LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 176

NOTICE OF LODGING Proposed Pretrial Conference Order Plaintiff LegalZoom.com Inc. (Attachments: # 1 Proposed Order Final Pretrial Conference Order, # 2 Exhibit A)(Heather, Fred)

EXHIBIT A

No. of Exhibit Offering
Party/Parties
1
Defendant

Beg. Bates

End Bates

Date

Description

GIG02399

GIG02405

1/28/2009

Email from Travis Giggy to [e-mail] re: FW: Research Brief:
Pre-Shop Customer Reviews Important to Online Customers
Appendix of Exhibits in Support of Motion for Partial Summary
Judgment Brought by Plaintiff LegalZoom.com, Inc.
Email from Scott MacDonell to Brian Liu, cc. Carrie Yutzy re: Yelp! I
need somebody *****HIGHLY CONFIDENTIAL*****
Email from Scott MacDonell to Travis Giggy re: disclaimer

Non Offering Party's
Objections
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: Relevance;
Compound; Foundation
No Objection

2

NA

NA

7/14/2014

3

Defendant

LZ001546

LZ001548

10/6/2011

4

Defendant

LZ001345

LZ001346

4/4/2012

5

Defendant

LZ000927

LZ000929

7/26/2011

6

Defendant

LZ001087

LZ001090

7

Defendant

LZ000958

LZ000958

8

Defendant

LZ001733

LZ001733

9

Defendant

LZ001791

LZ001792

10

Defendant

LZ001238

LZ001240

11

Defendant

LZ007351

LZ007354

12

Defendant

GIG02188

GIG02189

13

Defendant

NA

NA

14

Defendant

LZ001688

LZ001690

15

Defendant

LZ001296

LZ001299

16

Defendant

LZ007655

LZ006756

17

Defendant

NA

NA

11/30/2011 Email from Brandon Molina to Travis Giggy re: Fw: Google Policy
Complaints (update)
10/7/2011 Email from Scott MacDonell to Travis Giggy re: legalspring reviews.xlsx Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
2/14/2012 Email from Scott MacDonell to Dorian Quispe re: FW: Review has been Objection: E-mails Authored
entered on LegalSpring.com
by Travis Giggy Are Hearsay;
Foundation
No Objection
2/15/2012 Email from Scott MacDonell to Brian Liu and Frank Monestere, cc.
Jennifer Loo and John Suh, bcc. [e-mail] re: Not glowing
reviews on LegalSpring….
2/22/2012 Email from Scott MacDonell to Travis Giggy, Carrie Yutzy, Peter
Objection: E-mails Authored
Prucnel, cc. Dorian Quispe re: Review has been entered on
by Travis Giggy Are Hearsay;
LegalSpring.com
Foundation
12/6/2011 Email from Brian Liu to Brandon Molina, John Suh, Eddie Hartman, and Objection: Relevance
Scott MacDonell, cc. Dorian Quispe, Serge Topjian, Sarah Ryan, and
Travis Giggy, bcc. [e-mail] re: LWL Live
7/17/2012 Email from LegalZoom to Travis Giggy re: Start a Business from
Objection: Relevance
Anywhere
9/22/2013 Google search results for "legalzoom 99 incorporation"
Objection: Hearsay;
Foundation; Relevance
12/1/2011 Email from Patty Chikamagalur to Michael Kim re: FW: Social Media - Objection: Hearsay;
November Monthly Summary
Foundation; Relevance
3/7/2012 Email from Patty Chikamagalur to Travis Giggy, cc. Carrie Yutzy, Peter Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Prucnel, and Jeremy Vernassal re: Review has been entered on
Foundation; Relevance
LegalSpring.com
10/9/2008 Email from Jeremy Hermanns to Michael Turner, Brian Liu, Brian Lee, Objection: Hearsay;
Foundation; Relevance
Eddie Hartman, Frank Monestere, John Suh, cc: Scott MacDonell re:
RocketLawyer.com - Free living and Last Wills
9/29/2014 LegalZoom.com, Inc.'s Second Amended Response to Defendant Rocket Objection: Relevance;
Lawyer Incorporated's Notice of F.R.C.P. 30(b)(6) Deposition
Foundation

18

963958.1

Defendant

Defendant

LZ001622

LZ001634

Email from Scott Macdonell to Travis Giggy, cc. Brandon Molina re:
Legalspring reviews

11/16/2011 Email from Legalzoom.com, Inc. to Fred Krupica re: Completed:
Contract Approval Sheet & Affiliate Agreement - LegalSpring

1 of 25

Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
No Objection

Objection: Relevance

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
19
Defendant

Beg. Bates

End Bates

Date

LZ007437

LZ007438

5/9/2006

Description
Email from Brian Liu to Travis Giggy re: legalspring

20

Defendant

LZ007432

LZ007436

11/15/2006 Email from Brian Liu to Brian Lee, John Suh, and Eddie Hartman, re:
LegalSpring

21

Defendant

LZ000976

LZ000978

10/11/2011 Email from Travis Giggy to Brandon Molina re: LegalSpring reviews

22

Defendant

LZ001984

LZ001985

3/20/2012

23

Defendant

LZ002228

LZ002234

24

Defendant

LZ001676

LZ001677

25

Defendant

LZ001684

LZ001685

12/1/2011

Email from Dorian Quispe to Matt Withers re: Legal Spring Matrix
wireframe

26

Defendant

LZ007420

LZ007424

2/24/2012

27

Defendant

LZ007447

LZ007447

4/5/2006

Email from Dorian Quispe to Carter Gaffney, John Suh, and Brian Liu,
cc. Scott MacDonell, Bo Kjaer, and Serge Topjian, bcc.
[e-mail] re: LZ & RL: Site Also Visited Stats
Email from Brian Liu to Travis Giggy re: More bad reviews on LS.com

28

Defendant

LZ000753

LZ000755

5/26/2010

Email from Brian Liu to Travis Giggy re: LegalSpring

29
30

Defendant
Defendant

LZ002656_0002
LZ002656_0001

LZ002656_0002
LZ002656_0001

31

Defendant

NA

NA

3/11/2013

LegalZoom.com, Inc.'s Financial Performance by Quarter
LegalZoom.com, Inc.'s Revenue for Advertising Incorporation Services
Broken Down Quarterly
Rocket Lawyer Incorporated's First Set of Requests for Production

32

Defendant

NA

NA

8/22/2013

Rocket Lawyer Incorporated's Second Set of Requests for Production

33

Defendant

NA

NA

7/1/2014

Rocket Lawyer Incorporated's Third Set of Requests for Production

34

Defendant

RLI0063423

RLI0063425

6/23/2004

35

Defendant

RLI0063525

RLI0063526

1/28/2009

RLI Giggy Deposition Exhibit 1 - Legalspring.com - How the Legal
Industry is Being Transformed by the Internet
RLI Giggy Deposition Exhibit 4 - LegalSpring reviews. The 1/28/2009
review was attached as Exhibit 9 to the July 28, 2014 Declaration of
Hong-An Vu in Opposition to LegalZoom.com, Inc.'s Motion for Partial
Summary Judgment

Email from Serge Topjian to Dorian Quispe, cc: Brian Liu re:
LegalSpring
10/27/2011 Email from Matt Scanlan to Dorian Quispe, cc: Matt Taylor and Serge
Topjian re: Spanish Account Shell
12/1/2011 Email from Dorian Quispe to Matt Withers re: FW: Legal Spring Matrix
wireframe via myBals

NA
NA

2/5/2009

36

963958.1

Defendant

LZ000961

LZ000962

2/13/09
10/10/2011 RLI Giggy Deposition Exhibit 7 - Email from Travis Giggy to Scott
Macdonell re: legalspring reviews.xlsx

2 of 25

Non Offering Party's
Objections
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: Relevance
Objection: Hearsay;
Foundation; Relevance
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
No Objection

Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: Relevance
Objection: Relevance
Objection: Relevance;
Foundation
Objection: Relevance;
Foundation
Objection: Relevance;
Foundation
Objection: Hearsay;
Foundation
Objection: Hearsay;
Foundation

