Petroliam Nasional Berhad v. GoDaddy.com, Inc.

Filing 113

Declaration of John L. Slafsky in Support of 112 MOTION for Summary Judgment Notice of Motion, Motion, and Memorandum of Points and Authorities ISO Go Daddy's Motion for Summary Judgment filed byGoDaddy.com, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15)(Related document(s) 112 ) (Slafsky, John) (Filed on 11/2/2011)

EXHIBIT 13

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
PETROLIAM NASIONAL BERHAD
(PETRONAS),
Plaintiff,
CASE NO. 09-CV-5939PJH
VS.

GODADDY.COM, INC.,
Defendant.

::: CONFIDENTIAL :::

30(b)(6) DEPOSITION OF CAMILLE EDE

DATE:

Thursday, October 20, 2011

TIME:

1:11 p.m.

LOCATION:

BALLARD SPAHR, LLP
1 East Washington Street, Suite 2300
Phoenix, Arizona 85004

REPORTED BY: JANICE HARRINGTON, RPR, CRR, CLR
AZ Certified Court Reporter No. 50844
Registered Professional Reporter
Certified Realtime Reporter
Certified LiveNote Reporter
MBreporting
111 Deerwood Road, Suite 200
San Ramon, California 94583

10/20/2011
Camile Ede

Berhad/Petronas v. GoDaddy
1

claims? Do you know how many trademark claims Go

2

Daddy gets in a year?

3

A.

No, no.

4

Q.

Okay. So just turning to domain disputes

5

in general, what's Go Daddy's procedure for handling

6

a domain dispute?

7

A.

Once we receive notice if there's a filed

8

complaint through an arbitration or through a court,

9

we will lock the domain name which prevents the

10

customer from making any changes to the domain name,

11

and we also reach out to the customer and let him

12

know that his name is locked and that it will not be

13

unlocked until we receive notice of a decision.
And then once we receive the notice from

14
15

the court or the arbitration, we'll unlock the domain

16

name and follow the order of the court or

17

arbitration.

18

Q.

Okay. And how about trademark claims?

19

What's Go Daddy's procedure for handling trademark

20

claims?
A.

21

We have a form that a customer can fill

22

out with specific information that we need or else

23

they can follow the guidelines on our trademark

24

policy and submit an e-mail. It's basically the same

25

thing.

MBreporting

::: CONFIDENTIAL :::

Page: 14

10/20/2011
Camile Ede

Berhad/Petronas v. GoDaddy

Q.

1

Okay. And so the reason why Go Daddy

2

added employees to domain disputes was to deal with

3

the increasing number of disputes that that team was

4

dealing with?

5

A.

Yes.

6

Q.

And is that why Go Daddy would increase

7

the number of employees that are currently on the

8

team?

9

A.

Yes.

0
1

Q.

Okay. Is the number of disputes the

11

domain disputes team is handling increasing?
A.

12

We register a domain name every second.

13

So every time, you know, just the probability of a

14

domain name being part of a lawsuit because someone

15

might be possibly, you know, doing something wrong

16

with the domain name increases. As more and more

17

domain names get registered, there's obviously going

18

to be more and more issues. That's my understanding.

19

Q. And so it's your understanding that the

20

number of disputes that the domain disputes team is

21

handling is increasing?

22

A.

Yes.

23

Q.

And then turning to the trademark claims

24

team, is it your understanding that the number of

25

disputes that the trademark claims team is handling

MBreporting

::: CONFIDENTIAL :::

Page: 30

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CERTIFICATE

2
3
4
5

I, Janice E. Harrington, Certified Court
Reporter for the State of Arizona, certify:
That the foregoing deposition was taken

6

by me; that I am authorized to administer an oath;

7

that the witness, before testifying, was duly sworn

8

by me to testify to the whole truth; that the

9

questions propounded by counsel and the answers of

10

the witness were taken down by me in shorthand and

11

thereafter reduced to print by computer-aided

12

transcription under my direction; that deposition

13

review and signature was requested; that the

14

foregoing pages are a full, true, and accurate

15

transcript of all proceedings and testimony had upon

16

the taking of said deposition, all to the best of my

17

skill and ability.

18

I FURTHER CERTIFY that I am in no way

19

related to nor employed by any of the parties hereto

20

nor am I in any way interested in the outcome hereof

21

DATED this 25th day of October, 2011

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23
24
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Janice E. Harrington
Certified Court Reporter No
For the State of Arizona

50844