Official Final Public Cease-and-Desist Notice

Today, The Steve Huff Memorial Foundation is issuing a final public cease and desist notice regarding the unauthorized administration and use of the “Steve Huff Motorsports” Facebook page and related digital assets by Jill Andrews, Steve’s former public relations manager. This notice also formally demands that Meta Platforms, Inc. terminate Ms. Andrews’ access and immediately transfer full administrative control of the page and associated content to the lawful rights holder, Thomas Huff Sole Heir of the estate of Stephen Anthony Huff and The Steve Huff Memorial Foundation.
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In the interest of transparency with Steve’s family, friends, fans, and the motorsports community, the full text of the final cease and desist letter delivered to Meta’s Legal Department and to Ms. Andrews is provided below:

December 26, 2025

VIA CERTIFIED MAIL AND ELECTRONIC SUBMISSION Meta Platforms, Inc.

Attn: Legal Department / Intellectual Property Team 1601 Willow Road Menlo Park, CA 94025

RE: CEASE AND DESIST NOTICE AND DEMAND FOR IMMEDIATE TRANSFER OF INTELLECTUAL PROPERTY

Unauthorized Administration of "Steve Huff Motorsports" Facebook Page and Related Digital Assets.

Estate of Steve Huff; The Steve Huff Memorial Foundation v. Jill Andrews

To Whom It May Concern:

The Steve Huff Memorial Foundation and the estate of Stephen Anthony Huff (hereinafter; "Claimants") regarding the unauthorized and unlawful continued administration and use of the "Steve Huff Motorsports" Facebook page and all related digital assets, intellectual property, and content bearing or associated with the name, likeness, image, brand, and motorsports history of the late Steve Huff.

We write to demand the immediate cessation of all unauthorized use and administration by Jill Andrews and to require the prompt transfer of full administrative control and ownership of the aforementioned digital assets to the lawful rights holder— Thomas E. Huff, the Steve Huff estates sole heir and executive director of The Steve Huff Memorial Foundation.

I. FACTUAL BASIS

Following the death of Steve Huff, all rights in and to his name, likeness, image, brand identity, intellectual property, and digital assets passed to his estate and his sole heir. The Steve Huff Memorial Foundation was established by his estate and heir expressly to preserve, protect, manage, and perpetuate his legacy and intellectual property in perpetuity.

The "Steve Huff Motorsports" Facebook page, which serves as a digital repository of Steve Huff's professional identity, racing achievements, brand recognition, and commercial value, remains registered and operated under the unauthorized administrative control of Jill Andrews, identified as Steve Huff's former public relations manager.

Ms. Andrews has explicitly stated, in written communications with representatives of Claimants, that she believes she is entitled to ownership and control of the aforementioned page based solely upon her years of professional involvement with Steve Huff and his motorsports team. This assertion has no legal, contractual, or equitable basis whatsoever.

II. LEGAL AUTHORITY AND RIGHTS OF CLAIMANTS

A. Right of Publicity and Estate of Steve Huff

The right of publicity is a property right that survives death in most jurisdictions, including the States in which this matter may be litigated. The right of publicity encompasses the right to control the use of an individual's name, likeness, image, voice, signature, and distinctive characteristics for commercial purposes and public representation.

Upon Steve Huff's death, all right, title, and interest in his right of publicity vested in his estate and passed to his heirs and the entities designated to manage his legacy. No transfer of this right to Ms. Andrews occurred during his lifetime, nor could any such transfer occur post-mortem without explicit, documented authorization from the estate and heirs.

B. Trademark and Brand Identity

The "Steve Huff Motorsports" name and brand constitute valuable intellectual property, including potential trademark rights and trade secret value accrued over decades of professional racing achievement and public recognition. These assets are owned exclusively by the estate and heirs of Steve Huff.

Ms. Andrews' unauthorized continued administration and use of the page under this brand name constitutes trademark dilution, brand misappropriation, and unauthorized use of trade identity without license or authorization.

