Petroliam Nasional Berhad v., Inc.

Filing 115

Declaration of John Roling 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, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Related document(s) 112 ) (Slafsky, John) (Filed on 11/2/2011)

Download PDF
1 2 3 4 5 6 JOHN L. SLAFSKY, State Bar No. 195513 DAVID L. LANSKY, State Bar No. 199952 HOLLIS BETH HIRE, State Bar No. 203651 WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: (650) 493-9300 Facsimile: (650) 493-6811 7 8 Attorneys for Defendant/Counterclaimant GODADDY.COM, INC. 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 12 PETROLIAM NASIONAL BERHAD, 13 Plaintiff, 14 vs. 15 GODADDY.COM, INC., 16 Defendant. 17 GODADDY.COM, INC., 18 Counterclaimant, 19 vs. 20 PETROLIAM NASIONAL BERHAD, 21 Counterclaim Defendant. 22 23 24 25 26 27 28 J. ROLING DECLARATION ISO GO DADDY’S MOTION FOR SUMMARY JUDGMENT Case No: 09-CV-5939 PJH ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO.: 09-CV-5939 PJH DECLARATION OF JOHN ROLING IN SUPPORT OF GO DADDY’S MOTION FOR SUMMARY JUDGMENT Date: December 7, 2011 Time: 9:00 a.m. Courtroom: 3 Honorable Phyllis J. Hamilton I DECLARATION OF JOHN ROLING 2 3 4 5 I, John Roling, declare: Background I. I am a Software Development Manager at Go, Inc. ("Go Daddy"), and 6 have held this position since October, 2008. I have been employed at Go Daddy since 2002, and 7 have served as a senior application developer, a senior web developer and a Software 8 Development Manager. In my current position, I am responsible for Go Daddy's domain and 9 DNS "dashboards," the online user interfaces that allow Go Daddy customers to manage their 10 domain names and the services they have enabled or purchased with Go Daddy. II I am familiar with Go Daddy's policies and practices relating to routing and forwarding domain 12 names. I have personal knowledge of the facts set forth herein and, if called as a witness, I could 13 and would testify competently thereto. 14 Overview of registration, routing, and forwarding 15 2. In such capacity, Go Daddy registers over 16 million domains each year, and transfers in over 1 16 million more domains each year. As part of its basic registrar services, Go Daddy facilitates 17 registration of domain names, facilitates transfer of domain names between registrars (if 18 registrants choose to transfer), and facilitates resolution of Internet traffic to the websites of the 19 registrants' choice. To route a domain name to a website, a registrant who uses Go Daddy as its 20 registrar can designate name servers to point the domain name to where the website resides, or can 21 "forward" the domain name to an existing website by identifying the URL (web address) of the 22 existing website. Website content is not hosted on name servers, but rather on website hosting 23 servers. Website content could be hosted on Go Daddy's hosting servers, or on the hosting servers 24 of another company. Go Daddy does not charge customers for domain forwarding, but rather 25 offers this routing option as part of its registration services. 26 27 3. In facilitating the resolution ofInternet traffic, domain name registrars serve as an intermediary between domain name registrants and the registries, who ultimately keep track of the 28 ROLING DECLARATION 1 information necessary for routing domain names. If registrars stopped performing the function of 2 taking name server information and providing it to registries, the Internet would grind to a halt. 3 Domain Name Routing 4 4. When a domain name registrant wants to route a domain name to a website, he or 5 she can log into his or her account through the dashboard on Go Daddy's website, then identify 6 the name servers associated with the website (the hosting provider usually provides the names or 7 IP addresses of the name servers). The information is automatically sent to a different server at 8 Go Daddy (the application server), which in turn automatically sends the information to other 9 computers at Go Daddy. In the case of routing without forwarding, the information is 10 automatically sent from the dashboard application, to the application server, to the EPP service 11 (for .net, the .net EPP service). The EPP service automatically sends the name server information 12 to the registry (for .net, Verisign). 13 5. "Routing" a domain name, without forwarding, means that a domain name 14 registrant has identified name servers that contain the information to lead an ISP to the destination 15 website content. I have attached as Exhibit 1 a true and correct representation of the automated 16 process a domain name registrant customer of Go Daddy would complete to direct Go Daddy to 17 "route" a domain name, without forwarding, by providing name server information. Exhibit 1 18 shows the screen captures from July 27,2011. 