LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 31

NOTICE OF MOTION AND MOTION for Summary Judgment filed by Plaintiff LegalZoom.com Inc. Motion set for hearing on 10/7/2013 at 09:30 AM before Judge Gary A. Feess. (Attachments: # 1 Separate Statement, # 2 Proposed Order)(Heather, Fred)

PATRICIA L. GLASER -State Bar No. 55668
pglaser glaserweil.com
a FRED .HEATHER -State Bar No. 110650
(heather laserweil.com
T. NGUYEN -State Bar No. 269099
3 MARY
mnguyen laserweil.com
IL FINK JACOBS
4 GLASER
HOWARD AVCHEN & SHAPIRO LLP
s 10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
6 Telephone: [phone]
Facsimile: 310 556-2920
Attorneys for Plaintiff
s LegalZoom.com, Inc.
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CENTRAL DISTRICT OF CALIFORNIA

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UNITED STATES DISTRICT COURT

WESTERN DIVISION

iz LEGALZOOM.COM,INC., a Delaware
corporation,

CASE NO.: CV 12-9942-GAF(AGRx)

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Hon. Gary A. Feess
Courtroom: 740

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Plaintiff,

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ROCKET LAWYER INCORPORATED,
i6 a Delaware corporation,
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Defendants.

PLAINTIFF LEGALZOOM.COM,
INC.'S NOTICE OF MOTION AND
MOTION FOR SUMMARY
JUDGMENT; MEMORANDUM OF
POINTS AND AUTHORITIES•
DECLARATION OF MARY A~TN T.
NGUYEN
October 7, 2013
Date:
Time:
9:30 a.m.
Courtroom: 740
SEPARATE STATEMENT OF
ISPUTED MATERIAL FACTS;
PROPOSED ORDER FILED
ONCURRE TLY HEREWITH]
Complaint Filed: November 20, 2012

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PLAINTIFF LEGALZOOM.COM,INC.'S NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT
807872

TO THE DEFENDANT AND ITS ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE THAT on October 7, 2013 at 9:30 a.m. in

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Courtroom 740 ofthe above-referenced Court, located at 312 North Spring Street,

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Los Angeles, California 90012,Plaintiff LegalZoom.com,Inc.("LegalZoom") will

s and hereby does move for summary judgment on its claims. Specifically, LegalZoom
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moves this Court to enter summary judgment declaring that Defendant Rocket
Lawyer Incorporated ("Rocket Lawyer") is liable for False Advertising pursuant to

s the Lanham Act, 15 U.S.C. § 1125(a), False Advertising pursuant to California
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Business a.nd Professions Code section 17500, and Unfair Competition pursuant to

io California Business and Professions Code section 17200 et seq. as a matter of law,
ii leaving only the amount of LegalZoom's damages to be determined at trial.
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This Motion is made pursuant to Rule 56 ofthe Federal Rules of Civil

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Procedure and is based upon this Notice of Motion, the accompanying Memorandum

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ofPoints and Authorities, the Declaration of Mary Ann T. Nguyen, the Separate

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is Statement of Undisputed Material Facts, all papers and pleadings in the Court's file,
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and upon such oral argument as may be made at the hearing on this Motion. This

i~ Motion is made following the conference of counsel pursuant to L.R. 7-3, which took
is place on August 28, 2013.
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ai ~ DATED: September 4, 2013

Respectfully submitted,

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GLASER WEIL FINK JACOBS
HOWARD AVCHEN & SHAPIRO LLP

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By: /s/ Fred Heather
PATRICIA L. GLASER
FRED D. HEATHER
MARY ANN T. NGUYEN
Attorneys for Plaintiff
LegalZoom.com, Inc.
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PLAINTIFF LEGALZOOM.COM,INC.'S NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT

807872

TABLE OF CONTENTS
Page
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I
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II.

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III.

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Zs IV.

INTRODUCTION ...........................................................................................1
STATEMENT OF MATERIAL FACTS NOT IN DISPUTE........................1
A.
The Parties And The Products ..............................................................1
B.
Rocket Lawyer's Online Advertisements .............................................2
1.
"Free" corporations and LLCs....................................................2
2.
"Free help from local attorneys" and "Free legal review".........3
"Free trial" ..................................................................................4
3.
C.
LegalZoom's Prior Efforts To Resolve Matters Outside Of Court ......5
ARGUMENT ..................................................................................................6
Legal Standard For Summary Judgment ..............................................6
A.
B.
Rocket Lawyer's Advertisements Constitute False Advertising
Under The Lanham Act.........................................................................7
1.
Rocket Lawyer's Advertisements are False Commercial
Advertisements ...........................................................................8
a.
Rocket Lawyers advertisements are literally false...........8
b.
Rocket Lawyers advertisements are commercial
advertisements..................................................................9
i~
Commercial speech.
9
iii Parties in commercial competition.
10
iii) Purpose of influencing customers.
10
iv) Dissemination sufficiently to the relevant
purchasing public.
10
2.
Rocket Lawyer's Advertisements Are Presumed to Have
Deceived and Have the Tendency to Deceive a Substantial
Segment of its Audience ...........................................................11
3.
Rocket Lawyer's Advertisements are Materially Deceptive
in that it They Are Likely to Influence Purchasing Decisions.12
4.
Rocket Lawyer Caused its False Advertisements to Enter
Interstate Commerce .................................................................12
5.
Rocket Lawyer's False Advertising Caused Actual Injury to
LegalZoom ................................................................................13
Rocket La er's Advertising Constitutes False Advertising Under
C.
Cal. Bus. &~rof. Code § 17500 .........................................................14
D. Rocket Lawyer's False Advertising Constitutes Unfair
Competition Under Cal. Bus. &Prof. Code § 17200 .........................15
CONCLUSION .............................................................................................18

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PLAINTIFF LEGALZOOM.COM,INC.'S NOTICE OF MOTION AND MOTION FOR SUMMARY JiJDGMENT

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TABLE OF AUTHORITIES
Page

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5
6

FEDERAL CASES
Allsup,Inc. v. Advantage 2000 Consultants Inc.,
428 F.3d 1135 (8th Cir. 2005)................................................................................... 8
Anderson v. Liberty Lobby, Inc.,
477 U.S. 242(1986)................................................................................................... 6
Castrollnc. v. Pennzoil Co.,
987 F.2d 939(3d Cir. 1993)
....................................................................................... 8

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Certain Teed Cor . v. Seattle RoofBrokers,
2010 WL 264083,*5(W.D. Wash. June 28,2010).............................................. 10
Cincinnati v. Discovery Network,
507 U.S. 410(1993)...................................................................................................9
Coastal Abstract Serv. Inc. v. First Am. Title Ins. Co.,
173 F.3d 725 (9th Cir. 1999)..................................................................................... 9

is Coca-Cola Co. v. Tro~ picana Products, Inc.,
690 F.2d 312(2d Cir. 1982)
....................................................................................... 7

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Celotex Corp. v. Catrett,
477 U.S. 317(1986)...................................................................................................6

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Del Webb Cmtys., Inc. v. Partin ton,
2009 WL 3653709, *11, *16 ~D. Nev. Sept. 18, 2009)........................................... 13
Fleener v. Trinity Broadcasting Network,
203 F. Sup. 2d 1142(C.D. Cal. 2001)....................................................................... 6
Gordon &Breach Science Publishers, Ltd. v. American Institute ofPhysics,
859 F. Supp. 1521 (S.D.N.Y. 1994)........................................................................ 12

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24
25
26

2
,~ G 383 F. Supp.l d 1224(CD. Cal. 2005)..................................................................... 6
Harper House, Inc. v. Thomas Nelson, Inc.,
889 F.2d 197(9th Cir. 1989)................................................................................... 13
Healthport Corp. v. Tanita Corp. ofAmerica,
563 F. Supp. 2d at 1179 ........................................................................................... 12
In re Samuel Stores,
27 F.T.C. 882(1938)
................................................................................................ 12

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J.K. Harris & Co., LLC v. Kassel,
253 F. Supp. 2d 1120(N.D. Cal. 2003)................................................................... 14

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Maier Brewin Co. v. Fleischmann Distilling Corp.,
390 F.2d 11~ (9th Cir. 1968)..................................................................................... 7
PLAINTIFF LEGALZOOM.COM,INC.'S NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT

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Matsushita Elec. Industrial Co. v. Zenith Radio Corp.,
475 U.S. 574(1986)................................................................................................... 6
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Monsanto Chemical Co. v. Perfect Fit Products Mfg. Co.,
....................................................................................... 7
349 F.2d 389(2d Cir. 1965)

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4

Oxycal Lab. v. Jeffers,
909 F. Supp. 719(S.D. Cal. 1995)............................................................................. 9

s Playboy Enterprises, Inc. v. Baccarat Clothing Co.,
692 F.2d 1272(9th Cir. 1982)................................................................................... 7
6

Pom Wonderful LLC v. Coca Cola Co.,
.727 F. Supp. 2d 849(C.D. Cal. 2010)..................................................................... 11
s Pom Wonderful LLC v. Coca-Cola Co.,
679 F.3d 1170(9th Cir. 2012)................................................................................. 11
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ii Rice v. Fox Broadcasting Co.,
330 F.3d 1170(9th Cir. 2003)................................................................................. 10
12
Southland Sod Farms v. Stover Seed Co.,
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108 F.3d 1134 (9th Cir. 1997)................................................................... 7, 8, 11, 13

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POM Wonderful LLC v. Purely Juice, Inc.,
.................................................. 12
2008 WI., 4222045, *11 (C.D. Cal. July 17, 2008)

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Spiegel, Inc. v. Fed. Trade Comm 'n,
494 F.2d 59(7th Cir. 1974) ....................................................................................... 9
Summit Tech. v. High-line Med. Instruments. Co.,
933 F. Supp. 918(C.D. Cal. 1996).......................................................................... 10
The William H. Morris Co. v. Group W, Inc.,
66 F.3d 255 (9th Cir.1995) ...................................................................................... 11
Thermal Desig~c,Inc. v. Guardian Bldg. Products, Inc.,
................................................... 10
2009 WL 1181327, *2(E.D. Wis. Apr. 29, 2009)
Triton Energy Corp. v. Square D. Co.,
68 F.3d 1216 (9th Cir. 1995)..................................................................................... 6
United Indus. Cor . v. Clorox Co.,
140 F.3d 1175 ~th Cir. 1998)................................................................................. 11
United States Sutcliffe,
505 F.3d 944(9th Cir. 2007)................................................................................... 12

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2s
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United States v. Trotter,
478 F.3d 918 (8th Cir. 2007)................................................................................... 12
Western States Wholesale, Inc. v. S nthetic Inds., Inc.,
206 F.R. D. 271 (C.D. Cal. 2002~............................................................................ 11

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Zs STATE CASES
PLAINTIFF LEGALZOOM.COM,INC.'S NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT

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Brockey v. Moore,
107 Cal. App. 4th 86(2003)

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Cel-Tech Communications, Inc. v. Los Angeles Cellular, Tel. Co.,
20 Ca1.4th 163(1999)

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Colgan v. Leatherman Tool Group,Inc.,
135 Ca1.App.4th 663(2006)

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4

s Committee on Children's Television v. General Foods Corp.,
35 Ca1.3d 197(1983)

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Federal Trade Commission v. Willms,
2011 WL 4103542, *4(W.D. Wash. Sept. 13, 2011)
s Kasky v. Nike, Inc.,
27 Cal.4th 939(2002)

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14

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People v. E. W.A.P., Inc.,
106 Ca1.App.3d 315 (1980)

ii People v. Servantes,
8b Ca1.App.4th 1081 (2001)

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STATE STATUTES
California Business &Professions Code § 17600

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California Business and Professions Code § 17200
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California Business and Professions Code § 17500
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i~ FEDERAL RULES
15 United States Code § 1125(a)(1)(B)
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Federal Rules of Civil Procedure § 56(a)
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Federal Rules of Civil Procedure § 56(c)

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8, 17
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Federal Rules of Civil Procedure § 56(e)

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PLAINTIFF LEGALZOOM.COM,INC.'S NOTICE OF MOTION AND MOTION FOR SUMMARY JiJDGMENT
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MEMORANDUM OF POINTS AND AUTHORITIES

a ~ I.

INTRODUCTION

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This is a straightforward case about false advertising by an online company that

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purports to provide "free" online legal products. Defendant Rocket Lawyer

s Incorporated ("Rocket Lawyer")tells consumers that"Zoom Charges $99. Rocket
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Lawyer is Fast, Easy, &Free. Incorporate Your Business Today," that consumers can
"incorporate for free... pay no fees ($0)," and that consumers can get "free... LLCs,"

s "free help from local attorneys," "free legal review," and "free" trials of Rocket
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Lawyer's "Basic Legal Plan" and "Pro Legal Plan." However, as demonstrated

io below, each ofthese online advertising claims is literally false.
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Given Rocket Lawyer's use of false factual statements in its online

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advertisements, Rocket Lawyer has engaged in false advertising and unfair

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competition in violation ofthe Lanham Act and California Professions and Business

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Code, and an award ofsummary judgment on these claims for LegalZoom is

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appropriate.

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i6 II.

STATEMENT OF MATERIAL FACTS NOT IN DISPUTE

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A.

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LegalZoom and Rocket Lawyer are both providers of online legal products.

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(LegalZoom's Separate Statement of Undisputed Material Facts "SS," ¶ 1, Rocket

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The Parties And The Products

ao Lawyer's Answer to Amended Complaint and Amended Counterclaims ("Rocket
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Lawyer's Answer and Amended Counterclaims"), ECF No. 17, 12:2-3 ("Rocket

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Lawyer and LegalZoom compete with one another... in the legal services

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industry....").) LegalZoom and Rocket Lawyer compete with one another in the

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online legal products industry. (SS,¶ 2, id.) LegalZoom and Rocket Lawyer both

Zs offer incorporation and formation services and other online legal products. (SS,¶ 3,
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id. at 13:1-2.) On its website, Rocket Lawyer touts to provide affordable legal

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services to individuals, families and business owners. (SS,¶ 4, Declaration of Mary

as Ann T. Nguyen ("Nguyen Decl."), ¶ 3, Exhibit A, a true and correct copy of Rocket
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MEMORANDUM OF POINTS AND AUTHORITIES
807872

Lawyer's "About Us" webpage.)
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B.

Rocket Lawyer's Online Advertisements
1.

"Free" corporations and LLCs

At least in 2011, 2012 and 2013, Rocket Lawyer advertised "free"

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incorporation and "free" limited liability companies(EEGs). (SS,¶ 5, Nguyen Decl.,

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¶ 4, Exhibit B,true and correct copies of screen grabs of Rocket Lawyer's
advertisements.) For example, Rocket Lawyer has advertised "Zoom Charges $99.

s Rocket Lawyer is Fast, Easy, &Free. Incorporate Your Business Today,"
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"Incorporate for Free... Pay No Fees $0,""Incorporate Your Business at Rocket

io Lawyer Free,""Form Your LLC Free at Rocket Lawyer" and "Free... LLCs." (SS,¶
ii 6, Nguyen Decl., ¶ 4, Exhibit B,true and correct copies ofscreen grabs of Rocket
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i2 Lawyer's advertisements.) However, Rocket Lawyer's customers cannot incorporate

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or form an LLC for "free" through Rocket Lawyer's services. Indeed, customers

i4 seeking to incorporate or form an LLC through Rocket Lawyer's services are

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nonetheless required to pay the state fees associated with incorporation and formation.

i6 (SS,¶ 7, Nguyen Decl., ¶¶ 2, 5, Exhibit C,true and correct copies of screen grabs of
i~ state filing options through Rocket Lawyer's services on Rocket Lawyer's website.)
ig Even more, customers who access the Rocket Lawyer link to the "Incorporate for
i9 Free... Pay No Fees $0,""Incorporate Your Business at Rocket Lawyer Free,""Form
Zo Your LLC Free at Rocket Lawyer" or "Free... LLCs" do not discover that they must
ai actually pay the state filing fees until after they have accessed the Rocket Lawyer
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website, completed a "company setup" and filled out information relating to the

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"company details." (SS,¶ 8, Nguyen Decl., ¶ 6, Exhibit D,true and correct copies of

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screen grabs of Rocket Lawyer's "interview" for "company set up" and "company

Zs details" prior to "state filing option.") Rocket Lawyer subsequently changed the
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language ofthese advertisements after LegalZoom filed its original Complaint.l (SS,

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~ Nonetheless, liability for false advertising under the Lanham Act may not be avoided by removing
false statements from later advertising. Skydrive Arizona, Inc. v. Quattrocchi, 2009 WL 6597892,
MEMORANDUM OF POINTS AND AUTHORITIES

ao7s72

i ¶ 9, Rocket Lawyer's Answer and Amended Counterclaims, ECF No. 17, 2:26-3:1
a ("Rocket Lawyer admits that it has produced new advertisements regarding its
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business and a variety of services it offers since the service ofthe original

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complaint....").)

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2.

