Petroliam Nasional Berhad v. GoDaddy.com, Inc.

Filing 142

Declaration of Perry Clark in Support of 141 Reply in support of Motion for Partial Summary Judgment filed by Petroliam Nasional Berhad. (Clark, Perry) (Filed on 11/23/2011) Modified on 11/28/2011 (vlk, COURT STAFF).

1
2
3
4
5

PERRY R. CLARK, State Bar No. 197101
LAW OFFICES OF PERRY R. CLARK
825 San Antonio Road
Palo Alto, CA 94303
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Plaintiff
PETROLIAM NASIONAL BERHAD (PETRONAS)

6
7
8
9
10

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

11
12
13

PETROLIAM NASIONAL BERHAD
(PETRONAS),
Plaintiff,

14
15

vs.

16

GODADDY.COM, INC.,

17

Defendant.

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

18
19
20
21
22

DECLARATION OF PERRY CLARK
IN SUPPORT OF
PLAINTIFF PETRONAS’S
REPLY IN SUPPORT OF ITS MOTION FOR
PARTIAL SUMMARY JUDGMENT ON GODADDY’S LIABILITY FOR
CONTRIBUTORY CYBERSQUATTING

23
24
25
26
27
28
CLARK DECL. ISO REPLY ISO MTN. PART. SUMMARY JUDGMENT
Case No: 09-CV-5939 PJH

1
2

I, Perry Clark, declare:
1.

3

Plaintiff Petroliam Nasional Berhad (Petronas). I have personal knowledge of the

4
5

facts set forth in this declaration.
2.

6
7
8
9
10

I am an attorney admitted to practice law before this Court and the attorney for

Attached hereto as Exhibit A is a true and correct copy of cited portions from the
deposition transcript of the October 20, 2011 deposition of Tracy Carlson, Esq.

3.

Attached hereto as Exhibit B is a true and correct copy of GoDaddy’s
Supplemental Initial Disclosures in this action dated June 29, 2011.

I declare under penalty of perjury that the foregoing is true and correct. Executed in Palo
Alto, California on November 23, 2011.

11
12
13
14

By:

/s/ Perry R. Clark
Perry R. Clark

15
16
17
18
19
20
21
22
23
24
25
26
27
28
1
CLARK DECL. ISO REPLY ISO MTN. PART. SUMMARY JUDGMENT
Case No: 09-CV-5939 PJH

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18

Ex. A

19
20
21
22
23
24
25
26
27
28
2
CLARK DECL. ISO REPLY ISO MTN. PART. SUMMARY JUDGMENT
Case No: 09-CV-5939 PJH

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 TRACY CARLSON

DATE:

Thursday, October 20, 2011

TIME:

3:09 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
Tracy Carlson

Berhad/Petronas v. GoDaddy

1

::: APPEARANCES :::

2
3

FOR PETROLIAM NASIONAL BERHAD (PETRONAS) PLAINTIFF:

4

Law Offices of Perry R. Clark
By: Perry R. Clark, Attorney At Law
825 San Antonio Road
Palo Alto, California 94303
[phone]
[e-mail]

5
6
7
8

FOR GODADDY.COM, INC., DEFENDANT:

9
10
11
12

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]

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

::: CONFIDENTIAL :::

Page: 2

10/20/2011
Tracy Carlson

Berhad/Petronas v. GoDaddy

1

::: INDEX OF EXAMINATIONS :::

2
EXAMINATION BY:

PAGE

3
MR. CLARK

5

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

LINE

REQUEST

9
10

None

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

::: CONFIDENTIAL :::

Page: 3

10/20/2011
Tracy Carlson

Berhad/Petronas v. GoDaddy

1

::: INDEX OF EXHIBITS :::

2

NUMBER

DESCRIPTION

3

43.

Go Daddy's Response to Plaintiff's
Second Set of Interrogatories
(Nos. 9-20)

10

Letter to Mr. Clark from Mr. Slafsky,
10/18/11

11

Go Daddy's Response to Plaintiff's
Third Set of Interrogatories
(Nos. 21-25)

12

Verification of Defendant Go Daddy's
Response to Plaintiff's Third Set
Of Interrogatories (Nos. 21-25)

12

4
5

44.

