Petroliam Nasional Berhad v. GoDaddy.com, Inc.

Filing 124

Declaration of Nima Kelly in Support of 119 Administrative Motion to File Under Seal Motion for Partial Summary Judgment and Appendix in Support filed byGoDaddy.com, Inc.. (Attachments: # 1 Declaration Greg Schwimer ISO Plaintiff's Administrative Motion to Seal, # 2 Proposed Order, # 3 Exhibit A Part 1 to Proposed Order, # 4 Exhibit A Part 2 to Proposed Order, # 5 Exhibit A Part 3 to Proposed Order, # 6 Exhibit A Part 4 to Proposed Order, # 7 Exhibit A Part 5 to Proposed Order, # 8 Exhibit A Part 6 to Proposed Order, # 9 Exhibit A Part 7 to Proposed Order)(Related document(s) 119 ) (Slafsky, John) (Filed on 11/9/2011)

EXHIBIT A

1 PERRY R. CLARK, State Bar No. 197101
LAW OFFICES OF PERRY R. CLARK
2 825 San Antonio Road
Palo Alto, CA 94303
3 Telephone: [phone]
Facsimile: [phone]
4 [e-mail]
5 Attorney for Plaintiff
PETROLIAM NASIONAL BERHAD (PETRONAS)
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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13 PETROLIAM NASIONAL BERHAD
(PETRONAS),
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Plaintiff,
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vs.

17 GODADDY.COM, INC.,
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Defendant.

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CASE NO: 09-CV-5939 PJH
Noticed Hearing Date: December 7,
2011
Noticed Hearing Time: 9:00 a.m.

PUBLIC VERSION

PLAINTIFF’S APPENDIX
OF FED. R. CIV. P. 56(C)(1)(A) MATERIALS
IN SUPPORT OF MOTION FOR PARTIAL SUMMARY JUDGMENT

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PLAINTIFF’S APPENDIX
OF FED. R. CIV. P. 56(C)(1)(A) MATERIALS
Case No: 09-CV-5939 PJH

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Plaintiff Petroliam Nasional Berhad (Petronas) submits this Appendix of Fed. R. Civ. P.

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56(c)(1)(A) Materials In Support Of Motion For Partial Summary Judgment to facilitate the

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placement of materials into the record that support its factual positions. Plaintiff is submitting

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this appendix voluntarily as contemplated by the Committee Notes accompanying the 2010

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Amendment to Fed. R. Civ. R. Civ. P. 56, Subdivision (c)(1)(A), and to make use of the

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suggestion therein that “[p]ointing to a specific location in an appendix satisfies the citation

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requirement” of Fed. R. Civ. P. 56(c).

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The each page in this appendix has been number from APP001 to APP204 and Petronas
cites to specific location in this appendix by use of these page numbers.
Dated: November 2, 2011

LAW OFFICES OF PERRY R. CLARK

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By:

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-1PLAINTIFF’S APPENDIX
OF FED. R. CIV. P. 56(C)(1)(A) MATERIALS
Case No: 09-CV-5939 PJH

/s/ Perry R. Clark
.
Perry R. Clark
Attorney for Plaintiff
PETROLIAM NASIONAL BERHAD
(PETRONAS)

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 RONALD HERTZ

DATE:

Thursday, October 13, 2011

TIME:

12:05 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
APP001

Page 2
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::: APPEARANCES :::

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FOR PETROLIAM NASIONAL BERHAD (PETRONAS) PLAINTIFF:
Law Offices of Perry R. Clark
By: Perry R. Clark, Attorney At Law
825 San Antonio Road
Palo Alto, California 94303
[phone]
[e-mail]

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FOR GODADDY.COM, INC., DEFENDANT:
Wilson Sonsini Goodrich & Rosati
By: Tonia Ouellette Klausner,
Attorney At Law
1301 Avenue of the Americas, 40th Floor
New York, New York 10019-6022
[phone]
[e-mail]

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APP002

Page 3
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::: INDEX OF EXAMINATIONS :::

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EXAMINATION BY:

PAGE

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MR. CLARK

5, 14

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MS. KLAUSNER

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::: INDEX OF REQUESTS :::
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PAGE

LINE

REQUEST

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None

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APP003

Page 4
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::: INDEX OF EXHIBITS :::

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NUMBER

DESCRIPTION

PAGE

3

30

Document, Bates No. GD-00251-002607

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APP004

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Page 5
1

RONALD HERTZ

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being duly sworn by the Certified Shorthand Reporter

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to tell the truth, the whole truth, and nothing but

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the truth, testified as follows:

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EXAMINATION BY MR. CLARK

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Q.

Okay.

Good afternoon.

My name is Perry

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Clark.

I'm a lawyer for the plaintiff in this case,

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Petroliam Nasional Berhad who I will refer to as

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Petronas.

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MS. KLAUSNER:

And I'm Tonia Klausner.

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I'm here on behalf of Go Daddy.

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BY MR. CLARK:

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Q.

Okay.

Could you please state your name

for the record, please?

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A.

Ronald Hertz.

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Q.

Okay.

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A.

I do.

18

Q.

What is your current job title?

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A.

Vice President and Corporate Controller.

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Q.

How long have you had that title?

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A.

Approximately two years.

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Q.

And were you working for Go Daddy before

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And you work for Go Daddy?

you were Vice President?

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A.

I was.

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Q.

And what was your job title then?
APP005

Page 6
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A.

Corporate Controller.