"Free help from local attorneys" and "Free legal review"

At least in 2012, Rocket Lawyer advertised "Free help from local attorneys"
and "Free legal review." (SS,¶ 10, Nguyen Decl., ¶ 7, Exhibit E,true and correct

s copies of screen grabs of Rocket Lawyer's advertisements.) However, Rocket
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Lawyer's customers could not access "help from local attorneys" or "legal review"

io for free. Customers could access the "free help from local attorneys" and the "free
ii legal review" only ifthey were "Eligible Members" who had either(a)purchased
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i2 three consecutive months of Rocket Lawyer's monthly Legal Plan, or(b)purchased a
"i3 Rocket Lawyer annual Legal Plan. (SS,¶ 11, Nguyen Decl., ¶ 8, Exhibit F, a true
is and correct copy Rocket Lawyer's On Call Terms of Services, dated July 2012, as

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printed on November 27, 2012). This paid membership requirement for access to the

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purported "free help from local attorneys" and "free legal review" was not disclosed

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1~ in close proximity to the advertisements on Rocket Lawyer's website. (SS,¶ 12,
is Nguyen Decl., ¶ 9,see http://www.rocketlawver.com/on-call-terms-of -service.rl.)
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Indeed, this requirement was only disclosed in Rocket Lawyer's "On Call Terms of

Zo Service," which was accessible to customers on a separate link found at
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http://www.rocketlawyer.com/on-call-terms-of -service.rL (SS,¶ 13, Nguyen Decl., ¶

a2 9,see http://www.rocketlawver.com/on-call-terms-of -service.rl.) Rocket Lawyer
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subsequently changed the language of its "On Call Terms of Service," to provide that

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"Customers who enter into a one week (seven (7)calendar days)free trial are eligible

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25(D. Ariz. Feb. 2, 2009). In Skydrive Arizona v. Quattrocchi, the defendants argued that they had
removed the claimed objectionable language from their websites, but the court nevertheless held that
27 "those statements are indeed relevant to establish false advertising," and reasoned that the court had
come across no authority providing that removal offalse statements from later advertising could
28 shield a party from liability. Id.
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MEMORANDUM OF POINTS AND AUTHORITIES
807872

i to receive one(1)free legal matter consultation..." after LegalZoom filed its original
2

Complaint. (SS,¶ 14, Nguyen Decl., ¶ 10, Exhibit G,a true and correct copy of

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Rocket Lawyer's On Call Terms of Service, dated November 2012, as printed on

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November 27, 2012.) This access during a "free trial" was not available before

s LegalZoom's filing ofthe original Complaint. (SS,¶ 15, Nguyen Decl., ¶ 10,
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Exhibits F and G.) In any event, even with Rocket Lawyer's recent change, access
to the advertised "free help from local attorneys" and the "free legal review" was still

s conditioned upon customers actively enrolling in Rocket Lawyer's trial membership
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and negative option program and providing Rocket Lawyer with their credit card

io information. (SS,¶ 16, Nguyen Decl., ¶ 11, Exhibit G.) As provided in Federal
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Trade Commission v. Willms, 2011 WL 4103542, *4(W.D. Wash. Sept. 13, 2011), a

iz "free" offer subject to enrollment in a negative option program is not "free" and
i3 violates the Federal Trade Commission Act.
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3.

"Free trial"

At least in 2012 and 2013, Rocket Lawyer advertised on its website "free"
trials of its "Basic Legal Plan" and "Pro Legal Plan." (SS,¶ 17, Nguyen Decl., ¶ 12,

1~ Exhibit H,a true and correct copy of Rocket Lawyer advertisement("Try it Free").)
is However, Rocket Lawyer's customers cannot "try" Rocket Lawyer's "Basic Legal
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Plan" or "Pro Legal Plan" for "free." Customers who sign up for aone-week free

Zo trial membership under the "Basic Legal Plan" or "Pro Legal Plan" must first provide
ai Rocket Lawyer with their credit card information and enroll in Rocket Lawyer's
as "negative option" program — i.e., a program in which customers are automatically
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enrolled and billed and must contact Rocket Lawyer to opt out of. (SS,¶ 18, Nguyen

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Decl., ¶ 13, Exhibit I, a true and correct copy of Rocket Lawyer's "free" trial

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enrollment page after the outset ofthe offer.) As stated above, a "free" offer subject

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to enrollment in a negative option program is not "free." See FTC v. Willms, 2011

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WL 4103542, *4. A disclosure of Rocket Lawyer's negative option is found in

as standard font only upon the customer being directed to enroll in the "free trial." (SS,
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MEMORANDUM OF POINTS AND AUTHORITIES

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i ~ ¶ 19, Nguyen Decl., ¶ 13, see Exhibit I.) However, no further acknowledgement
a ~ regarding the negative option is provided. (SS,¶ 20, Nguyen Decl., ¶ 13,see Exhibit
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~ I•)
Le~alZoom's Prior Efforts To Resolve Matters Outside Of Court

4

C.

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In an attempt to resolve this matter amicably outside the courts, on October 13,

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2011, LegalZoom's Chairman, Brian Liu, contacted Rocket Lawyer's CEO,Dan Nye,
stating that there were "important issues that [LegalZoom's] legal department has

s brought up regarding [Rocket Lawyer's] advertising." (SS,¶ 21, Nguyen Decl., ¶ 14,
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Exhibit J, a true and correct copy ofthe email exchange between Brian Liu and Dan

io Nye, dated October 13, 2011.) Mr. Nye responded by stating that Mr. Liu should
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ii discuss this issue with Charley Moore, Rocket Lawyer's founder and Chairman, and

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copied Mr. Moore on the email exchange. (SS,¶ 22, Nguyen Decl., ¶ 14, Exhibit J.)
On October 14, 2011, Mr. Liu had a telephone conversation with Mr. Moore,

is stating that LegalZoom took issue with Rocket Lawyer's ads, which promised "Set up

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a Free LLC... Totally Free," and "100% Free," since state filing fees must always be

i6 paid when setting up an LLC through Rocket Lawyer. (SS,¶ 23, Nguyen Decl., ¶ 15,
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Exhibit K,a true and correct copy ofthe email from Brian Liu to Charley Moore,

is dated October 14, 2011.) Mr. Liu also implored Mr. Moore to read and follow the
19

Federal Trade Commission's guidelines regarding the use of the word "free" in

Zo advertising, which requires, among other things, that "all terms, conditions and
ai obligations upon which receipt and retention ofthe "Free" item are contingent should
as be set forth clearly and conspicuously at the outset ofthe offer so as to leave no
23

reasonable probability that the terms ofthe offer might be misunderstood." (SS,¶ 24,

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Nguyen Decl., ¶ 15, Exhibit K(emphasis added.) Mr. Liu requested that Rocket

Zs Lawyer immediately take down these and other misleading advertisements. (SS,¶ 25,
26
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Nguyen Decl., ¶ 15, Exhibit K.)
One month later, the misleading Rocket Lawyer advertising still had not been

as ~ changed or removed. (SS,¶ 26, Nguyen Decl., ¶ 16, Exhibit L.) Beginning
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MEMORANDUM OF POINTS AND AUTHORITIES

so7s72

i November 15, 2011, in a series of emails, Mr. Liu repeatedly requested that Rocket
2

~ Lawyer discontinue its false advertising and unfair competition practices to no avail.

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(SS,¶ 27, Nguyen Decl., ¶ 16, Exhibit L.)
~

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Thus, LegalZoom respectfully requests that this Court hold that Rocket

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~ Lawyer's advertisements constitute false advertising under the Lanham Act and false

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~ adverting and unfair competition under California law as a matter of law.
~ III.

ARGUMENT

s

A.

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Summary judgment shall be granted "if the movant shows that there is no

Legal Standard For Summary Judgment

io genuine dispute as to any material fact and the movant is entitled to judgment as a
ii matter of law." Fed. R. Civ. P. 56(a); see also Green v. Sun Life Assur. Co., 383 F.
J
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i2 Supp. 2d 1224, 1226(C.D. Cal. 2005). A "genuine issue" exits if"a reasonable jury
i3 could return a verdict for the nonmoving party" and a fact is material if it "might
is affect the outcome ofthe suit under the governing law." Anderson v. Liberty Lobby,

is

Inc., 477 U.S. 242, 248 (1986). The Court shall determine, if practicable, what

i6 material facts exist without substantial controversy. Fleener v. Trinity Broadcasting
i~ Network, 203 F. Sup. 2d 1142, 1147(C.D. Cal. 2001).
is

The initial burden is on the moving party to establish the absence of any

19

genuine issues of material fact and, thereby, establishing entitlement to judgment as a

ao matter of law. Fed. R. Civ. P. 56(c); see also Celotex Corp. v. Catrett, 477 U.S. 317,
ai 323(1986); Anderson,477 U.S. at 250. After the moving party has sustained its
22

initial burden, the nonmoving party must come forth with enough evidence to

23

demonstrate the existence of a "genuine issue" of material fact for trial. Anderson,

24

477 U.S. at 256; Fed. R. Civ. P. 56(e). The nonmoving party's burden is such that it

as must do more than simply show there is some metaphysical doubt as to the material
26

facts. Matsushita Elec. Industrial Co. v. Zenith Radio Corp., 475 U.S. 574(1986);

a~ see also Triton Energy Corp. v. Square D. Co.,68 F.3d 1216, 1221 (9th Cir. 1995)
as (providing that "[t]he mere existence of a scintilla of evidence in support ofthe
6
MEMORANDUM OF POINTS AND AUTHORITIES

so7sn

~ nonmoving party's position is not sufficient" to prevent summary judgment).
a
3
4

B.

Rocket Lawyer's Advertisements Constitute False Advertising
Under The Lanham Act

"The purpose ofthe [Lanham] Act is to insure truthfulness in advertising and to

s eliminate misrepresentations with reference to the inherent quality or characteristics
6

of another's product." Coca-Cola Co. v. Tropicana Products, Inc., 690 F.2d 312, 318
(2d Cir. 1982). The Lanham Act is designed and should be enforced to protect the

s public from deception by deterring deceivers. Monsanto Chemical Co. v. Perfect Fit
9 Products Mfg. Co., 349 F.2d 389, 395-96(2d Cir. 1965), cert. denied, 383 U.S. 942
io (1966). The Ninth Circuit too has stressed that the trial court's primary function
ii should center on making violations ofthe Lanham Act unprofitable. Maier Brewing
is Co. v. Fleischmann Distilling Corp., 390 F.2d 117(9th Cir. 1968); Playboy
13
14 I

Enterprises, Inc. v. Baccarat Clothing Co.,692 F.2d 1272, 1274(9th Cir. 1982).
To establish a false advertising claim under the Lanham Act2 a plaintiff must
,

15

show:(1)false statement offact by the defendant in a commercial advertisement

16

about its own or another's product;(2)the statement actually deceived or has the

i~ tendency to deceive a substantial segment of its audience;(3)the deception is
is material, in that it is likely to influence the purchasing decision;(4)the defendant
19

caused its false statement to enter interstate commerce; and (5)the plaintiff has been

ao or is likely to be injured as a result ofthe false statement, either by direct diversion of
ai sales from itself to defendant or by a lessening ofthe goodwill associated with its
22
23

2 Section 43(a) of the Lanham Act, codified at 15 U.S.C. § 1125(a) provides in pertinent part:
24

(a)
Any person who, on or in connection with any goods or services, or any container for goods,
uses in commerce any... false or misleading representation offact, which—
25
(A) ...

26

(B) in commercial advertising or promotion, misrepresents the nature, characteristics, qualities,
or geographic origin of his or her or another person's goods, services, or commercial activities,
27
shall be liable in a civil action by any person who believes that he or she is or is likely to be
28 damaged by such act. 15 U.S.C. § 1125(a)(1988).
7
MEMORANDUM OF POINTS AND AUTHORITIES

so7sn

i products. Southland Sod Farms v. Stover Seed Co., 108 F.3d 1134, 1139(9th Cir.
a ~ 1997).
LegalZoom can show by undisputed facts that Rocket Lawyer has engaged in

3
4

~ each element of a Lanham Act false advertising claim, and therefore is entitled to

s ~ summary judgment on this claim, as a matter of law.
1.

6

Rocket Lawyer's Advertisements are False Commercial
Advertisements

s

a.

Rocket Lawyers advertisements are literally false.

Whether a statement is literally false is a determination to be made as a matter

9

io ~ of law. Allsup, Inc. v. Advantage 2000 Consultants Inc., 428 F.3d 1135, 1138(8th
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ii ~ Cir. 2005). Therefore this determination is appropriate for summary judgment.
12

To demonstrate falsity within the meaning of the Lanham Act, a plaintiff may

i3 show that the statement was literally false, either on its face or by necessary
is implication, or that the statement was literally true, but likely to mislead or confuse

is

consumers. Southland Sod Farms v. Stover Seed Co., 108 F.3d at 1139. The test for

i6 literal falsity is simple: "if a defendant's claim is untrue, it must be deemed literally
i~ false." Castrollnc. v. Pennzoil Co.,987 F.2d 939,944(3d Cir. 1993); see also 16
is C.F.R. § 251.1 (2009)("FTC Guide Concerning The Use ofthe Word `Free' And
i9 Similar Representations")(false advertising occurs where the "free" offer is not
Zo accompanied by a sufficient disclaimer making clear that the offer is not actually
21
22

free).
As stated above, Rocket Lawyer's advertisements — "Zoom Charges $99.

23

Rocket Lawyer is Fast, Easy, &Free. Incorporate Your Business Today,"

24

"incorporate for free... pay no fees ($0),""form your LLC free at Rocket Lawyer,"

Zs "free help from local attorneys," "free legal review," and "free" trials of Rocket
26

Lawyer's "Basic Legal Plan" and "Pro Legal Plan" —are literally false. Rocket

2~

Lawyer customers cannot incorporate, form an LLC,get help from local attorneys,

zs get legal review or get trials of Rocket Lawyer's plans for "free." Rather, Rocket
s
MEMORANDUM OF POINTS AND AUTHORITIES

so~a~2

i Lawyer customers seeking to incorporate or form an LLC for "free" through Rocket
a Lawyer's services are nonetheless required to pay the state fees associated with
3

incorporation or formation, customers could access Rocket Lawyer's "free help from

4

local attorneys" and the "free legal review" only if they were paid members of

s Rocket Lawyer's "Basic Legal Plan" or "Pro Legal Plan," and customers who signed
6

up for aone-week free trial membership under Rocket Lawyer's "Basic Legal Plan"
or "Pro Legal Plan" were required to enroll in Rocket Lawyer's "negative option"

s program. See Spiegel, Inc. v. Fed. Trade Comm'n,494 F.2d 59(7th Cir. 1974)("free
.. trial" offers conditioned on customer's meeting retailer's credit criteria were not truly
free). Accordingly, Rocket Lawyer's advertisements are literally false as a matter of
law.

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b.

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Rocket Lawyers advertisements are commercial
advertisements.

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Commercial advertisements, for purposes of the Lanham Act are:(i)
commercial speech;(ii) by a defendant who is in commercial competition with

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plaintiff;(iii) for the purpose of influencing consumers to buy defendant's goods or

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services; and (iv) must be disseminated sufficiently to the relevant purchasing public
to constitute "advertising" or "promotion" within that industry. Coastal Abstract Sere.
Inc. v. FirstAm. Title Ins. Co., 173 F.3d 725, 735 (9th Cir. 1999), citing 15 U.S.C. §
1125(a)(1)(B).
(i)
Za

Commercial speech.

The Supreme Court has recognized that "expression related solely to the

23

economic interests ofthe speaker and its audience" will be considered commercial

24

speech. Oxycal Lab. v. Jeffers, 909 F. Supp. 719, 724(S.D. Cal. 1995)(citing

25

Cincinnati v. Discovery Network, 507 U.S. 410,422(1993)). Rocket Lawyer's

26

advertisements to customers and potential customers regarding the cost of Rocket

z~ Lawyer's products are purely economic in nature and therefore constitute commercial
as speech.
9
MEMORANDUM OF POINTS AND AUTHORITIES
807872

i
2

(ii)

Parties in commercial competition.

Commercial competitors, for purposes ofthe Lanham Act, are "persons

3

endeavoring to do the same thing and each offering to perform the act, furnish the

4

merchandise, or render the service better or cheaper than his rival." Summit Tech. v.

5

High-line Med. Instruments. Co., 933 F. Supp. 918,939(C.D. Cal. 1996). Since both

6

LegalZoom and Rocket Lawyer are providers of online legal products, they are in
commercial competition with each other.

s
9

(iii) Purpose of influencing customers.
To be considered a statement made "for the purpose of influencing consumers

io to buy the defendant's goods and services," the statement must propose a commercial
ii transaction. If it does not, it is not advertising and cannot be the subject of a Lanham
J
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12

Act "false advertising" claim. See, e.g., Rice v. Fox Broadcasting Co., 330 F.3d 1170,

13

1180-81 (9th Cir. 2003). Because Rocket Lawyer directs its advertisements to

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i4 individuals, families and business owners looking for affordable legal services and

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products, the purpose of its false advertisements concerning the costs of Rocket

a~

16

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Lawyer's products is to influence customers to purchase Rocket Lawyer's products.

