Cyndi's List, et al v. Mygenshare.com, et al

Filing 1

COMPLAINT FOR COPYRIGHT INFRINGEMENT, UNFAIR TRADE PRACTICES, TORTIOUS INTERFERENCE, UNJUST ENTRICHMENT, AND EQUITABLE RELIEF against defendant(s) All Defendants (Receipt # 0981-3055326), filed by Cyndi's List.(Abolins, Talis) Modified on 12/26/2012 to remove caps from filer's name (PM).

1 2 3 4 5 6 7 8 9 10 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON TACOMA DIVISION 11 12 13 14 15 16 17 18 19 20 CYNDI’S LIST, a dba of CYNTHIA HOWELLS, and CYNTHIA HOWELLS, an individual, Plaintiff(s), v. MYGENSHARE.COM, LLC, a Utah limited liability company, and BARRY J. EWELL, an individual, Defendant(s). Case No. ____________ COMPLAINT FOR COPYRIGHT INFRINGEMENT, UNFAIR TRADE PRACTICES, TORTIOUS INTERFERENCE, UNJUST ENRICHMENT, AND EQUITABLE RELIEF JURY TRIAL DEMANDED COMES NOW Plaintiff, CYNDI’S LIST and CYNTHIA HOWELLS, and 21 22 by this Complaint seeks money damages and equitable relief against 23 Defendants MYGENSHARE.COM, LLC and BARRY J. EWELL for: (1) 24 copyright infringement; (2) unfair trade practices in violation of Washington’s 25 Consumer Protection Act; (3) tortious interference; and (4) unjust enrichment, 26 and other equitable relief, and alleges as follows: Complaint for Copyright Infringement – Page 1 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 2 3 JURISDICTION AND VENUE 1. This Court has subject matter jurisdiction over this action This Court has Federal Question jurisdiction over this action pursuant to 28 U.S.C. 4 5 6 7 8 9 10 11 §§ 1331 and 1338 as an action arising under the laws of the United States, including Title 17 of the United States Code relating to copyrights. 2. This Court has pendent jurisdiction over the state claims under 28 U.S.C. § 1338(b) in that said claims are joined with substantial and related claims under the Copyright Laws of the United States, Title 17 United States Code. This Court also has supplemental jurisdiction pursuant to 28 U.S.C. § 12 1367. Pursuant to Rule 9(c), Plaintiff pleads that all acts and conditions 13 precedent for establishing jurisdiction have been performed or have occurred. 14 15 16 3. Venue and personal jurisdiction are proper in this district pursuant to 28 U.S.C. § 1400, 28 U.S.C. § 1391(b) and (c), and, pursuant to 17 FRCP 4, Washington’s long arm jurisdictional rules and statutes in that 18 Plaintiff is informed and believes and on that basis alleges that Defendant(s) 19 reside in this district and/or can be found in this district by virtue of their 20 activities, are engaged in substantial and not isolated activities in this district, 21 22 and engaged in acts in this district and/or injured persons in this district in 23 conjunction with activities carried on within this district by Defendants and/or 24 in the ordinary course of trade of Defendants. 25 26 4. Plaintiff is informed and believes and on that basis alleges that this Court has personal jurisdiction over Defendants by virtue of Defendants Complaint for Copyright Infringement – Page 2 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 2 3 transacting and doing business in this judicial district. 5. Plaintiff is informed and believes that Defendants have contacted Washington residents seeking advertising for Defendants website on 4 5 Washington residents’ internet sites; that Defendants operate online highly 6 interactive 7 internationally, and to the State of Washington; that Defendants operate 8 online digital subscriptions services that take subscriptions and payment from 9 10 11 webstores that take orders from and ship nationally, and grant access to national and international entities, including entities in the State of Washington; that Defendants conduct business with Washington 12 residents; and that Defendants have otherwise by their activity submitted to 13 the jurisdiction of the State of Washington. 14 15 16 PARTIES 6. CYNDI’S LIST. Plaintiff, CYNTHIA HOWELLS maintains a 17 professional website addressed to genealogy under the sole proprietorship 18 name of CYNDI’S LIST, with principal place of business in Edgewood, 19 Washington. 20 21 22 7. MYGENSHARE.COM LLC. Plaintiff is informed and believes and on that basis alleges that Defendant MYGENSHARE.COM, LLC is a 23 Utah limited liability company, conducting business nationwide including in 24 the State of Washington, and by such extensive conduct, residing in the State 25 of Washington, including by, among other things, contacting Washington 26 residents and Washington based websites for advertising on Washington Complaint for Copyright Infringement – Page 3 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 based websites, operating on line store(s) and subscription(s) addressed to 2 Washington residents. 