Petroliam Nasional Berhad v. GoDaddy.com, Inc.

Filing 143

Declaration of Perry Clark in Support of 134 MOTION for Partial Summary Judgment re Liability for Contributory Cybersquatting as to PETRONASTOWERS.NET filed byPetroliam Nasional Berhad. (Attachments: # 1 Exhibit A, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23, # 25 Exhibit 24, # 26 Exhibit 25, *** # 27 Exhibit 26 FILED IN ERROR. DOCUMENT LOCKED. DOCUMENT TO BE REFILED LATER. *** , # 28 Exhibit 27, # 29 Exhibit 28)(Related document(s) 134 ) (Clark, Perry) (Filed on 11/25/2011) Modified on 11/28/2011 (ewn, COURT STAFF).

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Ex. 14

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CLARK DECL. ISO REPLY ISO MTN. PART. SUMMARY JUDGMENT
Case No: 09-CV-5939 PJH

Perry

R.

Clark State Bar No.

Cu
KIRKLAND
Zhuanjia

950
Palo

Page

Miii

Alto

Telephone
Facsimile

State Bar No.

ELLIS

197101

244863

LLP

Road

CA 94303
650 859
650 859

7070
7000

[e-mail]
[e-mail]

Attorneys

For Plaintiff

PETROLIAM

NASIONAL BERHAD

10

11

UNITED STATES DISTRICT COURT
DISTRICT OF CALIFORNIA
SAN JOSE DIVISION.

12

NORTHERN

13

14

15

PETROLIAM

NASIONAL BERHAD

16

NO. 09-CV-__________

Plaintiff

PLAINTIFFS

17

GODADDY.COM

IN

RESTRAINING ORDER

V.

18

SUPPORT OF
MOTION FOR TEMPORARY

DECLARATION

fNC.

19

Defendant.
20

21

22

23

24

25

26

27

28
Declaration

APP087

GD-000698

Manokaran

Priya

am

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in

and

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of

downstream

oil

12

Petronas

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in

and

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gas

the

among

Fortune Global

the

encompasses
and

exploration

products

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full

production

processing

gas

of liquefied

marketing

gas

natural

investment.

property

countries

is

business

and

operations

shipping

than

oil

of petroleum

network

more

Petronass

of upstream

distribution

and marketing

and

corporation

world.

the

the areas

pipeline

operations

gas

worldwide

and

approximately

employs

people.

13

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Petronass

4.

Website.

official

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and

16

Petronas

the

uses

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petronastwintowers.com.my.

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are

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Petronas.

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commercial

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petronastwintowers.com.my

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possible

of the

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most

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project

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in

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redirect

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the values

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www.petronas.com

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gas

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of the employees

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among

management

through the Government
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manifestation

to

and

news

things

shareholders

of Malaysia

provide

other

of the

and

own

of

stake

information

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Declaration

APP088

GD-000699

about

hire

for

employees

On

7.

had

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at

and

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unauthorized

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use

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domain

name

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domain

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itself

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PETRONAS

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Trademark

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petronastower.net

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to

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sent

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According

sent to

hereto

as

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of Petronass

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name

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to

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to

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website.

domain

name

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of the

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through

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interest

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name and

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refusing

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need

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Ex.

name.

2009

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name ownership disputes

20

were

unknown

operating

www.petronastower.net

name and

domain

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supportgodaddy.com.

to

result

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2009

with

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about

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World

2009

with

26

associated

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on

displayed

of the petronastower.net

the

Ex.

November

about

or

and

www.petronastower.net

material.

26

registered

the

brand.

its

person or persons

www.pctronastower.net

November
been

that

promote

and

or consent.

knowledge

material

pornographic

learned

recruit

employees

and

products

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www.petronastower.net

pornographic
the

advertise

and

customers

potential

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26 2009

accessing

about

or

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and

otherwise

or

world

name

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obscene

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browser to

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26 2009

domain

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customers

name without Petronass

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8.

November

registered

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around

locations

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about

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with

communicate

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U.S.

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with

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Department

involved

in

domain

petronastower.net

the

wording

arbitration

of the

forum such

as

Id.

Trademark

copy

No.

of the

U.S.

2969707

Patent

for

and

No. 2969707.

PETRONAS

mark

in

connection

with the

or website.

28

Declaration

APP089

GD-000700

declare

and

correct.

Dated

under

of perjury

penalty

This declaration

is

of the laws of the United

being executed

in

Kuala

Lumpur

States

that

the

foregoing

is

true

Malaysia.

December 17 2009
ny

Manok

an

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12

13

14

15

16

17

18

19

20

21

22

23

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27

28

-4-

Dectaration

APP090

GD-000701