  
            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: 
              Sotsenko  Yaroslav (Vladimirovich) 
              Air Wing /  Production Company “MSK" / 000 Aeroslava  
              Highway  Revolution, d.114 office 26 
              St.  Petersburg, Russia  
              Website:  airwing.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 Air Wing / Production  Company “MSK”. These offenses are forcing financial burdens upon our  long-standing reputable businesses through loss of sales and confusion created  in the marketplace by the presence of counterfeit products. These unlawful  products are of inferior quality and lack the high safety standards of Neoteric  Hovercraft, Inc. – the original manufacturer and patent owner. 
            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
 
              - Unlawful  misleading advertising; false and misleading representations of fact
 
              - Misleading  commercial practices
 
             
            A Cease  and Desist Order was served to Air Wing / Production Company “MSK” on 12 April  2013, to which we received no response and none of the demands were met.  
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 Air Wing / Production Company “MSK”. 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.  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 Air Wing /  Production Company “MSK” is threatening consumer safety by illegally  manufacturing and 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. Air Wing / Production Company “MSK” is 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 Air Wing / Production Company “MSK” 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 “Niaterek”  and all other 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 AIR WING COMPLAINT 
             
            Air Wing  Avito advertisements
             
              
            Air Wing assembly facility with illegal copies of Neoteric  Hovertrek™ in production   
            
            
            
            
            
              
            Illegal  copies of Neoteric Hovertrek™ manufactured by Air Wing   
            
            
            
                        
            
           
           The  following photos appeared on the Boats  and Yachts forum:  
 
 
            
            
           
          
            
            
           
            
             
            
             
            
            
           
            
           
            
            
            
           
             
           
            
        
        
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