Objection: E-mails Authored
By Travis Giggy Are Hearsay;
Foundation

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
37
Defendant

Beg. Bates

End Bates

Date

LZ000915

LZ000918

5/26/2011

38

LZ001538

LZ001539

5/25/2011

39

Defendant

GIG02364

GIG02365

1/6/2009

40

Defendant

GIG02196

GIG02196

7/25/2012

41

Defendant

GIG02291

GIG02292

12/4/2012

42

Defendant

LZ007777

LZ007777

6/19/2008

43

Defendant

LZ007832

LZ007833

2/18/2009

44
45

Defendant
Defendant

LZ002964
LZ003595

LZ002964
LZ003596

4/9/2010
6/9/2010

46

Defendant

LZ003669

LZ003672

8/3/2010

47

Defendant

LZ001485

LZ001487

8/27/2010

48
49

Defendant
Defendant

LZ003551
LZ007505

LZ003553
LZ007508

NA
NA

50

Defendant

LZ007539

LZ007542

7/23/2011

51

Defendant

LZ003157

LZ003159

7/26/2011

52

Defendant

LZ007545

LZ007546

NA

53

Defendant

LZ007547

LZ007549

8/10/2011

54
55

963958.1

Defendant

Defendant
Defendant

LZ007405
LZ007550

LZ007405
LZ007552

8/11/2011
8/13/2011

Description

Non Offering Party's
Date Identified
Objections
RLI Giggy Deposition Exhibit 10 - Email from Matt Withers to Travis
Objection: E-mails Authored
Giggy and Eddie Hartman re: Rocket Lawyer
By Travis Giggy Are Hearsay;
Foundation
RLI Giggy Deposition Exhibit 11 - Email from Matt Withers to Travis
Objection: E-mails Authored
Giggy re: Rocket Lawyer
by Travis Giggy Are Hearsay;
Foundation
RLI Giggy Deposition Exhibit 14 - Email from Sandra Tanzberger to
Objection: E-mails Authored
Travis Giggy re: LegalZoom Review Verification
By Travis Giggy Are Hearsay;
Foundation
RLI Giggy Deposition Exhibit 15 - Email from Travis Giggy to Dorian
Objection: E-mails Authored
Quispe re: legalspring
by Travis Giggy Are Hearsay;
Foundation
Objection: E-mails Authored
RLI Giggy Deposition Exhibit 16 - Email from Travis Giggy to Doug
Ansell re: partner
by Travis Giggy Are Hearsay;
Foundation
Email from Travis Giggy to Eddie Hartman re: Morning
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Email from Scott MacDonell to John Suh, cc. Michael Turner, Brian Liu, Objection: Relevance
Frank Monestere, Fred Krupica, and Tracy Terrill re: Updated Aided &
Unaided Awareness
Email from Eddie Hartman to Carter Gaffney re: Home Page Test
Objection: Relevance
Email from Eddie Hartman to Brian Liu, cc. James Peters re: Forms
Objection: Relevance
subscription
Email from Adam Thomas to Frank Monestere re: FW: Inventor's Month Objection: Relevance
Announcement -- DRAFT UPDATE
Email from Derek Chew to Chris Cannon and Jeremy Hermanns re:
No Objection
customer review sites
Redacted email with excerpt of a customer's complaint
Document providing examples of competitors who are successfully
Objection: Hearsay;
bidding on "free" KWs
Foundation; Relevance
Email from Travis Giggy to Dorian Quispe re: Free Negative Term
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation; Relevance
Objection: Hearsay;
Email from Patty Chikamagalur to Victoria Coe, cc. Wagner Barrios,
Foundation; Relevance
Monica Fletcher, Richard Appert, Yoon Choi, Aaron Hong, Peter
Prucnel, and Brian Alejandro re: BBB Complaint - Express Gold
Incorporation - UT (500598061)
Screenshots of Legal CenterPro's Free Trial Application, Free Trial Sign- Objection: Relevance
up, and Unlimited Access Application web pages.
Objection: Relevance
Email from Dorian Quispe to Eddie Hartman, Scott MacDonell, and
Brandon Molina, cc. Serge Topjian, Daniel Alfi, and Travis Giggy re:
Gmail Targeting
Email from Carter Gaffney to Eddie Hartman re: RL raises $18.5 M
Objection: Relevance
Email from Brandon Molina to Eddie Hartman, cc. Travis Giggy re: FW: Objection: E-mails Authored
How to Quantify who is "winning" - The AdWords Game
by Travis Giggy Are Hearsay;
Foundation; Relevance

3 of 25

Date Admitted

No. of Exhibit Offering
Party/Parties
56
Defendant

Beg. Bates

End Bates

Date

LZ000932

LZ000932

9/1/2011

Description

Non Offering Party's
Date Identified
Objections
Email from Travis Giggy to Scott MacDonell and Amir Pirnia re:
Objection: E-mails Authored
Legalzoom search on google
by Travis Giggy Are Hearsay;
Foundation; Relevance
Email from Scott Macdonell to Travis Giggy, cc. Brandon Molina re:
Objection: E-mails Authored
Legalspring reviews
by Travis Giggy Are Hearsay;
Foundation
Email from Peter Prucnel to Scott MacDonell re: legalspring reviews.xlsx Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Email from Brandon Molina to Travis Giggy re: legalspring
No Objection
Email from Scott MacDonell to Travis Giggy re: legalspring reviews.xlsx Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Email from Travis Giggy to Patty Chikamagalur, Carrie Yutzy, and Peter No Objection
Prucnel re: Legal Spring
Email from Scott MacDonell to Brandon Molina and Dorian Quispe re: No Objection
LegalSpring reviews
Email from Brandon Molina to Justina Altiere re: project update
Objection: Relevance
Email from Matt Withers to Travis Giggy re: Links
No Objection
Email from Travis Giggy to Scott MacDonell and Carrie Yutzy, cc.
Objection: E-mails Authored
Brandon Molina re: Review has been entered on LegalSpring.com
by Travis Giggy Are Hearsay;
Foundation
Email from Peter Prucnel to Carrie Yutzy re: Review has been entered on Objection: E-mails Authored
Legalspring.com
by Travis Giggy Are Hearsay;
Foundation
Email from Charley Moore to Brian Liu re: Google Ads
Objection: Hearsay; Revelance

57

LZ000944

LZ000946

9/17/2011

58

Defendant

LZ001555

LZ001556

10/11/2011

59
60

Defendant
Defendant

LZ000969
LZ000971

LZ000969
LZ000973

10/11/2011
10/11/2011

61

Defendant

LZ000992

LZ000994

10/11/2011

62

Defendant

LZ001563

LZ001564

10/11/2011

63
64
65

Defendant
Defendant
Defendant

LZ001571
LZ000999
LZ001018

LZ001572
LZ000999
LZ001020

10/17/2011
10/21/2011
10/27/2011

66

Defendant

LZ001605

LZ001607

11/2/2011

67

Defendant

LZ006662

LZ006663

11/16/2011

68

Defendant

LZ001131

LZ001134

69

Defendant

LZ001179

LZ001179

12/15/2011 Email from Scott MacDonell to Travis Giggy, cc. Carrie Yutzy, Brandon
Molina, Peter Prucnel, Patty Chikamagalur, Jeremy Vernassal re: LS
review
1/30/2012 Email from Travis Giggy to Peter Prucnel, cc. Scott MacDonell and
Carter Gaffney re: Fwd: I have a question about Legal Spring

70

Defendant

LZ001712

LZ001714

2/1/2012

71

Defendant

LZ001197

LZ001197

2/1/2012

72

Defendant

LZ001199

LZ001202

2/14/2012

73

Defendant

LZ001759

LZ001762

2/14/2012

74

Defendant

LZ001763

LZ001766

2/14/2012

75

963958.1

Defendant

Defendant

LZ001206

LZ001209

2/15/2012

Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation; Relevance
Email from Dorian Quispe to Brian Liu, cc. John Suh and Serge Topjian, Objection: Relevance; More
Prejudicial Than Probative
bcc. [e-mail] re: Rocketlawyer
Email from Scott MacDonell to Travis Giggy and Dorian Quispe re:
Objection: E-mails Authored
Review has been entered on LegalSpring.com
by Travis Giggy Are Hearsay;
Foundation; Relevance
Email from Carrie Yutzy to Travis Giggy re: FW: can we get an official No Objection
answer to the first two reviews here?
Email from Dorian Quispe to Scott MacDonell, Carrie Yutzy, and Peter No Objection
Prucnel re: can we get an official answer to the first two reviews here?
Email from Carrie Yutzy to Scott MacDonell and Peter Prucnel, cc
Dorian Quispe re: can we get an official answer to the first two reviews
here?
Email from Travis Giggy to Carrie Yutzy re: can we get an official
answer to the first two reviews here?

4 of 25

No Objection

Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation

Date Admitted

No. of Exhibit Offering
Party/Parties
76
Defendant

Beg. Bates

End Bates

Date

LZ001214

LZ001217

2/16/2012

Email from Travis Giggy to Carrie Yutzy re: can we get an official
answer to the first two reviews here?
Email from Scott MacDonell to Brian Liu, cc. Dorian Quispe re: can we
get an official answer to the first two reviews here?
Email from Peter Prucnel to Carrie Yutzy and Peter Chikamagalur, cc.
Scott MacDonell re: LegalSpring
Email from Travis Giggy to Scott MacDonell, Carrie Yutzy, and Peter
Prucnel, cc. Dorian Quispe re: Review has been entered on
LegalSpring.com
Email from Travis Giggy to Carrie Yutzy re: Another LegalSpring review

77

LZ001810

LZ001815

2/15/2012

78

Defendant

LZ001858

LZ001863

2/16/2012

79

Defendant

LZ001241

LZ001244

2/22/2012

80

Defendant

LZ001245

LZ001251

2/22/2012

81

Defendant

LZ001880

LZ001880

2/23/2012

82

Defendant

LZ007420

LZ007424

2/24/2012

83

Defendant

LZ001272

LZ001273

3/1/2012

84

Defendant

LZ001988

LZ001993

3/22/2012

85

Defendant

LZ002001

LZ002002

3/23/2012

86

Defendant

LZ002003

LZ002004

3/28/2012

87

Defendant

LZ002055

LZ002057

88

Defendant

LZ002062

LZ002065

89

Defendant

LZ002159

LZ002159

90

Defendant

LZ002166

LZ002169

91

Defendant

LZ002171

LZ002172

92

Defendant

LZ001549

LZ001550

93

Defendant

RLI0063406

RLI0063410

94

963958.1

Defendant

Defendant

RLI0063426

RLI0063427

Description

Email from Scott MacDonell to Brian Liu, cc. Scott MacDonell re:
legalspring
Email from Dorian Quispe to Carter Gaffney, John Suh, and Brian Liu,
cc. Scott MacDonell, Bo Kjaer, and Serge Topjian, bcc.
[e-mail] re: LZ & RL: Site Also Visited Stats
Email from Patty Chikamagalur to Travis Giggy, cc. Carrie Yutzy, Scott
MacDonell, and Jeremy Vernassal re: FW: Review has been entered on
LegalSpring.com
Email from Jeremy Scarbury to Brandon Molina and Michelle Fortich,
cc. Shilpa Joshi, Ed Baldoz, Bo Kjaer, Keith Eich, Justina Altiere, and
Carter Gaffney re: Potential R&D Project Impairments
Email from Dorian Quispe to Matt Withers re: LegalZoom Affiliate
Relationship
Email from Patty Chikamagalur to Carrie Yutzy, cc. Jeremy Vernassal
and Peter Prucnel re: FW: Review has been entered on LegalSpring.com

Non Offering Party's
Objections
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
No Objection
No Objection
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
No Objection
Objection: Relevance

Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
Objection: Relevance

Objection: Relevance

Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
3/30/2012 Email from David Jin to Aaron Hong, cc Lee Gamel re: FW: LegalSpring No Objection
Review - Economy Incorporation - DE (9602212)
Objection: Relevance
3/31/2012 Email from Victoria Coe to Patty Chikamagalur, cc. Wagner Barrios,
Mary Stanislao, and Peter Prucnel re: LegalSpring Review - Economy
Incorporation - DE (9602212)
7/25/2012 Email from Pravin Chandrasoma to Tracy Terrill and Chas Rampenthal Objection: E-mails Authored
re: FW: legalspring
by Travis Giggy Are Hearsay;
Foundation
7/25/2012 Email from Scott MacDonell to Dorian Quispe re: legalspring
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
9/20/2012 Email from Carrie Yutzy to Patty Chiamagalur re: Older LegalSpring
No Objection
Review
10/7/2011 Email from Scott MacDonell to Brian Liu re: FW: legalspring
No Objection
reviews.xlsx
12/11/2012 Print-outs from LegalSpring's website regarding The Company
Objection: Hearsay;
Corporation Reviews and Company Information
Foundation; Relevance
1/27/2014 Print-outs from Offers.com's website regarding LegalZoom LLCs
Objection: Hearsay;
Foundation; Relevance