3 8. BARRY J. EWELL. Plaintiff is informed and believes and on 4 5 that basis alleges that Defendant BARRY J. EWELL is the owner, operator, 6 and principal of MYGENSHARE.COM LLC, that he operates and maintains 7 the www.mygenshare.com website, and that he dominates, controls, and 8 otherwise is the principal actor in the offending, infringing, tortious, and 9 10 illegal actions complained of herein. COMMON ALLEGATIONS OF FACT 11 9. 12 Plaintiff CYNDI’S LIST is a professional genealogy website, 13 having address www.cyndislist.com, that has been operating since March 4, 14 1996. 15 16 It is a comprehensive resource for genealogical research, with categorization and organization that is extremely creative and unique to 17 CYNDI’S LIST, different from other genealogical research websites. 18 CYNDI’S LIST is continually updated. 19 claimed on the website and its related works since inception. 20 registration protection is continually updated. 21 22 Copyright protection has been Copyright Copyright registrations and/or copyright registration applications have been secured and/or applied 23 for every year from 1997 through 2012, on at least a yearly basis. The first 24 copyright was filed and registered in 1997. 25 appeared on the site since inception. Copyright statements have 26 Complaint for Copyright Infringement – Page 4 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 2 3 10. Plaintiff was and is the sole owner of her copyrighted work in the www.cyndislist.com website (hereinafter “Copyrighted Work”). Plaintiff holds Copyright Registration No. TXu000787268 and TX 7615575 for the CYNDI’S 4 5 LIST website including the comprehensive, categorized and cross-referenced 6 compilation of internet links that point to genealogical research sites online, as 7 well as other pending or issued registrations. CYNDI’S LIST website gives a 8 clear notice of the existence of the copyright registration. 9 10 11 In addition CYNDI’S LIST holds Copyright Registration No.’s TX0005399878 and TX000426087 for CYNDI’S LIST books. These books also include prior 12 compilations of the copyright materials included on the CYNDI’S LIST 13 website. 14 15 16 17 18 19 20 21 22 23 24 11. Plaintiff has also applied for registration for, and or received registration on, its website for each year from 1997 through 2012. 12. Plaintiff’s copyright registration(s) are prima facie evidence of the validity, ownership, and originality of her Copyrighted Work. 13. People accessing CYNDI’S LIST are notified of the copyright claimed in the work. 14. Plaintiff is informed and believes and on that basis alleges that Defendants copied Plaintiff’s Copyrighted Work. 15. Plaintiff is informed and believes that Defendants were aware of 25 Plaintiff’s Copyrighted Work, accessed Plaintiff’s Copyrighted Work numerous 26 times, and, despite the copyright notice, willfully copied Plaintiff’s Complaint for Copyright Infringement – Page 5 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 Copyrighted Work and incorporated Plaintiff’s Copyrighted Work in 2 Defendants’ competing website www.mygenshare.com. 3 16. Defendants maintain a competing genealogical research website 4 5 6 7 8 9 10 11 12 13 14 15 16 for profit. Defendant’s website competes with Plaintiff’s website. 17. Defendant’s copying of Plaintiff’s Copyrighted Work was done for profit and is in no guise a fair use of Plaintiff’s Copyrighted Work. 18. Defendants gave a public presentation in 2012 at a Genealogical Society Jamboree in which Defendants admitted to accessing and reviewing Plaintiff’s’ Copyrighted Work. Defendants admitted in a 2007 presentation accessing Plaintiff’s Copyrighted Work numerous times. 19. Defendants’ copying of Plaintiffs’ Copyrighted Work is obvious throughout the Defendants’ links directory. Examples include the word for word heading and category arrangements throughout Defendants’ links 17 directory. Other obvious examples are that the broken links within CYNDI’S 18 LIST are the same broken links within Defendants’ links for the same 19 directory items. Defendants make a point in its live-streaming webinar from a 20 2012 genealogical jamboree that it developed its own links directory and 21 22 thereby avoided the broken links that were within CYNDI’S LIST and other 23 genealogy reference sites. The fact that the broken links are identical from one 24 to the other is an obvious sign of copying. 