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 glaserweil.com
2 FRED .HEATHER -State Bar No. 110650
(heather glaserweil.com
.ALLAN -State Bar No. 144406
3 AARO
aallan glaserweil.com
4~ GLAS R WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
s 10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
6 Telephone: (310_) 553-3000
Facsimile: [phone]
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
CASE NO.: CV 12-9942-GAF(AGI~)

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

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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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Defendant.

DECLARATION OF AARON P.
ALLAN IN SUPPORT OF MOTION
FOR PARTIAL 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 Dorian Quispe,
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 AARON P. ALLAN
894167

DECLARATION OF AARON P. ALLAN

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I, AARON P. ALLAN,declare and state as follows:
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I am an attorney at law duly admitted to practice before all courts of the

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State of California and am a Partner of the law firm of Glaser Weil Fink Jacobs

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Howard Avchen &Shapiro LLP, attorneys ofrecord herein for Plaintiff

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LegalZoom.com,Inc. I submit this declaration in support of the Motion for Partial
Summary Judgment brought by Plaintiff LegalZoom.com,Inc. I have personal

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

Attached to the Appendix as Exhibit C is a true and correct copy of

Exhibit 15 to Rocket Lawyer's Answer and Amended Counterclaims, ECF No. 17.
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Attached to the Appendix as Exhibit D is a true and correct copy of

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customer reviews of LegalZoom posted on LegalSpring.com on July 11, 2014.

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exemplar Rocket Lawyer advertisement that does not mention its competitors,

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accessed on July 10, 2014 on http://blog.rocketlawyer.com/section business.

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Attached to the Appendix as Exhibit E is a true and correct copy of an

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To the best of my knowledge, Rocket Lawyer has produced no market

is research or consumer surveys in this litigation to establish that consumers are being
i9 misled by Legalspring.com into believing that "all" online legal services providers are
Zo being reviewed by a "neutral" reviewer.
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I declare under penalty of perjury under the laws of the State of California and

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the United States that the foregoing is true and correct. Executed on July /~, 2014, in

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~ Los Angeles, California.

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AARON P. ALLAN

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DECLARATION OF AARON P. ALLAN

894167