5 of 25

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
95
Defendant

Beg. Bates

End Bates

RLI0063428

RLI0063429

96

RLI0063436

RLI0063443

97

Defendant

RLI0063449

RLI0063452

98

Defendant

RLI0063487

RLI0063501

99

Defendant

RLI0063502

RLI0063508

100

Defendant

NA

NA

101

Defendant

NA

NA

102

Defendant

NA

NA

103

Defendant

NA

NA

104

Defendant

NA

NA

105

Defendant

GIG02135

GIG02135

106

Defendant

GIG02151

GIG02151

107

Defendant

GIG02287

GIG02288

108

Defendant

GIG02438

GIG02443

109

Defendant

GIG01249

GIG01249

110

Defendant

GIG01262

GIG01263

111

Defendant

GIG01825

GIG01826

112

Defendant

GIG01846

GIG01848

113

Defendant

GIG01869

GIG01869

114

963958.1

Defendant

Defendant

GIG01933

GIG01933

Date

Description

Non Offering Party's
Objections
1/27/2014 Print-outs from pocketdeal.com's website regarding "LegalZoom coupon Objection: Hearsay;
codes, LegalZoom promotions and discounts"
Foundation; Relevance
7/9/2014 Print-outs from LegalSpring's website regarding BizFilings Reviews and Objection: Hearsay;
Company Information
Foundation; Relevance
7/9/2014 Print-outs from LegalSpring's website regarding Legalfilings.com
Objection: Hearsay;
Reviews and Company Information
Foundation; Relevance
7/9/2014 Print-outs from LegalSpring's website regarding MyCorporation.com
Objection: Hearsay;
Reviews and Company Information
Foundation; Relevance
7/9/2014 Print-outs from LegalSpring's website regarding The Company
Objection: Hearsay;
Corporation Reviews and Company Information
Foundation; Relevance
12/3/2013 LegalZoom.com, Inc.'s Supplemental Responses to Rocket Lawyer
No Objection
Incorporated's First Set of Special Interrogatories
7/14/2014 Declaration of Travis Giggy in Support of Motion for Partial Summary
No Objection
Judgment Brought by Plaintiff LegalZoom.com, Inc.
7/14/2014 Declaration of Dorian Quispe in Support of Motion for Partial Summary No Objection
Judgment Brought by Plaintiff LegalZoom.com, Inc.
8/28/2013 Google search results for "incorporation"
Objection: Hearsay;
Foundation; Relevance
9/23/2013 Legalzoom.com, Inc.'s Response to Rocket Lawyer Incorporated's First
No Objection
Set of Special Interrogatories
3/8/2012 Email from Travis Giggy to himself re: Review has been entered on
Objection: E-mails Authored
LegalSpring.com
by Travis Giggy Are Hearsay;
Foundation; Relevance
3/21/2012 Email from Travis Giggy to himself re: Review has been entered on
Objection: E-mails Authored
LegalSpring.com
by Travis Giggy Are Hearsay;
Foundation; Relevance
12/4/2012 Email from Travis Giggy to Doug Ansell re: partner
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
2/11/2009 Email from Travis Giggy to Jonathan Mizel, cc. Dr. Glenn Livingston re: Objection: E-mails Authored
Hi Jonathan :-)
by Travis Giggy Are Hearsay;
Foundation
11/2/2009 Email from Matt Withers to Travis Giggy re: LegalZoom Order
Objection: Relevance
Notification
1/4/2010 Email from Travis Giggy to Monique ([e-mail]) re: Startup Objection: E-mails Authored
Victory - 7 Steps to Startup S.U.C.C.E.S.S.
by Travis Giggy Are Hearsay;
Foundation; Relevance
10/11/2011 Email from Travis Giggy to Debra Toner re: Debra, download your free Objection: E-mails Authored
LLC guide now
by Travis Giggy Are Hearsay;
Foundation; Relevance
10/14/2011 Email from Travis Giggy to Debra Toner re: Debra, download your free Objection: E-mails Authored
LLC guide now
by Travis Giggy Are Hearsay;
Foundation; Relevance
11/1/2011 Email from Travis Giggy to [e-mail] re: Your
No Objection
LegalZoom review
11/30/2011 Email from Travis Giggy to Monique ([e-mail]) and Kevin Objection: E-mails Authored
King re: Wideframes needed for LegalSpring
by Travis Giggy Are Hearsay;
Foundation

6 of 25

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
115
Defendant
116

Defendant

GIG02064

GIG02064

117

Defendant

GIG02195

GIG02195

118

Defendant

GIG02355

GIG02355

119

Defendant

GIG01785

GIG01788

120

Defendant

GIG02079

GIG02079

121

Defendant

GIG02113

GIG02114

122

Defendant

GIG02230

GIG02231

123

Defendant

GIG02232

GIG02232

124

Defendant

LZ000909

LZ000909

125

Defendant

LZ000911

LZ000911

126

Defendant

LZ000912

LZ000914

127

Defendant

LZ000933

LZ000936

128

Defendant

LZ001537

LZ001537

Non Offering Party's
Date Identified
Objections
10/00/2011 Print-out from LegalSpring's website regarding LegalZoom Reviews and Objection: Hearsay;
Company Information
Foundation; Relevance
1/17/2012 Email from Lisette Howard to Travis Giggy re: Setting up Incorporation Objection: Hearsay;
Foundation; Relevance
7/24/2012 Email from Travis Giggy to Mark ([e-mail]) re: I have Objection: E-mails Authored
a question for the Legal Spring webmaster
by Travis Giggy Are Hearsay;
Foundation
1/2/2009 Email from Travis Giggy to Kirk Stone re: Not cool
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
9/7/2011 Email from Matt Withers to Travis Giggy, Eddie Hartman, and Brandon Objection: Hearsay;
Molina re: Rocket Lawyer Funding
Foundation; Relevance
1/30/2012 Email from Peter Prucnel to Travis Giggy, cc. Scott MacDonell, Carter Objection: E-mails Authored
Gaffney, Patty Chikamagalur, Jeremy Vernassal, and Carrie Yutzy re: I by Travis Giggy Are Hearsay;
Foundation
have a question about Legal Spring
2/15/2012 Email from Travis Giggy to Bobbi Perreault re: LS review update sql
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation; Relevance
9/20/2012 Email from Carrie Yutzy to Travis Giggy re: FW: Older LegalSpring
No Objection
Review
9/20/2012 Email from Patty Chikamagalur to Travis Giggy re: Older LegalSpring
Objection: E-mails Authored
Review
by Travis Giggy Are Hearsay;
Foundation
5/24/2011 Email from Travis Giggy to Brandon Molina and Eddie Hartman re:
Objection: Hearsay;
Fwd: Rocket Lawyer
Foundation
5/25/2011 Email from Travis Giggy to Matt Withers re: Fwd: Rocket Lawyer
Objection: E-mails Authored
by Travis Giggy Are Hearsay;
Foundation
5/26/2011 Email from Travis Giggy to Matt Withers and Eddie Hartman re: Fwd:
Objection: Hearsay; Relevance
Rocket Lawyer
9/7/2011 Email from Matt Withers to Travis Giggy, Eddie Hartman, and Brandon Objection: Hearsay;
Molina re: Rocket Lawyer Funding
Incomplete; Relevance
5/24/2011 Email from Eddie Hartman to Travis Giggy re: Rocket Lawyer
Objection: Hearsay; Relevance

129
130

Defendant
Defendant

NA
RLI0037146

NA
RLI0037148

5/10/2012
9/24/2012

131
132
133

Defendant
Defendant
Defendant

RLI0037159
RLI0037696
RLI0007924
RLI0007925
RLI0006636

RLI0037159
RLI0037696
RLI0007924
RLI0007925
RLI0006636

8/28/2012
1/27/2011
NA

134

963958.1

Beg. Bates

End Bates

GIG01934

GIG01934

Date

Description

Defendant

RLI0007918
RLI0007922

RLI0007918
RLI0007922

NA

LegalZoom.com, Inc.'s Form S-1 Filing
Email from David Baga to Michael Nelson, cc. Jarred Colli re:
Incorporation Ad without Free
Email from David Baga to Jarred Coli re: Ad Test Update
Email from Mark Kaufman to Pete Franco re: LegalZoom's Checkout
Exhibit F to the June 30, 2014 Declaration of Hong-An Vu in Support of
Rocket Lawyer Incorporated's Motion for Summary Judgment and/or
Adjudication - charts with Rocket Lawyer's business formation (i.e.
incorporation and LLC) advertisement and conversion data from
documents produced in Excel format
Exhibit K to the June 30, 2014 Declaration of Hong-An Vu in Support of
Rocket Lawyer Incorporated's Motion for Summary Judgment and/or
Adjudication - chart with Rocket Lawyer's free trial advertisement and
conversion data from documents produced in Excel format

7 of 25

Objection: Relevance
Objection: Incomplete

Objection: Incomplete
Objection: Lacks Personal
Knowledge

Objection: Lacks Personal
Knowledge

Date Admitted

No. of Exhibit Offering
Party/Parties
135
Defendant

136

Defendant

RLI0041618

RLI0041618

137

Defendant

RLI0044182

RLI0044183

138

Defendant

RLI0050135

RLI0050136

139

Defendant

NA

NA

140
141

Defendant
Defendant

RLI0050359
RLI0051655

RLI0050359
RLI0051655

142
143
144

Defendant
Defendant
Defendant

RLI0051661
RLI0051667
RLI0051764

RLI0051661
RLI0051667
RLI0051764

Non Offering Party's
Objections
1/2/2014 Exhibit M to the June 30, 2014 Declaration of Hong-An Vu in Support of Objection: Lacks Personal
Rocket Lawyer Incorporated's Motion for Summary Judgment and/or
Knowledge
Adjudication - screenshots of LegalZoom's free trial advertisements on
www.legalzoom.com
NA
Spreadsheet providing information regarding advertisements with state
fees, no state fees, and site links
10/20/2011 Email from Alisa Weiner to Michael Nelson, Rob Elhardt, and Matt
Kaufman, cc. Sasha Volkov and Pete Franco re: Who owns
LegalSpring.com
10/4/2012 Email from Alisa Weiner to Jarred Coli re: Updates on Free Ads
Language
6/27/2014 Exhibit N to the June 30, 2014 Declaration of Hong-An Vu in Support of Objection: Lacks Personal
Knowledge
Rocket Lawyer Incorporated's Motion for Summary Judgment and/or
Adjudication - Google and Bing instructions regarding keyword
advertisements on Google and Bing, respectively, and Google and Bing
search results for the keyword "incorporation"
NA
Spreadsheet regarding Tranche Analysis
Objection: Illegible
10/24/2011 Email from Sasha Volkov to Pete Franco re: Follow-up: LegalSpring +
Legalcenterpro; CR downward trend
10/00/2011 PowerPoint regarding Purchase Page Design
9/30/2011 Email from Mike N. to Pete Franco re: Funny LZ Ads
NA
Screenshot regarding "Select a processing option for your new business"