25 26 20. The Copyrighted Work in CYNDI’S LIST website, including the unique information and compilations of information on Plaintiffs’ website, Complaint for Copyright Infringement – Page 6 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 were created personally by Cyndi Howells. Plaintiff started her website in 2 1996, and over the last 16 years has, in fact, started from scratch and built her 3 compilation in a unique manner and style. Every affiliate link on CYNDI’S 4 5 LIST was hand created by Ms. Howells. She visited the affiliate website, 6 found the page/material/database to link to, confirmed the categorizations, 7 wrote the code, inserted her affiliate ID number, and applied an appropriate 8 item description for each link. This from-scratch effort was done one-by-one 9 10 11 12 13 14 15 16 and not through an automated process. For example, more than 12 years ago CYNDI’S LIST made a specific set of Amazon.com affiliate links with a specific title and specific parameters. 21. Defendants illegally copied Plaintiffs’ Copyrighted Work and then changed the affiliate codes—with, for example the name of Amazon.com stripped out and CYNDI’S LIST own affiliate ID replaced with that of 17 Defendants’ affiliate account. There are many other examples of this same 18 copying, stripping, and publishing on the Defendants’ website. It would be 19 impossible for this to happen if Defendants created its list on its own. 20 Defendants copied CYNDI’S LIST Copyrighted Work, inserted its own affiliate 21 22 23 24 25 account numbers into those links created by CYNDI’S LIST, and is using those links in its affiliate relationships for profit. 22. On October 31, 2012, Plaintiff transmitted to Defendants a Notice of Infringement. 26 Complaint for Copyright Infringement – Page 7 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 2 3 23. In response, Defendants did little to change titles and names of its categories. In many cases, Defendants simply lopped off several words and added the phrase “and related” to make a new title. CYNDI’S LIST 4 5 includes numerous categories of titles that are entirely unique to CYNDI’S 6 LIST and were created by Cyndi Howells over the many years that she has 7 worked on her website and list. Many names are non-traditional genealogical 8 titles and topics, but they are copies word for word onto the Defendants’ 9 10 11 website links directory. These titles have been witnessed by professionals in the field of genealogy prior to Defendants changing of those titles after 12 receiving Plaintiffs’ October 31, 2012 Notice of Infringement. Also, copies of 13 the original titles have been made as proof of the exact duplication of those 14 found on CYNDI’S LIST and the resulting alteration after being notified by 15 16 17 CYNDI’S LIST of the copyright infringement. 24. Plaintiff is informed and believes, and on that basis alleges, that 18 as a result of the copying of CYNDI’S LIST and its hundreds of thousands of 19 links, categories, and subcategories, Defendants have diverted, and will 20 continue to divert, people from CYNDI’S LIST to Defendants’ website for 21 22 financial gain. Persons searching on an exact link title or category found on 23 CYNDI’S LIST will also receive Defendants’ website as a search hit for that 24 same category. Defendants’ intentions in this matter are clearly to divert 25 internet traffic away from CYNDI’S LIST and create new subscription 26 customers for Defendants’ site and revenues from Defendants’ affiliate Complaint for Copyright Infringement – Page 8 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 contracts. At the same time this is taking income and revenue away from 2 CYNDI’S LIST’s affiliate contracts and otherwise from Plaintiffs’ website 3 25. Plaintiff is informed and believes, and on that basis alleges, that 4 5 Defendants copied, published and publicly displayed the Copyrighted Work, 6 and/or unauthorized derivative works created from the Copyrighted Work, in 7 Washington, and throughout the United States and internationally. 8 9 10 11 12 13 14 15 16 26. Plaintiff is informed and believes and on that basis alleges that Defendants used Plaintiff’s Copyrighted Work, without permission, to sell Defendants’ goods and/or services, and did not attribute that work to Plaintiff, and instead altered and removed attribution to Plaintiff. 