Google Inc. v. American Blind & Wallpaper Factory, Inc.
Filing
188
Attachment 16
Declaration of Ajay S. Krishnan
In Support of Counter-Defendant Google Inc.'s Motion to Compel Counter-Plaintiff ABWF To Satisfy Outstanding Discovery Obligations filed byGoogle Inc., Google Inc.. (Attachments: #
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19)(Krishnan, Ajay) (Filed on 9/7/2006)
Google Inc. v. American Blind & Wallpaper Factory, Inc.
Doc. 188 Att. 16
Case 5:03-cv-05340-JF
Document 188-17
Filed 09/07/2006
Page 1 of 4
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Dockets.Justia.com
Case 5:03-cv-05340-JF
Document 188-17
Filed 09/07/2006
Page 2 of 4
'-
REDACTED .
ATTORN-cIEN PRIVIL£GE
- .a .;
~----Original Message----- .
From: Britton Mauchline (mailto: brittonegoogle.
com)
Sent: Friday, February. 07, 2003.3: 41 PM
To: bydesignalrbcg. com .Cc: Jeff Edwards; Kimberli_ Heard
Subject: RE: Google/USA Wallp~per/ABWF
Hi Tammy-
I have submitted to add the negative kws .'blind' and' factory' that wi
11 prevent your ads fro~ coming up when someone searches on 'American
Blind & Wallpaper Factory'.
Have. a great weekend!
- -Google
Client Services Specialist
401 N. Michigan Ave. l1200
Britton -Mauchline
-Chicago, IL 60611 _ 'britton8google. com ~maiito:britton8google.co~ 312.840.8261 - P .
312.~840.8?89 - f
-~---Original Message-----
From: USA Wallpaper (mailto:bydesignelrbcg.coml
To: Britton Mauchline .
Page 1
Sent: Monday, February 03, 2003 5:02 PM
ABWF 001308
Subject: RE: - Google/USA Wallpaper/ABWF
BØØØØ24
Case 5:03-cv-05340-JF
Document 188-17
Filed 09/07/2006
Page 3 of 4
Google email re negative kw
- Hi Britton:
. We have a problem that I need your assistance
with. As I think you are aware, our coinpetitor, American Blind and Wallpaper Factory, has stated to both you and .Overture that. they will not allow any advertise search term "American Blind & Wallpaper" or combination.o r to use the
f.
,..;
I received an email from Google stating this (see below) so I know you _ are aware of this. We had no problem with that. . Today again our listing was showing up under "American Blind & Wallpap
er Factory" and "American Blind & wallpaper Co." as sponsored .
- . removed immediately, as they are threatening to sue us.
listing in Premium. My guess is those are being thrown in as freebies to satisfy the impressions in the campaign? Those ads need to be
,,
. We got our trademark attorney involved and there is no problem with us using the search term "American wallpaper" because that describes a product and they do not own the trademark on a descriptive phrasß such as that. However, all our terms for their trademark names "American
. . Tammy
Blind- & Wallpaper" "American Blir:d & Wallpaper Factory" and "Decorate -roday" must be removed immediately. Can you assist?
USA Wallpaper
1-800-573-5824 . maii to: bydesignalrbcg. com
http://www.usawallpaper.com
-----Or iginalMessage----From: Britton Mauchline fmailto:brittonØgoogle. com)
Sent: Tuesday, January 07,200312:06 PM
To: USA Wallpaper Cc: Jeff Edwards SubjeGt: Google/USA Wallpaper/ABWF
Hi Tammy-
Just wanted to touch base with you now that it i S a brand new year and
great things with your Premium campaign r Your we're seeing such CTRs have been steadily climbing and are pow between 10-12% when they the results had been between 6-8% before. I hope you're seeing
on your end as well!
On anothe~ note, American Blind & Wallpaper Factory has recently had G oogle remove all advertisers from their trademarked terms: American. Blind and wallpaper Factory, Decoratetoday and American Blind Factory. They have also requested to add the negative kws "Blind" and "Factory" to the kw "american wallpaper.' you have running in your campaigns so your ads will not appear on a query for their
Page 2
ABWF 001309 .
- ,.
SØØØØZ5
Case 5:03-cv-05340-JF
Document 188-17
Filed 09/07/2006
Page 4 of 4
Thanks so much for your help and I. look
are going for you so far this year!'
campaigns.
ng these negatives to that kw in both your Premium and AWS
trademarked brand. Please let me know if you would be amenable to addi
forward to hearing how things
Google email re negative kw
Britton Mauchline Client Services sP~ciålist
Google
. Chicago, IL 60611 '.
.312.840.8261 - p
:312.840.8289 - f
401 N. Michigan Ave. #1200
brittonØgoogle. com ~mail to: bri ttonØgoogle. com~
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LRBCG. COM, LRBCG. COM,
Inc ~ J
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ABWF 001310
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