Petroliam Nasional Berhad v. GoDaddy.com, Inc.
Filing
153
DECLARATION of Perry Clark in Opposition to 152 Opposition/Response to Motion, 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 (Part 1 of 3), # 22 Exhibit 20 (Part 2 of 3), # 23 Exhibit 20 (Part 3 of 3))(Related document(s) 152 ) (Clark, Perry) (Filed on 12/9/2011)
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CLARK DECL. ISO OPP. SUMMARY JUDGMENT
Case No: 09-CV-5939 PJH
OPPAPP001589
OPPAPP001590
Ex. A
OPPAPP001591
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: (650) 248-5817
Facsimile: (650) 248-5816
4 perry@perryclarklaw.com
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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(PETRONAS),
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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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CASE NO: 09-CV-5939 PJH
DISCLOSURE OF EXPERT
WITNESS TINA DAM
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that pursuant to Fed. R. Civ. P. 26(a)(2)(A), Plaintiff
Petroliam Nasional Berhad (Petronas) discloses Tina Dam. This disclosure is accompanied by
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the report attached hereto as Exhibit 1, which contains material designated as “confidential”
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under the protective order in this case.
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26 DISCLOSURE OF EXPERT WITNESS TINA DAM
Case No: 09-CV-5939 PJH OPPAPP001592
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Dated: October 3, 2011
LAW OFFICES OF PERRY R. CLARK
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By:
/s/ Perry R. Clark
Perry R. Clark
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Attorney for Plaintiff
PETROLIAM NASIONAL BERHAD
(PETRONAS)
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CERTIFICATE OF SERVICE
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On October 3, 2011, I served this DISCLOSURE OF EXPERT WITNESS TINA
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DAM by First Class Mail and electronic mail on:
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John L. Slafsky, Esq.
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David Lansky, Esq.
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WILSON, SONSINI, GOODRICH & ROSATI, P.C.
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650 Page Mill Road
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Palo Alto, CA 94304-1050
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650 493 9300
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jslafsky@wsgr.com
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dlansky@wsgr.com
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Dated: October 3, 2011
By:
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-2DISCLOSURE OF EXPERT WITNESS TINA DAM
Case No: 09-CV-5939 PJH OPPAPP001593
/s/ Perry Clark
Perry Clark
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Ex. 1
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-3DISCLOSURE OF EXPERT WITNESS TINA DAM
Case No: 09-CV-5939 PJH OPPAPP001594
Expert Witness Report
Of
Tina Dam
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OPPAPP001595
I.
Introduction
I have been retained as an expert with respect to the domain name system,
including domain name registration, the roles of domain name registrars,
registrants, and registries, domain name resolution, and URL redirection.
I am submitting this report in order to provide a statement of the opinions I have
rendered and the bases for those opinions as well as an identification of
information I considered in forming them, which I have done by citation to such
material throughout this report.
I am being compensated at my normal consulting rate of $500 per hour. A copy
of my resume listing my education and work experience is attached as Exhibit A.
II.
Overview
One of the fundamental aspects of the internet is the ability of hundreds of
millions computers to locate and exchange information with one another over a
flexible and reliable network. The domain name system (DNS) provides the
elemental foundation that makes this possible.
The DNS operates using IP addresses, which are numeric identifiers, such as
“192.0.43.7,” for every computer connected to the internet, and which allow
communications between them much like telephone numbers allow
communication between telephones (although technically not the same). A
critical function of the DNS is to allow a computer to determine the IP address of
another computer connected to the internet in order to establish a connection
and begin exchanging information.
Another important aspect of the DNS is the association of numeric IP addresses
with strings of letters forming “domain names,” which is easier for humans to
remember.
An example of a domain name is “generalmotors.com.” Here “generalmotors” is
the second‐level domain registered by the registrant under the top‐level domain
of .COM. The TLD .COM is administered by the registry Verisign.
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OPPAPP001596
By making what can be considered a directory functionality mapping domain
names to IP addresses available to virtually any computer with a web browser
(such as Internet Explorer) and a connection to the internet, the DNS provides a
critical enabling capability for the internet.