27. Plaintiff is informed and believes and on that basis alleges that Defendants are sophisticated internet designers and webhosts and are aware of U.S. copyright laws and the consequences for willful copy of the Copyrighted 17 Work of another. Defendants themselves prominently display copyright 18 statements on their website, showing their sophisticated knowledge and the 19 willfulness of their illicit copying. 20 21 22 28. Plaintiff is informed and believes and on that basis alleges that Defendants altered all affiliate links in the illegally copied Copyrighted Work 23 to commercial sites such as Ancestry.com and Amazon.com, removed 24 Plaintiff’s affiliate code and inserted Defendants’ own. This is also a violation 25 of the terms of use for each of the affiliate and a clear violation of the terms of 26 use for Google AdSense terms. Complaint for Copyright Infringement – Page 9 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 2 3 29. Plaintiff is entitled to compensation to the extent possible for damages, general and special, consequential, and incidental, in an amount to be proven at trial, for the harm caused by Defendant, and for attorneys’ fees, 4 5 6 costs, and pre- and post-judgment interest. 30. Plaintiff has suffered and likely will suffer immediate irreparable 7 damage and ongoing harm by reasons of Defendants’ unlawful acts unless 8 Defendants are restrained and enjoined, and Plaintiff is without adequate 9 10 11 remedy at law. 31. Defendants’ unlawful activities caused, and likely will continue 12 to cause, irreparable harm to Plaintiff, which cannot be fully compensated by 13 money damages. 14 32. 15 16 The public has an overriding interest in avoiding unlawful copying of the work of artists and in the enforcement of copyright and trade 17 practices laws, and in the proper attribution of source and association for 18 goods and services in commerce. 19 20 21 22 23 24 33. Accordingly, Plaintiff demands an amount of money damages to compensate the Plaintiff for the harm caused, including but not limited to Defendants’ profits, statutory and/or punitive damages, as well as equitable relief, attorneys’ fees, costs, and interest. FIRST CLAIM FOR RELIEF--COPYRIGHT INFRINGEMENT 25 34. Plaintiff re-alleges every paragraph in this Complaint. 26 35. Plaintiff is informed and believes and on that basis alleges that Complaint for Copyright Infringement – Page 10 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 by its aforesaid conduct Defendants willfully infringed Plaintiff’s Copyrighted 2 Works; that Defendants’ actions willfully and for profit violated exclusive 3 rights of the Copyright Laws of the United States; that Plaintiff owned valid 4 5 6 7 8 9 10 11 12 copyright on works which Defendants violated in acts of improper appropriation. 36. Accordingly, Defendants are liable to Plaintiff for statutory damages, and/or actual damages, including Defendants’ profits, at Plaintiff’s election, and Defendants should be enjoined to remove from their website all Copyrighted Work of Plaintiff, including Defendants’ link directory. SECOND CLAIM FOR RELIEF—UNFAIR TRADE PRACTICES 13 37. Plaintiff re-alleges every paragraph in this Complaint. 14 38. Plaintiff is informed and believes and on that basis alleges that 15 16 Defendant, by its aforesaid conduct, committed unfair trade practices in 17 violation of Washington’s Consumer Protection Act, RCW 19.86 et seq., that 18 Defendants willfully engaged in practices and acts that cause likelihood of 19 confusion or of misunderstanding as to the source, sponsorship, approval, or 20 certification of Defendants’ goods or services and/or as to affiliation, 21 22 connection, or association with, or certification by, Plaintiff and/or Plaintiff’s 23 products and/or that represent Defendants’ goods to have sponsorship or 24 approval that they do not have or a status, qualification, affiliation, or 25 connection that Defendants do not have. 26 Complaint for Copyright Infringement – Page 11 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 2 3 39. Plaintiff is informed and believes and on that basis alleges that Defendants’ unlawful acts were and are knowing, willful, and malicious. 40. Plaintiff is entitled to compensation to the extent possible in 4 5 damages, general and special, consequential, and incidental, in an amount to 6 be proven at trial, for the harm caused by Defendant, and for attorneys’ fees, 7 costs, and pre- and post-judgment interest. 