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(iv) Dissemination sufficiently to the relevant
purchasing public.
Advertisements on the Internet have been found to be disseminated sufficiently

Zo to the relevant purchasing public for purposes ofthe Lanham Act. See Healthport,
21

563 F. Supp. 2d at 1179; see also Certain Teed Corp. v. Seattle RoofBrokers, 2010

Za WL 2640083, *5(W.D. Wash. June 28, 2010)(providing that statements on websites
23

draw interstate audience and come within the ambit ofthe Lanham Act); Thermal

24

Design, Inc. v. Guardian Bldg. Products, Inc., 2009 WL 1181327, *2(E.D. Wis. Apr.

Zs 29, 2009)(marketing materials, including those on the Internet, meet the commercial
26

advertising requirement because they are "disseminated sufficiently to the relevant

a~ purchasing public.") Since Rocket Lawyer's advertisements were on the Internet, the
2g

advertisements are disseminated sufficiently to the relevant purchasing public.
10
MEMORANDUM OF POINTS AND AUTHORITIES

so7s72

i

2.

Rocket Lawyer's Advertisements Are Presumed to Have

2

Deceived and Have the Tendency to Deceive a Substantial

3

Segment of its Audience

4

Rocket Lawyer's advertisements are likely to deceive their intended audience,

s the users of online legal help, because they are likely to cause confusion or mistake as
6

to the actual cost ofthe purportedly "free" Rocket Lawyer services. In any event, if
an advertisement is literally false, or if a defendant intentionally misleads customers,

s a presumption arises that customers were in fact deceived and the burden shifts to the
9

defendant to prove otherwise. Pom Wonderful LLC v. Coca Cola Co., 727 F. Supp.

io 2d 849, 869(C.D. Cal. 2010)(affd in part, vacated in part, remanded sub nom.Pom
ii

Wonderful LLC v. Coca-Cola Co.,679 F.3d 1170(9th Cir. 2012))("if[the defendant

12

has] intentionally misled consumers,[the court will presume that] consumers were in

13

fact deceived and [the defendant] would have the burden of demonstrating

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is otherwise"); Southland Sod Farms v. Stover Seed Co., 108 F.3d at 1146; see also The

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i6 Indus. Corp. v. Clorox Co., 140 F.3d 1175, 1180(8th Cir. 1998)("If a plaintiff proves

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l~ that a challenged claim is literally false, a court may grant relief without considering

William H. Morris Co. v. Group W, Inc., 66 F.3d 255, 258(9th Cir.1995); United

is whether the buying public was actually misled; actual consumer confusion need not
i9 be proved"); Western States Wholesale, Inc. v. Synthetic Inds., Inc., 206 F.R. D. 271,
Zo 275 (C.D. Cal. 2002)("When a plaintiff shows that the defendant's false advertising
ai was intentional, the plaintiff is entitled to a presumption that customers were
as deceived."). Since Rocket Lawyer's advertisements are literally false and Rocket
23

Lawyer was made aware of the literal falsity of its advertisements, but nonetheless

24

intentionally continued to use such false advertisements to confuse and deceive

Zs customers into believing that its products and services were somehow "free," it can be
26

presumed that customers were in fact confused and deceived. Given such legal

2~

presumption in LegalZoom's favor, LegalZoom is entitled to summary judgment on

Zs this element.
ii
MEMORANDUM OF POINTS AND AUTHORITIES
807872

i

3.

a
3
4

Rocket Lawyer's Advertisements are Materially Deceptive in
that it They Are Likely to Influence Purchasing Decisions

Whether for online legal products or other consumer products, use ofthe word
"free" is a highly effective tactic used by retailers to lure customers to their stores and

s websites. In re Samuel Stores, 27 F.T.C. 882(1938). Rocket Lawyer's use ofthe
6

term "free" in its advertising is no different. Rocket Lawyer's advertisements are
likely to cause confusion or mistake as to the true costs of Rocket Lawyer products

s and services. Given that Rocket Lawyer's products and services are directed towards
9 economical individuals and small to medium sized businesses, cost is a key factor in
io such customers' purchasing decisions. In any event, where defendant's advertising
ii claims are literally false, such false statements are presumed to be material. See POM

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Wonderful LLC v. Purely Juice, Inc., 2008 WL 4222045, *11 (C.D. Cal. July 17,

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2008)affd, 362 F. App'x 577(9th Cir. 2009)(actually false claims are presumed

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is material). Accordingly, Rocket Lawyer's advertisements are materially deceptive.
is
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4.

Rocket Lawyer Caused its False Advertisements to Enter
Interstate Commerce

An advertisement enters into interstate commerce for purposes ofthe Lanham

is Act where the advertisement is widely disseminated to the purchasing public. See
19

Gordon ~ Breach Science Publishers, Ltd. v. American Institute ofPhysics, 859 F.

ao Supp. 1521, 1535-36(S.D.N.Y. 1994)("[w]hile the advertising need not be made in a
21

`classic advertising campaign,' but may consist instead of more informal types of

22

`promotion,' the representations... must be disseminated sufficiently to the relevant

23
24

ing public....")(emphasis added).
"As both a means to engage in commerce and the method by which

Zs transactions occur, `the Internet is an instrumentality and channel of interstate
26

commerce." United States Sutcliffe, 505 F.3d 944, 953 (9th Cir. 2007)(quoting

2~

United States v. Trotter, 478 F.3d 918,921 (8th Cir. 2007)); see also Healthport

2s Corp. v. Tanita Corp. ofAmerica, 563 F. Supp. 2d at 1179, 1180-81 (providing that
12
MEMORANDUM OF POINTS AND AUTHORITIES

so~sn

statements on the Internet constitute advertisements in interstate commerce for
purposes ofthe Lanham Act). Therefore, to prove that a defendant promoted false
statements in interstate commerce,the plaintiff can show that a defendant made false
4

statements on the Internet. Del Webb Cmtys., Inc. v. Partington, 2009 WL 3053709,

s *11, *16(D. Nev. Sept. 18, 2009).
6

By placing its false advertisements on the Internet(via search engines such as
Google, Yahoo and Bing as well as on its own and other websites), Rocket Lawyer

s clearly caused its false advertisements to enter interstate commerce.
9

io
ii
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5.

Rocket Lawyer's False Advertising Caused Actual Iniury to
Le~alZoom

It is well established that "a competitor need not prove injury when suing to

is enjoin conduct that violates section 43(a)" ofthe Lanham Act. Harper House, Inc. v.

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Thomas Nelson, Inc., 889 F.2d 197, 210(9th Cir. 1989); see also Southland Sod

14

Farms v. Stover Seed Co., 108 F.3d at 1146. Indeed,"an inability to show actual

15

damages does not alone preclude recovery" and the district court may "award the

16

plaintiff any just monetary award so long as it constitutes `compensation' for the

i~ plaintiffls losses or the defendant's unjust enrichment and is not simply a `penalty for
is the defendant's conduct."' Southland Sod Farms v. Stover Seed Co., 108 F.3d at
19

ao

1146 (citations omitted).
Given that LegalZoom and Rocket Lawyer are direct competitors for online

2i legal products and Rocket Lawyer's advertisements are literally false, injury to
22
23

LegalZoom is presumed and LegalZoom is injured by Rocket Lawyer's false
,advertising as a matter of law.3

24

3 In any event, direct diversion of sales from a plaintiff to a defendant constitutes actual injury under
the Lanham Act. Southland Sod, 108 F.3d at 1139. LegalZoom has lost business and continues to
lose business caused by Rocket Lawyer's false and misleading advertisements and unfair
26 competition practices as a result of at least one customer being diverted to the Rocket Lawyer
website and/or refusing to do business with LegalZoom due to the fact that the Rocket Lawyer
27 advertisements falsely state that Rocket Lawyer offers "free" incorporation," "free" LLCs,"free
help from local attorneys," "free legal review," and "free" trials of Rocket Lawyer's "Basic Legal
28 Plan" and "Pro Legal Plan," in an amount to be determined at trial.

25

13
MEMORANDUM OF POINTS AND AUTHORITIES
807872

C.

Cal. Bus. &Prof. Code § 17500

2
3
4

Rocket Lawyer's Advertising Constitutes False Advertising Under

Because the evidence shows that LegalZoom is entitled to summary judgment
on its false advertising claim under the Lanham Act, summary judgment should

s likewise be granted on LegalZoom's false advertising claim under California's false
6

advertising law, Cal. Bus. &Prof. Code § 17500 et seq. See, e.g., J.K. Harris & Co.,
LLC v. Kassel, 253 F. Supp. 2d 1120, 1130, n.9(N.D. Cal. 2003). California's false

s' advertising law, Cal. Bus. &Prof. Code § 17500 et seq., makes advertising products
9 or services by "untrue or misleading" statements unlawful. See Brockey v. Moore, 107
io Cal. App. 4th 86,98(2003), citing Cal. Bus. &Prof. Code § 17500."Section 17500
ii has been broadly construed to proscribe `not only advertising which is false, but also

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i2 advertising which[,] although true, is either actually misleading or which has a
13

capacity, likelihood or tendency to deceive or confuse the public."' Colgan v.

is LeatheYman Tool Group, Inc., 135 Ca1.App.4th 663,679(2006), quoting Kasky v.

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i6 violation of Cal. Bus. &Prof. Code Section 17500 requires proof that:(a) defendant

f~

Nike, Inc., 27 Ca1.4th 939, 951 (2002). A claim for false or misleading advertising in

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1~ intentionally or negligently disseminated an untrue or misleading statement with an
is intent to dispose of goods or services;(b)the statement was made in California and
19

disseminated to the public in any state; and(3)the statement deceived and harmed the

20 plaintiff.
21

Rocket Lawyer, acting directly or indirectly with the intent to induce members

22

ofthe public to engage Rocket Lawyer's services and purchase Rocket Lawyer's

23

products, made or caused to be made,false and misleading statements in the state of

24

California via the Internet that Rocket Lawyer offered "free" incorporation,"free"

as LLCs,"free help from local attorneys," "free legal review" and "free" trials of Rocket
26

Lawyer's Basic Legal Plan" and "Pro Legal Plan." As stated above, these

a~ advertisements are false because customers seeking to "incorporate for free" for form
Zs an LLC for "free" through Rocket Lawyer's services are nonetheless required to pay
14
MEMORANDUM OF POINTS AND AUTHORITIES

so7sn

the state fees associated with incorporation or formation, customers can access Rocket
Lawyer's "free help from local attorneys" and the "free legal review" only if they are
paid members of Rocket Lawyer's "Basic Legal Plan" or "Pro Legal Plan," and
customers who sign up for aone-week free trial membership under Rocket Lawyer's
"Basic Legal Plan" or "Pro Legal Plan" must nonetheless enroll in Rocket Lawyer's
negative option program. Rocket Lawyer was made fully aware that its
advertisements were false and misleading and so acted in violation of Section 17500
ofthe California Business &Professions Code. Rocket Lawyer's advertising further
violates Section 17509 and Section 17600 et seq.4 in that the advertisements require,
io as a condition ofthe "free" services, the payment of state fees, the purchase of paid
li membership and/or the enrollment in a trial membership plan subject to a negative
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12

option without adequate disclosure to customers. For these reasons, Rocket Lawyer's

13

advertising constitutes false advertising under California Business &Professions

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to Code Section 17500, et seq.

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D.

Rocket Lawyer's False Advertising Constitutes Unfair Comuetition
Under Cal. Bus. &Prof. Code ~ 17200

California's unfair competition law prohibits "any unlawful, unfair or

is fraudulent business practice and unfair, deceptive, untrue or misleading advertising.
19
20
21
22
23
24
25
26
27
28

4Under California's Negative Option Law (the "California Negative Option Rule"). Cal. Bus. &
Prof. Code § 17600 et seq., an offer which includes an automatic renewal provision must include a
clear and conspicuous disclosure that:(1)the subscription will continue until the customer
terminates the contract;(2)the cancellation policy of the offer;(3)the amount of the recurring
charges that the customer's credit card will be charged, and if the amount will change, and if so, the
amount that the charge will be changed by, if known;(4)the duration ofthe automatic renewal term
or that the subscription is continuous; and (5)if there is any minimum purchase requirement. The
statute spells out the requirements of"clear and conspicuous" and provides that to qualify as "clear
and conspicuous, a disclosure must be in larger type than the surrounding text, or in contrasting
type, font or color to the surrounding text of the same size, or set offfrom the surrounding text of
the same size by symbols or other marks, in a manner that clearly calls attention to the language."
In addition, the statute requires that the customer be provided with an acknowledgement that
includes the automatic renewal or continuous service offer terms, cancellation policy and
information regarding how to cancel in a manner that is capable of being retained by the customer.
As discussed above, Rocket Lawyer's negative option disclosure appears in standard font only upon
the customer being directed to enroll in the "free trial." Accordingly, the disclosure is not clearly
and conspicuously disclosed.
MEMORANDUM OF POINTS AND AUTHORITIES

807872

i Cal. Bus. &Prof. § 17200. "An unlawful business practice within the meaning of
2

[California's unfair competition law] is one that is forbidden by law, whether civil or

3

criminal, federal, state, or municipal, statutory, regulatory, or court-made." People v.

4

Servantes, 86 Ca1.App.4th 1081, 1087(2001). Rocket Lawyer's false and misleading

s advertising practices have violated numerous aspects of California's unfair
6

competition law.
First, an "unlawful" business act or practice is an act or practice that is

s undertaken pursuant to business activity and also forbidden by law. See People v.
9

E. W.A.P., Inc., 106 Ca1.App.3d 315, 319(1980). The "unlawful" act can be any act

io or practice forbidden by civil, criminal, federal, state, municipal, statutory, regulatory
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ii or court-made law. Id. As explained above, Rocket Lawyer's false and misleading
is advertising violates the Lanham Act and the California false and misleading

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advertising law and,thus, constitutes "unlawful" conduct under California's unfair

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competition law.

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16

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Rocket Lawyer's use ofthe term "free" in the aforementioned advertisements
not only violates the Lanham Act, but also violates Section 251.1 ofthe Federal Trade

1~ Commission (the "FTC") GuideS concerning the use ofthe word "free," which
is requires, among other things, that "all terms, conditions and obligations upon which
19

receipt and retention ofthe "free" item are contingent should be set forth clearly and

Zo conspicuously at the outset ofthe offer so as to leave no reasonable probability that
21

the terms ofthe offer might be misunderstood." (Emphasis added. Consistent with

i2

the clear language ofthe "Free" Guide, the FTC has repeatedly taken enforcement

23

actions against false "free" claims with automatic renewals that are not adequately

24

disclosed at the outset of an advertisement, but are hidden in footnotes and fine print.

25
26

5 See Waul v. Circuit City Stores, Inc., WL 1535825, *7(Cal. App.July 9, 2004)
a~ (providing that the wide is an advisory ~uide.suggesting a procedure that will prevent
the use ofthe term free" from being misleading when there are terms and conditions
as that must be fulfilled before a customer can receive the "free" product or service.)
16
MEMORANDUM OF POINTS AND AUTHORITIES
so7a7z

i See, e.g., In the Matter ofProdigy Servs. Corp., 125 F.T.C. 430,434(Mar. 16, 1998)
2

(Prodigy liable for advertising "free" Internet service but failing to disclose at the

3

outset that customers would be charged if they did not cancel during the trial period);

4

In the Matter ofAmerica Online, Inc., 125 F.T.C. 403,406(Mar. 16, 1998)(same re.

5

AOL). Stated differently, all ofthe terms, conditions and obligations should appear in

6

close proximity with the offer of"free" merchandise or service. 16 C.F.R. § 251.1
(1998). For example, disclosure ofthe terms ofthe offer set forth in a footnote of an

s advertisement to which reference is made by an asterisk or other symbol placed next
9

to the offer, is not regarded as making disclosure at the outset. Id. As indicated

io above, the terms, conditions and obligations upon which receipt of Rocket Lawyer's
ii purportedly "free" services and products are contingent are not conspicuously and
,~ ~ ~

is clearly set forth at the outset ofthe offer.

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i6 the law or otherwise significantly threatens or harms competition. Cel-Tech

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Second, in cases between competitors, an act or practice is "unfair" when it

is "threatens an incipient violation of an antitrust law, or violates the policy or spirit of
one ofthose laws because its effects are comparable to or the same as a violation of

i~ Communications, Inc. v. Los Angeles Cellular, Tel. Co., 20 Ca1.4th 163, 187(1999).
is As explained above, Rocket Lawyer's false and misleading advertising has met this
19

standard —Rocket Lawyer's false and misleading advertisements aim to deceive

Zo customers in an attempt to gain a competitive advantage for Rocket Lawyer over
21

LegalZoom.

22

Third, a business act or practice is "fraudulent" if members ofthe public are

23

likely to be deceived." See Committee on Children's Television v. General Foods

24

Corp., 35 Cal.3d 197,211 (1983). Rocket Lawyer's advertisements deceive and/or

as attempt to deceive customers as to the cost of Rocket Lawyer's services and products.
26

As.explained above, such advertisements are false and misleading, and the public

a~ likely will be deceived by such advertisements.
2g ///
i~
MEMORANDUM OF POINTS AND AUTHORITIES

so7sn

i IV.

CONCLUSION

2

Rocket Lawyer's false advertising constitutes false advertising under the

3

Lanham Act and false advertising and unfair competition under California law.