145
146

Defendant
Defendant

RLI0051765
RLI0051784

RLI0051765
RLI0051785

NA
5/20/2011

147
148

Defendant
Defendant

NA
RLI0052984

NA
RLI0052985

10/17/2013
11/21/2011

149
150
151
152
153

Defendant
Defendant
Defendant
Defendant
Defendant

RLI0053354
RLI0053385
RLI0053580
RLI0057292
RLI0061998

RLI0053354
RLI0053385
RLI0053580
RLI0057292
RLI0062001

NA
8/00/2010
12/00/2011
NA
11/16/2012

154

Defendant

RLI0065633

RLI0065634

5/9/2012

155

Defendant

RLI0066990

RLI0066992

10/21/2011

156
157
158
159
160
161

963958.1

Beg. Bates

End Bates

NA

NA

Date

Description

Defendant
Defendant
Defendant
Defendant
Defendant
Defendant

RLI0082569
RLI0079561
3QD0000363
3QD0000766
3QD0001289
3QD0002556

RLI0082569
RLI0079622
3QD0000363
3QD0000768
3QD0001290
3QD0002556

2/13/2013
5/15/2012
5/31/2011
4/3/2012
8/28/2012
NA

Screenshot regarding "Purchase Summary"
Email from Chris Innes to Pete Franco re: PROOF: Rocket Lawyer
160x600
Order re: Plaintiff's Motion for Summary Judgment
Email from Nathaniel Alexander to David Baga, cc. Gani Urgino re:
Objection: Hearsay
Fwd: Rocket Lawyer - Incorporation Follow UP
Spreadsheet listing "incorporation" keywords
PowerPoint regarding Incorporation Business Analysis
PowerPoint regarding Marketing Competitive Analysis
Rocket Lawyer screenshot regarding "Incorporate for Free"
Undated
Email from Acquisition ([e-mail]) to
[e-mail] re: [Acquisition] A new post was made
to Monthly Updates
Email from Charley Moore to Jarred Colli, cc. Pete Franco, Dan Nye,
David Baga, Alisa Weiner, Sasha Volkov, and Amir Khorram re: Incorp
space is getting more competitive
Email from Alisa Weiner to David Baga, cc. Dan Nye, Charles Moore,
and Execs re: LegalZoom competitive activity
Email from David Drummond to Charley Moore re: Follow up
PowerPoint slides regarding Rocket Lawyer Board Meeting
Email from Bob Sturges to himself re: PPCA Call 5/31
Objection: Hearsay
Email from David Baga to Gordon Khoo re: New Ad Copy
Email from David Baga to Gordon Khoo re: Ad Test Update
Spreadsheet with various tabs entitled "Notes from Meeting INC", "Ad
Test", "NPO Data", "Frequency Cap Data", "RL Docs Meeting", and "RL
UK"
8 of 25

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
162
Defendant

Beg. Bates

End Bates

3QD0002587

3QD0002590

163
164
165

RLI0003225
RLI0045693
RLI0007916

RLI000225
RLI0045693
RLI0007916

166

Defendant

RLI0007917

RLI0007917

167

Defendant

RLI0007918

RLI0007918

168

Defendant

RLI0007919

RLI0007919

169

Defendant

RLI0007920

RLI0007920

170

Defendant

RLI0007921

RLI0007921

171

Defendant

RLI0007922

RLI0007922

172

Defendant

RLI0007923

RLI0007923

173

Defendant

RLI0007924

RLI0007924

174

Defendant

RLI0007925

RLI0007925

175
176

Defendant
Defendant

RLI0036635
RLI0036636

RLI0036635
RLI0036636

177

Defendant

RLI0036637

RLI0036638

178

Defendant

NA

NA

179

963958.1

Defendant
Defendant
Defendant

Defendant

NA

NA

Date

Description

Non Offering Party's
Objections

11/16/2012 Email from Gordon Khoo to Bailey Lau re: Weekly Call Notes
11.16.2012
NA
Spreadsheet regarding calls by disposition
NA
Spreadsheet regarding membership cancellation
NA
Ad performance report for November 1, 2008 through September 30,
2013. Spreadsheet has tabs entitled "Free Legal Help" and Legal Zoom
Keywords"
NA
Ad performance report for November 1, 2008 through September 30,
2013. Spreadsheet has tab entitled "Ad performance reports (7).csv"
NA
Ad performance report for November 1, 2008 through September 30,
2013. Spreadsheet has tabs entitled "Free Trial" and Legal Zoom
Keyword - Free Trial"
NA
Report Regarding Free Help From Local Attorneys - Rocket Lawyer
March 2011 through September 2013. Spreadsheet has tabs entitled
"Free Help" and "Free Help - Legal Zm KW"
NA
Free Legal Help Report - Rocket Lawyer March 2011 through September
2013. Spreadsheet has tabs entitled "Free Legal Help" and "Free Legal
Help - Legal Zoom KW"
NA
Report Regarding Free Legal Review - Rocket Lawyer March 2011
through September 2013. Spreadsheet has tabs entitled "Free Legal
Review" and "Free Legal Review - Legal Zm KW"
NA
Free Trial Ad Copy Report - Rocket Lawyer March 2011 through
December 2011. Spreadsheet has tabs entitled "Free Trial Ad Copy" and
"Legal Zoom Keywords"
NA
Ad performance report for November 1, 2008 through September 30,
2013. Spreadsheet has tab entitled "Ad performance reports (7).csv"
NA
Ad performance report for November 1, 2008 through September 30,
2013. Spreadsheet has tabs entitled "Business Formation - Inc Acct",
"Legal Zoom Keywords", "Legal Zoom Kws - No State Fee", "Legal
Zoom Kws - + State Fee"
NA
Report regarding Bing Business Formation - All Free Ads - March 2011
through September 2013. Spreadsheet has tabs entitled "Business
Formation - Free", "Legal Zoom Keywords", "Legal Zoom KWs - State
Fee", "Legal Zoom KWs - No State Fee"
NA
Rocket Lawyer Incorporated - Financial Performance by Quarter
NA
Ad performance report for November 1, 2008 through September 30,
2013. Spreadsheet has tabs entitled "Google RL Search (All Free)",
"Google RL Search (LZ Free)", "Bing RL Search All Free", and "Bing
RL Search (LZ Free)
NA
Rocket Lawyer's business formation revenue from November 2008
through September 2013.
Objection: Relevance
12/3/2012 Exhibit 2 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of Rocket Lawyer's free immigration forms
9/21/2013 Exhibit 3 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of Rocket Lawyer's free legal dictionary

9 of 25

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
180
Defendant

Beg. Bates

End Bates

Date

Description

Non Offering Party's
Objections

NA

NA

12/7/2012

Exhibit 4 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of the free articles available on rocketlawyer.com

181

NA

NA

12/6/2012

Exhibit 5 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of the Pro Legal Plan free trial registration page

182

Defendant

NA

NA

12/6/2012

Exhibit 6 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of the Basic Legal Plan free trial registration page

183

Defendant

NA

NA

9/9/2013

184

Defendant

NA

NA

12/3/2012

185

Defendant

NA

NA

8/27/2013

186

Defendant

NA

NA

12/3/2012

187

Defendant

NA

NA

12/3/2012

Exhibit 7 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of the FAQ regarding Rocket Lawyer's free trial
plans
Exhibit 8 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of the option to enroll in a free trial of the pro
legal plan at the end of the document interview for the incorporation
process
Exhibit 9 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of one of Rocket Lawyer's disclosures of state fees
available on Rocketlawyer.com prior to the incorporation interview
program
Objection: Relevance;
Exhibit 10 to the September 23, 2013 Declaration of Hong-An Vu in
Incomplete
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of Rocket Lawyer's disclosure of state and county
fees in the incorporation interview
Objection: Relevance; Hearsay
Exhibit 11 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of a payment page at the end of an incorporation
interview, disclosing fees and other information services purchased by a
user but evidencing no charges for Rocket Lawyer's processing and filing
of incorporation forms when enrolled in a free trial of the Pro Legal Plan

188

Defendant

NA

NA

9/9/2013

189

Defendant

NA

NA

12/3/2012

190

963958.1

Defendant

Defendant

NA

NA

9/9/2013

Exhibit 12 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - Rocket Lawyer's current On Call Terms and Conditions,
which have been in effect since February 2013
Exhibit 13 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - Rocket Lawyer's On Call Terms and Conditions that were in
effect between November 28, 2012 and February 2013
Exhibit 14 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of a search on Google.com for "legal documents"

10 of 25

Objection: Foundation

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
191
Defendant

Beg. Bates

End Bates

Date

NA

NA

8/28/2013

192

NA

NA

8/28/2013

193

Defendant

NA

NA

8/26/2013

194

Defendant

NA

NA

9/5/2013

195

Defendant

NA

NA

9/5/2013

196

Defendant

NA

NA

8/26/2013

197

Defendant

NA

NA

9/14/2013

198

Defendant

NA

NA

9/11/2013

199

Defendant

NA

NA

9/6/2013

200

Defendant

NA

NA

9/6/2009

201

Defendant

NA

NA

9/6/2013

202

963958.1

Defendant

Defendant

NA

NA

3/12/2013

Description
Exhibit 15 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of a search on Google.com for "incorporation"
Exhibit 16 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshots of Lawdepot.com with similar services to those
of Rocket Lawyer and LegalZoom
Exhibit 17 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of LegalZoom's package of real estate documents
Exhibit 18 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of LegalZoom's personal plan
Exhibit 19 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of LegalZoom's business plan
Exhibit 20 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of LegalZoom's "how it works" page showing its
postal mail, hard-copy process
Exhibit 23 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot from LegalZoom's pricing for incorporation
Exhibit 24 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - LegalZoom's Supplemental Terms of Service for Corporate
Center
Exhibit 25 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - LegalZoom's webpage relating to incorporation that contains
a statement regarding its "A" rating with the Better Business Bureau

