August 22, 2018

VIA EMAIL & FEDEX

Donald J. Trump, President of the United States

c/o The White House
1600 Pennsylvania Avenue NW
Washington, DC 20500
Attn: Don McGahn, Esq., White House Counsel
John Kelly, White House Chief of Staff
Sarah Huckabee Sanders, Director of Communications;

Rhona Graff, Executive Assistant to Donald J. Trump

c/o The Trump Organization
725 Fifth Avenue
New York, New York 10022

Re: Steven Tyler / Infringements / CEASE AND DESIST

Dear Gentlepersons:

As you know, this office represents Steven Tyler, one of the founders of the iconic rock band
Aerosmith, in connection with his intellectual property matters. Reference is made herein to the
cease and desist letters sent by our office to you dated August 28, 2015 and October 10, 2015
(the “Previous Letters”).

It has come to our attention that President Donald J. Trump and/or The Trump Organization
(collectively, “Mr. Trump”) have been using our client’s song “Livin’ On The Edge” in
connection with political rally events (the “Rallies”), including at an event held yesterday at the
Charleston Civic Center in Charleston, West Virginia on August 21, 2018. As expressly outlined
in the Previous Letters, Mr. Trump does not have our client’s permission to use any of our
client’s music, including “Livin’ On The Edge”.

What makes this violation even more egregious is that Mr. Trump’s use of our client’s music
was previously shut down, not once, but two times, during his campaign for presidency in 2015.
Please see the Previous Letters sent on behalf of our client attached here as Exhibit A. Due to
your receipt of the Previous Letters, such conduct is clearly willful, subjecting Mr. Trump to the
maximum penalty under the law.

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As we have made clear numerous times, Mr. Trump is creating the false impression that our
client has given his consent for the use of his music, and even that he endorses the presidency of
Mr. Trump. By using “Livin’ On The Edge” without our client’s permission, Mr. Trump is
falsely implying that our client, once again, endorses his campaign and/or his presidency, as
evidenced by actual confusion seen from the reactions of our client’s fans all over social media.
This specifically violates Section 43 of the Lanham Act, as it “is likely to cause confusion, or to
cause mistake, or to deceive as to the affiliation, connection, or association of such person with
another person.”

Further, as we have also made clear, Mr. Trump needs our client’s express written permission in
order to use his music. We demanded Mr. Tyler’s public performance societies terminate their
licenses with you in 2015 in connection with “Dream On” and any other musical compositions
written or co-written by Mr. Tyler. As such, we are unaware of any remaining public
performance license still in existence which grants Mr. Trump the right use his music in
connection with the Rallies or any other purpose. If Mr. Trump has any such license, please
forward it to our attention immediately.

In addition, Mr. Tyler’s voice is easily recognizable and central to his identity, and any use
thereof wrongfully misappropriates his rights of publicity. Mr. Trump does not have any right to
use the name, image, voice or likeness of our client, without his express written permission, in
connection with his potential campaign or otherwise under state and federal laws, including, but
not limited to California Civil Code § 3344 and Section 43(a)(1)(A) of the Lanham Act. Any
such actions constitute interference with economic relations, trademark infringement, and a
violation of our client’s right of privacy, among other causes of action.

Accordingly, please confirm Mr. Trump’s compliance with this letter in writing within twenty-
four (24) hours of your receipt of this letter.

Please be advised that nothing contained herein or omitted herefrom shall be deemed to be an
admission by our clients of any fact as to any matter or a waiver or full explication of any of our
clients’ rights, remedies, contentions, damages or defenses with respect to the subject matter
hereof, in law, in equity or otherwise, all of which are hereby expressly reserved.

Sincerely,

Dina LaPolt

cc: Steven Tyler (via email)

Larry Rudolph (via email)
Rebecca Lambrecht (via email)
Sabrina Ment, Esq. (via email)
Lindsay Arrington, Esq. (via email)
Steve Gagliano, Esq. (via email)

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 ([KLELW७$

August 28, 2015

VIA EMAIL

Donald J. Trump for President, Inc.

725 Fifth Avenue
New York, New York 10022
Attn: Rhona Graff

Re: Steven Tyler / Infringements

Dear Gentlepersons:

This office represents Steven Tyler, one of the founders of the iconic rock band Aerosmith, in
connection with his intellectual property matters.

It has come to our attention that Donald J. Trump for President, Inc. (“Trump for President”) has
been using our client’s song “Dream On” in connection with campaign events (the “Campaign”),
including at a recent event at Ladd-Peebles Stadium in Mobile, Alabama on August 21, 2015.
However, Trump for President does not have our client’s permission to use “Dream On” or any
of our client’s other music. I wanted to bring this to your attention promptly, before the other
members of Aerosmith are made aware of this, in order to diffuse any potentially volatile
situations in the future.