C. Copyright in Digital Content

The "Steve Huff Motorsports" Facebook page contains original creative content, including photographs, videos, written posts, and curated historical material, all of which are owned by Steve Huffs estate. Ms. Andrews has no copyright interest in, and no authorization to reproduce, modify, distribute, or publicly display any portion of this content.

D. Meta's Terms of Service and Community Standards

Meta's own Terms of Service and Community Standards explicitly prohibit unauthorized impersonation, fraudulent account administration, misrepresentation of identity, and the use of accounts to represent deceased individuals without proper legal authorization.

Ms. Andrews' continued administration of an account bearing Steve Huffs name and brand without authorization from the lawful rights holder constitutes a material violation of Meta's policies and terms.

III. WRONGFUL CONDUCT AND UNAUTHORIZED ACTIONS

Ms. Andrews' continued administration of the "Steve Huff Motorsports" Facebook page and related assets after explicit demand via prior cease and desists letters and attempts for transfer constitutes:

1. Unauthorized Use of Persona and Identity: Posting, messaging, and publicly representing Steve Huff's name, image, brand, and legacy without authorization from the lawful rights holder

2. Misappropriation of Intellectual Property: Exercising exclusive control over valuable trademark, right-of-publicity, and copyright assets that belong to the estate and heirs of Steve Huff.

3. Breach of Meta's Terms of Service: Violating Meta's explicit policies regarding account administration, impersonation, and misrepresentation of identity.

4. Unjust Enrichment: Deriving benefit, recognition, and potentially financial value from the unauthorized administration and use of Steve Huff's name and brand.

5. Interference with Estate Administration: Obstructing the lawful management and preservation of estate assets and the legacy of the deceased.

The continued refusal to transfer administrative control, despite repeated written demands from the lawful rights holder, demonstrates willful and intentional misconduct.

IV. CEASE AND DESIST DEMAND

Effective immediately, and without further delay, Ms. Andrews and any parties acting in concert with her are hereby commanded to:

1. Immediately cease all administration, posting, messaging, and management of the "Steve Huff Motorsports" Facebook page and any related accounts, pages, or digital properties bearing Steve Huff's name, image, brand, or likeness.

2. Immediately cease all creation, production, distribution, or sale of merchandise, memorabilia, commemorative items, stickers, or any materials suggesting or implying official endorsement, memorial affiliation, or commercial association with Steve Huff or his estate.

3. Immediately cease all use of Steve Huff's name, likeness, image, brand, or intellectual property in any capacity, whether for commercial, memorial, or other purposes, absent explicit written authorization from the estate and The Steve Huff Memorial Foundation.

4. Preserve in their current state all content, posts, messages, photographs, videos, administrative records, metadata, and any other materials associated with the "Steve Huff Motorsports" page and related accounts, and take no action to delete, modify, destroy, or remove any such content.

V. TRANSFER OF ADMINISTRATIVE CONTROL AND DIGITAL ASSETS

Meta is hereby directed to:

1. Recognize and acknowledge that the lawful rights holder of the "Steve Huff Motorsports" Facebook page and all associated intellectual property is Thomas Huff Sole Heir of the estate of Stephen Anthony Huff and The Steve Huff Memorial Foundation, as evidenced by estate documents and corporate filings to be provided to Meta.

2. Immediately terminate Jill Andrews' administrative authority over the aforementioned page and all related accounts, effective upon receipt of this notice.

3. Prepare for immediate transfer of full administrative control and ownership of the "Steve Huff Motorsports" Facebook page to the designated representative of the estate of The Stephen Anthony Huff and The Steve Huff Memorial Foundation.

4. Execute the transfer of complete administrative control within ten (10) business days of receipt of proper authorization documentation from the lawful rights holder

5. Preserve all existing content on the page in its current form, with all historical posts, comments, photographs, videos, and metadata intact and unmodified, pending transfer.