Two separate and distinct processes are central to the operation of the DNS:
domain name registration and domain name resolution. These processes are
discussed in detail below.
III.
Domain Name Registration
In order to register a domain name, a Registrant must use the registration
services of an ICANN accredited registrar. 1 The registrars will also be authorized
to provide registration services under the various TLDs for the respective
registries.2
Domain names are used typically for web‐addresses and email‐addresses.
A would‐be registrant begins the registration process by submitting a registration
request to a domain name registrar, such as GoDaddy. Usually the potential
registrant submits his or her request via the registrar’s website by the following
steps:
1) Typing in the domain name to be registered, after which the registrar
will check the availability of that specific domain name.
2) If the domain name is available, the registrant will add it to a shopping
cart on the website, and proceed to check out.
3) At check‐out the registrant fill out required information, typically this is:
the registrant’s administrative and technical contact name and contact
information; and the registrant enters and authorizes charge on his/her
credit card information to cover the registrar’s registration fees.
1
Functional, conceptual, and implementation aspects of domain name registration are set forth in certain
documents or agreements that are within the purview of ICANN or registrars such as GoDaddy, including those
collected in Ex. F.
2
Many of the concepts and facilities of the internet and domain name system are set forth in documents
generated by the Internet Engineering Task Force, in particular RFCs 5730, 3375, 3632,2832, 1034, 1035, and 2616.
(Ex. H).
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OPPAPP001597
4) The registrant can also during check‐out typically select services related
to the domain name registration, such as hosting, email management,
and privacy services.
Registry
Verisign
Registrar
Register.com
Registrar
GoDaddy
Registrar
Network
In order to determine whether the requested domain name is available for
registration, the registrar’s system checks (i) the associated registry’s database of
registered domain names and (ii) the reserved list of names that are blocked for
registration. If the requested domain name is available for registration, and the
registrant has entered the contact and payment information as mentioned above,
the registrar then submits a command to the appropriate domain name registry
typically using a protocol called EPP.3 The content of this command commonly
includes: the domain name being registered, the ip‐addresses and names of the
primary and secondary nameservers designated for the domain name, identity of
the registrar, and expiration date of the registration.4 There are a number of
different domain name registries for the various “top‐level domains,” such as
“.com,” “.net,” etc. The registry for “.net” domain names is Verisign, Inc. The
registrar collects the registration fee for the registration before or simultaneously
to submitting the registration request to the registry.
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Ex. H.
Two Domain Name Servers are used for redundancy.
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OPPAPP001598
Following the successful registration, the registrant may make modifications to
the provided information and nameservers. In some cases there are grace‐
periods in effect which means that the registrant must wait for a certain time
period before he/she can make such changes.
The registry and registrar maintain a publicly accessible database, called the
whois database that contains information from the domain name registration
records of all registered domain names. The Verisign whois entry for
“petronastower.net” is below (Ex. G at GD‐000674):
Often, the name servers designated for a domain name when it is first registered
are owned and operated by the domain name registrar. This is the case for
“petrontower.net” and, as shown in the above example, the designated Domain
Name Servers “NS39.DOMAINCONTROL.COM” and
“NS40.DOMAINCONTROL.COM” are owned and operated by The Go Daddy
Group. This can be verified by checking the Whois information for
domaincontrol.com, and on the godaddy website, and below information
demonstrating that domaincontrol.com is used for hosting domain names at
Godaddy. (Ex. B).
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OPPAPP001599
The Whois information for domaincontrol.com shows the registrant is Special
Domain Services Inc. , and the Godaddy website shows that domaincontrol is used
as nameservers for Godaddy hosting customers.
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OPPAPP001600
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OPPAPP001601
Special Domain Services address includes
www.godaddy.com, and searching
information online shows that Special
Domain Services is a Godaddy subsidiary.
The registrant can, however, direct the registrar to designate Name Servers
selected by the registrant. This is typically done in the registrant’s interface or
account on the registrar’s website. While many domain name registrars provide
Name Servers for their registrant customers, registrants can operate their own
Name Servers or use Name Servers operated by other domain name registrars or
other web hosting companies.