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Q.

How long have you worked for Go Daddy?

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A.

Little over nine years.

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Q.

All right.

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in front of you.

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at Exhibit 1, please.

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there's a numbered paragraph 18 towards the top of

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that page.

So we have a pile of exhibits

Could you go ahead and take a look
If you could turn to page 9,

Do you see paragraph 18?

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A.

Yes.

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Q.

It says, "Go Daddy's business operations

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and financial information to which Go Daddy refers in

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its initial disclosure is dated July 15, 2010."

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you see that?

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A.

Yes.

15

Q.

Do

And do you understand you have been

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designated as Go Daddy's representative to testify on

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that topic?

18

A.

Yes.

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Q.

Okay.

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general -- okay.

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you might be giving a deposition in this case?

So can you tell me I guess in
When were you first informed that

22

A.

Approximately two weeks ago.

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Q.

Okay.

24

A.

Nima Kelly.

25

Q.

Okay.

And who was it?

Who informed you?

And what have you done to prepare
APP006

Page 7
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for your deposition?

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MS. KLAUSNER:

And I'll caution the

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witness not to disclose any conversations you might

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have had with attorneys.

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THE WITNESS:

I met with counsel and

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reviewed a couple of documents.

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BY MR. CLARK:

8

Q.

When did you meet with counsel?

9

A.

With outside counsel yesterday.

10

Q.

Okay.

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Did you do anything else to

prepare for your deposition?

12

A.

I did not.

13

Q.

Okay.

You said you reviewed some

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documents.

Did you review all the documents that you

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reviewed during your meeting with outside counsel?

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A.

No, I did not.

17

Q.

Okay.

You reviewed some documents

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outside of the time that you met with your counsel,

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correct?

20

A.

That is correct.

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Q.

All right.

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25

Do you recall what documents

you reviewed outside of your meeting with counsel?
A.

Yes.

I reviewed the Registrar-Registry

Agreement with VeriSign.
Q.

Any others?
APP007

Page 12
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A.

To the best of my knowledge, yes.

2

Q.

Do you know if this Registry-Registrar

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relates in any way to Go Daddy's domain name

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forwarding service?

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MS. KLAUSNER:

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THE WITNESS:

Object to the form.
Can you explain what you

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mean by "relates in any way"?

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BY MR. CLARK:

9

Q.

Does Go Daddy have any obligations

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arising from the .NET Registry-Registrar that relate

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to the conduct of its domain name forwarding service?

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MS. KLAUSNER:

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THE WITNESS:

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Can you restate the

question please?

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Object to the form.

BY MR. CLARK:

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Q.

Sure.

I'm just getting at, does the .NET

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Registry-Registrar Agreement govern any of Go Daddy's

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conduct with respect to providing its domain name

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forwarding service to Go Daddy's customers?

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22

A.

I'm not sure what you mean by governing

its conduct.
Q.

So can you explain in general what Go

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Daddy's obligations are under the .NET

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Registrar-Registry Agreement?

25

A.

My understanding of the agreement is it
APP008

Page 13
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sets out the guidelines between Go Daddy and VeriSign

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in registering .NET domain names.

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Q.

Does Go Daddy's domain name forwarding

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service relate to the registration of .NET domain

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names?

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A.

I'm not sure I understand the question.

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Q.

Is Go Daddy's domain name forwarding

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service part of its activity with respect to

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registering .NET domain names?

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A.

I don't believe the forwarding service

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relates at all to the registration of the domain

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name.

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Q.

Okay.

Just changing gears a little bit,

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topic 20 relates to an insurance agreement, and you

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mentioned an E and O insurance agreement.

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agreement made in connection with the Hiscox

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insurance agency?

18

A.

Hiscox is the insurance provider.

19

Q.

Okay.

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Is that an

Is that agreement still in effect?

Or I'm sorry, is that policy still in effect?

21

A.

It is not.

22

Q.

Has Go Daddy made a claim related to this

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case under any insurance policy other than the Hiscox

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insurance policy?

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A.

Not that I'm aware of.
APP009

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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]
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,
vs.
PETROLIAM NASIONAL BERHAD,
Counterclaim Defendant.

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CASE NO.: 09-CV-5939 PJH

GO DADDY’S RESPONSE TO
PLAINTIFF’S THIRD SET OF
INTERROGATORIES (NOS. 21-25)

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GO DADDY’S RESPONSE TO THIRD
SET OF INTERROGATORIES (NOS. 21-25)
Case No: 09-CV-5939 PJH

4534112_2.DOCX

APP010

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Pursuant to Federal Rule of Civil Procedure 33, Defendant / Counterclaimant

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GoDaddy.com, Inc. (“Go Daddy”), by and through its undersigned counsel, hereby responds to

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the Third Set of Interrogatories (“Requests”) by Plaintiff / Counterclaim Defendant Petroliam

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Nasional Berhad (“Plaintiff” or “Petronas”).

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No admissions of any nature whatsoever are implied by, or should be inferred from, these

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Responses. Each of these Responses is based on Go Daddy’s understanding of each individual

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interrogatory and, to the extent that Plaintiff asserts an interpretation of any interrogatory that is

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inconsistent with that understanding, Go Daddy reserves the right to supplement these

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Responses.

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GENERAL OBJECTIONS
Go Daddy makes the following general objections, whether or not separately set forth in

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response to each interrogatory. Although Go Daddy may repeat some of these general objections

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in a specific response because they are particularly applicable, such specific citations are not to

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be construed as a waiver of any other general objections applicable to the interrogatory. These

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general objections are incorporated in each response to each interrogatory as if fully set forth in

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each of the individual responses below.