PAGE

6
45.
7
8
46.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
MBreporting

::: CONFIDENTIAL :::

Page: 4

10/20/2011
Tracy Carlson

Berhad/Petronas v. GoDaddy

1

TRACY CARLSON,

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

EXAMINATION BY MR. CLARK

6

Q.

All right.

Good afternoon.

I'm a lawyer.

My name's

7

Perry Clark.

I represent Petroliam

8

Nasional Berhad also known as Petronas which is the

9

plaintiff in this case.

10

MS. KLAUSNER:

11

Klausner for Go Daddy, the defendant.

12

BY MR. CLARK:

13
14

Q.

And for the record, Tonia

Would you please state your name and

spell it for the record, please?

15

A.

Tracy Carlson, T-r-a-c-y C-a-r-l-s-o-n.

16

Q.

You've had your deposition taken before?

17

A.

Yes.

18

Q.

How many times?

19

A.

Once.

20

Q.

Okay.

21

A.

I do not recall specifically, but it was

22

earlier this year.

23
24

Do you recall when that was?

Q.

Okay.

Was Go Daddy a party to the case

in which that deposition was taken?

25
MBreporting

A.

Yes.
::: CONFIDENTIAL :::

Page: 5

10/20/2011
Tracy Carlson

Berhad/Petronas v. GoDaddy

1
2

Q.

Do you recall any of the other parties in

that case?

3

A.

AAMPAS.

4

Q.

Were there any others?

5

A.

I don't recall off the top of my head if

6

there's another party or not.

7

Q.

Is Go Daddy the defendant in that case?

8

A.

Yes.

9

Q.

Do you recall what the causes of action

10

are in that case?

11

MS. KLAUSNER:

And I'm going to instruct

12

the witness, although this is a little tricky because

13

she is a lawyer, but I'll instruct the witness to not

14

divulge information you learned as part of the

15

preparation for that deposition.

16

So if you independently have knowledge of

17

the case, then you can provide it, but you shouldn't

18

disclose what you learned from the counsel defending

19

you in that action.

20

THE WITNESS:

Okay.

I don't know off the

21

top of my head all the claims, but there is a ACPA

22

claim.

23

BY MR. CLARK:

24
25

Q.

All right.

That's fine.

So you're

currently employed by Go Daddy?

MBreporting

::: CONFIDENTIAL :::

Page: 6

10/20/2011
Tracy Carlson

Berhad/Petronas v. GoDaddy

1

attorney.

2

A.

Yes.

3

Q.

Okay.

4

Are you going to follow that instruction?

That's the reason why you're not

answering the question?

5

A.

Yes.

6

Q.

When did you first learn that Petronas

7

had raised an issue regarding the domain names

8

Petronas Tower and petronastowers.net with Go Daddy?

9

MS. KLAUSNER:

I'm going to object and

10

instruct the witness not to answer.

11

scope of the topic she's been designated for.

12

BY MR. CLARK:

13
14

Q.

Okay.

It's outside the

Are you going to follow your

counsel's instruction?

15

A.

Yes.

16

Q.

Were you involved at all in Go Daddy's

17

handling of Petronas' complaints regarding the domain

18

names petronastower.net and petronastowers.net?

19

MS. KLAUSNER:

And I'm going to make the

20

same objection and instruct the witness not to

21

answer.

22

MR. CLARK:

23
24

Okay.

(DEPOSITION EXHIBIT 43 WAS MARKED.)
BY MR. CLARK:

25
MBreporting

Q.

I'm going to hand you what's been marked
::: CONFIDENTIAL :::

Page: 10

10/20/2011
Tracy Carlson

Berhad/Petronas v. GoDaddy

1

as Carlson Exhibit 43 which are Go Daddy's Responses

2

to Plaintiff's Second Set of Interrogatories.

3

you ever seen this document before?

4

MS. KLAUSNER:

Have

I'm going to object that

5

as far as I'm aware, this has nothing to do with the

6

topics.

7

do with the topics, I may allow her to answer.

8

if you're going off topic and you acknowledge you're

9

going off topic, then I'm going to instruct her not

10

If you can explain how it has something to

to answer.

11
12

(DEPOSITION EXHIBIT 44 WAS MARKED.)
BY MR. CLARK:

13
14

But

Q.

