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I am an attorney with the law firm of Jenner & Block LLP. We<br />
represent Linda Sarsour. It has come to my client’s attention<br />
that you have made available for sale a book entitled “A Jihad<br />
Grows in Brooklyn” (the “Book”). You have represented to<br />
consumers and the public more generally that the Book<br />
contains the first-person “confessions” of my client, and have<br />
represented that my client is the author of the Book. However,<br />
as you are no doubt aware, my client had absolutely no<br />
involvement with the drafting, publication, or distribution of<br />
the Book, and, critically, she did not authorize its publication<br />
or approve its defamatory contents, which are designed to<br />
harm her and her family’s reputation.<br />
Your publication and distribution of the Book violates<br />
numerous state and federal laws.<br />
First, your conduct violates Section 43 of the Lanham Act, 15<br />
U.S.C. § 1051. In particular, your representation that my client<br />
is the author of the Book constitutes unlawful “passing off,”<br />
Waldman Pub. Corp. v. Landoll, Inc., 43 F.3d 775, 780 (2d Cir.<br />
1994), as well as product infringement, see, e. g., Sun Trading<br />
Distributing Co. v. Evidence Music, 1nc., 980 F. Supp. 722, 727<br />
(S.D.N.Y. 1997).<br />
Second, your conduct constitutes libel, as the Book is replete<br />
with false and defamatory statements about my client. In fact,<br />
the vast majority of the contents of Book constitute, by<br />
definition, false statements, as they are held out to be<br />
statements by Ms. Sarsour when they are not. In addition,<br />
many of the statements, likely to be perceived to be the firstperson<br />
utterances of my client, cause her serious and<br />
irreparable harm. For example, on page 41 of the Book, you<br />
write the following statement, purporting to come directly<br />
from Ms. Sarsour: “The Jews are a sick race: The Jewish pond