In addition to the initial registration of domain names, domain name registrars
perform functions associated with the maintenance of domain name
registrations, such as updating the registrant’s contact information, transferring
domain names between registrars and registrants, and collecting renewal fees.
I understand that GoDaddy was not the registrar which performed the original
registration of the domain names “petronastower.net” and
“petronastowers.net.” (Ex. C (Lewis Decl. at 2:23‐24)); (Ex. D, GD‐000393). In my
best assessment, based on received information, it is my opinion, the conduct of
GoDaddy that could be characterized as either the transferring‐in registrar and
following such transfer the registrar managing the maintenance of the domain
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OPPAPP001602
names “petronastower.net” and “petronastowers.net” consisting entirely of the
following:
On or before March 30, 2007, GoDaddy received a request from the
registrant of the domain names “petronastower.net” and
“petronastowers.net” for GoDaddy to become the registrar of record
for those domain names. (Ex. D GD‐000377).
On March 30, 2007, GoDaddy charged the registrant’s credit card for
“.NET Bulk Domain Name Transfer (6‐20)” for the domain names
“petronastower.net” and “petronastowers.net.” (Ex. D GD‐000475).
By April 1, 2007, GoDaddy completed the transfer of the domain
names “petronastower.net” and “petronastowers.net” from the
previous registrar to GoDaddy and on April 1, 2007 GoDaddy sent an
email to the registrant notifying it of the completion of the transfer.
(Ex. D, GD‐000367, 369, 110, 152).
On April 26, 2008 and May 3, 2008, GoDaddy set the domain names
“petronastower.net” and “petronastowers.net” to “auto renew,”
lilely in response to a request from the registrant. (Ex. D, GD‐000353,
350, 348, 346, 345, 344).
On May 3, 2008, GoDaddy charged the registrant’s credit card for
“.NET Bulk Domain Name Renewal (6‐20)” for the domain names
“petronastower.net” and “petronastowers.net.” (Ex. D, GD‐000467).
On May 2, 2009, GoDaddy again set the domain names
“petronastower.net” and “petronastowers.net” to “auto renew.”
(Ex. D, GD‐000313).
On May 2, 2009, GoDaddy charged the registrant’s credit card for
“.NET Bulk Domain Name Renewal (6‐20)” for the domain names
“petronastower.net” and “petronastowers.net.” (Ex. D, GD‐000447).
On July 2, 2009, GoDaddy sent a contact information update request
to the registrant of the domain names “petronastower.net” and
“petronastowers.net” and the contact information was updated. (Ex.
D, GD‐000310, 110, 152).
On December 18, 2009, GoDaddy received and logged a complaint
regarding the domain name “petronastower.net.” (Ex. D, GD‐
000302).
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OPPAPP001603
IV.
On December 21, 2009, GoDaddy sent a contact information update
request to the registrant of the domain name “petronastower.net”
and updated the contact information. (Ex. D, GD‐000302).
On January 24, 2010, GoDaddy sent a contact information update
request to the registrant of the domain name “petronastowers.net”
and updated the contact information. (Ex. D, GD‐000301, 110).
On March 23, 2010, the domain name “petronastowers.net” was
renewed. (Ex. D, GD‐000299).
On May 9, 2010, the domain name “petronastower.net” was
renewed. (Ex. D, GD‐000298).
On May 18, 2010, GoDaddy transferred the domain name
“petronastower.net” pursuant to a court order from the previous
registrant to Petronas. (Ex. D, GD‐000298).
On June 14, 2010, GoDaddy received and logged a complaint
regarding the domain name “petronastowers.net.” (Ex. D, GD‐
000296).
On August 30, 2010, GoDaddy transferred the domain name
“petronastowers.net” pursuant to a court order from the previous
registrant to Petronas. (Ex. D, GD‐000293).
Resolving Domain Names
The name servers is the critical component in the internet system that is
responsible for routing an internet user to the address where for example the
webpage content can be found for the webpage associated or linked to that
domain name.
