Perfect 10 Inc v. Google Inc et al

Filing 271

DECLARATION of Jeffrey N. Mausner In Support Of Reply for MOTION for Review of Portions of Magistrate Judge Hillman's Order of February 22, 2008 Granting in Part Perfect 10's Motion to Compel Defendant Google, Inc. to Produce Documents, and Objections Thereto; Memorandum of Points and Authorities i #257 filed by Plaintiff Perfect 10 Inc. (Attachments: #1 Exhibit A#2 Exhibit B#3 Exhibit 10#4 Exhibit 11#5 Exhibit C#6 Exhibit D)(Mausner, Jeffrey)

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Perfect 10 Inc v. Google Inc et al Doc. 271 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration Of Jeffrey N. Mausner In Support Of Plaintiff Perfect 10, Inc.'s Reply Memorandum For Its Motion for Review and Reconsideration of Portions of Magistrate Judge Hillman's Order of February 22, 2008 Dockets.Justia.com JEFFREY N. MAUSNER (State Bar No. 122385) DAVID N. SCHULTZ (State Bar No. 123094) Mausner IP Law 21800 Oxnard St., Suite 910 Woodland Hills, California 91367-3640 Telephone: (310) 617-8100; (818) 992-7500 Facsimile: (818) 716-2773 Attorneys for Plaintiff Perfect 10, Inc. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PERFECT 10, INC., a California corporation, Plaintiff, v. GOOGLE INC., a corporation; and DOES 1 through 100, inclusive, Defendants. AND CONSOLIDATED CASE MASTER FILE NO. CV04-9484 AHM (SHX) Declaration of Jeffrey N. Mausner In Support Of Plaintiff Perfect 10, Inc.'s Reply Memorandum Of Points And Authorities For Its Motion for Review and Reconsideration of Portions of Magistrate Judge Hillman's Order of February 22, 2008 Granting in Part Perfect 10's Motion to Compel Defendant Google, Inc. to Produce Documents, and Objections Thereto [Memorandum Of Points And Authorities and Declaration Of Dr. Norman Zada Submitted Concurrently Herewith] Date: April 14, 2008 Time: 10:00 A.M. Place: Courtroom of Judge Matz 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Jeffrey N. Mausner, declare as follows: 1. I am an attorney at law and a member of the State Bar of California. I am counsel of record for Plaintiff Perfect 10, Inc. ("Perfect 10") in this action. All of the matters stated herein are of my own personal knowledge, except where otherwise stated, and if called as a witness, I could and would testify competently thereto. 2. Attached hereto as Exhibit A is a true and correct copy of a letter to me from Rachel M. Herrick of Quinn Emanuel Urquhart Oliver & Hedges, LLP, counsel of record for Defendant Google Inc. ("Google"), dated March 19, 2008. 3. Attached hereto as Exhibit B is a true and correct copy of a document entitled "Declaration of Dr. Norm Zada In Support Of Perfect 10's Supplemental Memorandum In Support Of Its Motion To Compel Defendant Google Inc. To Produce Documents," without the exhibits thereto, which was filed by Perfect 10 in this action on November 5, 2007, and which is on file as Pacer No. 236 (the "2007 Zada Declaration"). 4. Attached hereto as Exhibit 10 is a true and correct copy of Exhibit 10 to the 2007 Zada Declaration discussed in the previous paragraph, which Dr. Zada describes in Paragraph 4 of the 2007 Zada Declaration as a printout that he made from Google Trends, showing the relative number of search results on Aria Giovanni (graph in blue) compared to searches on Ashley Judd (graph in red), and John Roberts (graph in green). 5. Attached hereto as Exhibit 11 is a true and correct copy of Exhibit 11 to the 2007 Zada Declaration, which Dr. Zada describes in Paragraph 5 of the declaration as a print-out of information regarding the number of searches done on a search engine known as overture.com for Perfect 10 model Aria Giovanni. As may be seen by a review of Exhibit 11, in January of 2007, there were 87,004 overture.com searches done specifically on the search term "aria giovanni." 1 Declaration Of Jeffrey N. Mausner In Support Of Plaintiff Perfect 10, Inc.'s Reply Memorandum For Its Motion for Review and Reconsideration of Portions of Magistrate Judge Hillman's Order of February 22, 2008

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