Okay.

I'm going to hand you what's been

marked as Carlson Exhibit 44.

15

MS. KLAUSNER:

And I'm going to make the

16

same objection for all of the exhibits unless you can

17

explain to me how they have to do with the document

18

retention policy topics per which this witness has

19

been designated.

20

BY MR. CLARK:

21

Q.

Okay.

So do you see on the second page

22

of Exhibit 44 it's the verification of Go Daddy's

23

second set of interrogatories from plaintiff dated

24

October 12, 2011 and signed by you?

25
MBreporting

MS. KLAUSNER:

And I'm going to again

::: CONFIDENTIAL :::

Page: 11

10/20/2011
Tracy Carlson

Berhad/Petronas v. GoDaddy

1

make the same objection and instruct the witness not

2

to answer.

3
4

She's not here as a personal witness.

(DEPOSITION EXHIBIT 45 WAS MARKED.)
BY MR. CLARK:

5

Q.

Let me now hand the witness what's been

6

marked as Exhibit 45.

7

45 as Go Daddy's Response to Plaintiff's Third Set of

8

Interrogatories?

9

And do you recognize Exhibit

MS. KLAUSNER:

And I'm going to make the

10

same objection and instruct the witness not to

11

answer, and I'm going to do it for all of these

12

documents unless you can explain how they pertain to

13

the topic for which the witness has been designated.

14

(DEPOSITION EXHIBIT 46 WAS MARKED.)

15

BY MR. CLARK:

16

Q.

I'm now handing the witness what's been

17

marked as Exhibit 46.

18

46 as the verification of Go Daddy's Response to

19

Plaintiff's Third Set of Interrogatories signed by

20

you and dated October 14, 2011?

21

And do you recognize Exhibit

MS. KLAUSNER:

I object again on the same

22

grounds.

23

which this witness has been designated.

24

here as a personal witness.

25

answer.

MBreporting

It's outside the scope of the topics for
She's not

Instructing her not to

::: CONFIDENTIAL :::

Page: 12

10/20/2011
Tracy Carlson

Berhad/Petronas v. GoDaddy

1

BY MR. CLARK:

2

Q.

All right.

Why don't you turn to Exhibit

3

1 which should be right there.

4

page -- well, can you tell me what Exhibit 1 is?

5
6

A.

Okay.

If you turn to

Notice of Federal Rule Civil Procedure

30(b)(6) Deposition to Defendant.

7

Q.

Have you ever seen Exhibit 1 before?

8

A.

Yes.

9

Q.

Okay.

10

A.

I have seen it several times over the

11

last week or two.

12

Q.

13

Okay.

When did you see it?

Can you turn to page 10, please.

Do you see numbered paragraph 26 on page 10?

14

A.

Yes.

15

Q.

And you understand that you've been

16

designated as Go Daddy's deponent on that topic?

17

A.

Yes.

18

Q.

And topic 26 is "Go Daddy's efforts to

19

preserve information including electronically stored

20

information related to this case including the

21

identity of all persons with knowledge of the

22

foregoing and all documents related to the

23

foregoing."

Do you see that?

24

A.

Yes.

25

Q.

Can you describe for me Go Daddy's

MBreporting

::: CONFIDENTIAL :::

Page: 13

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18

Ex. B

19
20
21
22
23
24
25
26
27
28
3
CLARK DECL. ISO REPLY ISO MTN. PART. SUMMARY JUDGMENT
Case No: 09-CV-5939 PJH

2

JOHN L. SLAFSKY, State Bar No. 195513
DAVID H. KRAMER, State Bar No. 168452
HOLLIS BETH HIRE, State Bar No. 203651
WILSON SONSINI GOODRICH & ROSATI

3

Professional Corporation
650 Page Mill Road
4 Palo Alto, CA 94304-1050
Telephone: [phone]
5 Facsimile: [phone]
j [e-mail]
6 [e-mail]
[e-mail]
7
8

Attorneys for Defendant
GODADDY.COM, INC.

9

10

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

11
12
13

PETROLIAM NASIONAL BERHAD,

14

Plaintiff,

15

vs.