Perhaps the most familiar function of the DNS is the use of a domain name by
computer users to find/resolve a website. When a computer user types a domain
name into a web browser, the DNS enables the web browser to obtain the
numerical IP address of the computer (often called a web server) that holds the
files that the web browser can use to display the content of the website
associated with the domain name.5
5
The concepts and facilities of the internet and domain name system are set forth in documents generated
by the Internet Engineering Task Force, in particular RFCs 5730, 3375, 3632,2832, 1034, 1035, and 2616. (Ex. H).
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OPPAPP001604
The process by which a web browser locates the Domain Name Server for a
particular domain name and obtains the correct IP address is called “domain
name resolution.” The domain name resolution process is invisible to the
computer user and usually is completed in mili‐seconds, by the following steps:
1. When a computer user types “JonsWidgets.com” into the address bar of his
or her web browser and the web browser submits a request to the Internet
Service Provider’s (ISP’s).
2. The ISP’s name server then searches its files (cached information) for the
domain name record for the domain name “JonsWidgets.com.”
‐ If the ISP’s DNS server has the authoritative name server on file (cashed)
for “JonsWidgets.com” in its own files, it will access the authoritative
server and inquire the IP address for the “JonsWidgets.com” web‐
address.
‐ If the ISP’s DNS server does not have the record for “JonsWidgets.com,”
it can pull the address of the authoritative server from the server for
.NET. The zonefile for .NET holds information of all authoritative servers
for the domains registered under .NET. The .NET zonefile is managed by
Verisign.
3. The webpage is displayed on the users computer screen
One of the important aspects of the DNS is that content (e.g. webpage content)
can change location anytime the owner has a need to do so, and without the
users accessing the site noticing the change of location. Also the address pointing
at a website can change. For example in cases where an owner of a
webpage/content wishes to draw users to his/her site by use of other domain
names where the new name makes more sense relatively to the content of the
site, or perhaps where the new name is a highly searched term and/or otherwise
holds high web‐search rankings. The new name will be pointed to the web‐
address and when users type or click the new domain name (that is, as a web‐
address link in a browser) then the user will get the webpage content displayed
on their site.
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OPPAPP001605
Domain name records are distributed across the internet through a hierarchal
arrangement of name servers (illustrated below). At the top of this hierarchy are
thirteen “root servers” which are specially maintained at select locations around
the world. These root servers contain records identifying the “top‐level” domain
name servers, or “TLD name servers,” for each top‐level domain, such as “.com”
or “.net.” These TLD name servers are maintained by the domain name registry
for each top‐level domain and contain records pointing to the Authoritative
Domain Servers for each domain name registered under the respective TLDs, and
which make up the lowest level of the hierarchy. The Authoritative Domain Name
Servers store the domain name records linking domain names to IP addresses
(used for web, mail and other).
A DNS server that is unable to locate a domain name record—such as for a newly
registered domain name—in its own files will either query the TLD Server, or one
of the Root‐servers in cases where it also does not know the location of the TLD
server. A recursive name server is virtually certain to be able to locate a domain
name record by first querying the “root servers,” then the TLD name servers, and
ultimately the network of Authoritative Domain Name Servers. It is by virtue of
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OPPAPP001606
this “hierarchy” and the use of recursive name servers that a new TLD or a new
domain name is accessible across the internet.
In my opinion, the domain name registrars (in their domain name registration
services) do not play a direct or active role in the process of domain name
resolution. Their only function related to domain name registration is to submit,
update, and otherwise maintain requests to the domain name registries for
registration including the name servers that are authoritative for the registered
domain name. It the responsibility of the registries to update the TLD name
servers with the domain names and their associated information including that of
the name server when they receive the information from the registrars.
V.
Domain Name Forwarding
Domain name forwarding or “URL redirection” is a function that “forwards” a
request for the files associated with one domain name to the IP address
associated a second domain name.
To illustrate domain name forwarding, consider a situation in which an internet
user inputs the domain name “example.com” into a web browser’s address bar.