Trump for President needs our client’s express written permission in order to use his music. By
using his music without permission, Trump for President is violating Mr. Tyler’s copyright in the
“Dream On” musical composition. Further, Trump for President is creating the false impression
that our client has given his consent for the use of his music, and even that he endorses Mr.
Trump’s presidential bid. While our client did attend the first Republican presidential debate in
Cleveland, Ohio, his appearance at such event does not imply an endorsement of Mr. Trump or
any other presidential candidate. Rather, our client enjoys participating in the democratic
process and becoming well informed about political matters.

Additionally, in connection with any potential future uses of any intellectual property, please
note that Trump for President does not have any right to use the name, image or likeness of our
client, without his express written permission, in connection with the Campaign or otherwise

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S:\LaPolt Law Files\Clients\Steven Tyler\Infringements\Trump for President Ltr 08-28-15.doc
under state and federal laws, including, but not limited to California Civil Code §3344 and
Section 43(a)(1)(A) of the Lanham Act. Any such actions would constitute interference with
economic relations, trademark infringement, and a violation of our client’s right of privacy,
among other causes of action.

Accordingly, please confirm Trump for President’s compliance with this letter in writing within
twenty-four (24) hours of your receipt of this letter.

Please be advised that nothing contained herein or omitted herefrom shall be deemed to be an
admission by our clients of any fact as to any matter or a waiver or full explication of any of our
clients’ rights, remedies, contentions, damages or defenses with respect to the subject matter
hereof, in law, in equity or otherwise, all of which are hereby expressly reserved.

Sincerely,

Dina LaPolt

cc: Steven Tyler (via email)

Larry Rudolph (via email)
Rebecca Lambrecht (via email)
Sabrina Ment, Esq. (via email)

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October 10, 2015

VIA EMAIL

Donald J. Trump for President, Inc.

725 Fifth Avenue
New York, New York 10022
Attn: Rhona Graff

Re: Steven Tyler / Infringements

Dear Gentlepersons:

As you know, this office represents Steven Tyler. Reference is made herein to the cease and
desist letter sent by our office to you dated August 28, 2015 (the “Previous Letter”).

In August, it came to our attention that Donald J. Trump for President, Inc. (“Trump for
President”) had been using our client’s song “Dream On” in connection with campaign events
(the “Campaign”), including at an August 21, 2015 event at Ladd-Peebles Stadium in Mobile,
Alabama. However, Trump for President does not have our client’s permission to use “Dream
On” or any of our client’s other music in connection with the Campaign because it gives the false
impression that he is connected with or endorses Mr. Trump’s presidential bid. In response, we
sent the Previous Letter, respectfully explaining that such usage of “Dream On” was
impermissible, and that our client does not consent to same.

Despite your receipt of the Previous Letter, it was again brought to our attention that Trump for
President is continuing its unauthorized use of “Dream On” in connection with the Campaign,
including today at a Campaign event at the North Atlanta Trade Center in Norcross, Georgia.
We are unaware of any public performance license granting Trump for President the right to
perform “Dream On” in connection with the Campaign. If Trump for President has any such
license, please forward it to our attention immediately. Further, by using “Dream On” without
our client’s permission, Trump for President is falsely implying our client’s endorsement of the
Campaign, in violation of Section 43 of the Lanham Act, and is infringing our client’s right of
publicity. Due to your receipt of the Previous Letter, such conduct is clearly willful, subjecting
you to the maximum penalty under the law.

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Additionally, please note that Trump for President does not have any right to use the name,
image or likeness of our client, without his express written permission, in connection with the
Campaign or otherwise under state and federal laws, including, but not limited to California Civil
Code §3344 and Section 43(a)(1)(A) of the Lanham Act. Any such actions would constitute
interference with economic relations, trademark infringement, and a violation of our client’s
right of privacy, among other causes of action.

Accordingly, please confirm Trump for President’s receipt of the Previous Letter and this letter,
and confirm your compliance with our demands, in writing within twenty-four (24) hours of
your receipt of this letter. If Trump for President does not comply with our demands, our client
will be forced to pursue any and all legal or equitable remedies which our client may have
against you.

Please be advised that nothing contained herein or omitted herefrom shall be deemed to be an
admission by our client of any fact as to any matter or a waiver or full explication of any of our
clients’ rights, remedies, contentions, damages or defenses with respect to the subject matter
hereof, in law, in equity or otherwise, all of which are hereby expressly reserved.

Sincerely,

Dina LaPolt

cc: Steven Tyler (via email)

Larry Rudolph, Manager (via email)
Rebecca Lambrecht-Warfield, Manager (via email)
Amanda Ruisi (via email)
Sabrina Ment, Esq. (via email)
John Meller, Esq. (via email)