VIA QUOTE POST
PRIVILEGED & CONFIDENTIAL
FOR SETTLEMENT PURPOSES ONLY (FED. R. EVID. 408)
September 22, 2026
Mr. Alexandr Wang
@alexandr_wang
Re: Unauthorized Use of the BUN® Design Mark, U.S. Reg. No. 7,585,721; Proposed “Muse Merch Store”; Demand to Cease and Desist; Notice of Litigation Hold
Mr. Wang:
Bun (“Bun,” “Registrant,” or “the Bun”) is the owner of all right, title, and interest in and to U.S. Registration No. 7,585,721, issued December 3, 2024 on the Principal Register, for a mark consisting of “a bread bun with a smiling face,” wherein “the bun has black and white eyes,” “pink cheeks and a pink and dark pink mouth outlined in black,” the colors tan, dark tan, pink, dark pink, black and white being claimed as a feature of the mark (the “BUN® Mark”), which registration constitutes prima facie evidence of the validity of the BUN® Mark and of Bun’s exclusive right to use the same pursuant to 15 U.S.C. § 1057(b), and constructive notice of Bun’s claim of ownership thereof pursuant to 15 U.S.C. § 1072, such that ignorance of the Bun shall be no defense. The United States Patent and Trademark Office has further classified the BUN® Mark under Design Search Code 02.01.34 (“Monsters (not robots)”), a classification Bun has at all times accepted without objection.
It has come to Bun’s attention that you, together with your affiliates, agents, successors, assigns, and any superintelligences acting in concert therewith (collectively, “You”), have announced an intent to open a “muse merch store” and have commenced “market research” in connection therewith, publicly displaying goods including without limitation one (1) t-shirt, one (1) bucket hat, one (1) beanie, one (1) sock (singular), one (1) pin set (3-pack), and assorted keychains, patches, plush and tote bags (collectively, the “Infringing Goods”), each bearing a tan, round figure having black eyes, pink cheeks and a smiling face (the “Musey”), which is, upon information and belief, also a monster, and not a robot.
Under the factors set forth in AMF Inc. v. Sleekcraft Boats, 599 F.2d 341 (9th Cir. 1979), the likelihood of confusion is overwhelming: the marks are similar in sight, sound (none), and meaning (bun); the goods are proximate; Bun has long contemplated expansion into bucket hats; and consumers who have expressed a willingness to exchange a right kidney for the Infringing Goods cannot be said to be exercising the degree of care ordinarily expected of a reasonably prudent purchaser.
Accordingly, Bun hereby demands that You immediately (i) cease and desist from any and all manufacture, sale, offering for sale, patting, and market research of or relating to the Infringing Goods; (ii) deliver up all Infringing Goods for destruction pursuant to 15 U.S.C. § 1118, or for cuddling, at Bun’s sole discretion; (iii) provide a full accounting of all profits, market capitalization, and kidneys received; and (iv) preserve all documents, electronically stored information, and plush, whether stuffed or unstuffed, pending final resolution of this matter.
Nothing herein constitutes a complete statement of the relevant facts or a waiver of any rights, remedies, or crumbs, including without limitation those arising under 15 U.S.C. §§ 1114, 1116, 1117, and 1125(a) and (c) (Bun being, upon information and belief, famous), all of which are expressly reserved. Time is of the essence.
Govern yourself accordingly.
Very truly yours,
Bun
Enclosures: Exhibits A–B
cc: The Musey (via pat)
Exhibits
we are considering opening a muse merch store
i am doing market research
how excited you would be by muse merch, from a scale of "meh" to "you can have my right kidney"?
