Ms. Sidora and her manager, Allison Jordan, together with Charles Sims, prepared a treatment (the “Treatment”) for the Project, which they registered with the Writers Guild of America on February 19, 2004 and again on April 8, 2004. In early 2005, Ms. Jordan and Corliss King pitched the Project and submitted the Treatment to Stacey Jenkins at VH1. Ms. Jordan and Ms. King described the Project as a reality show about “Ghetto Fabulous” girls who are taught proper etiquette and transformed from ghetto to glamorous. Ms. Jordan and Ms. King spoke with Ms. Jenkins on multiple separate occasions over the course of more than a year, setting forth many potential story ideas and scenarios.

Although Ms. Jenkins unequivocally indicated to Ms. Jordan and Ms. King that VH1 genuinely liked the concept and told them that VH1 intended to pursue the Project, Ms. Jordan and Ms. King did not hear from Ms. Jenkins or anyone else at VH1 again. Ms. Sidora therefore presumed that VH1 had elected not to pursue the development of the Project.

In light of the foregoing, Ms. Sidora, Ms. Jordan, Ms. King and Mr. Sims were shocked and outraged last week when for the first time they saw the promotional segments for the Series. VH1’s description of the Series reads like the description of the Project. Specifically, VH1 describes the Series as a reality series about “ghetto fabulous” girls who are enrolled in a charm school and thereby transformed from ghetto to glamorous.

VH1’s liability under copyright and tort law is clear. It is undisputed that VH1 had extensive access to the Project. Moreover, based on the overwhelming substantial similarities between the Project and the Series, a reasonable person would conclude that the Series is a blatant misappropriation of the Project.

Accordingly, Ms. Sidora demands that VH1 immediately cease and desist from any further development, production, distribution and any other exploitation of the Series, and confirm to us in writing not later than April 1, 2007 that VH1 has done so. In addition, VH1 must compensate Ms. Sidora for the illegal and infringing use of the Project and the loss of opportunity to produce the Project as a television series. If VH1 fails so to comply, our client will protect her rights by aggressively pursuing legal and equitable remedies against VH1, including asserting claims for copyright infringement, breach of implied contract, breach of confidence, interference with prospective economic advantage, and unfair competition—claims that carry significant compensatory and punitive damages as well as injunctive relief.