Petroliam Nasional Berhad v. GoDaddy.com, 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 byGoDaddy.com, 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)

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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: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Defendant/Counterclaimant
GODADDY.COM, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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PETROLIAM NASIONAL BERHAD,

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Plaintiff,

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vs.

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GODADDY.COM, INC.,

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Defendant.

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GODADDY.COM, INC.,
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Counterclaimant,
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vs.
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PETROLIAM NASIONAL BERHAD,
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Counterclaim Defendant.
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J. ROLING DECLARATION ISO GO DADDY’S
MOTION FOR SUMMARY JUDGMENT
Case No: 09-CV-5939 PJH

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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

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DECLARATION

OF JOHN ROLING

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I, John Roling, declare:
Background
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I am a Software Development Manager at Go Daddy.com, Inc. ("Go Daddy"), and

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have held this position since October, 2008. I have been employed at Go Daddy since 2002, and

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have served as a senior application developer, a senior web developer and a Software

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Development Manager. In my current position, I am responsible for Go Daddy's domain and

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DNS "dashboards," the online user interfaces that allow Go Daddy customers to manage their

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domain names and the services they have enabled or purchased with Go Daddy.

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I am familiar with Go Daddy's policies and practices relating to routing and forwarding domain

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names. I have personal knowledge of the facts set forth herein and, if called as a witness, I could

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and would testify competently thereto.

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Overview of registration, routing, and forwarding

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2.

In such capacity,

Go Daddy registers over 16 million domains each year, and transfers in over 1

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million more domains each year. As part of its basic registrar services, Go Daddy facilitates

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registration of domain names, facilitates transfer of domain names between registrars (if

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registrants choose to transfer), and facilitates resolution of Internet traffic to the websites of the

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registrants' choice. To route a domain name to a website, a registrant who uses Go Daddy as its

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registrar can designate name servers to point the domain name to where the website resides, or can

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"forward" the domain name to an existing website by identifying the URL (web address) of the

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existing website. Website content is not hosted on name servers, but rather on website hosting

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servers. Website content could be hosted on Go Daddy's hosting servers, or on the hosting servers

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of another company. Go Daddy does not charge customers for domain forwarding, but rather

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offers this routing option as part of its registration services.

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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

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ROLING DECLARATION

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information necessary for routing domain names. If registrars stopped performing the function of

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taking name server information and providing it to registries, the Internet would grind to a halt.

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Domain Name Routing

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When a domain name registrant wants to route a domain name to a website, he or

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she can log into his or her account through the dashboard on Go Daddy's website, then identify

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the name servers associated with the website (the hosting provider usually provides the names or

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IP addresses of the name servers). The information is automatically sent to a different server at

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Go Daddy (the application server), which in turn automatically sends the information to other

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computers at Go Daddy. In the case of routing without forwarding, the information is

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automatically sent from the dashboard application, to the application server, to the EPP service

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(for .net, the .net EPP service). The EPP service automatically sends the name server information

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to the registry (for .net, Verisign).

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5.

"Routing" a domain name, without forwarding, means that a domain name

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registrant has identified name servers that contain the information to lead an ISP to the destination

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website content. I have attached as Exhibit 1 a true and correct representation of the automated

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process a domain name registrant customer of Go Daddy would complete to direct Go Daddy to

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"route" a domain name, without forwarding, by providing name server information. Exhibit 1

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shows the screen captures from July 27,2011.

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updated periodically over the past few years, but the functionality of the dashboard, in particular

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as it functions with respect to routing domain names via name server information, has not changed

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in any significant way since October 2006.

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Domain Name Forwarding

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The aesthetics of this user interface have been

Many entities "forward" multiple domain names to a single website; for example,

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the www.unitedairlines.com

and www.ual.com domain names are both forwarded to the website

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that resides at www.united.com.

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the automated process a domain name registrant customer of Go Daddy would complete to

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"forward" a domain name, or route it to an existing website. Exhibit 2 shows the screen captures

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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
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ROLING DECLARATION

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past few years, but the functionality of the dashboard, in particular as it functions with respect to

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forwarding domain names via name server information, has not changed in any significant way

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since October 2006.

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Forwarding is automated - no one from Go Daddy receives and processes requests

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from registrants to forward domain names. The process takes approximately 30 seconds and can

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be achieved in 3 clicks.

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In the case of forwarding, the information that the domain name registrant enters

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into the dashboard is automatically sent from the dashboard application to a Go Daddy application

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server, which in turn sends the information to the EPP service (for .net, the net EPP service) and

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the forwarding management database. The EPP service automatically sends the name server

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information to the registry (for .net, Verisign). A forwarding service automatically moves the

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information from the forwarding management database to the forwarding database.

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Sometimes, entities elect to forward a domain name with "masking," which means

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that the URL appearing in the web browser does not change when the domain name is forwarded.

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For example, if the domain name www.ual.com forwards to www.united.com:

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•

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window.

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•

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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 www.united.com.

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Go Daddy can only provide domain name forwarding services to domain names for

which Go Daddy is the registrar.
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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.
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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.
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Go Daddy provides forwarding services to approximately 8.2 million domain

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names under its management, and has provided such service in combination with its domain name

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routing services since 2002 or before.
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Forwarding is essential to domain name registrants because it allows multiple

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domain names to resolve to the same website content. Though a domain name registrant could

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develop a separate copy of the website for each domain name, this procedure would be inefficient

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for numerous reasons:

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it would require hosting for each domain name, requiring extra space and cost to
the domain name registrant;

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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;

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it would affect the rank of the website in search engines like Google or Yahoo,

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because Internet traffic routed to each individual website would not be recognized

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as flowing to the same website.

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The petronastowner.net
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and petronastowers.net Domain Names

After transferring the www.petronastower.net

and www.petronastowers.net

domain

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names to Go Daddy on April 1,2007, later the same day the domain name registrant - Heiko

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Schoenekess - used the Go Daddy online dashboard to forward the Internet traffic for the domain

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names to an existing website. A true and correct copy of the page of the account information

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record indicating that the domain name registrant forwarded the domain names is attached as

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Exhibit 4.

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I declare under penalty of perjury that the foregoing is true and correct. Executed at
Hiawatha, Iowa, on October 31, 2011.

/YOn

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