Email Discussion Between Pi Beta Phi Legal Counsel Michelle Willbanks and Indigo Klabanoff

From: Michelle Willbanks <[REDACTED]>
Date: August 28, 2013, 12:23:08 PM MDT
To: Indigo Klabanoff <[REDACTED]>
Subject: Re: Phi Beta Pi Dixie State University


Thank you so much for responding to my email and so quickly.  I appreciate your understanding of our concerns, and changes you have already made.

Thank you also for sending me the FIRE letter–I had actually already seen it.  There are a number of articles with respect to this on their website. I am very familiar with FIRE and I applaud and appreciate their efforts in fighting for the rights of students.

I wish you the best in your efforts.



On Aug 28, 2013, at 11:49 AM, Indigo Klabanoff wrote:


I just wanted to provide you with a polite response apologizing for creating the confusion, and i want to voluntarily comply with your requests. I took down the Lily P print when I noticed that it had tiny trademarks!  As far as the constitution is concerned and the motto, it is nothing alike. We are PHI BETA PI (delta ) chapter. While we do use some of the core values (3 at the most) , we as a sorority have created  our own motto, vision, colors and  branding.  I want to also say that we ARE NOT using Any of your symbols (as our symbol is the skeleton key).

Especially at this early stage I think it is easy for confusion of our brand. ESPECIALLY with the school trying so hard to ban us, when it’s within our constitutional rights to start a club with Greek letters. I will attach the letter from FIRE, (FOUNDATION OF INDIVIDUAL RIGHTS IN EDUCATION   ), so you know what’s exactly going on! ( timeline, etc)

While we do like and admire your sorority, we don’t want to be associated with it, which is why we changed everything and inverted our letters.  We are PHI BETA PI and not associated with you in any way.

Please let me know if i can be of any help, or if you need any more information from me!

Warm regards,


Sent from my iPhone


On Aug 28, 2013, at 7:53 AM, Michelle Willbanks <[REDACTED]> wrote:

Dear Indigo,

It has been brought to my attention that you are interested in forming a club at Dixie State University under the name of Phi Beta Pi.

While I applaud the values you have selected for your club, I do have some concerns regarding the use of the name and our protected trademarks.

As you are probably aware, Pi Beta Phi Fraternity for Women is an international organization with collegiate chapters and alumnae clubs throughout the United States and Canada.

Our name and symbols are trademarked. The Lilly Pulitzer print that is on your Facebook page is also trademarked and includes within the print not only our flower and arrow (symbol of our badge and membership), but also includes the Greek letters of Pi Beta Phi, which is a violation of trademark rights of Pi Beta Phi.

In addition to the trademark violation, there is enormous potential for confusion in the use of Pi Beta Phi’s trademarked Greek letters and name, especially when combined with our symbols and colors, even the letters PBP.

Similarly, when a Pi Beta Phi chapter’s charter has been relinquished or revoked, per our governing documents, it may not use any part of the name Pi Beta Phi.

We also understand Dixie State has a policy regarding Greek letter organizations.

I must be clear Pi Beta Phi does not have a relationship with your proposed organization, nor would we be liable for any actions of the club or its members. In addition, Phi Beta Pi nor its members would not be covered under Pi Beta Phi’s insurance.

Therefore, I would request you immediately remove the Lilly Pulitzer print, the use of our symbols, Greek letters, colors and any other references, names or initials that could be construed or misunderstood to be Pi Beta Phi.

Thank you for your attention to this matter.  Please feel free to contact me should you have any questions.

Michelle Willbanks
Internal Legal Counsel
Pi Beta Phi Fraternity for Women

Juli Willeman, Executive Director Pi Beta Phi Fraternity for Women
Paula Shepherd, Grand President Pi Beta Phi Fraternity for Women
Eily Cummings, Marketing and Communications Director, Pi Beta Phi Fraternity for Women
Shawn Eagleburger, Member Services and Programming Director, Pi Beta Phi Fraternity for Women
Del W. Beatty Dean of Students, Dixie State University
Jordan Houston Administrative Assistant of Clubs, Dixie State University

Schools: Dixie State University Cases: Dixie State University: School Rejects Student Group Because Its Name Includes Greek Letters