Facebook, Inc. v. Pedersen

Filing 48

Declaration in Support of 47 Response to Order to Show Cause of Jeffrey T. Norberg filed byFacebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C (Part 1), # 4 Exhibit C (Part 2), # 5 Exhibit C (Part 3), # 6 Exhibit C (Part 4))(Related document(s) 47 ) (Norberg, Jeffrey) (Filed on 12/12/2011)

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COOLEY LLP
MICHAEL G. RHODES (SBN 116127)
([e-mail])
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Phone: [phone]
Fax: [phone]
ANNE H. PECK (SBN 124790)
([e-mail])
JEFFREY T. NORBERG (SBN 215087)
([e-mail])
3175 Hanover Street
Palo Alto, CA 94304-1130
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff
FACEBOOK, INC.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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FACEBOOK, INC.,
Plaintiff,

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v.

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DECLARATION OF JEFFREY T. NORBERG IN
SUPPORT OF PLAINTIFF’S RESPONSE TO
ORDER TO SHOW CAUSE RE PERSONAL
JURISDICTION

THOMAS PEDERSEN, an individual d/b/a
Faceporn.com, and RETRO INVENT AS, a
Norwegian private limited company d/b/a
Faceporn.com,
Defendants.

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Case No. CV10-4673–JSW (NMC)

I, Jeffrey T. Norberg, declare:
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I am an attorney with Cooley LLP, counsel of record in this action for Plaintiff

Facebook, Inc. (“Facebook”). I make this declaration in support of Facebook’s Response to
Order to Show Cause re Personal Jurisdiction. I have personal knowledge of the facts contained
within this declaration, and if called as a witness, could testify competently to the matters
contained herein.

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

1.

DECLARATION OF JEFFREY T. NORBERG ISO
PLAINTIFF'S RESPONSE TO OSC
CV10-4673-JSW

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2.

Attached hereto as Exhibit A is a true and correct copy of a screenprint of the

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Faceporn website I created today. To avoid filing pornography with the Court’s electronic case

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filing system, I have placed a black bar over any pornographic images on this page. I have also

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placed a red box around relevant text.

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3.

Attached hereto as Exhibit B is a true and correct copy of a letter dated July 7,

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2009, from J.D. Obenberger, at that time counsel to the operators of www.faceporn.com, received

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by Gavin L. Charlston, of this office.

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4.

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

Amended Complaint in this Action (D.I. 7).
I declare under penalty of perjury that the foregoing is true and correct. Executed on
December 12, 2011 in Palo Alto, California.
/s/ Jeffrey T. Norberg
Jeffrey T. Norberg

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

2.

DECLARATION OF JEFFREY T. NORBERG ISO
PLAINTIFF'S RESPONSE TO OSC
CV10-4673-JSW