Haynes and Boone, S.C.

Dear Revdex.com, Tiffany and Company d/b/a Tiffany & Co(“Tiffany”) has carefully evaluated the subject complaint, ID# ***, stemming from the removal of an *** listing featuring a purportedly authentic Tiffany & CoScottish Terrier Necklace (see attached screenshot of the
listing). Tiffany maintains its position that the item in question is counterfeit, and thus the complainant, *** ***, has no legitimate grounds to object to the suspension of his selling privileges via the *** website Tiffany & Corequested the removal of the subject listing in good faith and in accordance with ***’s Rules for Creating Legally Compliant Listings available at *** These Rules clearly state that “you can't list replicas, fakes, counterfeits, or other illegal copies on ***For example, you can't list an item that bears the brand name or logo of a company that didn't manufacture or authorize the product.” The Scottish Terrier Necklace that *** *** listed is not genuine Tiffany & Comerchandise. Tiffany has rigorous quality control standards, and Tiffany’s internal Quality Control (QA) Team is in a far better position to determine the authenticity of Tiffany & Comerchandise than any individual seller. Our QA Team has determined that *** ***’s Scottish Terrier Necklace is not authentic because the photos indicate that it was not manufactured in accordance with Tiffany & Costandards (e.g., the overall styling is inconsistent with authentic Tiffany merchandise and the product does not have appropriate Tiffany hallmarks; see attached photo of a similar, authentic Tiffany & Coitem) Tiffany has a legal obligation to combat the sale of counterfeit merchandise and categorically rejects the assertion that our enforcement strategy violates any applicable law. In addition, aside for Tiffany’s participation in ***’s VeRO Program (see our Participant page at ***), Tiffany has no other involvement with ***’s policies or procedures pertaining to the suspension of sales activity. *** *** should contact *** directly if he has any concerns with this *** seller account In view of the foregoing, Tiffany believes that the subject complaint is unfounded and should be closed accordingly. We encourage *** *** to return the Scottish Terrier Necklace to the store from which it was purchased and seek a full refund in reliance on this response Kind regards, *** ***

Dear *** ***,This complaint has been reviewed with management and a solution has been reachedWe are currently waiting to hear back from *** *** to complete a one time accommodation Sincerely,Melissa B***Tiffany and Co