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GENERAL OBJECTION NO. 1:

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Go Daddy objects to the Requests, and to each and every individual interrogatory, to the

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extent they seek information protected by the attorney-client privilege, work product doctrine,

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and/or any other applicable privilege or protection. Without prejudice to this objection, Go Daddy

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will provide responses to the Requests to the extent that such responses do not waive such

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privileges or protections.

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GENERAL OBJECTION NO. 2:

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All responses to the Requests are based upon the information presently known to Go

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Daddy and are given without prejudice to Go Daddy’s right to adduce evidence discovered or

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analyzed subsequent to the date of these responses. Go Daddy expressly reserves the right to

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revise and supplement its responses to the Requests.

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GO DADDY’S RESPONSE TO THIRD
SET OF INTERROGATORIES (NOS. 21-25)
Case No: 09-CV-5939 PJH

~2~
APP011

4534112_2.DOCX

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2

GENERAL OBJECTION NO. 3:
Go Daddy objects to the Requests, and to each and every individual interrogatory, to the

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extent they seek information outside of Go Daddy’s possession, custody, or control, on the

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grounds that any such request is overbroad and unduly burdensome, seeks to impose discovery

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obligations in excess of those imposed by the Federal Rules of Civil Procedure, and would subject

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Go Daddy to unreasonable annoyance, burden, and expense.

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GENERAL OBJECTION NO. 4:

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9

Go Daddy objects to the Requests, and to each and every individual interrogatory, as
unduly burdensome, oppressive and in violation of the Federal Rules of Civil Procedure to the

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extent they purport to require Go Daddy to respond on behalf of, or conduct any inquiry or

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investigation with respect to, any party other than Go Daddy. Go Daddy will only answer the

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request on its own behalf.

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GENERAL OBJECTION NO. 5:

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Go Daddy objects to the Requests to the extent that they seek information that is neither

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relevant, admissible, nor reasonably calculated to lead to the discovery of admissible evidence,

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and to the extent that they require Go Daddy to make legal conclusions.

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GENERAL OBJECTION NO. 6:

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Go Daddy objects to the Requests, and to each and every individual interrogatory, as

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overbroad and unduly burdensome to the extent they do not include a limitation or proposed

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definition of a relevant time period.

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GENERAL OBJECTION NO. 7:

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Go Daddy objects to the Requests, and to each and every individual interrogatory, to the

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extent they are not consistent with or do not meet the requirements of Federal Rules of Civil

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Procedure. Go Daddy’s agreement to endeavor to answer the Requests, and each and every

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individual interrogatory, is not, and should not be construed as, Go Daddy’s waiver of its right to

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object to these or any other requests as violative of the Federal Rules of Civil Procedure.

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GENERAL OBJECTION NO. 8:

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Go Daddy objects to the Requests, and to each and every individual interrogatory
GO DADDY’S RESPONSE TO THIRD
SET OF INTERROGATORIES (NOS. 21-25)
Case No: 09-CV-5939 PJH

~3~
APP012

4534112_2.DOCX

1

contained therein, to the extent they seek information related to experts. Go Daddy will provide

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information related to experts consistent with the Court’s schedule for expert discovery.

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GENERAL OBJECTION NO. 9:

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Go Daddy specifically reserves all objections as to the competence, relevancy, materiality,

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and admissibility of its documents and interrogatory responses or the subject matter thereof, and

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all rights to object on any ground to the use of any document or interrogatory response, or the

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subject matter thereof, in any subsequent proceeding, including without limitation the trial of this

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or any action. Go Daddy’s Responses are made expressly subject to, and without in any manner

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waiving, any and all objections to the competency, relevance, materiality and/or admissibility of

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any of the matters encompassed in the following Responses.

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SPECIFIC RESPONSES AND OBJECTIONS

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Go Daddy expressly incorporates the above General Objections as though set forth fully in

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response to each of the following individual interrogatories and, to the extent they are not raised in

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any particular response, Go Daddy does not waive those objections. An answer to an

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interrogatory shall not be deemed a waiver of any applicable specific or general objection.

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Likewise, an answer to an interrogatory shall not be deemed an admission of any assertions

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contained in that interrogatory.

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INTERROGATORY NO. 21:

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Please describe in detail the services provided by GoDaddy related to the disputed

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domain names, including technical aspects of routing/forwarding the disputed domain names.

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RESPONSE TO INTERROGATORY NO. 21:

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In addition to the General Objections, Go Daddy objects to this interrogatory on the

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grounds that it is cumulative, overbroad and harassing, vague, ambiguous and unintelligible,

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particularly with respect to the phrase “services provided by GoDaddy related to the disputed

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domain names...”.

