Neoteric Hovercraft Inc
1649 Tippecanoe Street • Terre Haute, Indiana, USA 47807-2394
TELEPHONE: 812-234-1120 • 800-285-3761 • FAX: 812-234-3217
EMAIL: Hovermail@NeotericHovercraft.com • WEB: NeotericHovercraft.com • RescueHovercraft.com

14 July 2013

TO:

Mikhail Ilyin
General Directorate Ministry of Internal Affairs of Russia
19 Zaharevskaya str
St. Petersburg, Russia

COMPLAINT AGAINST:

Sergey Sladkov, President/Chairman
MosHovercraft Group / Globatek Group JSC
127273, Moscow, ul. Birch Alley, 12 A
Websites: moshovercraft.ru and globatek.ru

This complaint is submitted by Neoteric Hovercraft, Inc., a company founded in 1975 with headquarters in the United States of America. Neoteric was the first light hovercraft manufacturer in the world, and LLC Sirius / Christy Hovercraft in St. Petersburg, managed by General Director Igor Vladimirovich Lavrov, is Neoteric’s licensed agent in Russia.

Numerous legal violations and unfair trade practices have been committed against Neoteric Hovercraft, Inc. and Christy Hovercraft by MosHovercraft / Globatek Group JSC. These offenses are forcing financial burdens upon our long-standing reputable businesses through loss of sales and confusion created in the marketplace

These offenses include but are not limited to:

• Industrial and economic espionage; theft of technology and trade secrets; piracy
• Patent, trademark and copyright infringement; plagiarism (The MosHovercraft web site consists almost entirely of text, photographs and videos copyrighted and owned by Neoteric Hovercraft, Inc. and plagiarized by MosHovercraft from the Neoteric web site and YouTube channel.)
• Unlawful misleading advertising; false and misleading representations of fact
• Misleading commercial practices

The enclosed Cease and Desist Order was served to MosHovercraft / Globatek Group JSC on 12 April 2013, to no avail. MosHovercraft / Globatek Group JSC responded with a brief email denying the Cease and Desist Order’s irrefutable allegations and did not meet any of the Order’s demands.

Neoteric Hovercraft, Inc. is in the process of informing appropriate United States governmental agencies of these offenses, including the U.S. Federal Bureau of Investigation (FBI); the U.S. Central Intelligence Agency (CIA); the U.S. Department of Commerce; and the Indiana Department of Commerce. We are also assisting Christy Hovercraft in reporting these offenses to the appropriate governmental agencies in Russia.

Neoteric Hovercraft, Inc. is also working conjointly with Christy Hovercraft to pursue legal action against MosHovercraft / Globatek Group JSC. In addition, a detailed report on their illegal actions, with full documentation, will soon be published in the World Hovercraft Organization’s Hovercraft Ripoff Report at http://worldhovercraft.org/hovercraft-ripoff-report.html. Enclosed please find an abbreviated chronology of the most egregious offenses committed by this company against Neoteric Hovercraft, Inc. and our licensed Russian agent Christy Hovercraft.

There is wide concern within the international hovercraft industry that MosHovercraft / Globatek Group JSC is threatening consumer safety by fraudulently marketing pirated, counterfeit hovercraft with no track record while fraudulently representing them as having the more than 40 years’ tested and proven history of Neoteric Hovercraft. These inferior imitation hovercraft are of particular concern when they are marketed to rescue agencies; they endanger the lives of first responders as well the lives of those they are tasked to save. These companies are producing and selling public rescue vehicles of questionable safety that may harm the public rather than protect it.

We petition the General Directorate Ministry of Internal Affairs of Russia to take action against  MosHovercraft / Globatek Group JSC for its ongoing violations of the law. We believe you will agree that there exist many well-founded reasons for your agency to not only impose all available penalties upon this company, but – for the safety of the public and the safety of rescue personnel – to also order immediate suspension of the production and marketing of their counterfeit hovercraft models.

I have provided my full contact information below, but I also authorize representatives from LLC Sirius / Christy Hovercraft to act on the behalf of Neoteric Hovercraft, Inc. My company and I are eager to provide any additional materials or assistance that you may need. Allowing disreputable Russian companies to use such unlawful business practices to market stolen products of questionable safety will, at the very least, tarnish the reputation of Russian-made products in general.

I thank you kindly for your thorough investigation into this serious situation.

Best Regards,

Chris Fitzgerald
President
Neoteric Hovercraft, Inc.
1649 Tippecanoe Street
Terre Haute, Indiana USA
47807-2394

Email: hovermail@neoterichovercraft.com
Telephone: 812-234-1120 or 800-285-3761
Fax: 812-234-3217

APPENDIX TO MOSHOVERCRAFT COMPLAINT

MosHovercraft Screenshot #1
www.moshovercraft.ru

• There exists no Neoteric Hovertrek™ model number 465.
• “Neoteric” is the trademarked business name owned by Neoteric Hovercraft, Inc., and “Hovertrek™” is Neoteric’s trademarked product name; MosHovercraft is using these illegally.
• MosHovercraft has no authority, license or permission to manufacture, “restyle”, market or sell Neoteric hovercraft and is doing so illegally.