)
)
)
)
)
)
)
)
)
)
)

16

GODADDY.COM, INC.,

17

CASE NO: 09-CV-5939 PJH

DEFENDANT'S SUPPLEMENTAL
INITIAL DISCLOSURES

Defendant.
__________________________________

18
19

Defendant GoDaddy.Com, Inc. ("Go Daddy"), through its attorneys, Wilson Sonsihi

20

Goodrich & Rosati, hereby supplements its initial disclosures to Plaintiff Petroliam Nasional

21

Berhad, ("Petroliam Nasional" or "Plaintiff'), pursuant to Rule 26(a)(l) of the Federal Rules of

22

Civil Procedure.

23

These supplemental initial disclosures are made without waiver of, or prejudice to, any

24

objections Go Daddy may have. Go Daddy expressly reserves all such objections, including but

25

not limited to the admissibility in evidence of these supplemental initial disclosures or the subject

26

matter thereof. Go Daddy expects to seek a protective order in the near future-if not

27

imminently-as Go Daddy's counsel has already circulated a proposed stipulated protective order

28

to Plaintiffs counsel.
4412312vl

DEFENDANT'S SUPPLEMENTAL INITIAL DISCLOSURES
Case No: 09-CV-5939 PJH

These supplemental initial disclosures are made to the best of Go Daddy's present
2

knowledge, information and belief, formed after an inquiry that is reasonable under the

3

circumstances. Go Daddy has not completed its investigation of this case, and has not completed

4

preparation for trial. Accordingly, these supplemental initial disclosures are provided without

5

prejudice to Go Daddy's right to introduce at a hearing or at trial any evidence that is

6

subsequently discovered. Go Daddy expressly reserves the right to clarify, amend, modify, or

7

supplement these disclosures.

8
9

A.

Disclosure pursuant to 26(a)(l)(A)(i)
Individuals Likely to Have Discoverable Information

1o

Go Daddy identifies the following persons as individuals who may have discoverable

11

information that Go Daddy may use to support its defenses. Go Daddy expressly reserves the

12

right to call these witnesses to testify about additional matters or to supplement these disclosures

13

and rely on additional witnesses.

14
15
16

17
18
19
20
21
22
23
24

Name and Address

Subject of Knowledge

Heiko Schoenekess
BPM 195226
372 Old Street
London, United Kingdom
ECIV9AU
[phone]

Registration and use of the disputed domain names;
hosting of destination website; destination website
content

David Daash
Avenida Lazaro
Colonia Las Brisas
Mexico, Mexico 64780

Registration and use of the disputed domain names;
hosting of destination website; destination website
content

Bruno Zehnder
Lavaterstr. 40
Zurich, Switzerland 8002
[phone]

Hosting of destination website; destination website
content

25
26
27
28

DEFENDANT'S SUPPLEMENTAL INITIAL DISCLOSURES
Case No: 09-CV-5939 PJH

2
3

Banner & Witcoff Ltd.
1100 13th Street Northwest
Washington, DC 20005-4057
[phone]

Plaintiff's trademark application and registration,
including goods/services intended to be used and
goods/services actually used by Plaintiff before and
after filing of the application that matured into U.S.
Trademark Registration No . 2969707, scope of
trademark registrations in Plaintiff's country of
origin, and knowledge of signatories when attesting
to use of or intent to use listed goods/services

Brian E. Banner
Hershkovitz & Associates
2845 Duke Street
Alexandria, VA 22314-4512

Plaintiff's trademark application and registration,
including goods/services intended to be used and
goods/services actually used by Plaintiff before and
after filing of the application that matured into U.S.
Trademark Registration No. 2969707, scope of
trademark registrations in Plaintiff's country of
origin, and knowledge of signatories when attesting
to use of or intent to use listed goods/services

Rod Simonini
c/o John L. Slafsky
Wilson Sonsini Goodrich & Rosati
650 Page Mill Road
Palo Alto, CA 94304
[phone]

Go Daddy' s communications with Plaintiffs
counsel

Matthew Bilunes
c/o John. L. Slafsky
Wilson Sonsini Goodrich & Rosati
650 Page Mill Road
Palo Alto, CA 94304
[phone]

Go Daddy's communications with Plaintiff's
counsel

Camille Ede
c/o John L. Slafsky
Wilson Sonsini Goodrich & Rosati
650 Page Mill Road
Palo Alto, CA 94304
[phone]