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Subject to and without waving the foregoing objections, Go Daddy responds as follows:

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Since April 1, 2007, Go Daddy has served as the registrar for the domain names

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“petronastower.net” and “petronastowers.net.” As part of its registrar services, Go Daddy
GO DADDY’S RESPONSE TO THIRD
SET OF INTERROGATORIES (NOS. 21-25)
Case No: 09-CV-5939 PJH

~4~
APP013

4534112_2.DOCX

1

provided routing services, pointing the domain names to the name servers or websites of the

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registrant’s choosing. At times, Go Daddy routed or “forwarded” the domain names to a pre-

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existing website, automatically at the request of the domain name registrant. Further information

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concerning the services provided by Go Daddy to the domain names can be found at GD-

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000293; GD-000298; GD-000361—GD-000362; GD-000366; GD-000384—GD-000392; GD-

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000560—GD-000563 of Go Daddy’s production. Go Daddy transferred the petronastower.net

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domain name to counsel for Petronas, Perry Clark, on May 18, 2010. Go Daddy transferred the

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petronastowers.net domain name to Clark on August 30, 2010. For additional details regarding

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the technical aspects of the services provided, see the Expert Report of Michael Palage, served

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on Petronas on October 3, 2011.

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INTERROGATORY NO. 22:

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Please describe in detail the information GoDaddy has in its possession regarding David

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Daash and the “registration and use of the disputed domain names; hosting of destination

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website; destination website content,” to which GoDaddy refers in its supplemental initial

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disclosures dated June 29, 2011, including when GoDaddy became aware that David Daash was

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the registrant of one or both of the disputed domain names and any changes to the Whois record

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related thereto.

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RESPONSE TO INTERROGATORY NO. 22:

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Subject to and without waving the foregoing objections, Go Daddy responds as follows:

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The contact audit history possessed by Go Daddy for domain name “petronastower.net”

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indicates that at the time petronastower.net was transferred to Go Daddy on April 1, 2007, Heiko

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Schoenekess was the registrant. The registrant of petronastower.net was changed by the account

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holder to David Daash on April 1, 2007. On July 2, 2009 the registrant was changed by the

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account holder back to Heiko Schoenekess. On December 12, 2009, the registrant of

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“petronastower.net” was changed by the account holder to David Daash, and again back to Heiko

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Schoenekess on the very same date. The contact audit history relating to David Daash and

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petronastower.net, including Daash’s listed registrant contact information, can be found at GD-

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000151—GD-000152 of Go Daddy’s production. A copy of the results of a Whois search for
GO DADDY’S RESPONSE TO THIRD
SET OF INTERROGATORIES (NOS. 21-25)
Case No: 09-CV-5939 PJH

~5~
APP014

4534112_2.DOCX

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petronastower.net from December 21, 2009—listing David Daash as the registrant—can also be

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found at GD-000618—GD-000619 of Go Daddy’s production.

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The contact audit history possessed by Go Daddy for domain name “petronastowers.net”

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indicates that at the time petronastowers.net was transferred to Go Daddy on April 1, 2007,

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Heiko Schoenekess was the registrant. The registrant of petronastowers.net was changed by the

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account holder to David Daash on April 1, 2007. On July 2, 2009 the registrant was changed by

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the account holder back to Heiko Schoenekess. The contact audit history relating to David

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Daash and petronastowers.net, including Daash’s listed registrant contact information, can be

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found at GD-000109—GD-000110 of Go Daddy’s production.

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INTERROGATORY NO. 23:
Please describe in detail the information GoDaddy has in its possession regarding Bruno

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Zehnder and the “hosting of destination website and destination website content” to which

13

GoDaddy refers in its supplemental initial disclosures dated June 29, 2011.

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RESPONSE TO INTERROGATORY NO. 23:

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Subject to and without waving the foregoing objections, Go Daddy responds as follows:

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On December 21, 2009, a search was performed in the Whois database to determine the

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domain name and contact information for the registrant of the domain name “visit-x.net”—the

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“destination website” to which “petronastower.net” had been directed as of December 21, 2009.

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The Whois search results indicate Bruno Zehnder to be the registrant of “visit-x.net.” Further

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information concerning this search, as well as a copy of the search results, can be found at GD-

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001593—GD-001603 of Go Daddy’s production.

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INTERROGATORY NO. 24:

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Please describe in detail GoDaddy’s services for “External Domains” to which GoDaddy

24

refers in the document produced with production PET GD 2469 (attached hereto as Exhibit A),

25

including the technical aspects of such services and the differences, if any, between those

26

services and the “routing/forwarding the disputed domain names” to which GoDaddy refers in its

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supplemental initial disclosures dated June 29, 2011 and by identifying all persons with

28

knowledge of the foregoing and by describing all documents related to the foregoing.
GO DADDY’S RESPONSE TO THIRD
SET OF INTERROGATORIES (NOS. 21-25)
Case No: 09-CV-5939 PJH

~6~
APP015

4534112_2.DOCX

1
2

RESPONSE TO INTERROGATORY NO. 24:
In addition to the General Objections, Go Daddy objects to this interrogatory on the

3

grounds that it is cumulative, overbroad and harassing, vague, ambiguous and unintelligible,

4

particularly with respect to the phrase “services provided by GoDaddy related to the disputed

5

domain names...”.

6

Subject to and without waving the foregoing objections, Go Daddy responds as follows:

7

The reference to “External Domains” in the document Bates-numbered PET GD 2469

8

indicates that Go Daddy hosting customers can have traffic routed to Go Daddy-hosted websites

9

from domains registered elsewhere (not with Go Daddy) (“external domains”). Such routing is

10

the same as “routing/forwarding” as referenced in Go Daddy’s supplemental initial disclosures.

11

Go Daddy does not provide any services for the external domains themselves.

12
13
14

Persons with relevant knowledge include Jeff Munson and John Roling.
INTERROGATORY NO. 25:
Please state when GoDaddy first began providing the domain name forwarding service to

15

which it refers in Paragraph 29 of its Amended Answer June 20, 2011 to any customer and

16

identify all persons with knowledge of the foregoing and describe all documents related to the

17

foregoing.