4

LegalZoom, as Rocket Lawyer's direct competitor, has suffered damages as a result

s of Rocket Lawyer's false advertising. Therefore, LegalZoom respectfully requests
6

that this Court grant LegalZoom summary judgment on the liability element of its
false advertising and unfair competition claims, leaving only computation of damages

s to be determined at trial.
9

io ~ DATED: September 4, 2013
ii
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Respectfully submitted,
GLASER WEIL FINK JACOBS
HOWARD AVCHEN & SHAPIRO LLP

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By: /s/ Fred Heather
PATRICIA L. GLASER
FRED D.HEATHER
MARY ANN T. NGUYEN
Attorneys for Plaintiff
LegalZoom.com,Inc.

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17
18
19
20
21
22
23
24
25
26
27
28
18
MEMORANDUM OF POINTS AND AUTHORITIES

so7sn

i

DECLARATION OF MARY ANN T. NGUYEN

2

I, MARY ANN T. NGUYEN,declare and state as follows:

3

1.

4

I am an attorney at law duly licensed to practice before all courts ofthe

State of California and am an Associate ofthe law firm of Glaser Weil Fink Jacobs

s Howard Avchen &Shapiro LLP, attorneys of record herein for Plaintiff
6

LegalZoom.com,Inc.("LegalZoom"). I make this declaration in support of Plaintiff
LegalZoom's Motion for Summary Judgment. The facts set forth herein are true of

s my own personal knowledge, and if called upon to testify thereto, I could and would
9

io

competently do so under oath.
2.

The following is a list of corporation and limited liability company

ii (LLC)filing fees by state. As shown below, every state has a filing fee for
is corporation and LLC filings. Accordingly, Rocket Lawyer's advertisements
13

regarding "free" incorporation or LLC formation are false since state filing fees must

14

always be paid when setting up a corporation or LLC.