Go Daddy's domain name registration process
relating to the disputed domain names, including the
process of transferring to Go Daddy an existing
domain name from another registrar

4

5
6
7
8

9
10

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

DEFENDANT'S SUPPLEMENTAL INITIAL DISCLOSURES
Case No: 09-CV-5939 PJH

2
3
4

5
6
7

8
9

Jessica Hanyen
c/o John L. Slafsky
Wilson Sonsini Goodrich & Rosati
650 Page Mill Road
Palo Alto, CA 94304
[phone]

Go Daddy's trademark polices relating to the
disputed domain names; application of Go Daddy's
trademark complaint/dispute practices relating to
the disputed domain names

Laurie Anderson
c/o John L. Slafsky
Wilson Sonsini Goodrich & Rosati
650 Page Mill Road
Palo Alto, CA 94304
[phone]

Application of Go Daddy's trademark
complaint/dispute practices relating to the disputed
domain names~ Go Daddy' s domain name
registration process relating to the disputed domain
names, including the process of transferring to Go
Daddy an existing domain name from another
registrar

Linda Jett
c/o Jolm L. Slafsky
Wilson Sonsini Goodrich & Rosati
650 Page Mill Road
Palo Alto, CA 94304
[phone]

Agreements governing the services Go Daddy
provided with respect to the disputed domain names

John Roling
c/o Jolm L. Slafsky
Wilson Sonsini Goodrich & Rosati
650 Page Mill Road
Palo Alto, CA 94304
[phone]

Go Daddy's domain name registration process
relating to the disputed domain names; services
provided by Go Daddy related to the disputed
domain names, including technical aspects of
routing/forwarding the disputed domain names

Jeff Munson
c/o John L. Slafsky
Wilson Sonsini Goodrich & Rosati
650 Page Mill Road
Palo Alto, CA 94304
[phone]

Services provided by Go Daddy related to the
disputed domain names, including technical aspects
of routing/forwarding the disputed domain names

Priya Manokaran
Petroliam Nasional Berhad
Level 68, Tower 1
Petronas Twin Towers
'Kuala Lumpur City Centre
50088 Kuala Lumpur, Malaysia
[phone]

Communications between Plaintiff and Go Daddy;
communications between Plaintiff and any person
regarding this lawsuit; the disputed domain names;
Plaintiff's, and/or any other person's, ownership of
and use of the Petronas mark, and any mark
incorporating the letter string "petronas," in the
United States; Plaintiff's ownership of and the
validity of U.S. Trademark Registration No.

10
II
12
13
14
15
16

17
18
19
20
21
22
23
24
25
26

27
28

-4DEFENDANT'S SUPPLEMENTAL INITIAL DISCLOSURES
Case No: 09-CV-5939 PJH

44

2969707; Plaintiffs ownership of and the scope of
Malaysian Registration Nos. 93007563, 93007565,
and 93007564, and any other foreign registration
that supports U.S. Trademark Registration No.
2969707; Plaintiffs efforts to contact the registrant
and the hosting service of the disputed domain
names; Plaintiffs damages in this action; the basis
for and evidence supporting the allegations and
claims in the First Amended Complaint in this
action; Plaintiffs documents produced and
discovery responses served in this case; Plaintiffs
policies regarding retention, storage, filing and
destruction of documents and things, including
electronic mail; Go Daddy's alleged knowledge of
and use· of Plaintiffs trademarks; the alleged use of
Plaintiffs trademarks by the registrant of the
disputed domain names; Go Daddy's alleged
services to the registrant of the disputed domain
names

2
3

4
5
6

7
8

9
10
11

12

13

B.