MosHovercraft Screenshot #2
http://moshovercraft.ru/catalog/Neoteric_Hovercraft_Inc_74/Neoteric_Hovertrek_465LC_19.html

• There exists no Neoteric Hovertrek™ model number 465lc.
• “Neoteric” is the trademarked business name owned by Neoteric Hovercraft, Inc., and “Hovertrek™” is Neoteric’s trademarked product name; MosHovercraft is using these illegally.
• The logo and text under “Neoteric Hovercraft, Inc.” at the top right of the page was plagiarized from the copyrighted Neoteric Hovercraft, Inc. web site.
• MosHovercraft has no authority, license or permission to manufacture, “restyle”, market or sell Neoteric hovercraft and is doing so illegally.

MosHovercraft Screenshot #3
http://moshovercraft.ru/catalog.html

• There exist no Neoteric Hovertrek™ models number 455 or 455L.
• “Neoteric” is the trademarked business name owned by Neoteric Hovercraft, Inc., and “Hovertrek™” is Neoteric’s trademarked product name; MosHovercraft is using these illegally.
• The logo and text under “Neoteric Hovercraft, Inc.” at the top right of the page was plagiarized from the copyrighted Neoteric Hovercraft, Inc. web site.
• The bottom photo is the property of LLC Sirius / Christy Hovercraft and is used without permission by MosHovercraft.
• MosHovercraft has no authority, license or permission to manufacture, “restyle”, market or sell Neoteric hovercraft and is doing so illegally.

MosHovercraft Screenshot #4
http://moshovercraft.ru/catalog.html

• There exist no Neoteric Hovertrek™ models number 465LP, 465LC, 4100L, 465LR or 6100L.
• “Neoteric” is the trademarked business name owned by Neoteric Hovercraft, Inc., and “Hovertrek™” is Neoteric’s trademarked product name; MosHovercraft is using these illegally.
• The photos on this page are the property of Neoteric Hovercraft, Inc. or LLC Sirius / Christy Hovercraft and were copied from their respective web sites and used without permission by MosHovercraft.
• MosHovercraft has no authority, license or permission to manufacture, “restyle”, market or sell Neoteric hovercraft and is doing so illegally.

MosHovercraft Screenshot #5
http://moshovercraft.ru/svp_v_nalichii_vikup.html

• There exists no Neoteric Hovertrek™ model number 465LP.
• “Neoteric” is the trademarked business name owned by Neoteric Hovercraft, Inc., and “Hovertrek™” is Neoteric’s trademarked product name; MosHovercraft is using these illegally.
• MosHovercraft has no authority, license or permission to manufacture, “restyle”, market or sell Neoteric hovercraft and is doing so illegally.

MosHovercraft Screenshot #6
http://moshovercraft.ru/videos.html

• The following is only one example of numerous videos on this page that were illegally copied from the Neoteric Hovercraft, Inc. and Neoteric dealer web sites across the world, and/or their YouTube channels, and used without permission.
• “Neoteric” is the trademarked business name owned by Neoteric Hovercraft, Inc., and “Hovertrek™” is Neoteric’s trademarked product name; MosHovercraft is using these illegally, along with the trademarked Neoteric Hovercraft, Inc. logo.
• MosHovercraft has no authority, license or permission to manufacture, “restyle”, market or sell Neoteric hovercraft and is doing so illegally.

MosHovercraft Screenshot #7
http://moshovercraft.ru/postsView/Neoteric_465_LP_v_Nalichii_44.html

• There exists no Neoteric Hovertrek™ model number 465 LP.
• “Neoteric” is the trademarked business name owned by Neoteric Hovercraft, Inc.; MosHovercraft is this business name illegally.
• MosHovercraft has no authority, license or permission to manufacture, “restyle”, market or sell Neoteric hovercraft and is doing so illegally.

MosHovercraft Screenshot #8
http://moshovercraft.ru/postsView/_Mezhdunarodnaya_vystavka_yaht_i_katerov_Moscow_Boat_Show_2013__42.html

• The photos on this page show illegally copied counterfeit “Neoteric” hovercraft illegally displayed by MosHovercraft without authorization at the 2013 Moscow Boat Show.
• In the text, MosHovercraft admits that it is “restyling” (illegally manufacturing and modifying) the patented Neoteric hovercraft.
• “Neoteric” is the trademarked business name owned by Neoteric Hovercraft, Inc., and “Hovertrek™” is Neoteric’s trademarked product name; MosHovercraft is using these illegally.
• MosHovercraft has no authority, license or permission to manufacture, “restyle”, market or sell Neoteric hovercraft and is doing so illegally.

MosHovercraft Screenshot #9

• This final screenshot is a random page from the MosHovercraft web site that publishes numerous photographs plagiarized from the Neoteric Hovercraft, Inc. web site and unlawfully used by MosHovercraft.
• “Neoteric” is the trademarked business name owned by Neoteric Hovercraft, Inc., and “Hovertrek™” is Neoteric’s trademarked product name; MosHovercraft is using these illegally.
• MosHovercraft has no authority, license or permission to manufacture, “restyle”, market or sell Neoteric hovercraft and is doing so illegally.