John C. Rawls, Esquire
c/o Blanc Williams Johnston & Kronstadt, LLP
1900 Avenue of the Stars
Los Angeles, CA 90067-4403
RE: Wolfe's Borough Coffee, Inc. d/b/a The Black Bear Micro Roastery
Dear Mr. Rawls:
Please allow this letter to serve as an acknowledgement of your April 10,1998 letter. I must, however, state at the outset that I am a little surprised by your statement that there has been no communication between the parties for some time, when I review the correspondence sent to Corporate Counsel Polly Kim Close, a copy of which I have enclosed for your edification. And I quote from that letter, which states as follows;
While Wolfe's Borough can comply with certain of your request such as how many unfilled packages there are currently in inventory; how many filled packages are in inventory; estimated costs to relabel, these request seem to miss the major mark of the foundation of a solution. The overriding issue is how, from a public relations perspective is this "name change" going to be accomplished. Irrespective of your position, Wolfe's Borough's position, as associated with their choice of the name, was spelled out a great length in their response to you. Now if they are being asked to change that, and for the sake of this letter we will assume, without any basis in law, than how are the mechanics of this to be accomplished. What is going to be the new name, and what is the reason for the change. How can Starbucks and Wolfe's Borough work together to bring about the desired results for both companies. How can this transition be made an advantageous procedure for both concerns.
Obviously, the resources at Starbucks is much greater than that of Wolfe's Borough. We would implore you to be creative such that this creativity can be a very positive step. Wolfe's Borough has already been approached by certain Boston area media about the situation, and has vowed to remain silent, with the hope and expectation that an amicable solution can be reached which will put both Starbucks and Wolfe's Borough in a very optimistic position going forward.
With their very limited resources, Wolfe's Borough request that Starbucks undertake the selection of a new name, the details of an appropriate publicity campaign detailing why there is a new name, compensation for change of their name, and compensation for their legal expenses incurred.
Accordingly, once again with the foregoing in mind, this office respectfully requests that you respond substantively to the above noted comments. Thanking you in advance, I am
cc: James 0. Clark III