Through the domain name resolution process, the record stored on the Name
Server for “example.com” would identify the IP address associated with
“example.com.” If the server at that IP address was programmed to respond with
files that could be used to display a web page, then the internet user’s web
browser would display the web page for “example.com.”
If the server for “example.com” was programmed to implement domain name
forwarding, it would respond to requests for “example.com” by pointing to
another domain name, such as “differentexample.com.” The domain name
resolution process could then first inquire example.com where it would be told to
look after differentexample.com, and in turn the address for
differentexample.com would be displayed for the user.
Godaddy offers their users free services under their domain management control
panel, such as the forwarding or redirection mechanism. The registrant used that
mechanism to forward or redirect specific domains to other domains that hosted
pornographic content. The forwarding or redirection service is an added service
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OPPAPP001607
typically provided by registrars to its customers. ln my opinion, such service is
separate to that of domain name registration. The bases for my opinion in this
regard include the documents in Exhibit I (GD-000550-563, aoa6B-629, 000659677,GD-001804-1821, GD-002o79-82, and GD-002M6-2550), as well as allof the
materials cited in the other sections of this report, and my background,
knowledge, and experience.
October 3,Z:OLL
Tina Dam
t4
OPPAPP001608
Ex. A
OPPAPP001609
TINA DAM
20 29th Ave #301 | Venice, California 90291 | USA |+1-310-862-2026
Email: tinadam@gmail.com
PROFILE:
Internet/DNS veteran and ex-ICANN Director, a leading expert and authority in Internationalized Domain Names and the
Domain Name System in the Internet industry. On the forefront of Internet technology and the domain industry for over a
decade with a leadership that transformed the Internet into a truly global platform by launching IDN TLDs in different
languages and scripts.
Extrovert with excellent communication skills. Creative, flexible, and always take the initiative. Extremely goal oriented and
enjoy challenges. Diplomatic nature and interpersonal skills keep teams satisfied and motivated to achieve company goals,
whereas my “shake and move” personality ensures efficiency. A committed drive and energy with a sharpness that enables
visibility of the big picture and at the same time a technology mastery that enables processes and procedures for strategic
product implementation.
Named as one of the Top 10 Talents in IT by the leading Danish tech magazine Berlingske.
Fluent in English, Danish, Norwegian and Swedish, intermediate in German and I have basic language skills in Spanish and
Turkish.
Core Strengths: ICANN, Strategy, Execution, Brand/Industry TLD Management, Government Negotiations and
Relationships, DNS Policy and Technical Expertise.
Key Track Record: 36 IDN TLD Implementation & Launch, ICANN Director, technical, policy, and marketing launch of all
existing gTLDs and ccTLDs.
Media: CNN,BBC, CBS,CNET, Wall Street Journal, Associated Press, AlJazeera, Washington Post & more.
PROFESSIONAL
EXPERIENCE:
MYTLD
Co-Founder
05/11 – PRESENT
MyTLD provides Top-Level Domain Management Services for Brands, Companies, Industries and
Governments looking to leverage the generic Top-Level-Domain (gTLD) right-of-the-dot opportunity to
create a sustainable, competitive advantage.
ICANN
Senior Director IDN Programs & Chief gTLD Registry Liaison Officer
05/03 – 08/11
The Internet Corporation for Assigned Names and Numbers (ICANN) is the non-profit corporation that
was formed to assume responsibility for the IP address space allocation, protocol parameter assignment,
domain name system management, and root server system management functions previously performed
under U.S. Government contract by IANA and other entities.
My responsibilities include: staff management; development and management of ICANN’s IDN
Programs (see overview below); main point of contact for interacting with registry operators on
legal/compliance, financial and product/technical issues; new product development; and overall project
management for most of ICANN’s new technical and financial products, as well as development and
implementation of new DNS policies.
Achievements include:
Development the gTLD Registry Liaison Department at ICANN from the bottom up.
Development and implementation of new DNS policies, including defining gTLD registry
processes and procedures in accordance with ICANN Agreements.
