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)

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EXHIBIT 15 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 ROD SIMONINI DATE: Wednesday, October 12, 2011 TIME: 2:54 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 10/12/2011 Rod Sirnonini Berhad/Petronas v. GoDaddy A. 2 Current -- in domain services, approximately three years. 3 Q. And what did you do before that? 4 A. Customer Care Rep. 5 Q. Okay. And when you say you do trademark 6 infringement claims, could you describe those for me? A. 7 Third-party trademark infringement 8 claims. We receive complaints on a website, we'll 9 investigate it. 10 Q. How many people are in your department? 11 A. Approximately 30. 12 Q. And how many people are responsible for 13 working on the trademark claims that Go Daddy 14 receives? 15 A. Five. 16 Q. And do you have a rough approximation of 17 how many trademark claims Go Daddy receives each 18 year? 19 A. Over 1,000. 20 Q. And are these claims related to Go 21 Daddy's domain name services or other services? 22 A. Domains and hosting. 23 Q. Okay. So those are the two services for 24 which your department handles complaints? 25 MBreporting A. For trademark, yes. ::: CONFIDENTIAL ::: Page: 6 1 CERTIFTCATE 2 3 4 I, Reporter f or 5 Janice the b y m e; 7 that 8 by me Lo testify 9 questions t,hat I the propounded the 11 thereafter L2 transcription 13 review L4 foregoing 15 transcript L5 the t7 skill witness were by taken reduced under to pages are whole that and the down by me in print by of said deposition, the answers short,hand that true, al-l- proceedings sworn and deposition that the and accurate and testimony all to the had upon best of FURTHER- ERTfFY Lhat, I C I 19 related 20 nor am I to in nor employed by any of any way int,erested DATEDthis in 2Sth day of am in no way t,he parties hereto the hereof . outcome October, 20lL 22 23 rringtbn Certified Court Reporter For the St,ate of Arizona .Tan 25 my and ability. l_8 24 of computer-aided was requested; a fuLL, an oath; was duly truth; counsel of taking was taken zed Eo administer test i fying, Court y: deposition my direction; and signature Certified Ari zorLa, certif foregoing before to Harrington, of am authori witness, the 10 2t State That, the 6 E. No. 50844

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