18

RESPONSE TO INTERROGATORY NO. 25:

19
20

In addition to the General Objections, Go Daddy objects to this interrogatory on the
grounds that it is overbroad and harassing.

21

Subject to and without waving the foregoing objections, Go Daddy responds as follows:

22

Go Daddy first began providing domain name forwarding services on April 3, 2001.

23

Persons with relevant knowledge include George Kearns

24
25

Dated: October 19, 2011

WILSON SONSINI GOODRICH & ROSATI
Professional Corporation

26
By:

27

.
John L. Slafsky
David L. Lansky
Hollis Beth Hire

28
GO DADDY’S RESPONSE TO THIRD
SET OF INTERROGATORIES (NOS. 21-25)
Case No: 09-CV-5939 PJH

~7~
APP016

4534112_2.DOCX

APP017

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 LAURIE ANDERSON

DATE:

Wednesday, October 12, 2011

TIME:

8:54 a.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
APP018

Page 2
1

::: APPEARANCES :::

2
3
4
5
6

FOR PETROLIAM NASIONAL BERHAD (PETRONAS) PLAINTIFF:
Law Offices of Perry R. Clark
By: Perry R. Clark, Attorney At Law
825 San Antonio Road
Palo Alto, California 94303
[phone]
[e-mail]

7
8
9
10
11

FOR GODADDY.COM, INC., DEFENDANT:
Wilson Sonsini Goodrich & Rosati
By: David L. Lansky, Attorney At Law
650 Page Mill Road
Palo Alto, California 94304-1050
[phone]
[e-mail]:

12
13
14
15
16
17
18
19
20
21
22
23
24
25
APP019

Page 3
1

::: INDEX OF EXAMINATIONS :::

2
EXAMINATION BY:

PAGE

3
MR. CLARK

5

4
5
6
7
::: INDEX OF REQUESTS :::
8
PAGE

LINE

32

15

REQUEST

9
10

Mark the transcript as 30(b)(6)
deposition

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
APP020

Page 4
1

::: INDEX OF EXHIBITS :::

2

NUMBER

DESCRIPTION

PAGE

3

1.

Anderson 30(b)(6) Deposition Notice

6

4

2.

Document, Bates No. GD-001494-001526

9

5

3.

Document, Bates No. GD-002446-2550

14

6

4.

Document, Bates No. GD-00560-561

28

7

5.

Document, Bates No. GD-00562-563

28

8

6.

Document, Bates No. GD-000272-392

32

9

7.

Document, Bates No. GD-000393-419

32

10

8.

Document, Bates No. GD-000614-629

48

11

9.

Document, Bates No. GD-000420-487

51

12

10.

Document, Bates No. GD-000532-559

53

13

11.

Document, Bates No. GD-000500-502

61

14

12.

Document, Bates No. GD-000488-499

63

15

13.

Document, Bates No. PET GD000216-272

66

16

14.

ICANN/Uniform Domain Name Dispute
Resolution Policy

71

17
18
19
20
21
22
23
24
25
APP021

Page 5
1

LAURIE ANDERSON,

2

being duly sworn by the Certified Shorthand Reporter

3

to tell the truth, the whole truth, and nothing but

4

the truth, testified as follows:

5
6

EXAMINATION BY MR. CLARK
Q.

All right.

Good morning.

I'm a lawyer.

My name is

7

Perry Clark.

I represent the

8

plaintiff in this case, Petroliam Nasional Berhad

9

also known as Petronas, and I think counsel probably

10

wants to make an appearance as well.

11

MR. LANSKY:

Yeah, this is David Lansky

12

of Wilson Sonsini Goodrich & Rosati on behalf of the

13

deponent.

14

BY MR. CLARK:

15

Q.

Now, do you understand that the oath you

16

took today, that means that the testimony you're

17

giving today is under penalty of perjury the same as

18

it would be in a court of law?

19

A.

Yes.

20

Q.

And can I ask that if you don't

21

understand any of my questions or need clarification

22

of anything I'm asking, that you ask me to clarify

23

the question?

24
25

A.

Yes.
MR. CLARK:

Okay, great.
APP022

All right.

I'd

Page 6
1

like to have the court reporter mark as Exhibit

2

number 1 the 30(b)(6) deposition notice that we

3

served in this case.

4
5
6

(DEPOSITION EXHIBIT 1 WAS MARKED.)
BY MR. CLARK:
Q.

So I'm handing the witness what's been

7

marked as deposition Exhibit Anderson 1, and have you

8

seen this document before?

9

A.

I have.

10

Q.

And so I'd like to begin by taking your

11

deposition as a Rule 30(b)(6) deponent, and we'll

12

have this part of the transcript marked as the

13

30(b)(6) deposition.

14

Now, you have been designated to testify

15

on a number of topics in this notice.

16

understand that?

17

A.

Yes.

18

Q.

Okay.

Do you

And if you could turn to page 8 of

19

the deposition notice, you'll see there there's

20

number 5 -- topic number 5.

21

A.

Okay.

22

Q.

And do you understand that you've been

23

designated to testify on that topic which is the

24

domain name forwarding service to which Go Daddy

25

refers in paragraph 29 of its amended answer, June
APP023

Page 7
1

20, 2011, including when Go Daddy began to provide

2

that service to any customer?

3

A.

Yes.

