Google Inc. v. American Blind & Wallpaper Factory, Inc.

Filing 17

Declaration of Susan J. Greenspon in Support of 16 Defendant's Reply Brief in Support of Its Motion to Dismiss, Or, Alternatively, to Stay filed by American Blind & Wallpaper Factory, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D)(Related document(s)16) (Phillips, Robert) (Filed on 3/22/2004)

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KELLEY DRYE & WARREN LLP 333 WEST W Case 5:03-cv-05340-JF Document 17 Filed 03/22/2004 Page 2 of 3 1 2 3 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 KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606 Declaration and, if called as a witness, could and would testify competently to such facts under oath. 2. Attached hereto as Exhibit A is a true and correct copy of Bill Smith' January 3, s 2003 e-mail to Britton Mauchline and Britton Mauchline' reply thereto. s 3. Attached hereto as Exhibit B is a true and correct copy of Alex Salkever' January s 22, 2004 article, Searching For Trouble? Keyword ads are big earners for Google, Yahoo!, and AOL, so trademark lawsuits currently in the courts could spell major hassles, which appeared in Business Week online. 4. Attached hereto as Exhibit C is a true and correct copy of Britton Mauchline' s November 20, 2002 e-mail to Bill Smith. 5. Attached hereto as Exhibit D is a true and correct copy of Google' AdWords s Keyword Suggestions for the term "American Blinds." 6. Google' "AdWords Keyword Suggestions" feature, is not available to, or even s viewable by, the public. 7. As part of Google' AdWords Keyword Suggestions feature, each of Google' s s "suggestions" are lumped into categories by Google and are sometimes referred to as an "optimization campaign" in marketing these key word groupings to Google' paying customers s looking to increase their advertising on Google. Google has labeled the optimization campaign containing numerous iterations of American Blind' trademarks, the "American Blind" s optimization campaign. Executed on March 22, 2004, at Chicago, Illinois. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. ______/s/ Susan J. Greenspon________ Susan J. Greenspon -2- DECLARATION OF SUSAN J. GREENSPON Case 5:03-cv-05340-JF Document 17 Filed 03/22/2004 Page 3 of 3 1 2 3 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 KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606 ATTESTATION OF CONCURRENCE OF FILING I attest that Susan J. Greenspon has concurred in the filing of this document. ______/s/ Robert N. Phillips__________ Robert N. Phillips -3- DECLARATION OF SUSAN J. GREENSPON

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