Non Offering Party's
Objections
Objection: Foundation

Objection: Foundation

Objection: Foundation

Objection: Foundation

Objection: Foundation

Objection: Foundation

Objection: Foundation

Objection: Foundation

Objection: Foundation

Objection: Foundation
Exhibit 26 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of an article with simultaneous advertisements for
Rocket Lawyer's and LegalZoom's incorporation services, where
LegalZoom has published that it has an "A" Rating with the Better
Business Bureau
Objection: Foundation
Exhibit 27 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - screenshot of the Better Business Bureau's website
www.la.bbb.org showing no "A" rating for LegalZoom.com, Inc.
Objection: Foundation
Exhibit 28 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - Article entitled "Better Business Bureau Expels Los Angeles
Organization for Failure to Meet Standards"

11 of 25

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
203
Defendant

Beg. Bates

End Bates

Date

NA

NA

9/11/2013

204

NA

NA

9/16/2011

205

Defendant

NA

NA

9/14/2013

206

Defendant

NA

NA

NA

207

Defendant

NA

NA

Defendant

NA

NA

1074

Defendant

NA

NA

1079

Defendant

NA

NA

1077

Defendant

NA

NA

1080

Defendant

NA

NA

213

Defendant

NA

NA

1082

Defendant

NA

NA

1075

Defendant

NA

NA

1078

Defendant

NA

NA

1081

Defendant

NA

NA

Exhibit 29 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - email from Karen S. (Council of Better Business Bureaus,
Inc.) to Hong-An Vu re: BBB LA Ratings
Exhibit 30 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - Article entitled "LegalZoom Takes New Twist to Old
Profession"
Exhibit 31 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - blog entry from June 2013, found at
http://iterationz.com/2013/06/25/creating-a-formal-business-structurewith-the-help-of-online-legal-services/, comparing Rocketlawyer.com and
LegalZoom.com
Exhibit 32 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - image of the analysis of LegalZoom's incorporation page,
found at http://iterationz.files.wordpress.com/2013/06/legalzoom1_2.png

NA

1076

963958.1

Defendant

Description

Exhibit 33 to the September 23, 2013 Declaration of Hong-An Vu in
Support of Rocket Lawyer's Opposition to Motion for Summary
Judgment - image of the analysis of Rocket Lawyer's incorporation page,
found at
http://iterationz.files.wordpress.com/2013/06/rocketlawyer1_4.png
9/23/2013 Rocket Lawyer Incorporated's Objections and Responses to Plaintiff's
First Set of Requests for Admission
9/23/2013 Rocket Lawyer Incorporated's Objections and Responses to Plaintiff's
First Set of Requests for Production of Documents and Things (Nos. 155)
12/3/2013 Rocket Lawyer Incorporated's Supplemental Objections and Responses to
Plaintiff's First Set of Requests for Production of Documents and Things
(Nos. 1-55)
10/11/2013 Defendant's Objections and Responses to Plaintiff's Second Set of
Requests for Production of Documents and Things (Nos. 56-59)
12/3/2013 Rocket Lawyer Incorporated's Supplemental Objections and Responses to
Plaintiff's Second Set of Requests for Production of Documents and
Things (Nos. 56-59)
2/24/2014 Rocket Lawyer Incorporated's Objections and Responses to Plaintiff's
Third Set of Requests for Production of Documents and Things (Nos. 6089)
7/21/2014 Rocket Lawyer Incorporated's Supplemental Objections and Responses to
Plaintiff's Third Set of Requests for Production of Documents and Things
(Nos. 60-89)
9/23/2012 Rocket Lawyer Incorporated's Objections and Responses to Plaintiff's
First Set of Special Interrogatories
12/3/2013 Rocket Lawyer Incorporated's Supplemental Objections and Responses to
Plaintiff's First Set of Special Interrogatories
12/20/2013 Rocket Lawyer Incorporated's Supplemental Objections and Responses to
Interrogatory No. 24
12 of 25

Non Offering Party's
Objections
Objection: Hearsay

Objection: Foundation;
Hearsay

Objection: Foundation;
Hearsay

Objection: Foundation

Objection: Relevance
Objection: Relevance

Objection: Relevance

Objection: Relevance
Objection: Relevance

Objection: Relevance

Objection: Relevance

Objection: Relevance
Objection: Relevance
Objection: Relevance

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
218
Defendant

Beg. Bates

End Bates

NA

NA

Date
6/18/2014

Rocket Lawyer Incorporated's Second Supplemental Objections and
Responses to Plaintiff's First Set of Special Interrogatories
2/24/2014 Rocket Lawyer Incorporated's Objections and Responses to Plaintiff's
Second Set of Special Interrogatories
7/21/2014 Rocket Lawyer Incorporated's Supplemental Objections and Responses to
Plaintiff's Second Set of Special Interrogatories
9/23/2013 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's First
Set of Requests for Admission
8/19/2014 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's
Second Set of Requests for Admission
9/23/2013 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's First
Set of Requests for Production
12/3/2013 LegalZoom.com, Inc.'s Supplemental Response to Rocket Lawyer
Incorporated's First Set of Requests for Production
9/23/2013 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's
Second Set of Requests for Production
12/3/2013 LegalZoom.com, Inc.'s Supplemental Response to Rocket Lawyer
Incorporated's Second Set of Requests for Production
7/31/2014 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's Third
Set of Requests for Production
7/31/2014 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's
Second Set of Special Interrogatories
10/21/2014 Spreadsheet regarding Zoom keyword performance report based on dates
in Ex. 22 and deposition testimony from Mr. Quispe, Tr. 80:14-83:11

1083

Defendant

NA

NA

220

Defendant

NA

NA

221

Defendant

NA

NA

222

Defendant

NA

NA

223

Defendant

NA

NA

224

Defendant

NA

NA

225

Defendant

NA

NA

226

Defendant

NA

NA

227

Defendant

NA

NA

228

Defendant

NA

NA

229

Defendant

NA

NA

1041-1048* Defendant

NA

NA

4/15/2014

231

Defendant

NA

NA

4/15/2014

232

Defendant

NA

NA

4/15/2014

233

Defendant

NA

NA

4/15/2014

234

Defendant

NA

NA

4/15/2014

235

Defendant

NA

NA

4/15/2014

236

963958.1

Description

Defendant

NA

NA

4/15/2014

Exhibits 2-9 to the Expert Report Submitted by Dr. Bruce Isaacson
Measuring the Impressions Conveyed by Materials Advertising Rocket
Lawyer
Table B: Summary of Results from Question 1 and Question 2 from the
Expert Report Submitted by Dr. Bruce Isaacson Measuring the
Impressions Conveyed by Materials Advertising Rocket Lawyer
Table C: Summary of Responses to Questions about Ads (Questions 3
and 4) from the Expert Report Submitted by Dr. Bruce Isaacson
Measuring the Impressions Conveyed by Materials Advertising Rocket
Lawyer
Table D: Summary of Responses to Questions About Website Pages
(Questions 5, 6, 7, and 8) from the Expert Report Submitted by Dr. Bruce
Isaacson Measuring the Impressions Conveyed by Materials Advertising
Rocket Lawyer
Appendix E Bill of Sale - Test Control Stimuli from the Expert Report of
Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of
Rocket Lawyer's Advertisement and Website
Appendix E Divorce Settlement Agreement - Test Control Stimuli from
the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer
Perceptions of Rocket Lawyer's Advertisement and Website

Non Offering Party's
Objections
Objection: Relevance
Objection: Relevance
Objection: Relevance
Objection: Relevance
Objection: Relevance
Objection: Relevance
Objection: Relevance
Objection: Relevance
Objection: Relevance
Objection: Relevance
Objection: Relevance

Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay

Appendix E Incorporation - Test Control Stimuli from the Expert Report Objection: Foundation;
Hearsay
of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of
Rocket Lawyer's Advertisement and Website
13 of 25

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
237
Defendant

Beg. Bates

End Bates

Date

NA

NA

4/15/2014

238

NA

NA

4/15/2015

239

Defendant

NA

NA

4/15/2014

240

Defendant

NA

NA

4/15/2014

241

Defendant

NA

NA

4/15/2014

242

Defendant

NA

NA

4/15/2014

243

Defendant

NA

NA

4/15/2014

244

Defendant

NA

NA

4/15/2014

245

Defendant

NA

NA

4/15/2014

246

Defendant

NA

NA

4/15/2014

247

Defendant

NA

NA

4/15/2014

248

Defendant

NA

NA

4/15/2014

249

Defendant

NA

NA

4/15/2014

250

Defendant

NA

NA

4/15/2014

251

963958.1

Defendant

Defendant

NA

NA

4/15/2014

Description
Appendix E Lease Agreement - Test Control Stimuli from the Expert
Report of Professor Jerry (Yoram) Wind Regarding Consumer
Perceptions of Rocket Lawyer's Advertisement and Website
Appendix E Power of Attorney - Test Control Stimuli from the Expert
Report of Professor Jerry (Yoram) Wind Regarding Consumer
Perceptions of Rocket Lawyer's Advertisement and Website
Appendix F - LegalZoom free trial advertisement from the Expert Report
of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of
Rocket Lawyer's Advertisement and Website
Appendix F - Capture of LegalZoom free trial from the Expert Report of
Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of
Rocket Lawyer's Advertisement and Website

Non Offering Party's
Objections
Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay

Appendix F - LegalZoom free trial offer from the Expert Report of
Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of
Rocket Lawyer's Advertisement and Website
Appendix G - Online Legal Services Study - Online Screener
Questionnaire from the Expert Report of Professor Jerry (Yoram) Wind
Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and
Website
Appendix H - Online Legal Study - Screening Results from the Expert
Report of Professor Jerry (Yoram) Wind Regarding Consumer
Perceptions of Rocket Lawyer's Advertisement and Website
Appendix I - Verbatim Responses from the Expert Report of Professor
Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket
Lawyer's Advertisement and Website
Appendix L - Computer Cross Tabulation from the Expert Report of
Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of
Rocket Lawyer's Advertisement and Website
Appendix L - Consumer Services Decision Tree Tables from the Expert
Report of Professor Jerry (Yoram) Wind Regarding Consumer
Perceptions of Rocket Lawyer's Advertisement and Website
Appendix L - Incorporation Services Decision Tree Tables from the
Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer
Perceptions of Rocket Lawyer's Advertisement and Website
Appendix M - Statistical Analysis - Results for the Consumer Perception
of Rocket Lawyer's Advertisement Incorporation Services from the
Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer
Perceptions of Rocket Lawyer's Advertisement and Website