Documentation, development, and implementation of ICANN's early business processes which
greatly increased the efficiency of the organization.
Development of close and confidential relationships with ICANN partners globally.
Management of training of gTLD Registry staff and ICANN colleagues in the legal framework
under which the gTLD Registry Liaison Department operates.
OPPAPP001610
Management and implementation of ICANN required policies, including negotiations with
Registries and presentations and advisories to the ICANN Board in their decision-making
capacity.
Development of the early ICANN Compliance Program.
Management of ICANN internal and external cross functional working groups and project
teams, including development of ICANN's initial project management approach.
Project lead on internal and external projects such as, new gTLD analysis, re-assignment of
.net, RFP for new sponsored TLD’s, Inter-Registrar Transfer Policy, strategy and policy for
introduction of new TLDs, and other projects that included broad community and global
participation.
Assisted in strategic preparation for Governmental Hearings including preparation of reports,
speeches and presentations.
Management of all ICANN IDN workshops.
Management and execution of all ICANN IDN programs and projects, including revision of
IDN guidelines, development of the IANA repository for IDN TLD practices, technical IDN
TLD experiments, review and authorization of registries and their IDN implementations,
development of policies concerning the introduction of IDN TLDs, and so forth.
Development and implementation of the ICANN IDN ccTLD Fast Track Program for
introduction of new IDN ccTLDs for countries and territories.
Execution and evaluation of received IDN ccTLD requests, resulting in the introduction of
more than 35 IDN ccTLDs, representing over 20 languages for close to 30 countries and
territories. These includes: Algeria, Bangladesh, China, Hong Kong, India, Iran, Jordan, Oman,
Palestine, Qatar, Russia, Serbia, Singapore, South Korea, Sri Lanka, Syria, Taiwan, Thailand,
UAE and many more.
Liaison to various linguistic and technical committees and working groups in the IDN field,
including IETF, IAB, SSAC, UTC, UNESCO, ARAB League, AFRNIC, and many more.
European Domain Registry absl, Luxembourg
Co-founder and Director
12/01-10/04
EUDR, headquartered in Luxembourg, was organized to bid for and manage the .EU domain name to
the European Commission. My responsibilities included co-founding the company and drafting various
aspects of the .EU application. As the organization has grown my position has evolved from being an
active officer of the company to a member of the board of directors, and so my current position will not
interfere with a full time position elsewhere.
11/02-05/03
Freelance Consultant
Consultant to technology organizations, including:
Tucows Inc. (Toronto, Canada)
Product Manager/Project Manager
Tucows is a leading provider of Internet services to Internet service providers (ISPs) and Web hosting
companies on a global basis. I completed a three month project managing new product development.
SWITCH (Zurich, Switzerland)
Analyst
SWITCH serves the Swiss science network which it is constantly expanding. I completed a short project
to analyse the business and technical impact of possible de-regulation of the policies and procedures
governing the ccTLD’s .ch and .li top level domains.
Momentous Inc. (Ottawa, Canada)
Acting VP Product
Momentous owns both ICANN and CIRA accredited domain name registrars. I completed a one month
interim project as acting VP Product.
Ascio Technologies Inc. , Denmark
1/01-11/02
Ascio Technologies Inc. is an ICANN accredited domain name technology provider with approximately
75 employees headquartered in Copenhagen, Denmark.
Project Manager & Product Manager, Domain Technology
End to end project manager on all external products within the Domain Technology. Among other
functions the job involves launching the new generic top level domains (responsible for all internal and
external relationships, both on the customer and the supplier side). Project manager on the company
OPPAPP001611
web-site, including definition of content and placement with focus on the need of the customer,
optimization of search engine results and on-line advertisement. Further, project manager on internal
products such as the partner billing system, development of price specification model, marketing and
sales material provider, pre-sale and negotiation of deals with large partners, account management, key
account management, technical account management, training of customer support personal,
telemarketing support and training, financial interface on new products.
