into this." Second, I want to compliment the membership on their attitudes and reactions to this situation. For the most part, I have been highly pleased to see rational and polite conversations and discussions on the lists I'm on and in the communications I've received privately. I've seen comments from both sides (pro-The Camarilla/NPO and pro-White Wolf), and I thank everyone for remaining calm and being polite as we move forward through these trying times.

I'm going to try and put some order to this post and cover some of the questions that I've seen as well as update you on the situation at this point in time. Some of the more high-profile questions include the trademark of the name The Camarilla and the incorporation of this organization. When the club first formed, White Wolf told us that any terms used in their books were their "trademarks" which White Wolf allegedly owned, including the name Camarilla. For this reason, you will find references in some of the older documentation to White Wolf owning that word. It was later determined that White Wolf's claim was false, and that White Wolf had never trademarked the name "The Camarilla". Consequently, commencing in 1998 The Camarilla filed an application to trademark the name "The Camarilla", along with the distinctive way we spell "Requiem" for our fanzine and our logo in order to protect the organization. The trademark was granted in February 2000. As an FYI, when an organization files for a trademark, the United States Patent and Trademark Office publishes a notice stating that someone has filed for a trademark and allowing a period of time for objections and other claims to ownership of the trademark. The Trademark Office also attempts to find any other uses of the word in question, where such an application may put the company using the word in violation of the upcoming trademark. There was no contest filed in response to our application by White Wolf or by anyone else.

The Camarilla was incorporated April 14, 1995. Our investigations have revealed that a different organization was formed sometime in 1992 or 1993 in Seattle Washington which also used "Camarilla" in its name. Apparently, the Seattle company signed a contract with White Wolf in 1993, and again in 1994, and it is my understanding that they were noted as the Official Fan Club at that time. I am uncertain as to the exact wording of those contracts, as I have never received a copy despite asking for one from White Wolf. The Seattle company apparently failed to renew its corporate registration and was involuntarily dissolved. There is no legal link between the group that organized the Seattle company and the group that organized the Salt Lake City company. Between the expiration of the incorporation in Seattle and the incorporation by the Salt Lake City group, the contract with White Wolf expired. There has been no signed contract since. However, we have cooperated with White Wolf and have had a good working relationship with White Wolf while attempting to negotiate a contract with them over a number of years. In that time, the club has grown, and that growth has supported White Wolf.

The Camarilla is a legally incorporated non-profit organization registered in the State of Utah that was incorporated April 14, 1995 by a group of individuals totally independent of White Wolf. It is a charity recognized by the Internal Revenue Service under Section 501(c)(7) of the Internal Revenue Code. The Camarilla is a corporation in good standing. It's corporate charter has not expired or been revoked. The Utah Department of Commerce made a mistake when the annual report was filed and incorrectly showed The Camarilla as being expired. This error was resolved the same day that we called it to the attention of the Division of Corporations, and our corporate filings with the State of Utah are current through April 2003, although this fact will not show on their website until they update it in about a week. The Camarilla is not and never has been a subsidiary of White Wolf. One of the reasons that the contract negotiations with White Wolf failed was that White Wolf was intent on assuming control of The Camarilla and in fact operating it as a subsidiary. It appeared to the Board that White Wolf was attempting to turn The Camarilla into a new profit center staffed by unpaid volunteers. Although there is nothing to prevent White Wolf from creating and running their own fan club, White Wolf is not in control of The Camarilla and cannot start up their own fan club using the name The Camarilla, or any other name deceptively similar to The Camarilla due to the Camarilla's trademark registration. It is the position of the Board that White Wolf will need to create its own fan club with a different name, rather than take over the organization and membership developed by the members of The Camarilla.

One of the complaints/comments I've heard is that the membership feels they have been blind sided due to the fact that there have been difficulties in the negotiations between The Camarilla and White Wolf. It is not common practice to post the details of contract negotiations while they are ongoing. It was my intent to have a contract signed and concluded early in my tenure as President. However, as I negotiated with White Wolf, I encountered more and more blocks to formation of an agreement with White Wolf as it became more and more apparent that White Wolf was intent on assuming control of The Camarilla. I assumed (perhaps incorrectly) that the continued mention of the fact that the contract was still under negotiation would indicate to the membership that something was not going smoothly, and eventually I dropped the comment as things simply were not progressing due to White Wolf's complete refusal to make the revisions to the contract we had requested in order to prevent White Wolf from taking over The Camarilla and shifting various of its liabilities to The Camarilla.