15
16

i~

Corp Filing
State Name

LLC Filing

Fee

Fee

is
19

Alabama

$100

$100

Zo

Alaska

$250

$250

Arkansas

$45

$45

Arizona

$60

$50

California

$100

$70

26

Colorado

$50

$50

a~

Connecticut

$250

$120

ag

Delaware

$89

$90

21

~~~
23
24

is

i9
DECLARATION OF MARY ANN T. NGUYEN
807872

Florida

$35

$100

Georgia

$100

$100

Hawaii

$75

$75

Idaho

$100

$100

Illinois

$175

$500

Indiana

$90

$90

Iowa

$20

$50

Kansas

$90

$165

e~

Kentucky

$506

$40

io

Louisiana

$75

$100

ii

Maine

$145

$175

12

Maryland

$120'

$100

13

Massachusetts

$275

$500

14

Michigan

$60

$50

~a

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Minnesota

$135

$135

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Missouri

$50

$50

i~

Mississippi

$50

$50

is

Montana

$70

$70

19

Nebraska

$60

$100

Zo

Nevada

$75

$75

ai

New Hampshire

$100

$100

F~►~

New Jersey

$125

$125

F~~

New Mexico

$100

$50

24

New York

$125

$200

Zs

North Carolina

$125

$125

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Includes $10.00 organization tax fee for 1,000 shares or less.
Includes $20.00 organization and capitalization fee.
DECLARATION OF MARY ANN T. NGUYEN

so7s72

i

$125

Ohio

$125

$125

3

Oklahoma

$50

$100

4

Oregon

$100

$100

s

Pennsylvania

$125

$125

6

Rhode Island

$230

$150

South Carolina

$110

$110

s

South Dakota

$150

$150

9

Tennessee

$100

$300

io

Texas

$300

$300

ii
o 'n.

$100

2

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North Dakota

Utah

$70

$70

is

Vermont

$125

$120

$75

$100

~~
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Virginia

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Washington

$180

$180

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Washington D.C.

$220

$220

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West Virginia

$50

$100

17

Wisconsin

$100

$130

is

Wyoming

$100

$100

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~

19

3.

On Rocket Lawyer's "About Us" webpage, Rocket Lawyer touts to

ao provide affordable legal services to individuals, families and business owners. A true
ai and correct copy of Rocket Lawyer's "About Us" webpage is attached thereto as
22
23
24

Exhibit A.
4.

At least in 2011,2012 and 2013, Rocket Lawyer advertised"Zoom

Charges $99. Rocket Lawyer is Fast,Easy, &Free. Incorporate Your Business

as Today," "free" incorporation and "free" limited liability companies(EEGs). For
26

example, Rocket Lawyer has advertised "Incorporate for Free... Pay No Fees $0,"

2~

"Incorporate Your Business at Rocket Lawyer Free,""Form Your LLC Free at

Zs Rocket Lawyer" and "Free... LLCs." A true and correct copy of Rocket Lawyer's
2i
DECLARATION OF MARY ANN T. NGUYEN
807872

i ~ advertisements containing these claims is attached hereto as Exhibit B.
z

5.

Rocket Lawyer's customers are required to pay the state fees associated

3

~ with incorporation and formation. A true and correct copy of Rocket Lawyer's state

4

~ filing options showing the state fee requirement through Rocket Lawyer's services is

5

attached hereto as Exhibit C.

6

6.

Rocket Lawyer customers who access the Rocket Lawyer link to the

"Incorporate for Free... Pay No Fees $0," "Incorporate Your Business at Rocket
s Lawyer Free,""Form Your LLC Free at Rocket Lawyer" or "Free... LLCs" do not
9

discover that they must actually pay the state filing fees until after they have accessed

io the Rocket Lawyer website, completed a "company setup" and filled out information
J
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~~
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~~
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ii relating to the "company details." Indeed, the state filing fees do not appear until
is after a customer has accessed the Rocket Lawyer website, completed a"company
i3 setup" and filled out information relating to the "company details." A true and
is correct copy of Rocket Lawyer's "Interview" for "Company Set-Up" and "Company

Q

is

-o
a ~v

16

Q
z

Details" is attached hereto as Exhibit D.
7.

At least in 2012, Rocket Lawyer advertised "Free help from local

1~ attorneys" and "Free legal review." A true and correct copy of Rocker Lawyer's
is advertisements containing these claims is attached hereto as Exhibit E.
19

8.

As provided by Rocket Lawyer's On Call Terms of Service, Rocket

Zo Lawyer's customers could access "help from local attorneys" or "legal review" for
ai 'free only if they were "Eligible Members" who had either(a) purchased three
i2

consecutive months of Rocket Lawyer's monthly Legal Plan, or(b)purchased a

23

Rocket Lawyer annual Legal Plan. A true and correct copy of Rocket Lawyer's On

24

Call Terms of Service, dated July 2012, as printed on November 27,2012, stating this

Zs requirement, is attached hereto as Exhibit F.
26
2~

9.

The paid-membership requirement for access to Rocket Lawyer's

purported "free help from local attorneys" and "free legal review" was not disclosed

as in close proximity to the advertisements on Rocket Lawyer's website. Indeed, the
a2
DECLARATION OF MARY ANN T. NGUYEN
807872

paid-membership requirement was only disclosed in Rocket Lawyer's "On Call
2

~ Terms of Service," which was accessible to customers on a separate link. See

3

~ http://www.rocketlawver.com/on-call-terms-of -service.rl.

4

10.

Rocket Lawyer subsequently changed the language of its "On Call

s Terms of Service" to provide that "Customers who enter into a one week (seven (7)
6

calendar days)free trial are eligible to receive one(1)free legal matter
consultation..." after LegalZoom filed its original Complaint. The access to "free

s help from local attorneys" and "free legal review" during a "free trial" was not
9

available before LegalZoom's filing ofthe original Complaint. True and correct

io copies of Rocket Lawyer's On Call Terms of Service, dated July 2012, as printed on
ii November 27,2012 and Rocket Lawyer's On Call Terms of Service, dated November
~ o
o'
~~

,~
~~ ~
;.~ ~,
-~

iz 2012, as printed on November 29, 2012, showing Rocket Lawyer's On Call Terms of
13

Service before service ofthe Complaint and Rocket Lawyer's On Call Terms of

is Service after service ofthe Complaint, are attached hereto as Exhibits F and G,

Q

is respectively.

~

i6

~,~

11.

As shown in Rocket Lawyer's On Call Terms of Service, dated

i~ November 2012, as printed on November 29, 2012, access to the advertised "free help
is from local attorneys" and the "free legal review" was still conditioned upon
19

customers actively enrolling in Rocket Lawyer's trial membership and providing

Zo Rocket Lawyer with their credit card information. See Exhibit G.
21

12.

At least in 2012 and 2013, Rocket Lawyer advertised on its website

as "free" trials of its "Basic Legal Plan" and "Pro Legal Plan." A true and correct copy
23

of Rocket Lawyer's advertisements containing these claims is attached hereto as

24

Exhibit H.

25

13.

However, as shown in Rocket Lawyer's "Free" Trial Enrollment Page,

26

customers who sign up for cone-week free trial membership under the "Basic Legal

2~

Plan" or "Pro Legal Plan" must first provide Rocket Lawyer with their credit card

2s information and enroll in Rocket Lawyer's "negative option" program — i.e., a
DECLARATION OF MARY ANN T. NGUYEN

so7sn

i program in which customers are automatically enrolled and billed and must contact
a Rocket Lawyer to opt out of. No further acknowledgement regarding the negative
3

option is provided. A true and correct copy of Rocket Lawyer's "Free" Trial

4

Enrollment Page is attached hereto as Exhibit I.

s
6

14.

On October 13, 2011, LegalZoom's Chairman, Brian Liu, contacted

Rocket Lawyer's CEO,Dan Nye, stating that there were "important issues that
[LegalZoom's] legal department has brought up regarding [Rocket Lawyer's]

s advertising." Dan Nye responded by stating that Liu should discuss this issue with
9

Charley Moore, Rocket Lawyer's founder and Chairman, and copied Moore on the

io email exchange. A true and correct copy of this email exchange is attached hereto as
ii Exhibit J.
,~
o
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~~
~~
~
~~
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Q

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iz

15.

On October 14, Brian Liu had a telephone conversation with Charley

i3 Moore, stating that LegalZoom took issue with Rocket Lawyer's ads, which promised
is "Set up a Free LLC... Totally Free," and "100% Free," since state filing fees must

is always be paid when setting up an LLC through Rocket Lawyer. Brian Liu also
i6 asked Charley Moore to read and follow the Federal Trade Commission's guidelines
1~ regarding the use ofthe word "free" in advertising, which requires, among other
ig things, that "all terms, conditions and obligations upon which receipt and retention of
19

the "Free" item are contingent should be set forth clearly and conspicuously at the

Zo outset ofthe offer so as to leave no reasonable probability that the terms ofthe offer
21

might be.misunderstood." This conversation was memorialized in an email from

22

Brian Liu to Charley Moore, dated October 14, 2011. A true and correct copy of this

23

email is attached hereto as Exhibit K.

Za

16.

In November 2011, Rocket Lawyer's advertising regarding "free" trials

25

and services still had not been changed or removed; as a result, beginning November

26

15, 2011, in a series of emails, Brian Liu repeatedly requested that Rocket Lawyer

a~ discontinue its false advertising and unfair competition practices. A true and correct
as copy of this email is attached hereto as Exhibit L.
DECLARATION OF MARY ANN T. NGUYEN
807872

i

I declare under penalty of perjury pursuant to the laws ofthe State of California

2 that the foregoing facts are true and correct.
3

Executed on September 4, 2013 at Los Angeles, California.

4

s

/s/ Mary Ann T. N~ven
MARY ANN T. NGUYEN

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
25
DECLARATION OF MARY ANN T. NGUYEN
807872

ExhYbit A

(87'l~ X81-0 47 yr
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Our laws were created[o pratett and empcHnrer us — as individuals,
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need because nfcastly legal fees and comple~city.
At Rocket Lays+~r, wE wanf to change things by maWng 1eg~1 services•
~fiwdable,simple and available to mare people than ewer t►efore, l'm
proud to say that welre I~en able to build a service that millions of peopCe
rely upon. Every day we spend o~rr time aid resources making it eerier for
people to gettheiegal help they need,sty they can focus on whaYs really
important --- Wking+rare oftheir famines and building Strong businesses.
Wecombine free legal documents aid free legal in~armatian writh:access to
affordable representation by licensed attorneys. With Rocket Lawyer 0~
[atl, you tan create a Alifor your family far free or incorporate a business
free from legaf'f~s.Then, because we kn~rnr there's no replacement liar
quali#ied counsel,local attorneys are here to help wt~e~ you need mare
guidance:4Vhh Rocket 1aw~r you Aever have to ga it alone.
Ourcammitmer~t tQ affordable and accessible legal services is at the hart
of everychm~ we da. Most attorneys and bar associations agree that much
can and should be done to improve access to the law by reducing post and
complexity. We incite you to try our Service end see wrhy customers like
Sean Reid say the}r're glad to have Rocke# LawyerOn Calf,
Together,we11 make tfie law work fur you.
enartey

Exhibit A, Page 26

Follow us

Oar founder,Charley 11~aore, on NBC Press Here

~~L STREET Ji1['~t1A~~ ~l~c1c~nfork ~;iu~c~

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Exhibit E, Page 45

Exhibit F

Pt~ge i ~f3

,A~rec~nent between You and Rocket i.awyer Incorporated
"I~tese Temps and Conditions are an ~grrement between you ("Eligible Member")and Racket ~;.awyer
Incarpor~t~("ItQcketI a~wyer") regarding Your use ofthe Rocket Lawyer On Calt'~("4n GaI1"}
benefits and features as yet forth belt~w. These (fin Call Terms and Can~it ons,and the
Rocic~tI.awyer.com Terms and Conditions, which covers your use oftt~e nformatian, software,
products,and services ~antained ire or availat~le through the RocketLswyer.ca~ weblike{and
together,the "Agr~ment"),constitute a legal agreement between you and Racket Lawyer regarding.
yvw access to, ar uss~ of (}n Call. inn CalI is offered to you cv~ditioned ~n gour acceptance without
modification ofthe terms,conditions,and notices cont~incd herein. Yaur trial membership oc
purchase of a Rockef Lawyer Legal Plan constitutes your acceptance and a~-eement to ali such terms,.
c4nd'[tions, and notices.
RockM Lawyer Qn Cafl~ &Legal Puns
Yda may purchase a monthly ae annual Rocket Lawyer Leal Plan, Rocket Lawyer Legal Flans may
include.certain access to Legat Information, which includes, but is not limited to,;questians,anew
articles and legal forms that ece available from time to time on the Itc~cketL~wyer cam website. for
Eligible Memt~ers(as defined below),Legal Plans may also include access to legal services from
Rocket L.awy~r C1n Cell attorneys on the temts attd conditions as described herein, You may not
~t8I15~~f t]i 85311]}r0{lY LC~BI PIBQ ~O BIiOf.I1~I ~StL~;provided, however, that certain benefits may ailaw
an Eligible Member to extend coverage to your Eligible family-Members(as defined below), ar yt~ur
designated.business.The "Effective Date" fir each Eligible Family Member shall be the date an
which the Eligible Member ofis to extend coverage to such family member.
for the purposes ofthis Agreement:
I»The term "Eligible Member":includes any individual who either(a}.purchases three t3j consecutive
months ofa Rocket Lawyer monthly Legal Plan, or (b~)gurchase~ a Rocket Lawyer annual Legal P sn.
2.f'he term "Eligible Family Member° includes:(a)an Ei gibl~ M~mbe~'s spouse or domes#iG
Partner;(b)a dependent individual under the age of25 (c)a dependent Chid,regardless cif age, who
(d)
is incapable'ofsysta nirtg employmen# by reason of meti#al or physical disability; and. dependent
individuals living in the Eligible Member's home.such as a parent or gi~ndparen. Each.Eligible
Family Member to whom you extend covergge under t?i s Agreement is considered an Eligible
Member under Un Call ar~d is bound by the terms ofthis Agreement.
3. Eligible Members have access to pre-negotiated billing rates and service commitrnent~ from a
nationwide neCwnrk of attorneys. eligible Members may receive the l~nefits described below from a
third party independent attorney or law firm ("Service Provider"), but,not from any employee or
agent of Rocket Lawyer. Rocket Lawyer does not provide legal services du~ectly. All such services
are delivemd in connection with a sepazate relationship between the Service Provider and you,to
which R~ket Lawyer is not a party. Each Service Provider is selely respc~n~ibie for the legal services
pravid~d direcCly w you, us[ng a separate attorney agreement bet~wecn you and the Service Provider.
Be~aef~ts &Features
The following services may be aysilabie at no ch$rge from your Service Provider depending on your
membership level:.
A set limitoffree consultations with a Service Provider per year;
* A set limit of ~e~al document reviews up to ten(10)Pages each:

http:/Iwww~mck~tlawyer.rtrrrJon-call-terms-vf-service.rl

Exhibit F, Page 46

11/27/ZQi2

Page 2of7

Legal documents will be eligible far review ifsuch documents mectthe 14-page
m~citnw~x r~guirement and such documents have the same font size and style as
generated by the RocketL~r~vycr.com website("Legal Doct~rnent Requirements"). ~.egaf
documents that do not meet the.Legal Document Regwrernents maybe reviewed.at the
Service Frov der's d sccsun~l r~<te
• ~tevievu ofa Simple Will for the Etigible lVlember and his ax her family, ~s well as update the
W 11 annually for free,. A Simple Will is a last will and testament completed oa the Rocket
Lawyer site distributing personal property and homesteads Ilof'i[►vOlvillg trusts, specil"tc
bequests, real cst~te, tax matters, guardianships,living wills, health care proxies ar partitions;.:
arid,
• Ass sta~xce in resolving matters with pertain government programs,such as INS and welfare,
When deemed appropriate by the Service Provider, such Service Provider may.:
wri#e letters on the:Eligible IViember's behalf(one Iett~r per legal matter upto two(2)
pages, with na limit on the number of new legal matters);
make phone colts on the Eligible Member's behalf(one phone cal} per legal matter,. with
na limit on the number ofnew teg~l matt.~rs);
p provide assistance with. small claims court matters.
Additional details aboutyaur plan coverage can be:found. by coiling 888-627'-1192 or by
visiting http:!/~vww.rocketlawyer.eom/plans-pricing.rl while fogged into your account.
Rocket Lawyer wilt ne~,otiate discounted rates ft~c certain services frgnn Service Providers and publish
such pre-negotiated rates anti services on the RocketI:awyer website ifand when available to
Eligible Members.Ifan Eligible Member engages a Service Prouider~ such Service Provider has
contracted to c}~arge na more then $125.()U per hour,or 4~°le of~the Service Provider's usual and
eustotne~ry E~ourty`rate, whichever is Brea#er,for legal care that goes beyond the benefits and features
above,
In the case ofadditional services beyond the benefits and.features listed above,including.matters
where the Sexvice Provider provides a flat rate price far then services,-other fee arrangements shall be
negotiated dimly between the user and the:Service Prodder,as needed..
Imparturrt: Service Providers rrray requere an initial retainer andfor independent reta nerl~ngagemereat
agre~merrtpriorto deliu~ry ojservices Services Providers may also require addr'tivt~41 peayrreentfor
Berta r~ services acrd ar t-vf-pvcicet e rases.
E~cciusion~ from Oa Gull
The following items are specifically excluded from the Legal Plans,and. are not t~enef is ofClr~ Csl1:
• Any action that dir~ctl~ or ind r~tly involves Rocket.Lawyer Incorporated or any of its
affiliates, directors, agents, or employees;
Any action that dire~cily ar indirectly involves any Service Provider,provided, h4weverr that a
Service Provider rnay, at its sole discretion atyd risk, represent an Eligibly Member in a matter
in which another Service Pmv Wiz'is representic►g $pother party as legal cpuz~sel;
spansore~ Legal Plans,anX action by an Eligible Ivlem~er of such Legal Plan that
• Far employer.
directly ar indir~tly involves such Eligible Member's employer sponsor,
Any matter involving the laws ofjurisdictit~ns outside ofthe Linited States or its subd visiar~s;
