December 24, 2025
Santa Claus
Chief Executive Officer
North Pole Industries
123 Elf Road
North Pole, 88888
RE: NOTICE TO CEASE AND DESIST AND DEMAND FOR IMMEDIATE RETRACTION
Dear Mr. Claus:
This firm has been retained to represent Brandon Ratt, a/k/a B. Ratt (hereinafter “Client”) regarding the egregious and unsubstantiated publication of their name on the 2025 “Naughty List.”
It has come to our attention that you, acting in your capacity as CEO of North Pole Industries, have categorized our Client as a “naughty” individual. This classification, disseminated to elves, reindeer, and parental units worldwide, constitutes defamation per se.
Our investigation indicates that your “List” is based on hearsay, unauthorized surveillance (i.e., “seeing them when they’re sleeping”), and a total lack of due process.
Our Client’s claims are actionable based on the following:
- Factual Falsity: Our Client has maintained a record of impeccable conduct. Any alleged “naughtiness” is either a localized misunderstanding or a fabrication by disgruntled third parties (e.g., siblings).
- Economic Damages: By placing our Client on the Naughty List, you have signaled an intent to withhold “toys” and “goodies,” replacing them with coal—a substance that is not only a logistical burden but also carries a significant carbon footprint and disposal cost.
- Reputational Harm: The social stigma associated with “Naughty” status has caused our Client severe emotional distress and irreparable “playground” standing.
To avoid a protracted litigation process in the High Court of Christmas, our Client demands the following by midnight on December 24, 2025:
- Immediate Reclassification: The formal moving of our Client’s name from the “Naughty” column to the “Nice” column.
- Full Disclosure: A copy of all data points collected during your unauthorized surveillance of our Client.
- Specific Performance: Delivery of one (1) [Insert Desired Gift Here] in mint condition, with no assembly required.
- Public Retraction: A formal “Ho-Ho-Hold on, I was wrong” announcement via the North Pole broadcasting network.
Be advised that our Client is prepared to seek equitable relief (including but not limited to an injunction against further defamation), as well as monetary damages. If you would like to discuss an amicable resolution of this matter, please contact me directly. I suggest a meeting over milk and cookies.
Sincerely,
A. Turney, Esq.