Revdex.com:
I have reviewed the response made by the business in reference to complaint ID# ***, and have determined that my complaint has NOT been resolved because:
On October *, 2016 I put Tiffany on notice that "In the attachments below, there are three *** listings, two of them have the exact same terrier necklace as mine and a brooch with two dogs of the same group of Tiffany & Coaccessories Two of those items are still listed on *** and have been for over three months without being removed or having their *** trading suspended. Tiffany's Internal Quality Control Team (QA) does not treat sellers in a balanced or impartial way and clearly this is Cherry Picking or an act of DISCRIMINATIONTiffany wrote "The overall styling is inconsistent with authentic Tiffany merchandise and the product does not have appropriate Tiffany hallmarks; see attached photo of a similar, authentic Tiffany & Coitem. Tiffany sent terrier examples without showing the hallmarks located on the backIn fact Tiffany never shows the hallmarks on back in any photographs released to the publicThey take professional photo's and computerized photo programs to emphasize glamour and diamonds but never show the ugly back. I am not a professional photographer, I simply put multiple clear images on my listings for ***, just like all other sellersI cannot use another sellers pictures because "these are not internal Tiffany QA images but rather sourced from unaffiliated third parties and they cannot be used as the basis to establish the authenticity of *** ***'s piece." I have repeatedly asked Tiffany to provide source images of the terrier, but Tiffany has ignored all of my requests. Do I have to file a lawsuit to subpoena Tiffany to supply the proper pictures? Why can't Tiffany provide reasonable correspondence to find a fair and equitable solution? Why can't Tiffany use the pictures "sourced from unaffiliated third parties" against those same sellers to declare them as "Counterfeit Tiffany Items."? "Tiffany has rigorous quality control standards, and Tiffany’s internal Quality Control (QA) Team is in a far better position to determine the authenticity of Tiffany & Comerchandise than any individual seller." What an ASININE, POMPUS and IGNORANT statementTiffany’s Internal Quality Control (QA) Team is not perfect as they pretend. An individual seller possesses the actual Terrier can feel the actual weight of the artwork, test the silver for content and can see the quality of the workmanship by viewing the Terrier from all anglesHow can Tiffany judge a piece of jewelry from a few amateur 2D pictures, GIA Certified Jewelers require the actual piece of jewelry to appraise or certify if the jewelry is real or fake.Thank you, Tim G***, for providing Tiffany Source Photos of two Terriers and suggesting I perform a side by side comparison between my terrier and them.The first terrier provided was created with a polished sheet of Sterling Silver and a cookie cutter device, the cheapest modern way to make cartoonlike jewelry.The second example terrier is amazingly similar to my terrier, they were both cast in a mold which requires more investment, human labor, and artistic ability to create Fine Jewelry Unlike the prepolished stamping ,They have to be filed and polished and hand finished to create Fine Jewelry. I own a Terrier Brooch which you have identified as authentic with your provided Tiffany Source PhotoIt is a bit hard to compare these two terriers because of their size difference and orientation, but a reasonable person can determine basic similarities from the photographs in my below attachmentThe two terriers profiles match and both have diagonal stripes across their bodiesBeside the emerald and gold bezel, the eyes have the same motif and placementthe ears and upturned tails are exactly the same. Observing the back both have a casting ring to provide strength and depth and clearly the Hallmarks are consistent. I have many photographs from "unaffiliated third parties" which would further substantiate my observations."Our QA Team has determined that *** ***’s Scottish Terrier Necklace is not authentic because the photos indicate that it was not manufactured in accordance with Tiffany & Costandards (e.g., the overall styling is inconsistent with authentic Tiffany merchandise and the product does not have appropriate Tiffany hallmarks; see attached photo of a similar, authentic Tiffany & Coitem." The first terrier provided was created with a polished sheet of Sterling Silver and a cookie cutter device, the cheapest modern way to make cartoonlike jewelry.The second example terrier,from 1989, is amazingly similar to my terrier in both design and trademark. I own a Terrier Brooch which you have identified as authentic with your provided a Tiffany Source PhotoIt is a bit hard to compare these two terriers because of their size difference and orientation, but a reasonable person could determine their similarity."We believe that we have sufficiently addressed all claims and continue to maintain our position that the Scottish Terrier Necklace that *** *** listed is not genuine Tiffany & Comerchandise." Tiffany has not met it's burden of proof that my Terrier is a counterfeitThey have not provided any evidence to prove beyond a reasonable doubt that my terrier is not genuine Tiffany merchandiseTiffany is not deserving of a AAA plus rating from the Revdex.com, they are devoid of ethics and do not make any attempt to resolve any complaint and have no respect for individuals rightsTiffany has used outrageous claims of Godlike divinity, disingenuous snobbery, intimidation and try to confuse people with their odious subterfuge.The Revdex.com should examine Tiffany's actions and see how they compare with the Revdex.com mission statement.*** ***
In order for the Revdex.com to appropriately process your response, you MUST answer the question above
Sincerely,
*** ***

Dear *** ***,The Sales Manager at the store has reached out to *** and provided a satisfactory resolution to her concerns. SincerelyTim G***Tiffany & Co.