I met with Mike Tinney in July 2001, and a couple minor points were agreed upon. In particular, they agreed to put a clause into the contract that they would not sell the membership list, and they offered that the only approvals they would require on the Board would be President, EVP, VP Finance, and VP Information. I noted at that time that we would have to run this issue by our lawyer. That was when we discovered that, by Utah statute, we could not give White Wolf the right to approve Board members unless our Bylaws were amended by a vote of the full membership. White Wolf never responded to this issue or to my offer to have the membership vote on the prospective amendment. We had our lawyer prepare an acceptable contract which included many of the terms requested by White Wolf, but which maintained the integrity of the organization as a volunteer, non-profit corporation managed by its members rather than by White Wolf. We also offered to have our lawyer work directly with White Wolf's lawyer, as we were running into some legal issues. This offer was denied and White Wolf insisted that we accept their contract without any of the changes we had requested.

In addition to the letter sent to the membership by Mike Tinney, on January 15, our legal counsel received a letter from White Wolf's lawyer. This letter detailed the steps White Wolf is taking to assume control of our organization and requested that The Camarilla be dissolved; that the membership lists be turned over to White Wolf; that all intellectual property of The Camarilla be conveyed to White Wolf; that all merchandise either be destroyed or turned over to White Wolf, including Requiem; and implied that legal pressure would be brought if the organization did not abide by these terms. White Wolf's lawyer had the audacity to include three transfer documents along with his letter, including documents to transfer ownership of our website, mailing lists and all other assets to White Wolf.

Allow me to clarify that despite current events, we are not anti-White Wolf. We are still open to negotiating an acceptable contract. We still believe it is in the best interests of both our group and White Wolf to work together, but that will require compromise on both sides. A lot of people have worked very hard over the past seven years to make The Camarilla what it is today. The Board is committed and determined to preserve this organization, protect its assets and do what is in the best interests of its membership.

On January 16, 2001, the day after our legal counsel received the letter stating that White Wolf was assuming control of The Camarilla, The Camarilla filed a lawsuit against White Wolf in the United States District Court for the District of Utah seeking a preliminary injunction against White Wolf Publishing, Inc. and White Wolf, Inc. to prevent them from using the name The Camarilla; to restrain them from claiming to be The Camarilla or to be in control of The Camarilla; for a declaratory judgment that The Camarilla owns the assets which it has trademarked, along with the art work, rules supplements and other publications its members have developed over the years; for theft and conversion; for violation of the Landham Act; for intentional interference with existing and prospective economic relations; and for trademark misuse. On Friday, January 18, our attorneys filed a Motion for Temporary Restraining Order, and we have obtained an expedited hearing on that motion, which will be heard on Wednesday morning. Our legal counsel has advised us that the Courts are very reluctant to grant temporary restraining orders and preliminary injunctions, especially in cases involving trademark infringement, but we feel we have a strong case. If we do not prevail on this motion we will continue to prosecute The Camarilla's claims against White Wolf. We do not anticipate that this matter will be resolved any time soon. However, as I said earlier, we continue to be willing to negotiate a reasonable settlement with White Wolf. Such a settlement will not include turning this organization or its assets over to White Wolf. All assets we as members have created, supported and paid for.

The bottom line is that nothing has changed, except that The Camarilla can no longer claim to be "The Official Fan Club" of White Wolf. We are doing all we can to protect your organization and the assets it has developed during the past seven years. We will update you from time to time as the legal proceedings progress. In the meantime, please continue to have your games, your chapter meetings and your domain meetings. Plan for the regional and national events! We are here to enjoy each other's company and to have a good time. We do not anticipate any changes in the near future, but if something does change, we will let you know as quickly as we are able.

Shea

**********
Shea Porr, 9509-075
President
The Camarilla (r)