Objection: Foundation;
Hearsay

Incorporation and online legal services results table from the Expert
Report of Professor Jerry (Yoram) Wind Regarding Consumer
Perceptions of Rocket Lawyer's Advertisement and Website
Sample size chart from the Expert Report of Professor Jerry (Yoram)
Wind Regarding Consumer Perceptions of Rocket Lawyer's
Advertisement and Website
Stimuli test and control comparisons from the Expert Report of Professor
Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket
Lawyer's Advertisement and Website

Objection: Foundation;
Hearsay

14 of 25

Objection: Foundation;
Hearsay

Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay

Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
252
Defendant

Beg. Bates

End Bates

Date

NA

NA

5/15/2014

253

NA

NA

6/27/2014

254

Defendant

NA

NA

Defendant

NA

NA

256
1026*
258

Defendant
Defendant
Defendant

RLI0036800
RLI0039562
RLI0039522

RLI0036802
RLI0039565
RLI0039524

259

Defendant

RLI0042326

RLI0042327

260

Defendant

RLI0042332

RLI0042333

1020*

Defendant

RLI0042339

RLI0042340

1022
263

Defendant
Defendant

RLI0042345
RLI0042523

RLI0042347
RLI0042523

264

Defendant

RLI0065734

RLI0065737

265

Defendant

RLI0065741

RLI0065743

266

Defendant

RLI0065758

RLI0065760

267

Defendant

RLI0066972

RLI0066974

1011*

Defendant

RLI0039820

RLI0039820

1012*

Defendant

RLI0042598

RLI0042620

270*

Defendant

RLI0040722

RLI0040726

271

Defendant

RLI0042638

RLI0042641

272

Defendant

RLI0048851

RLI0048851

273

Defendant

RLI0083881

RLI0083881

Exhibits A-F to the Rebuttal Report of Professor Yoram (Jerry) Wind in
Response to Report of Dr. Bruce Isaacson
Chart regarding The Relationship between Intention to Buy and Actual
Purchase from the Supplemental Report of Yoram (Jerry) Wind

6/27/2014

255

963958.1

Defendant

Description

Appendix A- Results Tables from the Supplemental Report of Yoram
(Jerry) Wind
6/27/2014 Appendix B - Statistical Analysis from the Supplemental Report of
Yoram (Jerry) Wind
4/10/2013 Email from John Whelan to Brian Kocher re: Incorporation
11/18/2011 Email from Brian Liu to Charley Moore re: Google Ads
12/11/2011 Email from Executive Team ([e-mail]) to Charley Moore
re: [Executive Team] 2011-12-05 was updated
12/7/2011 Email from Christian Knuetter to Dan Nye, cc. Alisa Weiner, Charles
Moore, David Baga, John Whelan, and An Tran re: LegalZoom Attack

Non Offering Party's
Objections
Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay
Objection: Foundation;
Hearsay

Objection: Relevance

12/7/2011

Email from Katherine K. to Charley Moore, cc. Alisa Weiner re: Policy Objection: Hearsay; Relevance
Follow Up
12/2/2011 Email from Katherine K. to Charley Moore, cc. Alisa Weiner re: Rocket
Lawyer Follw Up
12/1/2011 Email from Charley Moore to Alisa Weiner re: Policy Issues
10/20/2011 Email from Katherine K. to Michael Nelson, cc. Sasha Volkov and Alisa Objection: Hearsay
Weiner re: Policy Follow Up
12/13/2011 Email from Katherine K. to Charley Moore, cc. Alisa Weiner re: Rocket
Lawyer Follw Up
12/8/2011 Email from David Baga to Charley Moore, cc. Christian Knuetter, Dan Objection: Relevance
Nye, Alisa Weiner, John Whelan, and An Tran re: LegalZoom Attack
12/5/2011

Email from Katherine K. to Charley Moore, cc. Alisa Weiner re: Rocket
Lawyer Follow Up
12/6/2011 Email from Alisa Weiner to Charley Moore, cc. Dan Nye, Courtney
O'Connell, David Baga, An Tran, Christian Knuetter, David Kreitzer and
Pete Franco re: Fwd: Rocket Lawyer Follow Up
4/16/2010 Interviews from Ferguson's April 2010 study
Objection: Incomplete;
Hearsay; Lack of Knowledge;
Misleading
10/17/2011 Email from Jenny Dearing to Michael Margolis, cc. Kevin McSpadden, Objection: Incomplete;
Hearsay; Misleading
John Fernandes, Alisa Weiner, and Sasha Volkov re: Notes from UX
interviews 1-4. Notes pertaining to usability interviews is attached
NA

Notes pertaining to usability interviews.

10/10/2011 Email from Michael Margolis to Alisa Weiner, cc. ThinkBrandNew,
John Zeratsky, and Jenny Dearing re: Connecting
2/17/2011 PowerPoint slides regarding Rocket Lawyer's Board of Directors
Meeting
4/15/2010 PowerPoint slides regarding Rocket Lawyer's Board of Directors
Meeting

15 of 25

Objection: Incomplete;
Hearsay; Misleading

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
274
Defendant

Beg. Bates

End Bates

NA

NA

275

Defendant

NA

NA

276

Defendant

NA

NA

277

Defendant

NA

NA

278

Defendant

NA

NA

279

Defendant

NA

NA

280

Defendant

N/A

N/A

281

Defendant

RLI0044139

RLI0044139

282

Defendant

NA

NA

283
284

Defendant
Defendant

NA
NA

NA
NA

285

Defendant

NA

NA

286
287
288

Defendant
Defendant
Defendant

NA
NA
NA

289

Defendant

290

Date

Description

Non Offering Party's
Date Identified
Objections
Objection: Relevance; Hearsay

10/24/2014 Screenshot of the Business Consumer Alliance's review of
LegalZoom.com found at
http://www.businessconsumeralliance.org/report/legalzoomcominc13156151
Objection: Relevance; Hearsay
10/24/2014 Screenshot of the Business Consumer Alliance's review of Rocket
Lawyer Corporate Services LLC found at
http://www.businessconsumeralliance.org/report/rocket-lawyer-corporateservices-llc-104856689
10/24/2014 Top Ten Reviews for Rocket Lawyer found at http://online-legal-forms- Objection: Relevance; Hearsay
review.toptenreviews.com/rocket-lawyer-review.html
10/24/2014 Top Ten Reviews for LegalZoom.com found at http://online-legal-forms- Objection: Relevance; Hearsay
review.toptenreviews.com/legalzoom-review.html
NA
Placeholder for the demo video of the consumer flow
Objection: Relevance;
Foundation; Hearsay
NA
Undisputed Statements of Fact for Summary Judgment Not Disputed or
Not Properly Disputed
Rocket Lawyer's Answer to First Amended Complaint and Amended
Counterclaims
11/7/2011 Email from Alisa Weiner to [e-mail] re: 1:1 videos

NA
NA
NA

Rocket Lawyer, Inc.'s Initial Disclosures Purusant to Fed. R. Civ. Proc.
26(A)(1)
9/20/2013 Amended Rule 26(A)(1) Disclosures of Rocket Lawyer Incorporated
10/24/2014 Rocket Lawyer, Inc.'s Second Amended Disclosures Pursuant to Fed. R.
Civ. Proc. 26(A)(1)
4/8/2013 LegalZoom.com, Inc.'s Initial Disclosures Pursuant to Fed. R. Civ. P.
26(A)(1)
9/26/2013 LegalZoom.com, Inc.'s Amended Rule 26(A)(1) Disclosures
10/24/2014 LegalZoom.com, Inc.'s Supplemental Rule 26(A)(1) Disclosures
10/27/2014 Historic screenshots from LegalCenterPro.com

Objection: Relevance; Hearsay

NA

NA

10/27/2014 Historic screenshots from LegalSpring.com

Objection: Relevance; Hearsay

Defendant

RLI0003391

RLI0003391

8/12/2010

Objection: Relevance; Hearsay

291

Defendant

RLI0074319

RLI0074319

3/14/2013

292

Defendant

RLI0083634

RLI0083634

6/29/2011

293

Defendant

RLI0083880

RLI0083881

4/14/2010

294

Defendant

NA

NA

1001

Plaintiff

1002

963958.1

4/8/2013

Plaintiff

NA

Rocket Lawyer PowerPoint presentation entitled "Incorporation Business
Analysis"
Rocket Lawyer PowerPoint presentation entitled "Incorporation Business
Update"
Rocket Lawyer PowerPoint slides entitled "Actual & Projected Customer
Lifetime Value (LTV)" and "Traffic Distribution"
Email from Charles Moore to Dan Nye and Jeff Wheeler re: BOD Slides
04-15-10 draft v4.pptx. Attached to the email is a Rocket Lawyer
PowerPoint presentation entitled "Board of Directors Meeting April 15,
2010"
Screenshots of Websites Advertising "Free"
Rocket Lawyer advertisement on Google.com featuring “Incorporate for
Free…Pay No Fees ($0).”
Rocket Lawyer advertisement on Yahoo featuring “Zoom Charges $99,
We’re Free.”
16 of 25

Objection: Relevance; Hearsay
Objection: Relevance; Hearsay
Objection: Relevance; Hearsay