Dear *** ***,The Director of our Dallas store has reached out to *** *** to discuss his conerns and they have come to a satisfactory resolution that *** *** was pleased with. If you require anything additional please feel free to contact me.Sincerely,Tim
G***Tiffany & Co

To Whom it May Concern, After further review and a phone call between *** *** and MsK***, a resolution was reachedTiffany and Cogreatly appreciates *** *** feedback and has forwarded her concerns to the appropriate channelsWe have provided *** *** with a Sterling Silver cleaning spray and two cleaning cloths to utilize between store visitsThis should finalize this complaint.Sincerely,Tim G***Tiffany & Co

Dear *** ***,We have reviewed all of *** ***'s orders and would first like to apologize that they did not meet the requested delivery date of February ***. However, earlier this week an email was sent to *** *** providing the UPS tracking information and confirmation of delivery as
of February 19th for all of the orders in question. We again offer our sincere apologies for missing the requested date but this should provide closure to the situation. Thank you,Tim G***Tiffany & Co.

To whom it may concern:This issue was reviewed with the management team at the Chicago store where *** *** concerns originated. They worked with *** *** to address her issue with the merchandise and felt this matter was resolved. We feel the actions
already taken have provided an adequate resolution to her concerns and we regrettably will not be able to honor her request for a store credit.Sincerely,Tim G***Tiffany & Co.

Revdex.com:
I have reviewed the response made by the business in reference to complaint ID#? ***, and have determined that my complaint has NOT been resolved because:
I don't agree with Tiffany about this matter, I think they have been looking in the wrong century to? research my Terrier PendantThe photo you sent is the? 2016? currently available terrier from Tiffany & Co.? for a? comparison to my terrier made in 1981.? You wrote, "the overall styling is inconsistent with authentic Tiffany merchandise and the product does not have appropriate Tiffany hallmarks; see attached photo of a similar, authentic Tiffany & Coitem."? In the 178? years of Tiffany & Cosexistance, styles have changed (e.g., Tiffany? shoe button hooks)All of the three terrier? items( plus mine for a total of four)? bear a hallmark "TIFFANY & CO 925"? and? are? contemporary with Tiffany hallmarks of the early eighties"Tiffany’s internal Quality Control (QA) Team is in a far better position to determine the authenticity of Tiffany & Comerchandise than any individual seller."? Tiffany should be doing research? on my necklace? from when it was made and that? the styles were different than todayI'm certain you would make a similar? discovery.In the attachments below,? there are three? ***? listings, two? of them have? the exact same? terrier necklace? as? mine and a brooch with two dogs of the same group of Tiffany & Coaccessories It is clearly? UNETHICAL? for Tiffany to accuse? me? without sanctioning all three? of the of trademark violators.Here are a few of Tiffany terrier picturesIt appears that my terrier's? overall styling is more consistent with authentic Tiffany merchandise? than the terrier you providedSincerely,*** ** ***
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In order for the Revdex.com to appropriately process your response, you MUST answer the question above
Sincerely,
*** ***
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Dear [redacted],We have been in touch with [redacted] and reviewed her concerns.? As a result, we have offered her the? final courtesy of replacing the bracelet for her.? It will be adjusted to the required length? before sending it to her.? ? [redacted] seemed satisfied with this resolution; therefore, we consider this issue resolved.Sincerely,Tim G[redacted]Assistant Manager Customer RelationsTiffany & Co

Hello,We have made several attempts to get in touch with *** *** but have had difficulty connecting with her.? We will continue to follow up with her to address her concerns.Sincerely,Tim G***Tiffany & Co.?

Revdex.com:
I have reviewed the response made by the business in reference to complaint ID#? ***,
and have determined that my complaint has NOT been resolved because:
Not true I had a bracelet repaired there which they took out links and put the bracelet on my wrist it was no repaired properly and broke off somewhere in pieces, it is a tiffanys hammered cross the store has done nothing to replace the bracelet this is not acceptable igore is not assisting me properly! The bracelet needs to be replaced since it was not fixed properly this is not acceptable! He is refusing to help me because of the Revdex.com complaint which is why I escalated to the corporate level!
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In order for the Revdex.com to appropriately process your response, you MUST answer the question above
Sincerely,
*** ***
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Dear [redacted],The sunglasses were reviewed a second time more closely and it was determined to be a minor servicing that was required.? [redacted] was contacted and we first apologized for the issue and advised that we will be completing this servicing at no charge to her.? She was
pleased with this and we will be returning her sunglasses to her? shortly.Thank you,Tim G[redacted]Tiffany & Co

