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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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
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would
interested
to
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in
you
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domain
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of
pursuing
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Management
expect
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federal
Rule
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well-known
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even
each
though
of
to
bring
claims
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subsequently
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against
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separate
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doomed.
are
registrar
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attorney
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of
and
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infringers
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concerning
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litigation.
are
you
caused
You
PURSUANT
--
Your
You
PM
clark
perry
Subject
14 2010 215
June
Monday
To
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file
that
propose
on
the
parties
that
and
July15
Management
do
GoDaddy
this
by
submission
joint
Statement
July
8.
15
one
i.e.
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of
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by July
week
before
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Management
forward
another
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the
with
stipulation
these
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Conference.
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dates
do
work
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to
us.
this
dates.
Please
confirm
agreement
your
deadline.
the
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against
both
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John
Conference
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and
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intend
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client.
your
the
to
advise
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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
jslafskywsgr.com
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
GoDaddy.com
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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