Petroliam Nasional Berhad v., 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Ex. 21 19 20 21 22 23 24 25 26 27 28 CLARK DECL. ISO REPLY ISO MTN. PART. SUMMARY JUDGMENT Case No: 09-CV-5939 PJH Red acted From John Slafsky Sent RE Petronas/GoDaddy CONFIDENTIALAND Perry e-mail could federal now FURNISHED messages have court Your that RULE OF EVIDENCE 408 with below on now court are clients 22 need in which case exchange to If Initial would interested to We Disclosures. in you control violation via days court domain the in domain the FRCP of pursuing Conference Management expect though 60 federal Rule name UDRP well-known December name and you arbitration even each though of to bring claims your small for process chose subsequently fraction the against the of in separate in required court doomed. are registrar fees federal attorney lawsuit rem This of and has 11. infringers it can either UDRP bring claims or can sue by it the July in infringers court. is It absurd to burden. policing Case we is in registrar blatant in within client your the even registrar client your for against GoDaddy registrar trademark concerning stipulation July the name motion the against litigation for TRO futile bring unacceptable. your domain petronastower to expense assume proposed will federal unnecessary registrar however parties opted demands the disturbing. you and forwarded available The TO FEDERAL disputed proceeding settlement suggest very the Instead easily significant are today secured litigation. are you caused You PURSUANT -- Your You PM clark perry Subject 14 2010 215 June Monday To Case file that propose on the parties that and July15 Management do GoDaddy this by submission joint Statement July 8. 15 one i.e. Case of Please by July week before Statement Management forward another Case the with stipulation these These 1. Conference. Management dates do work not for We are to us. this dates. Please confirm agreement your deadline. the Case against both At John Conference Management and you intend we Under client. your the to advise Hamilton Judge circumstances GoDaddy is committed to will be proceeding moving with the to dismiss sanctions this case motion altogether even you if and ii for moving elect subsequently sanctions to dismiss including this an baseless award attorney-fee and ill-advised lawsuit. Slafsky Wilson Sonsini Goodrich 650 Page Mill Palo CA Alto Rosati Road 94304 650-320-4574 ph 650-493-6811 fax From Sent To Clark Perry 1013 AM John Slafsky Subject 14 2010 June Monday Petronas/GoDaddy CONFIDENTIALAND FURNISHED PURSUANT TO FEDERAL RULE OF EVIDENCE 408 John It has to our come attention that domain PETRONASTOWERS.NET website name is mirroring registered at the website previously as was associated the with PETRONASTOWER.NET the PETRONASTOWER.NET domain name domain the Court name ordered is located transferred at PETRONASTOWERS.NET. to Petronas. The It appears registrant also that the appears to be the same. Could if please you your let would client me know consider whether agreeing your client to inform would Petronas be in willing the to transferthe future when PETRONASTOWERS.NET GoDaddy receives an application domain name to register to Petronas domain and name on using what the terms and PETRONAS conditions. In addition please let me know mark. Best Perry Law Offices of Perry 3457 Cowper Palo Tel. Alto R. Clark St. CA 94306 6502485817 APP155 CONFIDENTIAL GD-001 930

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