19 updated periodically over the past few years, but the functionality of the dashboard, in particular 20 as it functions with respect to routing domain names via name server information, has not changed 21 in any significant way since October 2006. 22 Domain Name Forwarding 23 6. The aesthetics of this user interface have been Many entities "forward" multiple domain names to a single website; for example, 24 the and domain names are both forwarded to the website 25 that resides at 26 the automated process a domain name registrant customer of Go Daddy would complete to 27 "forward" a domain name, or route it to an existing website. Exhibit 2 shows the screen captures 28 from July 27,2011. I have attached as Exhibit 2 a true and correct representation of The aesthetics of this user interface have been updated periodically over the -2- ROLING DECLARATION I past few years, but the functionality of the dashboard, in particular as it functions with respect to 2 forwarding domain names via name server information, has not changed in any significant way 3 since October 2006. 4 7. Forwarding is automated - no one from Go Daddy receives and processes requests 5 from registrants to forward domain names. The process takes approximately 30 seconds and can 6 be achieved in 3 clicks. 7 8. In the case of forwarding, the information that the domain name registrant enters 8 into the dashboard is automatically sent from the dashboard application to a Go Daddy application 9 server, which in turn sends the information to the EPP service (for .net, the net EPP service) and 10 the forwarding management database. The EPP service automatically sends the name server 11 information to the registry (for .net, Verisign). A forwarding service automatically moves the 12 information from the forwarding management database to the forwarding database. 13 9. Sometimes, entities elect to forward a domain name with "masking," which means 14 that the URL appearing in the web browser does not change when the domain name is forwarded. 15 For example, if the domain name forwards to 16 • 17 window. 18 • 19 20 21 22 23 24 25 26 forwarding without masking would reveal www.united.comin the web browser forwarding with masking would continue to show www.ua1.comin the browser window, even after the domain name is forwarded to 10. Go Daddy can only provide domain name forwarding services to domain names for which Go Daddy is the registrar. 11. Information about forwarding is available in a "help" article on Go Daddy's website. A true and correct copy of this article is attached as Exhibit 3. 12. To an Internet user, there is no distinction between routing and forwarding. Either way, the user types in the URL, and ends up at the destination website. 13. Go Daddy provides forwarding services to approximately 8.2 million domain 27 names under its management, and has provided such service in combination with its domain name 28 routing services since 2002 or before. -3ROLING DECLARATION 1 14. Forwarding is essential to domain name registrants because it allows multiple 2 domain names to resolve to the same website content. Though a domain name registrant could 3 develop a separate copy of the website for each domain name, this procedure would be inefficient 4 for numerous reasons: 5 • 6 it would require hosting for each domain name, requiring extra space and cost to the domain name registrant; 7 • 8 when the domain name registrant wanted to make a change to the website, he or she would have to make the change numerous times, instead of only once; 9 • it would affect the rank of the website in search engines like Google or Yahoo, 10 because Internet traffic routed to each individual website would not be recognized 11 as flowing to the same website. 12 13 The 15. and Domain Names After transferring the and domain 14 names to Go Daddy on April 1,2007, later the same day the domain name registrant - Heiko 15 Schoenekess - used the Go Daddy online dashboard to forward the Internet traffic for the domain 16 names to an existing website. A true and correct copy of the page of the account information 17 record indicating that the domain name registrant forwarded the domain names is attached as 18 Exhibit 4. 19 20 I declare under penalty of perjury that the foregoing is true and correct. Executed at Hiawatha, Iowa, on October 31, 2011. /YOn 21 O} ~: By: 24 25 26 27 28 -4ROLING DECLARATION ~ol~.

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?