The projects were run in a disciplined and fast paced work environment and contained very sharp and
externally set deadlines and milestones. The results were very successful as Ascio/Speednames was
consistently among the top five registrars, globally, for all new generic top level domains. Internally the
projects resulted in creation of standard work methods for establishment of new products.
Registry Relation Manager
Executive reporting to the CEO with responsibility for developing and maintaining relationships with
registries and other suppliers. Negotiated contract terms and prices as well as establishment of policy
and procedure agreements. Current portfolio holds more than 200 top-level domains. Managed
operational, product, technical, service and sales aspects of new products implemented by research and
analysis of industry standards and initiatives. This was more specifically possible by participating in all
ICANN conferences as well as other Internet events, including membership of the registrar’s
constituency.
This position included detailed knowledge and hands-on experience as well as planning on the overall
strategic level.
8/99-12/00
Microsoft Corporation (formerly Navision Software a/s), Denmark
Microsoft purchased Navision in July 2002. Based in Denmark, Navision has excelled in delivering
business solutions in Europe and worldwide since 1985.
Software Designer, Systems Architecture Division
Key area of focus comprises analysis and design of architecture and applications on the new generation
of products (initially a field service management system), which is based on an entirely new platform.
This includes carrying out design documentation used for the programmers, ordinary documentation for
the business architects as well as minor programming, testing and presenting (live and video) of
prototypes. Researching analysis tools and documentation standards.
Associate, Management Information
Responsible for developing, maintaining and implementing procedures within the areas of financial
management and information management. Responsible for developing models to make cost and
investments budgets. This included annual budgets, rolling budgets every 3 month and multi-year
budgets, as well as financial management systems. Working as the financial controller regarding all cost
consumptions.
Assist with implementing and developing the project management system.
Responsible for developing and implementing the department’s time accounting system.
Responsible for maintaining user and access rights.
9/98-6/99
Aalborg University, Denmark
Teacher in Statistics, the Business Faculty
A two-semester course for MBA students, giving an introduction to Business Statistics. Main focus on
methods for statistical description and analysis.
EDUCATIONAL/PERSONAL
EXPERIENCE:
BBA Marketing Management & International Management and Economics
Copenhagen Business School , Denmark
9/99-5/03
A business oriented education in three parts each estimated to 2 years. It is a challenging education that
takes place at night in a unique professional assembly. It is especially relevant for people with practical
experience and with the demand for continuing professional education at a high level. It gives a solid
basis in the economically line and a specialized theoretically knowledge within a chosen business
economics area.
Master of Science in Mathematics and Physics
Aalborg University, Denmark
OPPAPP001612
7/93-7/99
My thesis is a comprehensive report with focus on the theory on spatial point processes. Defining point
processes, classes, models including various simulations and algorithms. The thesis is now used for
educational purposes at Universities in Denmark.
BOARD OF DIRECTORS/
ADVISORY BOARD POSITIONS:
Founding Board Member, EUDR
A pan-European organization bidding for the EU Commission’s Registry Operator for the
top-level domain DOT EU. http://www.eudr.org
Advisory Board Member, Organic Names
A UK based company that recently applied for the registry for the top-level domain DOT
ORG. http://www.organicnames.org
Member of Ladies Circle Denmark - counterpart to the Round Table foundation.
Pending member of the Eastern Star – counterpart to the Freemasonic Association
PUBLICATIONS:
Spatial Point Processes - Models, Simulation, and Statistical Inference, by T. Dam, JB. Soerensen, and MH. Thomsen, June
1999.
LANGUAGE SKILLS:
Besides my native language (Danish) and the other Scandinavian languages, Swedish and Norwegian, I am fluent in English,
intermediate in German, and I have basic skills in Spanish and Turkish.
OPPAPP001613
TINA DAM
20 29th Ave #301 | Venice, California 90291 | USA |+1-310-862-2026 | Email: tinadam@gmail.com
Tina Dam has been on the forefront of Internet technology and the domain industry for over a decade. Tina's leadership
played a vital role in shaping the latest effort in transforming Internet architecture and the domain name system into a truly
global platform by launching Internationalized Domain Names in different languages and scripts. She was also named as
one of the Top 10 Talents in IT by the leading Danish tech magazine Berlingske.