Disclosure pursuant to 26(a)(l)(A)(ii)
Documents Relevant to Disputed Facts

14

15
16
17

Go Daddy expressly reserves the right to supplement these disclosures and rely on
additional documents.
Category and Description

Location

18
19

20
21

22
23
24

25

Documents relating to Plaintiffs trademark
registration and use of the mark in the U.S.,
including goods/services intended to be used and
goods/services actually used by Plaintiff before and
after filing of the application that matured into U.S.
Trademark Registration No. 2969707, scope of
trademark registrations in Plaintiffs country of
origin, and knowledge of signatories when attesting
to use of or intent to use listed goods/services

c/o Plaintiff;
c/o Banner & Witcoff Ltd.;
c/o Brian E. Banner

Documents relating to registration of disputed
domain names, and content and hosting of
destination website

c/o Heiko Schoenekess;
c/o David Daash;
c/o Bn:mo Zehnder

26
27
28

DEFENDANT'S SUPPLEMENTAL INITIAL DISCLOSURES
Case No: 09-CV-5939 PJH

2

3

Documents relating to customer accounts for
disputed domain names and registration of disputed
domain names

Go Daddy servers which are
accessible from computers
located at Go Daddy
headquarters in Scottsdale, AZ

Go Daddy contracts and agreements relating to the
disputed domain names

Go Daddy servers which are
accessible from computers
located at Go Daddy
headquarters in Scottsdale, AZ

Documents regarding Go Daddy's domain name
registration process relating to the disputed domain
names

Go Daddy servers which are
accessible from computers
located at Go Daddy
headquarters in Scottsdale, AZ

Communications between Plaintiff's counsel and
Go Daddy

Go Daddy servers which are
accessible from computers
located at Go Daddy
headquarters in Scottsdale, AZ

Documents regarding services provided by Go
Daddy to the registrant of the disputed domain
names, including forwarding ofthe disputed domain
names to a pre-existing website

Go Daddy servers which are
accessible from computers
located at Go Daddy
headquarters in Scottsdale, AZ

4

5
6
7
8
9
10

11
12

13
14

15

16
17
18
19

C.

20

21
22

23

24
25

26

Disclosure pursuant to 26(a)(l)(A)(iii)
Computation of Damages

Go Daddy is not seeking damages at this time. Go Daddy expressly reserves the right to
supplement these disclosures as more information becomes available.

D.

Disclosure pursuant to 26(a)(l)(A)(iv)
Insurance Agreements

Upon entry of an appropriate protective order, Go Daddy will produce a copy of an
insurance agreement under which an insurance company may be liable to satisfy all or part of a

27
28
DEFENDANT'S SUPPLEMENTAL INITIAL DISCLOSURES
Case No: 09-CV-5939 PJH

1 · possible judgment in this action or to indemnify or reimburse for payments made to satisfy a
2

judgment.

3

4 Dated: June 29, 2011

WILSON SONSINI GOODRICH & ROSATI

:fu

5

6
7

:o:LS1Ms1CY

8

Dnvid H. Kramer
Hollis Beth Hire

9

Attorneys for D~endant

10

GODADOY.COM, lNC.

11

12
13
14
15

16
17

18
19

20
21
22
23

24
25
26
27
28
DEFENDANT'S. ~AL .INITIALDISCLOSURES
09-cv~s939 PJH'

Case No:

CERTIFICATE OF SERVICE BY MAIL

1

2
3

4

I, Lisa M. Ruiz, declare:

I am employed in Santa Clara County. I am over the age of 18 years and not a party to the

5

within action. My business address is Wilson Sonsini Goodrich & Rosati, 650 Page Mill Road,

6

Palo Alto, California 94304-1050.

7

I am readily familiar with Wilson Sonsini Goodrich & Rosati's practice for collection and

8

processing of correspondence for mailing with the United States Postal Service. . In the ordinary

9

course of business, correspondence would be deposited with the United States Postal Service on

10

11
12

this same date.
On this date, I served:

DEFENDANT'S SUPPLEMENTAL INITIAL DISCLOSURES

13

on each person listed below, by placing the document(s) described above in an envelope addressed

14

as indicated below, which I sealed. I placed the envelope(s) for collection and mailing with the

15

United States Postal Service on this day, following ordinary business practices at Wilson Sonsini

16

Goodrich & Rosati.
Perry R. Clark, Esq.
Law Offices of Perry R. Clark
825 San Antonio Road
Palo Alto, CA 94303

17

18
19

20
21

I declare under penalty ofpetjury under the laws ofthe State of California that the
foregoing is true and correct. Executed at Palo Alto, California on June 29, 2011 .

22
23

LisaM. Ruiz

24
25

26
27

28
DEFENDANT'S SUPPLEMENTAL INITIAL DISCLOSURES
Case No: 09-CV-5939 PJH