Dear *** ***,Thank you for reaching out to Tiffany and COYour case is currently being reviewed with management and we look to provide you with an update as soon as possible via the contact information you providedShould you have any additional questions in the interim, please reach out to
our Customer Relations department at ###-###-#### Monday-Friday 9am-6pm ESTSincerely, Melissa B***Tiffany and CO

Dear Revdex.com,
We believe that we have sufficiently addressed all claims and continue to maintain our position that the Scottish Terrier Necklace that [redacted] listed is not genuine Tiffany & ComerchandiseThe photos that [redacted] provided do not change our positionThese are not internal Tiffany QA images but rather sourced from unaffiliated third parties and they cannot be used as the basis to establish the authenticity of [redacted]'s piece.Sincerely,Tim G[redacted]Tiffany & Co

To Whom it May Concern, ? We reviewed the customers concerns with the sales management teamThey worked with our inventory department to provide an alternative bracelet with the darkest stone available in this designThis second bracelet was provided complimentary, however [redacted] continues to be displeased with the coloring of this natural stoneAs an alternative, a full refund was offered to [redacted] with the requirement that both bracelets be returnedAlthough [redacted] has declined both of our offers, we feel we have provided adequate solutions to address her concerns? Tim G[redacted] Tiffany and Co

Revdex.com:
I have reviewed the response made by the business in reference to complaint ID [redacted], and find that this resolution is satisfactory to me and the matter has been resolved
Sincerely,
[redacted]
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Revdex.com:
I have reviewed the response made by the business in reference to complaint ID#? [redacted], and have determined that my complaint has NOT been resolved because:
First of all I mentioned in my original letter to the Revdex.com that I spoke to the [redacted].? store but then I AGAIN followed up with CORPORATE because all the manager? did at the [redacted] was try and explain away my issues and never concretely addressed themTelling a customer on the phone? that you (manager) are [redacted] so therefore they couldn't have been treated with prejudice s acceptable when?? I didn't care than and really don't care nowA register not working not once but twice and denying a charge? and a customer being told that their card is not working but? in REALITY IT IS THE STORE'S REGISTER IS NOT is EMBARASSING AND? ACCEPTABLEBeing treated like a second class citizen and being lead to believe that your significant other may be making numerous other purchases is crapFollowing up with Teresa R[redacted] in the Executive Office and then being transferred to a Shannon K[redacted] (Manager of Customer Relations)whom you recount on her VM as requested by MsR[redacted] the whole situation? including the phone call? that I got from? the manager? at the [redacted] and to still not have once heard from MsK[redacted] is really unacceptableI am shocked at the whole way Tiffany has handled this entire situation and I am surprised to say that they lack quality customer service and their treatment? OF CUSTOMERS (REPEATETIVE ONES)is deplorable at mostThe constant sweeping of this entire situation ? under the rug is deplorable and I will never patronize ANY OF the storeS againI will be sure to inform all of my friends, Co-workers, and thousands of FB followers of this situation and hope that they don't bother with the? establishment either.?
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In order for the Revdex.com to appropriately process your response, you MUST answer the question above
Sincerely,
[redacted]
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Dear [redacted], ? This issue has been reviewed with managementOur records show that on March [redacted], [redacted] visited one of our store locations and received a cash refund for the amount disclosedAs the refund has now been provided, we feel that an adequate resolution has been met
? ? Sincerely, Melissa B[redacted] Tiffany and Co

no no refund? the problem with the shipment was that the prices they quoted were different than what they originally quoted.? i.eI have one email where they state one price for shipment and another email for another price