A~ymatter that, ~s detez~nit~ed by the Service Provider in the Seen ce Peovider's sole discretion,
is frivolous in nature or objective; or
• Any case matter or requested.service that, as determined by the Service Frovidec in the Service
Provider's sole discretion, hacks s~ut~icien~ merit to warrant pwswt.
Any 1eg~1 matter involving a violent crime_

http://www.r~ckettawyer.corn/an~call-teems-af-service.rl

Exhibit F, Page 47

1IC17/2012

Page 3 of7

Rocket Lawyer(3rr CsU and:Users, I?isclaimers
Rocket Lawyer On Call is not a lawyer referral service, insurance product arpre-paid legal service of
any kind. Rocltet Lawyer is not a law firth d does not give legal advice, filte RocketLawyer.com
website does not create an atCorney-client relationship between you and Rocket Lawyer. The
RocketLawyer cam website is an online venue that facilitates communication between.potential users
oflegal services and legal grofes~ic~nats. By using Rocket I,awycr On Gail, you acknowledge that
you are initiating contact with prospective Service Providers. any carnrnunications with Rocket
Lawyer do not create sn aitt~m~y~lient relationship with Racket Lawyer and are not subject to an
attorney's duty of~eonfidentiality. My infor~nat"con provided tan the site is not a substitute for the
advice o£an attorney.
T~ocket Lawyer dae~ hat guarantee that Eligible M~mb~rs will successfully find Legal representation
through Racket Lawyer Un CaIL Hitsng an attorney is ate important decision that should nc~t be bass+~d
solely upcfn advertisements. Service Providers may provide cer~ n information regardicag Legal
practice areas, pricing,and.ex~rience ~n their Lawyer Prafiies. The Lawyer Proles are
advertisements and you should read and interpret them as such. Rocket Lawyer does not investigate,
verify or warrant the accuracy ~fsuch information. As Mated, Service Providers are third-pazty
independent contractors who:are solely re~ible for the legal servrre provided d`erectly to yoU,not
through Rocket Lawyer, using a separate ~ttomey retainer agre~tt~eni befiuveen .you and the Service
Provider.
As with all legal situations, you shou~+d discuss any concerns yot~ may have re~,arding the teal
repres~entalon with your at#orney and get your ageement in writing. Mos[$~rvices Frcaviders
di~oura,ge the use of e-m~i! for confidential or sensitive information. The Eligible Member'rs solely
responsible for assessing the quality,integrity,and trustworchin~ss ~fall persons with whom ttie
Eligible Mcix►bcr communicates regarding his or her legal needs. Each Service Provider is solely
responsible tc~ tka~ Eligible Member for main#ainingtheattorney-client relationship and all legal
.services provitkd. ~aCh Service Provider reserves.tl~e right to make inde}~endent professicural
judgme~ais t+egarding the legal ~eprescntatia~ns. Rocket i,~rvyer has no itafluence on or invo~~emcnt in
the professional services crf the Service Providers. Igo representation is made that khe quality afthe
legal setn+ices to be perfcarmed is greater than the quality.oflegal services performed by other
atWtneys. Results ofan attorney's prior legal representation do not guarainte~e ~ similar outcome.
Rocket Lawyer Legal Plans sod Use
that Rocket Lawyer m ay establish general.guidelines regardir~~ On fall,
you ackt~ow~ledg~ and a
including without limitation, the max moan numberoffree legal services you may receive in a given
period oftime. In addition, you ~re res~onsibl~ for all expenses throned ar other actions that rn~y
occur tl~rou~h your use of(ht Call. You also acknowleci,~e and:agree that Racket Lawyer reserves the
right t~ modify or amend these general guidelines at any time,.in its sole discretion, with ar without
notice. The details car ~v~ilability of t7n Call in any state is subject.to change without notice.
Cf you are entering into this Agreement on behalfofa cocnpa~ny or other legs] entity, you represent
il~at you have the legal suthorily to bind such enti#y to these terms,in whic}~ case the terms"you" ac
„your"shad refer to such entity. If you do not have such authority or if you do not agree witk these
Teems end Ganditions, you may not sign up far ar use On Cali. If Rocket.L.~wyec discovers that you
do not have suth~rity to bold t}~ entity for which you have put+ohased the mcmbcrshig, you will be
personally responsible foe the obligations in this Agre~ernent and your Rocket Lawyer account,
including without limitation, any payment obligations. Rocket Dwyer is riot liable ~tsr anyloss or
damage resulting from avr neIiance on any ns~uct an, notice, d~u~n~ent or communica#ion,
re~onably believed by us to be genuine and delivered by an auth~riu~ed representative of your
company. Ifthere is reasonable doubt regarding the authenticciy of anysuch instruction, notice,

htipJlwww.r~cketl$wyer.camlan-call-terms-af-servr,~.tl

Exhibit F, Page 48

11/27!2012

Page 4 of'7

document, or cflmm~nicalion, we may,but are not obliged ta, require additional suthenticatian from
you. You moist immediately aleck R.oeket Lawyer'of any fraudulent, unauthori7xd, illegal, or
suspicious use ~f4n Call, or any other breach ofseccurity dr unauthorized oc illegal activity that yc~u
reasonably spspect.
Prahibiiions on Use
State and federal laws,rules,.and:regulations shad be referred to as„Laws." The co~try,state,
territory, court, or adm nistrt~t ve agency where sService Provider is licensed to practice law st►a1l be
lCiCl'CC~ I.Q 3S '~.~17I7S(~1GtlOIf n

Fitch Eligible Member can only u~the services a~aiFable ttirouGgh On Call if any such services do not
con#]ict with ar violaf~ the Taws ofthe Eligible Member's jurisdiction{s). Rocket Lawyer dogs not
intend far usersto participate in Qn Cal! if it is prohibited by the Laws ofthe Jurisdictiort(s}. Any
availability ofthe RacketLaw~rrer.c~om website and ~n Call in the 3urisd ction(s)is nit an invitatiQtt ter
offer by Rocket Lawyer to access or use the Rocketl.~wyer.com website and any services in which
Racket Lawyer user's aec~ss and urge will violate aay Laws a~the 3urisdiction(s). By using ih~
Rockcti.uwyer.com website and the Un Call,Eligible Member ~cepts soli responsibility for
confining that you or any Eligible ~'amiiy Mecnbe~'s use nr access to the Rocket LavWyer website and
4n C~11 does nt~t violate any Laws ofthe Jurisdiction(s). ~tacket Lawyer reserves the right to refuse
xi~mbcrsh p,or sus~nd ar terminate a user's accae~nt immediately and without prior notice ai our
ds~retian.
Dispute Resol+utiun By Binding Arbrtrati+nn: PLEASE READ THIS SECTI{)N CAREFULLY
AS IT AFFECTS YQUR;RIGHTS.
Mnst ~ustamer cone c.~n be resolved giiic~ely and to the customer's satisfaction by calling our
customer service deparnnent at 1 W$7T-8810947.I~ the unlikely event that our customer service
Begat tment i~ unable.to resolve s complaint you mad bave(or if Roe~Cet Lawyer has no# tin
able to resot~e ~ di~pate it has with you afEer at~emptin to do so nfurmallY),~+re +each agreeto
resolve those disputes through b r~din~ arbitration, medistiod,or small claims eourt instead of
inn courts of gegerai jurisdiction. Arhitrrraarion, wh eh is often chca~ee,faster, and less fQmwal thin a
lawsuit in cawrt, uses:a neutral arbitrator 'rnstead ofajudge orjury. Arbi tors can award the same
damages and r~iiefthat a courk can award. Also,in any arbitration under this arbitration prflvisian in
v~rhich you seek less than $75,040 in damages,Rocket Lawyer wilt pay finable attorneys' fees
shou)ci you prevail. Racket Lawyer wilt not see~C attorneys' tees from you. However,if you initiate an
~rrbitration in which you seek mare than $?5,000 in dAmages, the payment ofatt~rne~+s'fees.r~vill be
governed by the AAA rules. Any orb #ration under this Agr meet wi[1 take pace as an
ndivicNual bads; clays arbitrations and +~la~ss act~ns are not permitted.
Arbitration Agreement
Racket Lawyer and you agr~+e to arbitrate all disputes and cif ms between.us.This agreement to
arbi trate is intended to be broadly interpreted. It includes, bin is not limited ta:
• claims.arising.out ofor relating to any aspect.ofthe ralatic~nship between us, whether based in
contract,tart,statute,fraud, misrepresentation ar any aver legal th~ry;
claims that arose before this ar any prior agreement(including, brit not limited ta,claims
relating to advertising);
• claims that are currently the subject ofpurportesl class action lid t c>n in wluic6 you are oot a
meml~r ofa cetitified class, and

http://www.rtHcke~larivy~r.cum/on-call-terms-af-servic~.rl

Exhibit F, Page 49

]1/27/2012

Page 5 of7

claims that may arise after fh~ termination ofthis Agr~em~n t.
References to "Rockct Lawyer" "you", and "ets"include out respective subsidiaries, a~Iiates, agents,
employees,predecessors in interest, successors,and assigns, as well as all authorized or unauthorized
users ut beneficiaries ofservices or devices tutdec this or prior agreements between.tts.
Notwithstgnding die foregoing, either parEy may bring~ar~ individual. action in small claims court, This
arbitration agreenncnt does not preclude you from bringing issues to the attention of federal, state, or
local agencies, including, for example,the Federal Cc~rnmunica~t[ans Commission. Such agencies can,
ifthe law ailc~ws, seek relief against us an your behalf. You a~ee the#, by entering into this
Agreement yvn and Racket Lawyer are each waiving the ci~trt to a trial by jury or to participate in a
c}atss action. This Agreement evidences a tratssaction in the interstate commerce,,and thus the Federal
Arbitration Act governs the interp~ on and enf+~rcement ofthis provision. This arbitration
provision shall survive termination ofthis A~emerrt,
A patty:who intends to seelr arl~ tm~on nnust first send #o the other, by certified mail, a written Notice
Notes to Rocketsawyer should be addressed to General Counsel,Rocket
ofDispute {'T+Totice").
Lawyer Inc~rporaied, 1~2 Howard Street #830,Sin Francisco, CA 14105("Notice Address"). The
Notice must(s}describe the nature and basis ofthe claim or disputre; $nd {b} set.forth the specific
reliefsought("Demand" ,Tf Rocket Lawyer and you do not teach an agreement to resolve the claim
within si7cty(60~ calendar days after the Notice is received, you or Racket Lawyer may commence an
arbiUatian proceeding. During the arbitration, the amount ofany settlement o 'er made by Rocket
Lawyer ter you shall not be disclosed to #~e arbi#ratar until aver the arbitrator determines the amount,
Rfar~y, to which you or Rocket I.Kwyer is entitled,
T'he arbitration ►will be govtm~ by the Commercial Arbitraiic~n Riles and the Supplementary
P'racedures for CansumEr Related Disputes {catlectively,"AAA Rules")ofthe American Arbitration
Association("AAA"),a$ modified by this Agreement, and will be admiunistered by the AAA,The
AAA Rules ace availably anlin~ at adr.€rrg, by calling the AAA at 1-8t}U-778-7879, or by writing to
the Notice Aridness. The arbitrator is bound by the terms ofthis Agr~ment.ill issues are for the
arbitrator to decide, including,lout not lima ted tc~, issues relating t4 the scope= enforce~biiity,ai~td
arbitrabiiity oft}►e arbitratiop provision. Unless Rocket Lawyer and you agree otherwise, any
arbitration heazings will #eke place in a reasonably convenient location for both parties with due
cons deeaca~taon Qftheir ability to tcaYel and other pertiner►t circ~mst~nc~. if d~~ parties are unable to
agree on a location,the de#ermination shall be made by AAA,Ifyour cla nx is for $lO,QUQ orless,we
a~+e that you.may chcaose whether the arbitration will be conducted solely an the basis ofdocuments
submitted to the arbitrator, through a telephonic hearing,or by an in-persa~ hearing as established by
the AAA Rules. If your claim.exceeds $1U,0{lU,the right to a hearing will be de arm nod by the AAA
Rules.Regardless ofthe manner in which the orb Uration, is conducted,fire arbitrator shall issue a
reasoned written decision sufficient to explain the esaent al findings gnd conclusions on which the;
award is bossed.Rocket Lawyer will pay all t~AA filing, administration, and azbitz~tor fees for any
a~itr~tion initiated in s~ccordance with the AAA Rules. However,if you in ti~a~ce an arbitration in
which tau seek mere than ~7S,OOQ in damages,the payment of these fees will he governed by the
AAA rules.
The arbitr~tur may make rulings and resolve disputes as to the payment and reimbursement offees
and.eupenses at any time ding the proceed'mg and upon r~uest &am eithex party made witt %n 14
days ofthe:arbit~atot's ruling on the,merits,
The arbitrator may award declaratory or injuncgve reliefonly in fever ofthe individual parry seeking
relief and.only to the extent nec~ss~ry Ua provide relief warranted by #hat party`s individual claim.
Y4U AN13 ROCKET LAWYER AGREE THAT EACH MAY BRING CLAIMS AGAINST

http:!/ww~r.rocketlawyer.com/on-call-terms-ofservice.rl

Exhibit F, Page 50

1I/27/2U12

Page6 of'7

SHE OTHER O~1I.Y IN YOUi~ UR ITS INDIVIDUAL CAPACITY,AND NAT A,S A
PLAlNTTFF'UR CLASS 14~14BER IN ANY PURPORTED CLASS OR RE~'RESENTATIVE
FROCEEDll1tG. Further, unless both you and Rocket Lawyer agree otherwise,the arbitrator may not
consolidate more tk~an one person's claims, and may not otherwise preside t~ver any form ofa
representative or class prcxeeding. If this specific provision is fouttd tp be unenfprceable, then the
entirety of this arbitration provision shall t~ mull and void.
Nahvithstariding any provision in this Agreement[o the c,~mtt~y we agree that ifRocket Lawyer
.
mikes and fut~nre change.to this arbitxa~ on provis are {ether Chahar►► a change to the ~1a~ic~ Address)
during your embership> You may reject any such:change by sending us written notice within thirty
(30)calertd~rr days ofthe change to the ArbiVation l~iotice Address provided above. By rejecting any
future change, you are agreeing that yot~ will arbi#r~te aany dispute be#ween us in accordance with the
lattguse of this provision.
Further, notwithstanding anything to the c~niracy,in the case of any conf] ct between any okher terms
and conditions of your use ofarty Racket Lawyer websiCe or service,the Germs and conditions ofthis
Agreement shall prevail.
Eligible Members and .~,ezv ce Frovitters:

Eligible ivlembers have the right tea file a cocnplaixrt with his or her state's bar assaciatia n c€rncern ng
the conduct of a Service Provider.
Disclosures and. Na#ices
Internal Revenue Service ITRS)Cire~lar 230 Ta~c Advice I7isclosur~
Td insure cotnplzance with requ rernems imposed by itte FRS under Circular 2311, we inform you that
any U.S. fcc3cral ta~c advice contained in any cornmtimcaton from Rocket Lawyer(including
information provided by a S~rvice.Prov der offering.~ free cansultataan)is and was not intended or
written to be rased, and.. cannot be used, fog the purpose of{1)~voit~ing ~nalties under the internal
Revenue Code ur(2}promoting, marketing,ar recommending #o anotk~er pasty any mars addressed
th~tein.
If you aze a resident ofFlorida click here
Copyright and #rademark notices
All contents oftlae RacketLawyer.cam website are Copyright ~ ~U12 Rocket Lawyer Incor~rated
andCar its suppliers, affi~ates and partners. Ali rights reserved.

Trademarks
Rocket.La~ryer~" and RocleetLawyer.com~'' are trademarks and Rocket Dwyer l~n Calt~ is a
registered trademazk ofRacket Lawyer Inc~rp~ora~ted. The names ofactual companies and products
mentioned beret» maybe the trademarks oftheir re~pcctive owners

httpJ/www.rocketlawyer.cam/on-~a11-temts-af-service.rl

Exhibit F, Page 51

11/27/2012

Page 7 of7

Notices and proce~ar~e f~rr making claims.ofcvpyrigif infr ngeme~it
Pursuantto Title 17x United States Code,'sec#':on 512(c)(2), notifications of c~aimmed copyright.
infringement under United States copyright law should be sent to Service Pnnvicicr"s Designated
Agent. ALL INQUIRIES NOT RELEVANT'TU '~'HE ABOVE pROCEL}UIt~ WILL RECEIVE NO
1~ESPCINSE.
~'or more informateon,please review our Terms and conditions, PrivacyPolicy, and.our FAQ.Sec~ic~n

Ju[y.201.2
Close

http.!/www.r~ke#tawyer~cam/on-call-temas-of-sservi~c.rl

Exhibit F, Page 52

ll/2fi/~012

E►bit +G

Page l of7

A~re~mentbetty a.Yuu aid ~tock~t Dwyer Iac~rpa»ted
cnt("A~rP+>ment'*1 betw~n you ("F,Iigible Membear'~j end
These Teams and Conditions are an
ofthe Racket Law}rcr art ill
("Rocket Y,avvy~r"j regarciu~ your
Rocket Dwyer Incorporated
features as set Earth below. These(7n Cai!TGnns and Condi~ians, and t}
t"On Call,'°} benefits and
RocketLawy~r cam Teas, d Conditions. whicE~ covers your use ofthe ~nformaticrn, software,
products,and services contained in or available trough the R+~cketLawyer.com website(aad
.g
together,the "Agreement"),.+constitute alegal.agreement between you and Rockef ~.awyer
ofthe
access ~,ar use offln CaZI. Oi► ~sll is offe~-eci to you conditiane4i on your a
your
terms, conditicans, and noiices co~tancd kcreim. Your trial membtrslug or purchase ofa ~tncket
merit to alt such terms,cc~nciit ons, and
~wy~r Legal Pfau consti~uces your a«~pcar~e and ~
notices. TheseTeens and Ct~nditions contain a d svute r+c~lutirnn rrrc~vision that i~cfucies arbitzai an
aid that tnay at~ctyyaur rights. Please read this entire Agreenae~ ~~rrefuily.
~tacket.Lawyer Oa Cam& Uegat dams
Yau may purc~~ase a mthly nr annual Itcxcket Lawyer Legal Flan: Rocket I,~rr~ycr Legal Plans may
include certain access to L,ega1 Information, v►rhich inclades, but is no#limited to, questions, swets
rtuticies and Jegal farnis that are acv Table from time to time- on the RocketLawyer.com website. For
Eligible Members(as defined below), Legal Plans may also include. access to Iepal services from
Racket Lawyer On Cali attorneys en the:t~ern~s and conditions as described herein. You m~~ not
transfer or assign your Legal Plan to angther party;provided, however, that certain l~nefit~ may allow
an E~tgible Member to ~Cend Cov~ra~~ to your Eligible Faznily Members(as defused below), or your
d~signatcd business. The "Effective Tate" for cash Eligible Family Member shall. be the date an
wvhicb the Eligible Member elects tc~ extend coverage to such faxriily member,
For the purposes offlue agreement:
Les~_Plan.
1. Trie tern "Eligible Membea"inalud~s any castoEner who p~uchas~s a Rocket~L~a
C'~stomers who enter into a one week (seven f7)calendar daysl free trial are eligible to receive ore
~1)free legal matt~.,cansultatian, as described below.
2. The term "Et gable Family Member"includes:(a)an Eligible Members spouse ar dnmcstia partner;
(b} a dependent individual under the age of25;~G~ S ~G~ClAd ~~11~(~, regardless cifape,vrho is
incapable ofsustaining employment by reast~n ofinentat 8r physical disability, and(d}dependent
individuals living irrthe Eligible Member's home such as ~ parent or grandgaren~ Each Eligible