4

Q.

Okay.

Now, when did Go Daddy first

5

provide domain name forwarding services to any

6

customer?

7

A.

I believe it was April of 2001.

8

Q.

Okay.

9

And when did Go Daddy first begin

providing domain name registration for customers?

10

A.

I think it was November of 2000.

11

Q.

Go Daddy was able to provide domain name

12

registrations without providing domain name

13

forwarding services from November 2000 to April 2001?

14

A.

I didn't work there at that time so I

15

really can't say.

16

Q.

Okay.

Can you describe -- actually,

17

referring back to topic number 5, the domain name

18

forwarding service to which Go Daddy refers in

19

paragraph 29 of its amended answer, is that the

20

domain name forwarding service it provided for the

21

registrant of the domain names Petronas Tower and

22

petronastowers.net?

23

A.

Yes.

24

Q.

Can you describe that domain name

25

forwarding service for me?
APP024

Page 8
1
2

A.

Domain name forwarding directs a domain

name to a specific URL.

3

Q.

It's a type of routing.

Are ICANN accredited registrars required

4

to provide domain name forwarding to their registrant

5

customers?

6

A.

I don't know.

7

Q.

Are ICANN accredited registrars required

8

to provide any sort of routing services to their

9

registrant customers?

10
11

A.

I don't know whether that's required or

Q.

Do you know if Go Daddy was an ICANN

not.

12
13

accredited registrar between November 2000 and April

14

2001?

15
16
17

A.

I believe they became a registrar -- an

ICANN accredited registrar in November of 2000.
Q.

So ICANN stands for the Internet

18

Corporation for Assigned Names and Numbers; is that

19

correct?

20

A.

Correct.

21

Q.

Okay.

Does ICANN require accredited

22

registrars like Go Daddy to provide the function of

23

routing Internet traffic to websites of registrant's

24

choices?

25

A.

I don't know whether they require it, but
APP025

Page 15
1

Q.

So these would include instructions for

2

Go Daddy customers as to how to use Go Daddy's

3

services?

4

A.

Yes.

5

Q.

Could you please turn to the page marked

6

with Bates number GD-002453.

7

second full paragraph on that page, please?

8
9

A.

Now, could you read the

"If you registered your domain name with

another provider, you can still purchase a hosting

10

account with us.

11

use our CashParking or Quick Content services.

12

you do any of those, you must view your nameservers

13

and your account with us and then set the nameservers

14

with your domain name registrar."

15

Q.

These are off-site DNS services or
If

So can a customer of Go Daddy's who's

16

registered their domain name with another provider

17

purchase a hosting account and use Go Daddy's

18

off-site DNS services?

19

A.

I believe so.

20

Q.

Could -- and if a customer who registered

21

-- if a Go Daddy customer who registered their domain

22

name with another provider and had purchased a

23

hosting account with Go Daddy and used Go Daddy's

24

off-site DNS services, would that customer have to

25

use Go Daddy's nameservers?
APP026

Page 21
1

Q.

Okay.

So as Go Daddy's designated

2

representative for topic number 5 in the Rule

3

30(b)(6) deposition notice which is the domain name

4

forwarding service to which Go Daddy refers in

5

paragraph 29 of its amended answer, you don't know if

6

Go Daddy could have performed the registration and

7

maintenance of the domain names petronastower.net and

8

petronastowers.net without providing that domain name

9

forwarding service?

10
11

MR. LANSKY:
question.

12
13
14

Object to the form of the

THE WITNESS:

Can you repeat?

BY MR. CLARK:
Q.

So you understand that you're Go Daddy's

15

designated representative for topic 5 in Petronas'

16

Rule 30(b)(6) deposition notice, correct?

17

A.

Yes.

18

Q.

And topic number 5 is the domain name

19

forwarding service to which Go Daddy refers in

20

paragraph 29 of its amended answer dated June 20,

21

2011, correct?

22

A.

Yes.

23

Q.

Do you know if Go Daddy would have been

24

able to perform the registration and maintenance of

25

the domain names Petronas Towers -- petronastower.net
APP027

Page 22
1

and petronastowers.net without providing that domain

2

name forwarding service?

3

MR. LANSKY:

4

THE WITNESS:

Object to the form.
I believe that's -- I

5

believe that they could depending on what the

6

customer requires or wants to do with the domain

7

name.

8

BY MR. CLARK:

9

Q.

So you believe that Go Daddy could have

10

performed the registration and maintenance of the

11

domain names Petronas Tower and petronastowers.net

12

without providing its domain name forwarding service,

13

correct?

14

MR. LANSKY:

Object to the form.

15

Misstates the entirety of her testimony and asked and

16

answered.

17

THE WITNESS:

If Petronas Towers domain

18

names could have been pointed to another website by

19

using the A record method, so I'm going to say yes.

20

BY MR. CLARK:

21

Q.

Okay.

22

A.

In other words, the same thing could have

23
24
25

been accomplished using the A record method.
Q.

Okay.

So Go Daddy did not -- well, we've

already covered that.
APP028

Page 27
1

MR. LANSKY:

2

THE WITNESS:

3

Object to the form.
I don't know.

BY MR. CLARK:

4

Q.

Do you know when Go Daddy first began

5

providing domain name forwarding services for the

6

domain name petronastower.net?

7

A.

I don't recall.

8

Q.

Do you know if Go Daddy provided domain

9

name forwarding services for petronastower.net at the

10

time it first became the registrar for that domain

11

name?

