LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 69

NOTICE OF MOTION AND MOTION for Partial Summary Judgment filed by Plaintiff LegalZoom.com Inc. Motion set for hearing on 8/18/2014 at 09:30 AM before Judge Gary A. Feess. (Attachments: # 1 Proposed Statement of Uncontroverted Facts & Conclusions of Law, # 2 Declaration of Travis Gigi, # 3 Declaration of Dorian Quispe, # 4 Declaration of Aaron Allan, # 5 Appendix of Exhibits, # 6 Proposed Order)(Heather, Fred)

PATRICIA L. GLASER -State Bar No. 55668
pglaser(a~glaserweil.com
2 FRED I5. HEATHER -State Bar No. 110650
flieather(c~glaserweil.com
3 AARON.ALLAN -State Bar No. 144406
aallan(a~glaserweil.com
GLASER WEIL FINK HOWARD
4
AVCHEN & SHAPIRO LLP
s 10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
6 Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
LegalZoom.com,Inc.
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CENTRAL DISTRICT OF CALIFORNIA

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UNITED STATES DISTRICT COURT

WESTERN DIVISION

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LEGALZOOM.COM,INC., a Delaware
corporation,

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Plaintiff,

CASE NO.: CV 12-9942-GAF(AGRx)
Hon. Gary A. Feess
Courtroom: 740
DECLARATION OF DORIAN

IV.

ROCKET LAWYER INCORPORATED,
a Delaware corporation,
Defendant.

MOTION FOR PRTIAL
SUMMARY JUDGMENT
BROUGHT BY PLAINTIFF
LEGALZOOM.COM,INC.
August 18, 2014
Date:
9:30 a.m.
Time:
Courtroom: 740
~Notice of Motion and Motion;
Proposed Statement of Uncontroverted
Facts; Declarations of Aaron P. Allan,
Travis Giggy; Appendix of Exhibits;
and (Pro osed) Order filed concurrently
herewith~J

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Complaint Filed: November 20, 2012
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DECLARATION OF DORIAN QUISPE
894015

DECLARATION OF DORIAN QUISPE

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I, DORIAN QUISPE, declare and state as follows:
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1.

I submit this declaration in support of the Motion for Partial Summary

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Judgment brought by Plaintiff LegalZoom.com, Inc.("LegalZoom"). I am over the

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age of 18 years. Unless otherwise indicated, I have personal knowledge of the facts

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set forth herein, and if called upon to testify thereto, I could and would competently
do so under oath.
2.

I am currently employed by LegalZoom. From August 2013 to the

present, I have held the title of Vice President, Acquisition for LegalZoom. From
June 2011 to July 2013, I held the title of Senior Director, Online Media &Marketing
for LegalZoom.
3.

As part of my duties and responsibilities for LegalZoom,I have become

familiar with Legalspring.com, an affiliate referral site which was formerly owned
and moderated by Travis Giggy, and which Mr. Giggy sold to Inenvi, Inc. in March
is 2013. From time to time, my subordinates or I have been involved in day to day
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communications with representatives of Legalspring.com, including Mr. Giggy, and

t~ Inenvi, Inc. The relationship between Legalspring.com and LegalZoom is, and
is always has been, that of affiliate and client.
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4.

LegalZoom has not authored any of the reviews on Legalspring.com, and

Zo has no responsibility for the reviews which are actually posted.
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5.

To the extent that consumers visit LegalZoom's web site as a result of

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having first visited Legalspring.com, LegalZoom has provided compensation to

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Legalspring.com.

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6.

While Mr. Giggy, at one time, received compensation from LegalZoom

as for any products sold by LegalZoom as a result of a consumer first visiting
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Legalspring.com, that relationship terminated as of March 2013.
7.

Like other affiliate referral sites, Legalspring.com has received

2g II commissions and/or other compensation from its affiliates, including from
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DECLARATION OF DORIAN QUISPE
894015

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