VIA FACSIMILE AND U.S. MAIL
Joseph G. Adams
WILSON SONSINI GOODRICH & ROSATI
650 Page Mill Road
Palo Alto, CA 94394-1050
Re: Network
Associates, Inc. – Trademark Matters
Mark:
SNIFFERS
Dear Mr. Adams
Our client, the Board of Trustees of the Leland
Stanford Junior University (“Stanford”), has asked that we respond to your
letter of April 9, 2002, regarding the above.
We disagree that there
is any likelihood of confusion between your client’s SNIFFER line of products
and our client’s use of SSL Sniffer and SSL v.3/TLS Sniffer in connection with
a non-commercial student project. As
one of many factors indicating no likelihood of confusion, we note that the
term “sniffer” is commonly used in the industry to refer generically to a type
of program and/or device for network management or monitoring data traveling
over a network. Your client’s mark
lacks the inherent or acquired strength sufficient to overcome these
facts.
We can confirm that our
client has no plans to commercialize this student product under the SNIFFER
name or mark.
We trust this responds to your
inquiries. Please call if you have any
questions.
Very truly yours,
Laura C. Gustafson
bcc: Professor
Boneh