Family Member to whom you.e~ctend coverage under this Agreern~ntis considered an ~ligihl~.
Mc~rab~r under 4n Call and is ba~tnd by the terms ofthis Agreement.
3. Eligible Members may have acce~ to pre-anegatiated billing rats and service comimitments from a
eat ~nw d~ network of attorneys, Elig~'ble Members may re~~ive the benefits described f~elo~v from.a
third parry independent aCtazney ar taw fisrn("Service Provide~'~, but,not from.any employee Qr
:Rocket Lawyer. Ro~lcet Lawyer does not provide legal services directly. All such services
agent of
one delivered in con~►►cction wwith a separate relationship between the S~+'u e Provider anti you,to
which Rocket Lawyer i~ not a party. Each Service Provider is sadely r~sspansible fnr the legal services
pmvidcd direckly to you,using a separate attorney engagement agaeement between:you and the
Service Provider. You aclmowled~►e that the.services t~rovided vwill be limited to your specific reau~s#
and bas~e~i nn.tt~e iu rmation you pm~~de~r~ S
Pry
. Eu~the~,You understand that any
information ox advice provided by the Service Provider does nit c~n~suw~c a ~uardntee of succcess u►
your l~gat s~tuataon.

http ilwww.r~cketlawyer.com/on-call-terms-of-se~vice.r~

Exhibit G, Page 53

il/29/2f11

Page 2 cif7

The follov~ing services tn~►y' be available at no chazge from your Seivtc~ Pzc~vit~t':
A setlimit.offi~ee legal matter consultations up to thirty 13t~1 minutes for.~ach new legal metier
with a Service Provider per yr,~r;
A set Iimit oflegal documentreview consultations for comgie#e documents ug to xen(1Q~ des
in len~t~ each:
Legal documez►ts will be eligible fc~r review if such docum~nt~ meet the 10-g~ige
m~cimum requirement and such documents bavc the sanne font size and ~tyie as
generated by the RockeiLawyer.cvm we~site("I,eg~ Documezrt R~equirennents"~. Legal.
dacuimme7nts that do not meet the Lega~I I?ocurnent RegaYirements may be.~vewed at the
Service Provider's discounted rate,
Review of a Supple Will for ~e Elig hie Member and h%s ar hec family; A 5irnplc Will is a Iasi
r~rill at~d t~cstamcnt ~ornplet+ad on the Rocket Lawyer site distributing personal property and
homestead, got involving gusts,specific beq~tcsts, real estate,talc mat eFs, guardianships, living
wills, health care dies or p~rtitioras,and,
Atthe Service Providers discre#ion,such Service ~vider'~nay:
(one l~eiter up La two(~)pages)
write lett+~rs on the ~ligtbfe 111lembcr's behalf

P snake phone calls on the Eligible Member's behalf(vne pt~une caul.
• provide:assistance with small cl$ ms court matters and resc~ vzng ~$tters with ceartain
gavernm~nt programs,such asINS and w~:l~ar~
Rocket Lawyer will n~~ottate discounted rates for.certain ~rviccs from Sery r~ Providers anc~ publish
such gre-negotiated ra#es and..services an-the Bucket Law}r~r websetc,ifand whey ~vailabl~ to
Etigibia Mc~ubc~~. Flat rite services may be available in select sates. but aze zit g~earanteed in any
market,Ifan El%g~ible Mea~oer tires a 5~n~e !'mv der,such.~~ce Yrovi~ier had co ctect
benefits anrd feat~ucs above.
charge the=pre-negoti~tcd rsxe for legal services that ga laeyand
17~er~nciin~ on the matter this i~lgy.b~ aflatr3t~ ~r where $~url~ rat~s~pl~r~ m~t~e than ~125,UU per
;
~
hour,or 4U'!o vffthe Service Provider`s usual and cusWmary hourly rate, whichever is greater,.
Tfan Eli~ibie Mere is ns~~lis~~ v►~th ~.Senc cue Psa~ider,..s
alt~rn~~ive Servile Par~vider *+rip
.L,a ~ Direr

-.

A~ma~~ ~cl+ect sn

t?tt~er fee arrangements shall be negotiated directly between the.u~r Anr1 the ~P~Fravidex,as
needed..

,Impar~tur~t: Service Providers »gay require an initial retainer and/or separate attorney engagement
agreementprior to delivery ofservices Setviaes Prnvirlers may also regrtire additionalp~rymerttfor
certvin services atut out-nf-pocket expenses.
Ez~tasion~ from (?n Call
T~~ fallowing tins are specifically e~cclud«I from the Legal Pions, ar~d are not benefits ofOn Cell:
• Any action that directly or indirec#!y involvesRocket Lawyer Tncorpt~rate~ Qr any ofits
affiliates, directors, agents, or employees;.
• ~y action ihat.direcfly cn indirrecctly ,naives any. Serviicc Provider;provided, however, that.a
Service Pr+avider may,at its sole discretion and risk,.represent an Eligsble Member in a matter
in which another Service Pra~vider is repiescntang another parky_.as Iegal coeuYscl
• Uegal matters in which.~ Program Sponsor t~fthe Eligible Member in question teas an adverse
~nter~~, c r is w~ic~ a~ay clir~ctor,.affic~r went or empt~y~eetbereaf hay an adverse nteres~..Fs~z

http:/lwww,roGketlawyer.ca~lon-coil-terms-ofservice.rl

11/29012
Exhibit G, Page 54

Page 3 of7

the nurp s ofthis provision."Pra~ram S~nsnt'r is any.cvmpanyE or~ani on or aff~iation
ha~ea on behalfof its members a Rocket. Lawyer Legal plan through wholesale
"that
cf~nnels,retail c~atine~ls or otherwise:
• Any mattcr invoivin~ the Iaws ofjurisdicxions a~tside oftth~ United Stags or its seibdiv suns;
• Any matter that, as dcterrmined 6y the Service Provider in the Service Provider's sale discretion,
in n~t~tre ar objective;
is frivol
•
matter or requested service thai, as determined by the Service Provider in the Service
Provider's sote discretion, licks s cent merit to warrant puestut, or that has tx~en zaised an
excessive ar unreasonable number oftimes without a change ire circumstances;
• AtY~+T+Tega1 nrxaUer involving a~ alleged violent crjme,
• Any matter fot which the Eligible Member is currently represented by otherlegal rowasel.
Racket Dwyer Oa Gall and Usars; D s

i~uaers

Rocket Lawyer Ou Colt is not a lawyer referral service,insurance pradu+~t or pre-gold legal service of
any kind. Rocket Lawyer is not ~ Iaw frr~n aid does na#give Legal advice. The RocketLawyer.com
wehsite does not create an attorney-client relation p between you and Rocket Lawyer. The
Rr~cketLawyer cu~n website is an online venue that fa;~ilita~es caammunication.between potential users
oflegal services and l al professionals. By using Rocket Lawyer(hy Coil, you acknowledge that
yvu arc initiating contact with pc~spective Service Prvviders..Any communica~tians with Rocket
Lawyer do not create an attorney-client relationship with Root Dwyer and ate not subject to an
attorney's duty ofconfidentiality. Any infonAaatio~ provided an tt~ site is not a substitute for the
advxc+e of a~n attorney.
Kocl~et Lawyer does not guarantee that Eligihtc Members will successfully fnd legal represcntat~+~n
through docket Lawyer On Call. Hiring an attorney is an important decision that should not be based
solely upon advicertisements. Service Froviders may provide certain information regarding legal
practice areas,pricing, and ex~riience on thezr Lawyer Profiles, Thy Lawyer profiles are
advertisements and you shonid read and interpret them as such.. Rocket ~.awyer does not urvestigate,
verify ar warrant the accuracy ofsuch infornYabion. As sta#ed,Service PrEaviders are third-patty
independent cimtracta~rs who are solely responsible far the legal service ptnvided directly to you,nit
through Rocket Lawyer, using a separate attore~y engagement agreement betweca you end the
Service Provider.
r'~s with a111ega1 situtations, you should discuss any concerns you may have regarding the legal
representation with.your attorney and get the casts and scope of your agrecmeni for legal
reor entatian in writing. Most Services Providers discoura~c tht us+~ of e-mail foz confidential or
sensitive information.. The Eligible Member is solely resp~ansible for assessing the quality, uxt~~gtity,
and trustworthiness of all persons with whom the Eligible Memrtaer co~nrn~micates regarding his ar her
legal. neecLs. Each Service Provider is solely re risible to the Eligible Member for maiaann~taining the
attorney-client relationship and all legal services provided. E~h Service Provider reserves the right
w Make independent pzofessional j~gments regarding the legal representations. Rocket Lawa+cr has
no influence can or invalvemerit in the professional services ofthe Service Proviclerrs. No
representation is made that the quality ofthe legal services tv be performed is greater than the quality
oflegal services porfartncd by otter attorneys. Results ofan attorney's prior legal repr~sentatic~n do
not guarantee a similar outcome,
Rocket Lawyer

!Plans snd Use

You acl~owledge and agree that Rocket Lawyer may establish general.guideEines regarding C}n Call,
including wit~~ut limitation,the maximum number offree legal services you may receive in a given
period oftime. In addition, you_are responsible for all ewes incurred or otter actions tE~at may

ht#p:Nv~rww.rocketlawyer.corn/an-colt-temss-af-service.xl

11129/2012
Exhibit G, Page 55

Pie 4 of7

oc:~ur t~raugh your use ofQn ~a1L Yau atso acknowledge and agrees that Ftock~t Lawyer res~rrves tie
right to modify Qr amend these.general.. guider'tries at any time,inits sole discretion, with-or withotrt
notice. The details or availability vf~Un ~a11 in any sttate is subj~t to change without noire,
Yf you gre entering intio this.~,greement ou t~halfof a comity or other legal entity> Yau represent..
tbet you have #hc legal authority to bind such entity to these teams,in which case the terms "you" err
"yt~ur" sh~li refer to such entity. If you.do not hav+~ such authority ar if you do not agree with hcsc
'Terms and Conditian~, you may not siga~ up for or use 4n Call. I~Racket Lawyer discovers that ynu
do not have authority to bird the eniity for wltich yc~u have pu~ch~sed the. membership,Yqu will b~
personally responsible for the obligations is thus Agre~mernt and your Rocket Lawyer ac~uc~~,
nc udiug without lira tatioc~, anY P~Y~~nt obligations. Rocket Lawyer'is nit liable for any 1as~ ar
~a~xiage resviting h+~m our rel~nr.~ on any imstructit~n,notice,docwn~nt or communication,
reasonably bclicvcd by us to be genuine anti delivered by an aud~ori d repre~se~tative ofyour
company. Ifthtrc is reasonable doubt regarding the authenticity ofany such instruction, notice,
dacutne~.t,err t~mmun cation, we may,but arc not o6t gcd to, require additional authentication from.
you. You musti~unediatexy alert Rocket T,awyer of~ny fi~udulent, unauthorized,i11eg~1, or
suspicious u se off'An Call, ar amy other breach of~caurity or unauih[~r zed or illegal ~,ctiviry that you
reasonabl~r suspect.
Prohibitions on L1ae
Staff sad federal laws, n71es, and r~g~ila~iuns shall be referred to as "Laws." `~'he cau~try, state,
tear tary,court, ar a~ninistrative agency where a Services Provider is licensed to practice I~w shall be
referrcxi to as ~]urisdic~ian."
Each Eligible Member can only use the services available through.Un Coil ifany such services c~a not
conflict with or violate the Laws ofthe Eligible'Member's Jtuisdiction(s). Rocket Lawyer does not
int~nrl far use to paitic~ipa~t~ in On Ct~II of t is prohibited by t ie Laws ofthe Jurisdictian(s}. Any
availability ofthh~ RocketLawyer.com wehsite and On Call.in the Iurisdict on(s}is not acs invitation or
offer by Rocket Lawyer to access or use tic RacketI.Rwyet.corn vvehsite and any services in which
Rocket Lawyer' users access amd usage wail violate any Laws oft3io 7u~isdic#ion(s}. By using the
Ro~kctLawyer.cam wcbsite and ft~e Qn Call,Eligible Member accepts sole responsibility for
confiriming that you or any Eligible F~nily Member's use ar mess to the Rocket Lawyer website and
Un Call does aot violate atay Laws oftha Jurisdictiomts~. Rooker Lavryez reserves the right to reit~se
mefnbership,or suspend ar terniinate a user's account immediately and without prior notice apt our
dscr~tiurr.
Di~spn#e Rrsalution By Binding Arbitration:PLEASE READ THIS SECT`IQN CAREFULLY
AS IT AF~+ECTS YOUR RIGHTS.
Most customer concerns aan be resolved qui~kty arni to the customer's fat sfaGtion by calling our
customer service depa~trnent at 1-877=$$1-0447.In the unliluely event that our cos#~mer service
department is unable to resolvescamplamt you may Gave(or ii Rac~Cet La~ryer has riot ~cn
able to resohwe a dispute ii Eras with.you ~ftier a#tempt rig to do so informa►ll~'), we each agree to
solve thane dispates t~rougti b udiag arbitration, miediption or small claims court instend ~f
courts of gc~erxl jurisdiction. Arbitration, which is of~n caper,faster,.and less format than a
lawsuit is courts uses a neutral arbitrator instead ofajudge or JvrY. Arbihatots can award the same
damages and reliaf that a court c:an award. Also,in any arbitration under this arbitt~tion provision in
which you seek less then ~75,QOQ in damages, Racket Lawyer will pay reasonable attorn~s° fees
shoutd you prevail.. Rocket Lavryer will not.seek attazn~eys' feesfrom you. However,if you initiate an
arbirtratior~ in which you seek more than S75,t?4U sn damages,the payment ofattameys'fees will be

http;~/www.rocketlawyer.ramlan-call-terms-of-scrvice.rl

Exhibit G, Page 56

11(29/2012

Pagc 5 of7

:governed by tkae;A.AA rules. Aay ~rbitrat~n under this Agr~em~ent hill take p]acc an ~n
i~dividosl bssa; cta8s ar6itrR#ions and;cl~ss actiuus are no# p~rua~tcd.
Arbitration Ag~teernent
Rocket I.ac~rer and you agree to arbi~atz all d~sput~ and clafms between us. This agreement..to
erbitratc is intended to be broadly interpr~tcd. It includes, bud is not limited ta:
• claims arising aut ofor r~l~t ng to anY aspect oft~ lati~ns6ip between us, whether based in
contract,tort, statute,£gaud, misrepresentation or any otherlc~al theory;
• claims that arose hcforc this pr a~sy prior agreement{including,but not;liinited to,;claims
xelating tv advertising);
clauns that are eurresntty the subject ofpurgart~d ~Iaiss action litigation in wtuch you are riot a
merabet ofa certified class; and
• clainc~ thhat may arise after the termination ofthis Agreement
Re#'erences to "Rocket Lawry~r","you"',and "us" include oux zespectiv~ subsidiaries,affiliates, ageriits,
emplaye~s, pred~cesstrrs in interest,successors, aad assigns,~ we#1 as all authorized or=unauthorized
users oz b~aeficisries ofs~cv ces or devic+r~ under this or prior dents between us.
Notwithstandjng the foregoing, either pity may bring an indiv club action in small claims cc~eurt. l~r s
arbitration agreement does not greclu~e you from bringing issues to #h~ ~Ct~ntion offederal, s~tatc, or
lc~c~l agencies,including,for example,the Fedctal Cammw~iicatians Cvxnm~ssio~x ~au~~ ~~~aci+es can,
i the law alloy ,Lek relief against us on your bch~f. You agree that, by entering inia this
Agr went,You and RockeC I.awycr arc each waiving the right to a trial by]~Y or to part cip~#e in a
Mass:action. This Agzeementevidences a transaction in the int~:rstat~ commerce,and thus the F~det~l
A~rkr tratiQn Act governs the interpretation and enfarceme~t ofthis provision, This arbitration
provision shall survive termination of this Agreement.
4 party who intends to seek arbitration must first sc~ to the othct, by certified mail,a wxii~en 1~Iotice
ofY7ispute("Notice"). Tie Notice to Rocket Lawyer sh€~uld be as~dressed to Geh l Counsel,Racket
Lawyer Incarporatec~, 18~ Hov~ard Stmt#830,San Franc spa,~A 94It?5 ("1+Iotice Address") The.
nature:and. basis ctfthe claim ar eli te; aid(b)yet forth the specific
Notice must(a)describe
reliefsoug6t("Deanand"),IfRocket Lawyer and you do riot reach sn a~ree~nent tc~ resolve the clar`~m
within sixty(60)calendar days after the Notice isreceivecl you or Racket Lawyer may c4anamer an
arbitration prayed ng.D~iuin~; the arbitration, the aruount ofany settlern~ant a~fer made by ~€ocket
Lawyer car you shall anoi be d s~lo~ed to the ~rbitrafor until after the arbitrator determines the aznount,
ifanyy to which ~ou (1r RbCketLawyer is ertt tlttl.
The arbitration will be governed by t~ Co~nmezcial Arbitra~on Rules and the Supplementazy
P'ro~edures for Cansurner Related' Disputes(collec~valy,".4AA 1~u[es")ofthe American Airbitration
Association{"AAA"), modified.b~ this Agreement,and wviii be ad~n mistened by the AAA.The
at l-80U-778-7879,or by writing.to
AAA Rules arG available online at adr.org, by calling the
araitrator is hound..by tt~e ternas ofthis Agree~en~ All issues arc for the
the Notice Address, The
arbitrator to decide, including, but nitlimited to,issues relating to the scope, enforceability,and
azbi~biIa~ty ofthe orb ~aiion pravxsivu. Unless Rt~l~et l awyer and you agree-,otherwise, sub'
arbitration heazings will take glace in a reasonably canv~nient location for both parties with due
consideration oftheir ability to travel and other pertinent circu~nstarnces. Ifthe pazt es arc unable to
agrac an a location,the deteriaination shall be made by AAA.If yc~ut claim is for $10,000 or less, we
tratian will be conducted sally vn the basis ofdocuments
agtc~ that you may choose whether the
submitted to the arbitrator, through ~ telephonic hearing, yr by as in-p~rs~~ bearing as established by
the AAA Rules. lfyaur alarm exceeds S]O,OOQ,the right to a hears'ng will be determined by the 1~AA
Rotes. Regazdless ofthe manner m which floe arb~trativa is ctsnd~ucted, the arbitrator shall issue a

http://rvww.rocket~awyercc~m/on-call-terms-af-servicre.rl

Exhibit G, Page 57

11/912412

Page b of7

rc~soncd wriritten decision $uffici~nt to eacpla a t~~ essential findings ~trd c4ncltuiflns on which #ht>
.award is bas+ed~ Rockc# I.2~wy~r will PaY all AAA filing,administration,~nnd arbitrator fees fnr y
~dancc wiCh the E#AA Itul~s. Haw~ver~ i#'yna uutiate an arbitr~tivn in
arbitration iluiiated in
which you saek more thin X75 0~0 isr damages,tie paymtxrt of~ese fees will be governed.by ate
t'~1A rules.
The arb h~tor may make pilings alad resolve disputes as to the payment d re mbu rn~nt offees
:and expenses at an'y time during the procecd%ng az~d ugo~request Gom either p~rtiy' made within 14
days of the arbiteator's ruling on the merits.
'Y`he arGitratar may a~vatd decla~at~try or inju~cfi~ue relief only in favor ofthe individual party seekrng
P~'h'~s ind vi€lual Grim.
relief and only to the e~eat necessary to provide ~re~ief warr~fxxi by
RQC~ET LAWYEit AGREE THAT EACH MAY BRII~FG CLAIMS AGAINST
Y(?U AND
THE +~'TI~R C?NLY IN YUiIR (~1t YT5 ~iDN1DUAL CAPACITY,ANl? NUT AS A
FL~AINTIFF OR CLASS MEMBER IN ANY PL~RpORTED CLASS QR REPRESENTATIVE
FR~CEEbING.Further, mess both you and Rocket Y~awyer agree otherwise, the arbitrator may not
conso3idat~ mope thazt o~ ~xsoa's claims, and may nit otherwise preside averany form ofa
zepc'esent~tive or class proc,~edin8.IftEus specific grQviseon is found to b~ un~nforccabt~c,then the
~ntirr~~ty ofthis arbitcati+an provision sFtal~ be null aad void
Not~wv~ thstai►din8 ~Y Provision in this A~neememt to the cantraary, we agree thy# ifdocket Lawyer
a~aztge to this arbitration provision (other than a change t~ the 1V~tic~ Address)
makes slay fry
during year Mernbers~►ip, Yau y rejPcs arty sr~cl~ c}aange by sending us writ~,en notice ~vithiii4 t1~inY