12

A.

I don't recall.

13

Q.

If Go Daddy had not provided domain name

14

forwarding services when it first became the

15

registrar of petronastower.net, could it have

16

performed the registration and maintenance of that

17

domain name?

18

MR. LANSKY:

19

THE WITNESS:

20
21

I believe so.

BY MR. CLARK:
Q.

Is the same true for petronastowers.net?

22

MR. LANSKY:

23

THE WITNESS:

24

MR. CLARK:

25

Object to the form.

Object to the form.
I believe so.
I'm now going to have the

court reporter mark as Anderson Exhibit 4 a document
APP029

Page 44
1

Q.

And in that box there it says, "Action

2

taken.

We received notification of pending court

3

dispute.

4

admin fee.

5

complaint from complainant's representative within

6

the next few days."

Lock name, set to status 10 and charged
Registrant should receive notice of the

Do you see that?

7

A.

Yes.

8

Q.

Do you know if Go Daddy had any

9

communication with the registrant of

10

petronastower.net after it received the notification

11

referred to in this document?

12

A.

I don't know.

13

Q.

Do you see to the left of this entry

14

there's a name there.

It's Christopher Patterson?

15

A.

Yes.

16

Q.

Who's Christopher Patterson?

17

A.

He's disputes representative.

18

Q.

Was he responsible for handling the

19
20

dispute regarding petronastower.net?
A.

He would have been the one that set it up

21

when we received the claim -- or when we received the

22

dispute, he would have set up the claim.

23

Q.

Okay.

Now, do you know if the registrant

24

of the domain name petronastower.net ever disputed

25

Petronas' allegations that it was committing
APP030

Page 45
1

trademark infringement?

2

A.

I don't know.

3

Q.

Okay.

Now, if you could turn to the page

4

bearing Bates number GD-00298.

And a little bit

5

above, halfway down the page there's another entry.

6

It says, "Domain services tracking."

7

towards the bottom of that entry it says, "Action

8

taken.

9

see that?

10

A.

Yes.

11

Q.

So what does that refer to?

12

A.

If we receive a court order to implement

And sort of

Transferred domain per court order."

Do you

13

a decision to or a temporary restraining order.

14

Sometimes we'll be ordered to move a domain name to

15

the control of the complaining party.

16

Q.

Okay.

Now, it says there in the next

17

row, it says, "Canceling petronastower.net order ID

18

one row ID one name space forwarding resource ID."

19

Do you see that?

20

A.

Yes.

21

Q.

What does that refer to?

22

A.

When the domain name was moved out of the

23

account, the forwarding would have been automatically

24

canceled.

25

Q.

Okay.

Now, after the domain name was
APP031

Page 65
1

A.

We could not have canceled the domain

2

names because we are subject to the UDRP.

3

would have had to have either an arbitration decision

4

or a court order to transfer the domain names or

5

cancel them.

6

Q.

Uh-huh.

So we

But is there anything in the

7

Universal Terms of Service agreement or any other

8

agreement between Go Daddy and the registrant that

9

would have prevented Go Daddy from suspending those

10

domain names in response to the complaints from

11

Petronas?

12

MR. LANSKY:

13

THE WITNESS:

14
15

Object to the form.
I don't -- I don't know.

BY MR. CLARK:
Q.

Is there anything in any of the

16

agreements between Go Daddy and the registrant of the

17

domain names petronastower.net and petronastowers.net

18

that would have prevented it from stopping its domain

19

name forwarding service for those domain names?

20

MR. LANSKY:

21

THE WITNESS:

22
23

Object to the form.
I don't know.

BY MR. CLARK:
Q.

Do you know if Go Daddy ever received any

24

complaint or any communication from the registrant of

25

those domain names when Go Daddy stopped providing
APP032

Page 66
1

its domain name forwarding service?

2

A.

I don't know.

3

Q.

Okay.

4
5
6

(DEPOSITION EXHIBIT 13 WAS MARKED.)
BY MR. CLARK:
Q.

I'm now handing the witness a document

7

that has been marked as Exhibit 13, and it has

8

production numbers PET GD000216 to 272.

9

tell me what Exhibit 13 is?

10
11
12
13

A.

And can you

It appears to be the May 2001 version of

the Registrar Accreditation Agreement.
Q.

And do you know if this is the Registrar

Accreditation Agreement that was in effect in 2010?

14

A.

I don't know.

15

Q.

Okay.

Now, is there anything in this

16

Registrar Accreditation Agreement that would have

17

prevented Go Daddy from discontinuing its domain name

18

forwarding service for the domain names Petronas

19

Tower and petronastower.net?

20

A.

I don't know.

21

Q.