Objection: Relevance; Hearsay

Date Admitted

No. of Exhibit Offering
Party/Parties
1003
Plaintiff

Beg. Bates

End Bates

1004
1005

Plaintiff

1006
1007

Plaintiff
Plaintiff

RLI 0036654
RLI 0040580

RLI 0040632

1008

Plaintiff

RLI 0040744

RLI 0040744

1009

Plaintiff

RLI 0040687

1010

Plaintiff

RLI 0040728

1011

Plaintiff

RLI 0039820

1012

Plaintiff

RLI 0042598

1013
1014

963958.1

Plaintiff

Plaintiff
Plaintiff

RLI 0005804
RLI 0036680

Date

Description

Non Offering Party's
Objections

Rocket Lawyer advertisement on Yahoo featuring “Zoom Costs $99,
We’re Free.”
Rocket Lawyer advertisement on Google featuring “Free Legal Forms &
LLC’s” from Rocket Lawyer
Rocket Lawyer advertisement on Rocketlawyer.com featuring “Free help
from local attorneys.”
Freemium Yellow Brick Road presentation/document
4/0/2010 Rocket Lawyer Usability Research April 2010
Hearsay, FRE 801; research
participants and Ferguson not
available to testify; prejudicial,
FRE 403, jury may be led to
believe it is an actual consumer
survey
10/0/2010 Rocket Lawyer Usability Research October 2010 [Produced in Native
Hearsay, FRE 801; research
Format]
participants and Ferguson not
available to testify; prejudicial,
FRE 403, jury may be led to
believe it an actual consumer
survey
6/0/2011 Rocket Lawyer Detailed Usability Findings Small Business Owner and Hearsay, FRE 801; research
Consumer Research June 2011
participants and Ferguson not
available to testify; prejudicial,
FRE 403, jury may be led to
believe it is an actual consumer
survey
10/21/2011 Rocket Lawyer: UX Research Toplines October 21, 2011
Hearsay, FRE 801; research
participants and Margolis not
available to testify; prejudicial,
FRE 403, jury may be led to
believe it is an actual consumer
survey
4/0/2010 Handwritten Notes from April 2010 Usability Study – Author Unknown Hearsay, FRE 801; research
participants and Margolis not
available to testify; prejudicial,
FRE 403, jury may be led to
believe it is an actual consumer
survey
Handwritten Notes from UX Interviews – Author Jenny Dearing of
Hearsay, FRE 801; research
Thinkbrandnew.com
participants and Margolis not
available to testify; prejudicial,
FRE 403, jury may be led to
believe it is an actual consumer
survey
10/15/2012 Email from Justin Tenuto to Jarrad Colli
10/23/2012 Email from Chris Faville to Alisa Weiner
Hearsay, FRE 801, to the
extent to show that people are
getting confused with RLI's UI.

17 of 25

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
1015
Plaintiff

Beg. Bates

End Bates

Date

Description

RLI 0036803

2/5/2013

Email from John Whelan to Chris Faville

1016

RLI 0037960

7/20/2010

Email from David Baga to Jennifer Paulus

1017

Plaintiff

RLI 0037987

7/21/2010

Email from Eric Geibel to David Baga

1018

963958.1

Plaintiff

Plaintiff

RLI 0037098

8/17/2010

Email from Jenn Mazzon to David Baga

18 of 25

Non Offering Party's
Date Identified
Objections
Hearsay, FRE 801, to extent LZ
offers customer responses to
show actual customer
confusion; prejudicial, FRE
403; irrelevant 401, 402 ("a
handful of customer statements
on one online review site is not
sufficient to demonstrate that a
'significant portion' of
customers were deceived and is
not necessarily a reliable
consumer survey or market
research" SJ Order. ECF 44 AT
10.
Hearsay, FRE 801, to extent LZ
offers customer response to
show actual customer
confusion; prejudicial, FRE
403; irrelevant 401, 402 ("a
handful of customer statements
on one online review site is not
sufficient to
demonstrate that a 'significant
portion' of customers were
deceived and is not necessarily
a
reliable consumer survey or
market research" SJ Order.
ECF 44 AT 10.
Hearsay, FRE 801, to extent LZ
offers customer response to
show actual customer
confusion; prejudicial, FRE
403; irrelevant 401, 402 ("a
handful of customer statements
on one online review site is not
sufficient to
demonstrate that a 'significant
portion' of customers were
deceived and is not necessarily
a
reliable consumer survey or
market research" SJ Order.
ECF 44 AT 10.

Date Admitted

No. of Exhibit Offering
Party/Parties
1019
Plaintiff

Beg. Bates

End Bates

Date

Description

RLI 0001021

4/30/2012

Email from Pete Franco to Mike N

1020

RLI 0042339

12/2/2011

Email from Katherine K. of Google to Charley Moore

1021
1022
1023
1024

Plaintiff
Plaintiff
Plaintiff
Plaintiff

RLI 0042354
RLI 0042345
RLI 0037788
RLI 0049002

12/1/2011
12/1/2011
12/14/2010
1/29/2011

Email from Michael Nelson to Sasha Volkov
Email from Charley Moore to Alisa Weiner
Email from David Baga to Dave Yoo
Email from Jenn Mazzon to Rebecca Carpenter

1025
1026
1027
1028
1029
1030

Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff

RLI 0039576
RLI 0039562
RLI0037010

11/16/2011
11/18/2011
12/12/2011
9/23/2014
10/1/2014
9/23/2013

1031
1032
1033
1034
1035

Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff

1036
1037

Plaintiff
Plaintiff

4/15/2014

Email between Brian Liu and Charley Moore
Email between Brian Liu and Charley Moore
Email from Dan Nye to Charley Moore
Excerpts of the Deposition of Alisa Weiner
Excerpts of the Deposition of Paul Hollerbach
Declaration of Paul Hollerbach In Support of Rocket Lawyer’s
Opposition to Motion for Summary Judgment
Excerpts of the Deposition of Mark Sedlacek
Excerpts of the Deposition of Pete Franco
Excerpts of the Deposition of David Baga
Excerpts of the Deposition of Charley Moore
LegalZoom Answer to Rocket Lawyer’s Amended Counterclaims
(Docket No. 18)
First Amended Complaint filed by LegalZoom (Docket No. 14)
Tab No. 1 to the Expert Report of Alan Goedde, Ph.D.

1038

963958.1

Plaintiff

Plaintiff

4/15/2014

Tab No. 2 to the Expert Report of Alan Goedde, Ph.D.

RLI 0039577
RLI 0039565

10/1/2014
10/3/2014
10/8/2014
10/9/2014

19 of 25

Non Offering Party's
Date Identified
Objections
FRE 407 – subsequent
remedial measures – evidence
that we changed our ads in
response to pressure from
LegalZoom is not admissible to
prove culpable conduct or a
need for a warning or
instruction
Incomplete, FRE 106, there are
later emails with Katherine K

The email attaches RLI
October 2010 Usability
Research. Hearsay, FRE 801;
research participants and
Ferguson not available to
testify; prejudicial, FRE 403,
jury may be led to believe it an
actual consumer survey

Hearsay, FRE 801
Hearsay, FRE 801

Hearsay, FRE 801
Hearsay, FRE 801
Hearsay, FRE 801
Hearsay, FRE 801

Relevance, FRE 402;
prejudicial, FRE 403. This
version of the Goedde report
has been expressly superseded
by the 2nd supplemental report
Relevance, FRE 402;
prejudicial, FRE 403. This
version of the Goedde report
has been expressly superseded
by the 2nd supplemental report

Date Admitted

No. of Exhibit Offering
Party/Parties
1039
Plaintiff

Beg. Bates

End Bates

Date

Description

4/15/2014

Tab No. 3 to the Expert Report of Alan Goedde, Ph.D.

Non Offering Party's
Date Identified
Objections
Relevance, FRE 402;
prejudicial, FRE 403. This
version of the Goedde report
has been expressly superseded
by the 2nd supplemental report

1040
1041
1042
1043
1044
1045
1046
1047
1048
1049
1050
1051
1052

4/0/2014
4/0/2014
4/0/2014
4/0/2014
4/0/2014
4/0/2014
4/0/2014
4/0/2014
4/0/2014
4/15/2014
4/0/2014
4/0/2014
6/3/2014

Exhibit 1 to the Expert Report of Dr. Bruce R. Isaacson
Exhibit 2 to the Expert Report of Dr. Bruce R. Isaacson
Exhibit 3 to the Expert Report of Dr. Bruce R. Isaacson
Exhibit 4 to the Expert Report of Dr. Bruce R. Isaacson
Exhibit 5 to the Expert Report of Dr. Bruce R. Isaacson
Exhibit 6 to the Expert Report of Dr. Bruce R. Isaacson
Exhibit 7 to the Expert Report of Dr. Bruce R. Isaacson
Exhibit 8 to the Expert Report of Dr. Bruce R. Isaacson
Exhibit 9 to the Expert Report of Dr. Bruce R. Isaacson
Exhibit 1 to the Expert Report of Dr. Larry Chiagouris
Exhibit 2 to the Expert Report of Dr. Larry Chiagouris
Exhibit 3 to the Expert Report of Dr. Larry Chiagouris
Tab 1 to the Supplemental Expert Report of Alan Goedde, Ph.D.

1053

Plaintiff

6/3/2014

Tab 2 to the Supplemental Expert Report of Alan Goedde, Ph.D.

Relevance, FRE 402;
prejudicial, FRE 403. This
version of the Goedde report
has been expressly superseded
by the 2nd supplemental report

1054

Plaintiff

6/3/2014

Tab 3 to the Supplemental Expert Report of Alan Goedde, Ph.D.

Relevance, FRE 402;
prejudicial, FRE 403. This
version of the Goedde report
has been expressly superseded
by the 2nd supplemental report

1055

Plaintiff

10/0/2014

Part 1 to the Second Supplemental Expert Report of Alan Goedde, Ph.D.

1056

Plaintiff

10/0/2014

Part 2 to the Second Supplemental Expert Report of Alan Goedde, Ph.D.

1057

Plaintiff

10/0/2014

Part 3 to the Second Supplemental Expert Report of Alan Goedde, Ph.D

1058

Plaintiff

10/0/2014

Part 4 to the Second Supplemental Expert Report of Alan Goedde, Ph.D.