Tina is a leading expert and authority in Internationalized Domain Names (IDNs) and the Domain Name System (DNS) in
the Internet industry. She is the co-founder of myTLD, a technology company specializing in launching new innovative
Top-Level Domains (TLDs) for industry sectors, communities and brands [http://mytld.com]. Tina serves as COO of
.music, the exclusive community top-level domain for the global music industry [http://music.us].
Tina is IDN advisor to various Internet organizations, including ICANN, the governing body that co-ordinates the operation
and evolution of the DNS root name server system and ensures the stable and secure operation of the Internet.
Tina previously served as ICANN Director for IDNs, where she developed and managed all IDN-related projects and
launches. Tina's primary track-record at ICANN focus on included the implementation, launch and management of the
IDN ccTLD Fast-Track Process for global governments as well as the new IDN gTLD Program that will enable the
deployment of internationalized top-level domains on the Internet.
Under her leadership at ICANN, the following countries obtained approval for their IDN ccTLD: Algeria, Bangladesh,
China, Egypt, Hong Kong, India, Iran, Jordan, South Korea, Morocco, Oman, Pakistan, Palestine, Qatar, Russia, Saudi
Arabia, Serbia, Singapore, Sri Lanka, Syria, Taiwan, Thailand, Tunisia, Ukraine, and UAE. These countries represent a
total of 36 IDN ccTLDs.
Tina is a frequent speaker at Internet and DNS Industry events. Conferences include: ICANN meetings, Business Access
meetings, and Regional Gatherings; Asia Pacific Network Information Center (APNIC) events; Asia Pacific Top Level
Domain Association (APTLD) events; Latin American and Caribbean TLD Association (LACTLD); DNS Root Server
System Advisory Committee (RSSAC) Meetings; Internet Engineering Task Force (IETF) Meetings; Domain Round
Tables events; and many more.
She also have developed IDN focused videos and provided presentations and tutorials for the U.S Department of
Commerce, law enforcement agencies such as the FBI, universities, and all ICANN supporting organizations and advisory
committees, such as Generic Names Supporting Organization (GNSO), Country-Code Names Supporting Organization
(ccNSO), Governmental Advisory Committee (GAC) and the At-Large Advisory Committee (ALAC).
Tina has been featured in television, radio, online, and print media, including the Wall Street Journal, the Washington
Post, the Associated Press, BBC, CNN, Aljazeera, CNET, Inc, Techcrunch, Mashable, PC Mag, Computer World, ZDnet
and many other major media outlets and blogs across the world.
Tina joined ICANN in 2003 as Chief gTLD Registry Liaison, where she was responsible for developing ICANN's gTLD
Registry functions including defining, managing, and implementing processes in accordance with ICANN agreements and
consensus policies for servicing gTLD registries.
Prior to ICANN she worked with several companies in the Internet DNS community including ICANN-accredited registrar
Tucows; ICANN-accredited registrar Ascio Technologies (formerly known as SpeedNames), where she oversaw the
launches of the .biz, .info, and .name top-level domains as well as managed the development of all related internal and
external products and product marketing materials. Prior to her experience in the domain industry, Tina served as
Systems Architecture Engineer at Navision Software (now Microsoft), establishing the architecture design of the
company's next generation of enterprise business platform products, which currently are on the market.
Tina held the following Board positions: Founding Board Member, EUDR - A pan-European organization bidding for the
EU Commission’s Registry Operator for the top-level domain DOT EU); Advisory Board Member, Organic Names - A UK
based company that applied for the registry for the top-level domain DOT ORG.
Tina holds a Master of Science in Mathematics and Physics from the Aalborg University in Denmark and a BBA in
Marketing Management and International Trade from Copenhagen Business School.
OPPAPP001614
Ex. B
OPPAPP001615
OPPAPP001616 to
OPPAPP003008
NOT INCLUDED
CLARK DECL. ISO OPP MTN. SUMMARY JUDGMENT
Case No: 09-CV-5939 PJH
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