Do you know why Go Daddy did not

22

discontinue its domain name forwarding service for

23

the domain name petronastower.net after it received

24

Petronas' notification of trademark infringement

25

related to that domain name?
APP033

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APP039

lvarlredirllogs/redir-03-23-2010.1o9:[20:15:08] redirect_type:301,
RowAction:
masked:3467763,
subdomain:.petronastowers.net,
domain:petronastowers.net,
p,
statuspendsetu http://unruw. mfunchat. m
ca
co
:
subdomain.
.3467763
lvarlredirllogs/redir-03-23-2010.1o9:[20:15:08]
PENDSETUP masked
domain:petronastowers.net url:http://wunnr. mfunchat.com
ca
petronastowers.net
from
Ivarlredirllogs/redir-03-23-2010.1o9:[20:1INFO- deleting
5:08]
removequeue
table
petronastowers.net
from
lvarlredirllogs/redir-03-23-2010.log:[20:15:08] - deleting
lNFO
masked
table
vrnnnru.petronastowers,net
/var/redir/logs/redir-03-23-2010.1o9:[20:15:08]- deleting
INFO
from maskedtable
petronastowers.net
lvarlredirllogs/redir-A3-23-2010.1o9:[20:15:08] inserting
and
INFOpetronastowers. into maskedtable
urunr.
net
(2)
lvarlredirllogs/redir-03-23-2010.1o9:[20:15:08]- deleting petronastowers.net
and
INFO
petronastowers.net pointers
uruwv.
table
from
/var/redir/logs/redir-O3-23-2010.1o9:[20:15:08] inserting
add-fwd-domain
eventinto
INFOpetronastowers.
orionfor
net
/var/redir/logs/redir-05-02-2009.1o9:[10:00:39] redirect_type:301
RowAction:
,
masked:3467763,
domain:petronastowers.net,
subdomain:.petronastowers.net,
statu :pendsetup, http.
s
//wnv. camfunchat.com
/var/redir/logs/redir-A5-02-2009.1o9:[10:00:39]
PENDSETUP masked:3467763
subdomain:
domain:petron stowe net url:http://unnnu. mfunchat.com
a
rs.
ca
petronastowers.net
Ivarlredirllogs/redir-05-02-2009.1o9:[10:00:39] deleting
from
INFOremovequeue
table
petronastowers.net
lvarlredirllogs/redir-05-02-2009.1o9:[10.00:39]- deleting
from
INFO
masked
table
lvarlredirllogs/redir-05-02-2009.1o9:[10:00:39]- deleting
unirnru.petronastowers.net
INFO
frommasked
table
petronastowers.net
and
/var/redir/logs/redir-05-02-2009.1o9:[10:00:39]- inserting
INFO
petronastowers. into maskedtable
unnnrv.
net
(2)
/var/redir/logs/redir-05-02-2009.1og:[10:00:39]- deleting petronastowers.net
and
INFO
petronastowe net from pointers table
un*nv.
rs.
lvarlredirllogslredir-05-02-2009.1o9:[10:00:39]- inserting
INFO
add-fwd-domain
eventinto
orionfor petronastowers.
net
/var/redir/logs/redir-A5-02-2009.1o9:[1 RowAction:
0:15:01]
redirect_type:301
,
masked:3467763,
domain:petronastowers.net,
subdomain:.petronastowers.net,
status:active,
http://rlww. mfunchat.com
ca
/var/redirllogs/redir-05-02-2009.1o9:[10:15:01]ACTIVE:
rilssk€d:3467763
subdomain:
domain:petron stowe net url:http://uruurv.mfunchat.com
a
rs.
ca
(2)
Ivarlredirllogs/redir-A5-02-2009.1o9:[10:15:01] deleting petronastowers.net
and
INFOpetronastowers. from pointers
wrnru.
net
table
/var/redir/logs/redir-05-02-2009.1o9:[10:30:01]RowAction:
redirect_type:301,
masked:3467763,
domain:petronastowers.net,
subdomain:.petronastowers.net,
status:active,
http://unnnv.mfunchat.com
ca
Ivarlredirllogs/redir-05-02-2009.1o9:[10:30:01]- masked
ACTIVE
.3467763
subdomain:
domain:petronastowers.net url:http:/lunrrnry.mfunchat.com
ca
(2)
and
lvarlredirllogs/redir-05-02-2009.1o9:[10:30:01]- deleting petronastowers.net
INFO
petronastowers. from pointers
net
table
wruw.
Ivarlredirllogs/redir-05-03-2008.1o9:[14:15.07] redirect_type:301,
RowAction:

APP040

CONFIDENTIAL

GD-000560

masked:3467763,
domain:petronastowers.net,
subdomain:.petronastowers.net,
p,
statu :pen
s
dsetu http/Aruunv. nchat.
:
camfu
com
lvarlredirllogs/redir-05-03-2008.1o9:[14:15:07] - masked:3467763
PENDSETUP
subdomain:
doman:petro astowe net url:http//unrrnry. unchat.com
i
n
rs.
:
camf
lvarlredirllogs/redir-05-03-2008.1o9:[1415:07]
petronastowers.net
INFO deleting
from
removequeue
table
lvarlredirllogs/redir-05-03-2008.1o9:[1415.07]
petronastowers.net
tNFO deleting
from
masked
table
lvarlredirllogs/redir-05-03-2008.1o9:[14.15.07]
INFO deleting
vrnrrnrv.petronastowers.net
frommasked
table
lvarlredirllogs/redir-05-03-2008.1o9:[14.15:07]
petronastowers.net
INFO inserting
and
wnv.petronastowers.intomasked
net
table
lvarlredirllogs/redir-05-03-2008.1o9:[141507]
(2)
INFO deleting petronastowers.net
and
petronastowers.frompointers
unruw,
net
table
lvarlredirllogs/redir-05-03-2008.1o9:[14:15:07]
INFO inserting
add-firvd-domain into
event
petronastowers.
orion
for
net

APP041

CONFIDENTIAL

GD-000561

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APP042

http://www.godaddy.com/hosting/web-hosting.aspx?ci=8971

PET GD002468

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Web Hosting | Secure Hosting Plans with Unlimited Bandwidth

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