Claimants are providing again to Meta all necessary documentation—including certified copies of estate documents, corporate filings for The Steve Huff Memorial Foundation, court filings and orders, and other evidence of authority—to facilitate the immediate transfer of administrative control.

VI. LEGAL CONSEQUENCES OF NON-COMPLIANCE

Failure to comply with this demand shall result in:

1. Immediate legal action against Meta Platforms, Inc., seeking declaratory judgment, injunctive relief, damages for breach of contract and violation of its own Terms of Service.

2. Legal action against Jill Andrews, seeking:

o Declaratory judgment establishing the rights of the estate and The Steve Huff Memorial Foundation

o Preliminary and permanent injunctive relief requiring cessation of all unauthorized use

o Damages for trademark dilution, unjust enrichment, and conversion of intellectual property

o Statutory damages for copyright infringement (up to $150,000 per infringement)

o Actual damages and disgorgement of profits

o Attorney's fees and costs of litigation

o Criminal referral for potential identity fraud and misappropriation

3. Complaints to state regulatory authorities, including the Attorney General's office and state consumer protection divisions, regarding Meta's failure to enforce its own Terms of Service and its material support of unauthorized use of deceased individuals' identities and intellectual property.

4. Public disclosure of Meta's failure to protect the intellectual property rights of deceased individuals and their estates, including publication of this correspondence and the underlying facts to media outlets and industry watchdog organizations.

VII. RESPONSE REQUIRED

A written response to this notice is required within ten (10) business days of receipt, addressing:

1. Confirmation that Ms. Andrews' administrative authority has been terminated

2. Confirmation that the "Steve Huff Motorsports" page and all related assets are being preserved pending transfer

3. Confirmation of the date and time by which Meta will execute the transfer of administrative control to the lawful rights holder

Responses and all further correspondence regarding this matter should be directed to the undersigned at admin@thestevehuffmemorialfoundation.com and (206) 778-0434.

VIII. PRESERVATION OF EVIDENCE

All parties are placed on notice of the requirement to preserve all evidence related to the "Steve Huff Motorsports" Facebook page, including:

• Account administrative history and audit logs

• All posts, comments, messages, and metadata

• Access logs and IP addresses used to administer the account

• Communications between Ms. Andrews and Meta or between Ms. Andrews and any third parties regarding the page

• Any payments, compensation, or financial arrangements related to the page

Destruction, deletion, or alteration of any such evidence may result in additional legal liability, including sanctions for spoliation of evidence.

IX. RESERVATION OF RIGHTS

This notice constitutes a final demand prior to litigation. It does not constitute a waiver of any claims, defenses, or remedies available to Claimants under state or federal law. All rights are expressly reserved.

Claimants reserve the right to amend, supplement, or expand the scope of this demand based on facts and evidence that may be discovered during litigation or investigation.

Sincerely,

Thomas E. Huff
President - Executive Director
The Steve Huff Memorial Foundation
Non-Profit 501(c)(3)
Phone: (206) 778-0434
Address: 4849 San Francisco Dr NE, Space #20, Salem, OR 97305
Email: admin@thestevehuffmemorialfoundation.com​
Website: https://www.thestevehuffmemorialfoundation.com
Former Vice President, IAFF Local 10060 Southern Region
IAFF Active Retired – 1099835

Enclosures:

• Copies of estate documents (furnished to Meta Only)

• Copies of corporate filings for The Steve Huff Memorial Foundation (furnished to Meta Only)

• Copy of Death Certificate (furnished to Meta Only)

• Copies of Living Trust and Pour Over Will (furnished to Meta Only)

• Copies of previous Cease and Desist Letters Sent to Jill Andrews (furnished to Meta Only)

cc:

The Steve Huff Memorial Foundation / admin@thestevehuffmemorialfoundation.com​

Jill Andrews / jillagaintravels@gmail.com