8 9 10 11 12 13 14 15 16 17 41. Plaintiff has and will suffer immediate irreparable damage and ongoing harm to its business, reputation, and goodwill by reasons of Defendants’ unlawful acts unless Defendants are restrained and enjoined, and Plaintiff is without adequate remedy at law. 42. Accordingly, Plaintiff demands an amount of money damages to compensate the Plaintiff for the harm caused, including but not limited to Defendant’s profits, statutory and/or punitive damages, as well as equitable relief, attorneys’ fees, costs, and interest. 18 THIRD CLAIM FOR RELIEF-TORTIOUS INTERFERENCE 19 43. Plaintiff re-alleges every paragraph in this Complaint. 20 44. Plaintiff is informed and believes and on that basis alleges that 21 22 Plaintiff had and has valid business relationships and/or business 23 expectancies based on its affiliate relationships; Defendants were and are 24 aware of those relationships and expectancies; Defendants intentionally, with 25 improper purpose and improper means, removed affiliate codes from Plaintiff’s 26 Copyrighted Work and replaced those codes with Defendants’ own affiliate Complaint for Copyright Infringement – Page 12 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 codes, interfering with those relationships and expectancies and directly and 2 proximately causing damage to Plaintiff thereby, including but limited to loss 3 of revenue, emotional distress. 4 FOURTH CLAIM FOR RELIEF-UNJUST ENRICHMENT 5 6 45. Plaintiff re-alleges every paragraph in this Complaint. 7 46. Plaintiff is informed and believes and on that basis alleges that 8 9 10 11 Defendants are unjustly enriched Plaintiff’s detriment by taking Plaintiff’s Copyrighted Work, placing it on Defendants’ website, and changing the affiliate codes in Plaintiff’s Copyrighted Work to Defendants affiliate codes to 12 divert revenue that Defendants was not entitled to from Plaintiff to 13 Defendants; that these acts are contrary to justice and equity. 14 15 16 17 47. disgorgement from Defendants, of and for all monies and/or other revenue by which Defendants were unjustly enriched DEMAND FOR JUDGMENT & PRAYER FOR RELIEF 18 19 20 21 22 23 24 Plaintiffs are entitled to an accounting by Defendants, and WHEREFORE Plaintiff prays for judgment against Defendants as follows: (a) Granting judgment in favor of Plaintiff against Defendants on all claims; (b) Awarding actual, general and specific, consequential and 25 incidental, damages against Defendants, jointly and severally, in an amount 26 to be determined at trial; Complaint for Copyright Infringement – Page 13 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 2 3 (c) Awarding Plaintiff exemplary, statutory, treble damages against Defendants, jointly and severally; (d) Adjudging Defendants liable under United States copyright laws 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 to Plaintiff for statutory, and/or actual damages and disgorgement of Defendants’ profits, at the election of Plaintiff; (e) Enjoining Defendants to account for all gains and advantages derived from its acts of infringement, misattribution, unfair trade practices, tortious interference, unjust enrichment, and for its other violations of law, and in disgorgement, reduce all such gains and advantages to money judgment in favor of Plaintiff; (f) Enjoining Defendants to remove Plaintiffs’ Copyrighted Work from Defendants’ website, such removal to include at a minimum, Defendants’ Links Directory from its website; (g) Awarding Plaintiff’s its reasonable attorneys’ fees and costs, including costs for experts, pursuant to State and Federal law; 19 (h) Awarding Pre- and post- judgment interest; and 20 (i) Entering such other and further relief as the Court deems 21 22 appropriate under the circumstances. 23 24 25 26 Complaint for Copyright Infringement – Page 14 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513 1 2 JURY DEMAND Plaintiff hereby demands trial by jury in this action. 3 4 5 6 7 8 9 DATED __________________ /s/ Steve Burnham ______________________________ STEVE BURNHAM, WSBA 13270 steveb@cdb-law.com CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 Tel: (253) 848-3513 Fax: (253) 845-4941 10 /s/ Kurt M. Rylander 11 15 KURT M. RYLANDER, WSBA 27819 rylander@rylanderlaw.com RYLANDER & ASSOCIATES PC P.O. Box 250 Vancouver, WA 98666 Tel: (360) 750-9931 Fax: (360) 397-0473 16 Of Attorneys for Plaintiff 12 13 14 17 18 19 20 21 22 23 24 25 26 Complaint for Copyright Infringement – Page 15 I:\DATA\D\SAB\HOWELLS, CYNDI\ACOMPLAINT FOR COPYRIGHT INFRINGEMENT.DOCX CAMPBELL, DILLE, BARNETT & SMITH, PLLC 317 South Meridian Puyallup, Washington 98371 253-848-3513