(30)callendar days of tht change.W the Arbitration Notice Address pravid~d above.By zejectittg any
.future charge, you are agreeing that you will srbitraie any dispute between us in aceordan+ce with the
language ofthis gtavision.
Further, notwithstandi~rg an~i~ng to the coni~ary,in the case ofany conflict betvv~en and other terns
and ccmdiiions ofyour use ofany pocket Lawyer website or service, the ternls.snd conditions of this
Ageement sbali prevail.
Eli~ibl~

embers attd Service Providers:

utes between Eligible Merrtbers and Service Providers. Foible
~orket Lawyer does ns~t ~c~tl~~v
Me~nabers ma~aotifv Rocket Lawyer if you believe a Service Prov dex has'violated these t}n tali
Tez~ns and Conditions., eligible Members alp leave the right t~ ~i~e a complaint with your sta#e's tsar
`assocla~un canceming the condeict o~a Service ~ravider.
Il►isc~osnres and No~ie~s
Intecna~ Revcziue Sec~ic~ {TRS} Circular 23Q Tax Ad~i~e Dsciast~re.
Ta ensnare compliance with requia~ements im~o~d by the.IRS under circular Z34,we inform you.thaC
any U.S.. ~C[~l8~ ~"AX 8t~V1C~ COII#31ACd iD 2I1x fAffiII1U111C~IlUA ~TO[A RO~CICCt LAWyt'1'~lIIG~Ut~iII~
information provided h~ a Service Pravider afferiag a free cons~iltation)is and was ao~ imended ar
si of(I}avoiding penalties under the Internal
wrii#en to be used,and cannot be usced,for the p
Revcnu~e Code or(2)promoting.inarketin~, or recommend rig to ~noth~r party any matters addressed
therein.

I~129f2pI

http:Nwww.t`acketlawyer.cum/an-call-terms-of-s~rv~e.r1
Exhibit G, Page 58

Page? of
7

Copyrightamd trademark entices
till conieuts afthe RacketLawyer com rvcbsite au~ Copyc glzt ~ 2012 Rocic~t Dwyer ln~rporad~
andror its su~apl ers, affiliates aad part~~ers. All rigt~fs reserved.

"Crademsrks
Racket Lawyers and Rock~tLawyer corn pare tr~demas~ks and Rocke# Lav~ryer Un Ca11~ isa
registered trade~n~r1~ ofRacket Lawyer Incorporated,'The names of actin!companies and products
mez~tionesl herein may be tt:e trademarks oftheu respective owners.

General Notices
Notice ofchanges to these Teemsend Conditions will ~ provided in the manner permitted i~ 1~' the
. - E~.vck~t Lawyer Terms and Canciitions,

Notices a~ procedure far making cta~m~ of ~op;~t~ight in#rin~ement
Pu~su~nt to Title 17,.CJnited States CAde Section S12(c)CZ), notifications ofclaimed.co~ryright
u~fn ngement under U~aited:States cagyrigtet law should be sent tv Sert+ice Provider's Des gyrated
Agent ALL TNQ~IJ~IRIES N{}T RELEVANT TQ THE ABOVE FIt(~~DUIt~ WILL REiCEIVE I'+IO
RESPONSE,
For more irifafmation, please review o~c Terms std Condition,Privacy Policy,and aw FAQ Section

November 2012
Close

bttp /lwww.rock~il~v►ryer.corr~ft~n-cat1-teems-of-service.rl

11!29/2012
Exhibit G, Page 59

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Exhibit J

Frain:
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~r~m Biian liu
5~tt Ftiday. October ~4, 24111:43'~f
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Sti6je+ct: Re: Fdbw lJp
.~
W~~IC 4'VCI~IIi:t(7 g~# ~CQU21I1~. I mCL IQ}]II Sill ~ C011~1C Of ~t'.8L3 8~[3,and I've heazd a Iflt ofgood stu~fabaui

Y~
Congrats an getting Sue I?eck~r on your board,by the way.: Uur lads ga to school tageth~'at~d we have a lot of
mutu~I friends and acquaiA►t~.nc~s. She's awesome.
I'm available tomarrnw,anytime before I4ac~►; from 1Q:30am -1lam,or 1;30pm - 2:3t~m Hopefully, vne of
those slog is free for you ioc>?
pth~rwise,l'm tzaveling ne~ct week until Friday.

On'Xhu,Oct 13,2Q11 at 4.23 PM,Dan Nye <daveCa~kracketlawver.com? wmt~:
Brian.-Give, the.topic.you wish to discuss.it saund5 like the.best approach is for yQn tv speak to Charley. He's
included on this xn~essage so Ill leave t~ the two o~ youta tike itfrom here. In addition,this should be more
e~ficieat since T am au the road.
~1: 1_

i
Exhibit J, Page 64

m} wrcjte:
tan Thu,Oct 13,2011 at 3.41 PM,Brims Liu <btiu{~egai~~om.co
lea,

.

at would be good to recoanect, bu#I wanted to reaef~
Thauks fi r gcrting beck #o me. I've actually met C~atley before,and
out to you si~ace we've never met

that our Iegat depart~i~nt has foughtug regarding your advertising thatIwazite~l
Tn. ~dditioq t~ ere is ate importanti
next ww~eelc, twould begoad ~ talk.
to pe onaity discuss with you first: T6erefar~, if`yax }~av+~ tine early

Pleaso let me lmow if yon have tune to folk ne~ct Monday or'Tuesday.

Sriaa Liu.

wv~.cc~~a]
Frame.Daa Nyz[mxilto;dny
p
5eeuf:"fh~uscla:()ctt►btr 13,2Qli 133PM
To.Brim Liu
[e:f~arles Mtaure
Snbj+~#: Follo~+rUp

IHIt~~C b{~1GC ~0~3~I DC ~OIIIOIIOW. Pd be
Brian - I received your VM from yesterday. U~ofvrtunately~ 18111
for Chazley Moors(Fouaderl~hai~nman)#o join us. Cau you
Y to have a ca11 and I tExin~ it vvauld be greaxprovide sck~ne times tha# you will be availably on I1/1,i 1I2 ~r t1I4?

Thx~ks,
Din

d~~~cke#lav►,~~er.com
41~-5~&6384
z
Exhibit J, Page 65

i

d~nye a racketlav~ver.com
415-5:18-63$4

3

Exhibit J, Page 66

Exhibit K

From:.
Setrt:
~4~

Subject
AtWchmenfs:

From: ~riarl Liu
Sit:Friday f7ctober 14, ~f11i 3.41 PM
{
s
'fp:`C~ar1 Moore`
Subs RE Ffi1bw Up
f:
,.
2
~hartey
It was goad speaking with you today. lust wanted to get tack to you before you left vuith same of the ads and
landing pages that our guys are having problems withl which are in the a#tached document
#you haven`t seen the FiC guidance,it`s beret httt~:llwww.ftc.~ov/hcts/guides/free.htm Specifically,"a(t a
the termsr con~itit~ns and obligations should appear in doge injunction with the offer 4f'Free' merchandise
ar se€vice.»"
As for cur awn Gaagle ads, it appears that the "don't trust free" langeiage only appears on search terms that
include t[~e word "free". We don't offerfree documents,so what tfiis ad is tetl'mg people isto not trust the
canee~t oaffree in genera[(since often,there are strings attached. However,l did see one ad that linked
"r~an't trustfree" to something 5pecifc,such as the legal"rty ~fthe document. I agree that is ouerly aggressive
and will ask our guys to take tF~at d~nwn.
Thanksfvi~ looking into Lhis, When 1'rn in SF next, it wuerld be gad to sit dawn and grad a drink.
-- B~ria n

ism:(~wries Moc►re fmailin crn~r~cicetlawyer.aantl
Sent:Thursday, Od~abex 13,20115:0 PM
7'u: Brian Lw
C~ Gran Nye
5u6~ec~ Re: Flow Up.
Briat~
We're overdue t,~ get a~cqusiut~ti. I met:T+nhn Sub a couple of yc~s ago,and Pv~ heard a lot of.good stuff about
you.
~ongrats an getting Sue Decker an your boazd,by the way. (hu kids go to s~cyol together and we have a lot ~f
mu~.ua!friends and soquaintan~s. Sh~c`~ awesome.
i
Exhibit K, Page 67

fully, rune of
I'm availabte tomu~rro~w, any~bimc before ~ Oam;ftam 14;3Oam ~- l laux,or 1:3(fpam -2 30przi. Hap
thane slots is free far you too?
(?the~wis~, l'rn ttavel~g next week'until Friday.
.

$est,

Charley
~7n 7~ui, t)ct 1~,241..1. apt 4.23 PM,Dau Nye <dnvc a ocketlawv~.cc~m> wrote:
Brian -Gives the topic you wish to discuss,if ~uuds Iike the best appraactx is fi r you t.~ speak to Chaz]e~+. No's
included on this message so ~ll leave t+~ the f~vvo of you to take it from here. In addition,this should t~ more
cfficient since I azn one ttte mad.
Dau
f?r~ Thu,oct l 3,20ll a# 3:41 Pbt,Brian. Liu.. <bliu~r aegal~c~om.cc~rn~ wrote:
Ilan,

Thanks for getting back tsa mc. I've ~ctualiy mel:Charley beforq and it wtcruld he good ~a rer~nn

butI vv~nted to teach

41st t0 ~4U SIIIGC'WC'V~ flCt+rCf ~I1CL

Iu additi+~n,there is an important issue that our Legal deparmie~t has brought ug regarding your advertising that T wanted
to personally discuss with you first Th fore, if you hive time early next week,it would $e goad to talk...

P[case Let r~nc iaraw ifyou have time to tallc next Moada~ or Tuesday.

$Tian Liu

Frain:Dami Nyc[mailta:d~ye(~rocketlawver.coml
SruE: ~hut~y,t?ctabor l~,2Ui1 135PM
1`a:Briaa Liu
Ccc Charles 11~oore
Snbje.~t: Fallow Up

z
Exhibit K, Page 68

in the office today or tomorixrw. I'd be
Brian - Iz+e~eived your VM from yesterday. Unfisrl~uu~tely,Iam not
for Charley Moose(Euun~arlChairma~} tojoie us. Cau you
b;aPpY to Dave a call and 11~snk it would be
provide some times mat you wi~11 be available ou ll/f,lt/2 or 1114?

t~ll'~ ~fJl'(1C~CB~$:

~L.CAYTI

f~Il~['OCICC~3WV~t.COT[t
1~-Pl~-~T~~
?

3

Exhibit K, Page 69

Set U~ a Free LLC(877)4a7 ~~SQ
wn~rw.rocket[awyer.coml~ree=LLC
Simple!
Farm ~n LAG in Under $Minutes. LLB Fling that is C~ead
11Ve're Totally Free
L erg Charge $99+, We're free -8 Minute LLC ~ Why
to pay filing fermi.
1. Sayutg that it's totals free is rnisleaciiing since you hive
~nnd must be disclosed, See ETC
2. Free is also conditioned on crpfing in to a legal plan
guidelines,
Minutes; Frey LLL SetuC~(877)4fl7 595p
allsfates.rr~cketlawyer.c~mt~re~-L.LC
s, Stmt Nc~w
~cpert Guidance, Np Processing Fees Professional ~ilsng
figs.
1. Setting up the LI,G is natfree since you mast pay filing
s.they would ha~re tabs ceztifieti
Z. Even ifyo~ have lawyers guide you through the proces
3. Are {awyers doing the filings?
.rl
Landing Page: httn://www.rocketiawver.com/incorporate-far-free
headline
1. pia disclosure rtes to the word ~'R.~E ab+~ut the.conditavns in the
ions in the question. mark click
2, In the Com~ar~ Pricing tab, simply disclosing the condit
isn't enough to satisfy F~'C g~tidelincs
TM motive.
3, LegalZoom fs not our proper name,and,there is no
e,so that is misleading.
4. W~ doa't sell a corporate kit for $lUU anywhere on the websit
kit.
..Our standard package:contains mare t}zan just a corporate
service is not $159.
5. Registered ~g~xt
for us is way
6. Their processing times are nv~ the sgme a~ ours. For oxarnple —Delaware
faster thsa 6 we~el~s.

Frei Lec~~l C~ocuments - VUhy P~,y? We're ~t D0°/a Free
awyer.cam
.
!egal rocket)
Leda! Forms, Contract, WiII, Lease.
Z. This ad appears an the I,~gal2oom brand term.
fees. far r~thcr
2. RL is trot l0U%free, For LLGs,and incorporations, you must pay ~]ing
See ~"TC guidance.
forms, it's canditior~ed upon opting in to the plan.

Exhibit K, Page 70

E~h~U# L

Ser►t:
To:
St~bjec~
Tmpart:~nts.

---Qriginal M
Frc~r~: Brian tiu

s~,t: r~;day, n~ovemt~r ~s,~a~x ~i:i4 ~t

To: `criej► t~.k~re'
Subject RE: Googfe Aids
Importance: High`

.
.

C,t~a ey,
~ I #rigid c~llir~ you but the line isn't 9oin9 through. Can you cayl me at 3~'3-79 1356? Thank
Bin
--Original M~es~s~ge--~-Frnrtt: Charley Moore [mailtn:+r~n@rvds~iawyer aim]
Send 7ritm~ay,(Vc nber ll, 20119:00 PM
To~ Brun Liu
'Subject; Re; Gocagl~ Ads
SUr~ lei's talk amain.
~your calf at 11:15 tomorrow. 4].5-7~&7699.
Y~{
e.

~ttot~m.a~tn> wrote:

Un ~Etry 17, 2011:, at 5:27 Pit, Brian Liu <bliu

the
> I can't bell whet~ex you`re misi~fo€irwd, stati ng, w sarttetfi rig Ise. Onae again, You 3ust dtan`t stern ~ tmow
~n early d4 yourself aid I have dorms so. Scr+et~n s~Ots
taasic fats. Yc~u asked m~ bn oanfirrn ~nettung #twk
from 6oday ~e below.
> H~ are the t~r~ee tF~ngs tt~t you ~d do dv:
1. ll~e ~ nv possible way to get a truly "free" naarpa'atiQrt tar LLC~ Rndc~..avrer, You always Five to pay
your'no p~oo~ss ~g fee" offier is oorrdiGiar~ d ups japing your legat plan, which you hide.
fi[ir~ mss. A~xi
There~nre,any acJ tl~at says"F~e I.LC,"'S+~ up a ~t~ee LLG""Int~orporate fnr free," "St,~rt an LLG f~- Free," or any
ad t hat: says'Frye" witfiot~t rn~tioning tfiat you have tic pair fi!' fees + s'~n up for y~r tell Win, must be taken
dawn i~mrr~tiiat~ly.
i
Exhibit L, Page 71

"and "Free ~nco~oraG«,°
"
f "1Nhv pav? we're
~., Qn Legaf~On, brand teens,y~oi, acivett~~e "100%
searching tar
. As y~ kr~avv,zna~r
which are c~omp~teiy false.and c~anstitr~ :e unfair business
bc~ form an t1,CC, sv arty tune you ~y"Free" in tfie ati, iYs not true.
L,egalZvorn brand t~rnns an Gt~gt~ arr~ laaitirg
TrFEYP.~OTB~ 3fi~t ~ Oft L,~~~ZC)f!('i't ~I'w~ ~72tTit5 ~~ t15E:S
't(11~YIQ~f~Y~~f f~R~V2~=

W~Dtid "I'Y(~E~ 4Yi1~141Jt 51~1yIM~ ~

.-

S S~'K~J~i~

mPle. Yau state that wet 6
~9. For
> 1. Your mmpar~son d to L.egalZo~am's priccing Es oamP~Y
iCs r~6~,~t takes us 1 Vic. wit's why w~ charge $Sll ~xha fir std
v~ae~s to pr~oroess a[~laware LLC ad
Radca9e}. Our Re
pedlt~e fees. Uur ~Cteral Tax Tt) prise iscM`t'X79(You get a ~' ur►t with c~uuc Gc~ki
't start un~l the LLC's ~fFec~ive date,
d
lent service isn't $],59 per' Year -you +get a fre+~ month, and the dadc
find thak anywh~ on our site.
l ow you came up wttfi our "e~cpedibed praoes5ing" fee Ls beyond rne,since I cant
are the same, but we aff~r a muttih~ of ~adcages witfi
Arrd your line-byr-line ~rt~pa~ison i fies that our of~erirr~
must be im~r~ediately
a~it~nal f :fits }rou cart't matr~. Th~r+efare. Y~~ t ~J comparison chart~ is iT.ot~m
defeb~d.
> ~"d stiN be hammy bra spe~K ~i yrou br~morrow at 11:15 arr;, bi.rk at this point,i f+e~! like i~ene's
ti~ough~ they
E'v~e~7 y~su se2metf ~D #hink tl~at yOUF ads Wefe WfDCIg, WIi1Ch is why yW

little more ba spy,

e t~tcett dOW~1. ~'II wait

c~-rinisteading ads at tf~at-time,
until-n€~ct~Tue~ay bo sc~ what d~aarx~s you made. B~~if-you awl running unF~ir
v~ will take action.
> ~ince~ely,
}&ian liu

jcid:irnagetlUl,jP9~i 01CCA.55~.EEtl~A?.FT4]
[c~d:rnage0t}Z]P9~~~t~CAS55.~0AZfl~]
}
> [~d:im~g~lU3.iP3@o1CCA555.~ED~12R~1
.y
> [cad: rtta~e0U~4.1P9~1(7C'A555.~EOA2f~7
> [cad:irn~geEl05.jP9~01CCA5S5.EE0A~FFD]
a

[~d.imagef3Q6:,1P9~1C~CA555.ER-0]

> E~tian Liu ~ C]~aim~
> bfiu~le9alzaom.mm ~ Phone [phone] ~ fax [phone]
vvww.kegalz~im.o~m<http:/~www.legalzoa~n.rntn> ~ 1U1 N. Brand Bh►d.,1lth
> Flov~', Glenda{e, CA 91x03
> [cad:irnag~07.g'tf~tO~C~A555,~CIu42FfU]<1~:(/www.l~gatzoort~.00rr~/~
tfie intended reapienb(s).
> This trar~smissian may oo~ain oonfidentiat aid pcivil~ed rn~t~erial ~the sole use aP
t~it~ad. If you are eat tl~ ir~nded redpient(ar
is sd~tiy
Arty r~ev~w, use,d~Shibution or disclosure by others

Exhibit L, Page 72

~.
;

authar'r~ed to reoeiv~ fvr 1i~ recipient). i

by reply ~nnail and deJet~ all espies cif tfi~s

~ mn~ct tine

drection. L.egalZaam.c~n,
> LegalZo[~m is riot an attorney and can only prnvu~ self I~Ip servioe~ at yKx~r specific
I document ass star#, #OIt~E, Los Arrgetes t:o tY(exp. I2J11). Pt s, Ee+ea es,
Inc. ~ a reg ~t~ect a~ bonded
ire suhjec# tq d~ange without notice.
'harms a~xf aond'

> ~'t~om: t~de~r Moan [mail~o:rnn@rocketlaveyer,c~um~
> Sent» Th~sday,i+Javernb~r i7, ~f311721 AM
To. Btiar~ Liu
> SuE~ec#~ Re: ~oog~ Ads

.

> Brian,
> My Yarn has c~nfifmied to me tfiat we are not running.ads.vwid~ tt~ coPY You;complained
> Why dr~`~ you.i~cieper

to ~s shout

tly mn5rm tf~at car' send rr~e ejcamp~?

.
y(~ar~y
n~~wrot~--> C}ft WEd~'IWDv 16`r 2011 d`C5::3~'~M;f~riatTi L.i~~blu~tegaiz~artna~rncmatt~:bliu~legalzcrxnro~r
~ p~rleY.
> Tm nc~t avai~ble on Friday, but this needs to be removes! quickly. Cari you make tame bar
available all clay.

aw? I can be

.

—Brian
> I~raNm: Char M1~aare
7[mai{to:cm~rc~cket~awyer.cam<rna~:cm~raclwy~.com>]
~ Sent: Wedtt~sda}r, Novemt 16, ~Q113:15 PM

,-

> 70 Brian Lht
> S+~bject: ate: ~oog~ /~#s
> Arian,
> I`m ah tf~e ~

i until Friday. Fianrs 11.15 Friday for yau?

Cria~iey
On Nov 16,Zpii, at S.b8 ~,Brian Liu <bliu@
fh~rleyr

lzoom.oaro<mailtn.bliu~l~galzoom,uom» wrote:

> if you.are availaf~fe rxzw, we can. ai9a drat, i'II!~ here for anatf~er k
> — ~ri~n
> From: Charley Moore
> [ma~It~:c~nCc~ro~ck~eaav+r~".c7om<mal6cr:cm~cocwy~r'.c]am>]
a S~nG Wedne9day,lVovember 16,2011 11:51 AM
> To: Brian Liu
Subject: Re; Coogte Ads
Bfl~flr
3

Exhibit L, Page 73

.

~ Lookkirig bade, tlr+~ kfiraad an tl~ s
> May I.suggest that we g~ back an tfiie plane and r~sohre a few i
tf~at LZ has been n~tning ads far rrwltiple sites it r~perat~ for t#
st~spped wft~ ~+re di~rered (end you aonfim~ed)
same keyvaancf~, why vw~at~s gdaJf~ S~fi7 rubs.
~ We're rat'int+ere~bed in getting ink a pissing ma6dt at~d continue to wish ~rou v+r~if,
> 77Mis ~5off is nab a good cue oftine fur eiffier of us I sus~t.
Charley
a
> Os~ l~v 15, 2U11,at5:53 PM Brian Liu ~btiuC°~le~~lzoom.mm~mailtn:blie@legatz~oom.mm>> wrote:
Charley,
IYs tr~en ate a rnontfi since we I~st spaite, and I'm c~sappa~rted that no~tung has charx,~ed Qn~your end
~
regardingyraur Gs~ogle ads.

.

There's no d~wbt that your "I009~o Free" ad thaCs cu~tiy running on ~r brand kerms ~ 140% fad and
i to
miis{eading. The idea that your lLCs ar~~"tc~a~Cy free" is tally BS. Yow ELC lac~cting pate's mmpa
Arid your"Free" axis that I'r~: aocr~e a+ooss vn C~g~ are ~71~ga1 aaoor~ding fi~ the FfCs
LegalZoom is tdblfy off
~_
—rg~id~fit~e5.
a
ned tie val'~iity cad free ducvrn~tt~,and we did so imrr~eci ably, cver~
You asked us-in remove our acs that qu
th~h there's naft~itx,~ il{ I about it
> I don't l"fee 1z~ e5r.~late #dings if tJ~re's a bier vuay to g~ things res~lv~d, s+~'1~ me know you'd
ti~is issue.

bn tf~3 with

&ian Uu
> Brian llu (Ct~irrrr~n
> bliu~l~at~oorn.c7o~m<mailt~.hlit~(e9an.a7m~ ~ F'hune
> 323.740-1358<tei.323.790-13~8> (~aX 33.337-073U<bef:323.337-07~tI>
.
~ rvww.tegatzc~om cz~m~1'~kp://www.legatzoum.00m~ ~ 101 N. Brame ~vd,11th
> Fiac~r, G{endafe# CA 912Q3 <image001.g'►fa~htl~//v~rw►~r.le~ltaant.cnrn~>
~ Th~ transmission may oorttain cor~iderttiial an~i pritirt(eged material far tfie sale ~e of~e ink$nded recipi~b(~}.
Anp re+iiiew, use, cGsfibubion c~ disrfosu~ try atfiers is stricter prohibited, If you are not tt~e inben~d reapie~t(cam
alt vopies ~ tfi s
autfx~ri~ed ko ~'~re for tfie r+eap`~ent), pose ot~ntact khe sender 6y reply email and d
~•
> L~gal~aom ~s not an atborne~r and can only pra~►ide self help seivi~es ~t yaur speaf~t direc~c~n.
sbr~t, #01U4,Ln~s
t
aril banded legal. dcx~u
LegalZoom.cn~n<http;//Cegal~ont~.00tn>,Inc. is a
d talons ~re subject trr ct~ang~ witliaut riotiae.
~ rnxs and
+~rY ~~P. 12f1i). Rriaes,futures,
y
cimat~eOUi.~pg>
<tma~eDU~.~rg>
> <image0t33.jpg~
jpg>
> <(map4
jpg>
> <image0Q5.
<imageIX~6.~g>
> Gmage0~7.c~tf>

a
Exhibit L, Page 74

i

CERTIFICATE OF SERVICE

2

STATE OF CALIFORNIA,COUNTY OF LOS ANGELES

3

I am employed in the County of Los Angeles, State of California; I am over the
4

age of 18 and not a party to the within action; my business address is 10250
s
Constellation Boulevard, 19th Floor, Los Angeles, California 90067.
6

On September 4, 2013,I electronically filed the following documents)using
the CM/ECF system.
s
PLAINTIFF LEGALZOOM.COM,INC.'S NOTICE OF MOTION AND
9

MOTION FOR SUMMARY JUDGMENT; MEMORANDUM OF
io
POINTS AND AUTHORITIES; DECLARATION OF MARY ANN T.
ii
NGUYEN
~~
o•

~
~~
~~
~~
V

i2
Participants in the case are registered CM/ECF users and will be served by the
i3
CM/ECF system.
is

~Q

is

N ~
~a
~=

I declare that I am employed in the office of a member of the bar of this court at

i6

whose direction the service was made. I declare under penalty of perjury that the
above is true and correct.
i~
Executed on September 4, 2013 at Los Angeles, California.
is
19

Zo

/s/ Fred Heather
Fred Heather

ai
22
23
24
25
26
27
28

PROOF OF SERVICE
so7a7z