1059
1060
1061
1062
1063
963958.1

Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff

Plaintiff
Plaintiff
Plaintiff
Plaintiff
Plaintiff

LegalZoom’s First Request for Production of Documents
LegalZoom’s Second Set of Requests for Production of Documents
LegalZoom’s Third Set of Requests for Production of Documents
LegalZoom’s First Set of Interrogatories to Rocket Lawyer
LegalZoom’s Second Set of Interrogatories to Rocket Lawyer
20 of 25

Relevance, FRE 402;
prejudicial, FRE 403. This
version of the Goedde report
has been expressly superseded
by the 2nd supplemental report

Date Admitted

No. of Exhibit Offering
Party/Parties
1064
Plaintiff
1065
Plaintiff
1066
Plaintiff
1067
Plaintiff
1068
Plaintiff
1069
Plaintiff
1070
Plaintiff
1071
Plaintiff
1072
Plaintiff
1073
Plaintiff

Beg. Bates

End Bates

Date

Non Offering Party's
Objections

LegalZoom’s First Set of Request for Admissions to Rocket Lawyer
10/24/2014 LegalZoom’s Amended Rule 26(a)(1) Disclosures
Amended Notice of Deposition of Alisa Weiner
Amended Notice of Deposition of Paul Hollerbach
Amended Notice of Deposition of Mark Sedlacek
Amended Notice of Deposition of Pete Franco
Amended Deposition Notice of David Baga
Amended Deposition Notice of Charley Moore
LegalZoom’s Notice of 30(b)(6) Deposition
Rocket Lawyer’s Responses and Objections to LegalZoom’s Notice of
30(b)(6) Deposition
Rocket Lawyer’s Incorporated’s Objections and Responses to Plaintiff’s
First Set of Requests for Production of Document and Things (Nos. 1-55)

1074

Plaintiff

1075

Plaintiff

1076

Plaintiff

1077

Plaintiff

1078

Plaintiff

1079

Plaintiff

1080

Plaintiff

1081

Plaintiff

1082

Plaintiff

1083

Plaintiff

1084

Plaintiff

9/4/2013

1085

963958.1

Description

Plaintiff

9/4/2013

Rocket Lawyer’s Incorporated’s Objections and Responses to Plaintiff’s
First Set of Special Interrogatories
Rocket Lawyer’s Incorporated’s Objections and Responses to Plaintiff’s
First Set of Requests for Admission
Defendant’s Objections and Responses to Plaintiff’s Second Set of
Requests for Production and Things (Nos. 56-59)
Rocket Lawyer Incorporated’s Supplemental Objections and Responses
to Plaintiff’s First Set of Special Interrogatories
Rocket Lawyer Incorporated’s Supplemental Objections and Responses
to Plaintiff’s First Set of Requests for Production and Things (Nos. 1-55)
Rocket Lawyer Incorporated’s Supplemental Objections and Responses
to Plaintiff’s Second Set of Requests for Production and Things (Nos. 5659)
Rocket Lawyer Incorporated’s Supplemental Objections and Responses
to Interrogatory No. 24
Rocket Lawyer Incorporated Supplemental Objections and Responses to
Plaintiff’s Third Set of Requests for Production of Documents and
Things (Nos. 60-89)
Rocket Lawyer Incorporated’s Objections and Responses to Plaintiff’s
Second Set of Special Interrogatories
Exhibit A to the September 4, 2013 Declaration of Mary Ann T. Nguyen
in support of Plaintiff LegalZoom’s Motion for Summary Judgment
Exhibit B to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incompete and misleading,
in support of Plaintiff LegalZoom’s Motion for Summary Judgment
FRE 106 and 403, to that the
ads that other ads that appear
on search engine results are not
included and to the extent that
the screenshot is not clear as to
whether the image shows a
paid advertisement or an
organic search result

21 of 25

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
1086
Plaintiff

Beg. Bates

End Bates

Date
9/4/2013

Description

Non Offering Party's
Date Identified
Objections
Exhibit C to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incomplete, FRE 106;
in support of Plaintiff LegalZoom’s Motion for Summary Judgment
misleading, FRE 403; to extent
it is offered to show the only
disclosure of state filing fees on
Rocketlawyer.com and only a
portion of the user journey
Exhibit D to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incomplete, FRE 106;
in support of Plaintiff LegalZoom’s Motion for Summary Judgment
misleading, FRE 403; to extent
it is offered to show the only
disclosure of state filing fees on
Rocketlawyer.com and only a
portion of the use journey
(missing summary of order and
payment pages)
Exhibit E to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incomplete, FRE 106;
in support of Plaintiff LegalZoom’s Motion for Summary Judgment
misleading, FRE 403 to the
extent that the first page is used
to show what services are
included in the free trial and as
to the second page, it is unclear
what the status of the user is at
the time this screenshot was
taken and the offer for free
legal review was made.

1087

9/4/2013

1088

Plaintiff

9/4/2013

1089

Plaintiff

9/4/2013

Exhibit F to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incompete and misleading,
in support of Plaintiff LegalZoom’s Motion for Summary Judgment
FRE 106 and 403, 407 to the
extent used to show
negligence; culpable conduct; a
defect in a product or its
design; or a need for a warning
or instruction through remedial
action

1090

Plaintiff

9/4/2013

Exhibit G to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incompete and misleading,
in support of Plaintiff LegalZoom’s Motion for Summary Judgment
FRE 106 and 403, 407 to the
extent used to show
negligence; culpable conduct; a
defect in a product or its
design; or a need for a warning
or instruction through remedial
action

1091

963958.1

Plaintiff

Plaintiff

9/4/2013

Exhibit H to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incomplete, FRE 106;
in support of Plaintiff LegalZoom’s Motion for Summary Judgment
misleading, FRE 403 to the
extent that the first page is used
to show what services are
included in the free trial and as
to the second page
22 of 25

Date Admitted

No. of Exhibit Offering
Party/Parties
1092
Plaintiff

Beg. Bates

End Bates

Date

Description

9/4/2013

Exhibit I to the September 4, 2013 Declaration of Mary Ann T. Nguyen
in support of Plaintiff LegalZoom’s Motion for Summary Judgment

1093

9/4/2013

Exhibit J to the September 4, 2013 Declaration of Mary Ann T. Nguyen
in support of Plaintiff LegalZoom’s Motion for Summary Judgment

1094

Plaintiff

9/4/2013

Exhibit K to the September 4, 2013 Declaration of Mary Ann T. Nguyen
in support of Plaintiff LegalZoom’s Motion for Summary Judgment

1095

Plaintiff

9/4/2013

Exhibit L to the September 4, 2013 Declaration of Mary Ann T. Nguyen
in support of Plaintiff LegalZoom’s Motion for Summary Judgment

1096

Plaintiff

1097

Plaintiff

7/21/2014

1098
1099

Plaintiff
Plaintiff

7/21/2014

1100

Plaintiff

7/21/2014

1101

Plaintiff

7/21/2014

1102

Plaintiff

7/21/2014

1103

963958.1

Plaintiff

Plaintiff

7/21/2014

Non Offering Party's
Date Identified
Objections
Incompete and misleading,
FRE 106 and 403, to the extent
that it is offered to show that
this is the only disclosure of
Rocket Lawyer’s free trial
terms

Declaration of Mary Ann T. Nguyen in support of Plaintiff LegalZoom’s Hearsay, FRE 801, Misleading,
Motion for Summary Judgment
FRE 403, to the extent that it
suggests that RLI charges fees
outside of state processing fees
or that RLI's free trial is not
actually free
Hearsay, FRE 801, Jerry
Exhibit A to the July 21, 2014 Declaration of Patricia J. Winograd in
Wind's deposition transcript;
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
incomplete and thus
Incorporated’s Motion for Summary Judgment and/or Summary
misleading, FRE 106 and 403
Adjudication
Intentionally Left Blank
Misleading as to date Exhibit B to the July 21, 2014 Declaration of Patricia J. Winograd in
metadata has 7/20/2011
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
Incorporated’s Motion for Summary Judgment and/or Summary
Adjudication
Exhibit C to the July 21, 2014 Declaration of Patricia J. Winograd in
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
Incorporated’s Motion for Summary Judgment and/or Summary
Adjudication
Exhibit D to the July 21, 2014 Declaration of Patricia J. Winograd in
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
Incorporated’s Motion for Summary Judgment and/or Summary
Adjudication
Exhibit E to the July 21, 2014 Declaration of Patricia J. Winograd in
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
Incorporated’s Motion for Summary Judgment and/or Summary
Adjudication
Exhibit F to the July 21, 2014 Declaration of Patricia J. Winograd in
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
Incorporated’s Motion for Summary Judgment and/or Summary
Adjudication

23 of 25

Date Admitted

No. of Exhibit Offering
Party/Parties
1104
Plaintiff

Beg. Bates

End Bates

Date
7/21/2014

1105

7/21/2014

1106

Plaintiff

7/21/2014

1107

Plaintiff

7/21/2014

1108

Plaintiff

7/21/2014

1109

Plaintiff

1110
963958.1

Plaintiff

Plaintiff

RLI0005744

RLI0005746

5/18/2011

Description

Non Offering Party's
Objections

Exhibit G to the July 21, 2014 Declaration of Patricia J. Winograd in
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
Incorporated’s Motion for Summary Judgment and/or Summary
Adjudication
Exhibit H to the July 21, 2014 Declaration of Patricia J. Winograd in
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
Incorporated’s Motion for Summary Judgment and/or Summary
Adjudication
Exhibit I to the July 21, 2014 Declaration of Patricia J. Winograd in
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
Incorporated’s Motion for Summary Judgment and/or Summary
Adjudication

Exhibit J to the July 21, 2014 Declaration of Patricia J. Winograd in
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
Incorporated’s Motion for Summary Judgment and/or Summary
Adjudication
Exhibit K to the July 21, 2014 Declaration of Patricia J. Winograd in
support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer
Incorporated’s Motion for Summary Judgment and/or Summary
Adjudication

Email between John Whelan and Matt Kaufman re Advertisement of
Rocket Lawyer On Call

Demonstrative Evidence
24 of 25

Hearsay, FRE 801, to extent LZ
offers customer response to
show actual customer
confusion; prejudicial, FRE
403; irrelevant 401, 402 ("a
handful of customer statements
on one online review site is not
sufficient to
demonstrate that a 'significant
portion' of customers were
deceived and is not necessarily
a
reliable consumer survey or
market research" SJ Order.
ECF 44 AT 10.
Hearsay, 801

Hearsay, 801, Relevance, FRE
402; prejudicial, FRE 403.
This version of the Goedde
report has been expressly
superseded by the 2nd
supplemental report
Hearsay, FRE 801, to extent LZ
offers customer response to
show actual customer
confusion; prejudicial, FRE
403; irrelevant 401, 402 ("a
handful of customer statements
on one online review site is not
sufficient to
demonstrate that a 'significant
portion' of customers were
deceived and is not necessarily
a
reliable consumer survey or
market research" SJ Order.
ECF 44 AT 10.

Date Identified

Date Admitted

No. of Exhibit Offering
Party/Parties
1111
Plaintiff
1112
Plaintiff
1113
Plaintiff
1114
Plaintiff
1115
Plaintiff

963958.1

Beg. Bates

End Bates

Date

Description

Non Offering Party's
Objections

Demonstrative Evidence
Demonstrative Evidence
Demonstrative Evidence
Demonstrative Evidence
Demonstrative Evidence

25 of 25

Date Identified

Date Admitted