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<br /> <br /> <br /> <br />The Reserve Building <br />724 Bielenberg Drive, #19 <br />Saint Paul, MN 55125-2620 <br />Telephone: 651.894.6800 <br />Web: www.ploen.com <br />E-mail: sploen@ploen.com <br /> <br /> <br />February 26, 2023 <br /> <br />Via Electronic Mail with Confirmation by First Class Mail <br />Mr. Nathan Landucci <br />Wildflower Twinhomes, LLC <br /> c/o Landucci Construction, Inc. <br />13230 20th St Ct N. <br />Stillwater, MN 55082 <br />E-mail: <landucnl@hotmail.com> <br /> <br />Dear Mr. Landucci: <br /> <br /> This firm represents Wildflower at Lake Elmo, Inc. ("Wildflower"), a Minnesota not-for- <br />profit corporation established in 2015. Via its predecessor-in-interest Robert Engstrom <br />Companies, Inc. ("Engstrom"), Wildflower owns Minnesota state trademark registration no. <br />807912600038 for the mark WILDFLOWER AT LAKE ELMO, registered with the Office of <br />the Minnesota Secretary of State on January 26, 2015. A copy of the registration certificate for <br />the trademark is attached. <br /> <br /> Wildflower has used the WILDFLOWER AT LAKE ELMO trademark, as well as the <br />shortened form WILDFLOWER, continuously since November, 2014 in connection with <br />designing, developing and constructing a master-planned residential community in Lake Elmo, <br />Minnesota; additional information about the community may be found at <br /><https://wildflower.engstromco.com>. Since its establishment, the WILDFLOWER AT LAKE <br />ELMO neighborhood has received wide recognition as a high-quality development of single- <br />family homes, including having been named the "Best New Residential Development in the <br />Twin Cities" in 2017 by the Builders Association of the Twin Cities. The neighborhood's homes <br />continue to be the subject of strong consumer demand, and Wildflower recently opened its 4th <br />addition for development. <br /> <br /> Given Wildflower's substantial investment in establishing, developing, and protecting its <br />rights in the WILDFLOWER AT LAKE ELMO trademark, you will understand that the <br />corporation polices those rights against third parties who are using trademarks that, whether <br />deliberately or inadvertently, cause confusion amongst consumers or otherwise injure the <br />valuable goodwill associated with the WILDFLOWER AT LAKE ELMO trademark. <br /> <br /> Wildflower thus was troubled to learn of Wildflower Twinhomes, LLC's ("Wildflower <br />Twinhomes") purchase of Washington County property no. 13.029.21.21.0009 (the "Property") <br />in Lake Elmo, Minnesota. Wildflower also was troubled to learn that Wildflower Twinhomes, <br />via a related entity, Landucci Construction, Inc. ("Landucci"), is seeking permission to construct <br />thirty single-family twinhomes on the Property in what Landucci describes as "our Wildflow er