CLRB Hanson Industries, LLC et al v. Google Inc.

Filing 90

Declaration of M. Christopher Jhang in Support of 85 First MOTION for Summary Judgment or in the Alternative, for Summary Adjudication filed byGoogle Inc.. (Attachments: # 1 Exhibit Exhibit A# 2 Exhibit Exhibit B# 3 Exhibit Exhibit C# 4 Exhibit Exhibit D# 5 Exhibit Exhibit E)(Related document(s) 85 ) (Jhang, Christopher) (Filed on 10/2/2006)

CLRB Hanson Industries, LLC et al v. Google Inc.

Doc. 90

Case 5:05-cv-03649-JW

Document 90

Filed 10/02/2006

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DAVID T. BIDERMAN, Bar No. 101577 JUDITH B. GITTERMAN, Bar No. 115661 M. CHRISTOPHER JHANG, Bar No. 211463 PERKINS COIE LLP Four Embarcadero Center, Suite 2400 San Francisco, CA 94111-4131 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail] Attorneys for Defendant Google Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

CLRB HANSON INDUSTRIES, LLC d/b/a INDUSTRIAL PRINTING, and HOWARD STERN, on behalf of themselves and all others similarly situated, Plaintiffs,

CASE NO. C O5-03649 JW DECLARATION OF M. CHRISTOPHER JHANG

15 v. 16 GOOGLE, INC., 17 Defendant. 18 19 20 21 22 23 24 25 26 27 28
DECLARATION OF M. CHRISTOPHER JHANG CASE NO. 05-03649

I, M. Christopher Jhang, declare as follows: 1. I am an attorney duly licensed to practice law in all of the courts of the State of

California and this Court, and am an attorney with the law firm of Perkins Coie LLP, counsel for defendant Google Inc. ("Google") in this action. I submit this declaration in support of Google's Motion for Summary Judgment, or in the Alternative, for Summary Adjudication. I have personal knowledge of the facts set forth below except as to those matters stated on information and belief, and as to those matters, I believe them to be true. If called upon to testify, I could and would testify competently as to the matters set forth herein.

[41063-0023/BY062740.011]

Dockets.Justia.com

Case 5:05-cv-03649-JW

Document 90

Filed 10/02/2006

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2.

Attached hereto as Exhibit A are true and correct copies of excerpts of the

deposition transcript of Brett R. Hanson, plaintiff CLRB Hanson Industries, LLC, d/b/a Industrial Printing's representative, taken in this case on August 18, 2006. 3. Attached hereto as Exhibit B are true and correct copies of excerpts of the

deposition transcript of plaintiff Howard Stern, taken in this case on August 16, 2006. 4. On August 15, 2006, I printed the Google Inc. Advertising Program Terms from

the Google AdWords web site. Attached hereto as Exhibit C is a true and correct copy of that document. 5. On August 14, 2006, I printed the Google Inc.'s AdWords Frequently Asked

Questions ("FAQs") from the Google AdWords web site. Attached hereto as Exhibit D are true and correct copies of excerpts of that document. 6. Attached hereto as Exhibit E is a true and correct copy (without exhibits) of the

Class Action Complaint styled as CLRB Hanson Industries, LLC d/b/a Industrial Printing v. Google, Inc., filed in the Superior Court of California, for the County of Santa Clara, on August 3, 2005. I declare under penalty of perjury under the laws of the State of California and the United States that the foregoing is true and correct. Executed this 2nd day of October, 2006, at San Francisco, California.

/S/ M. Christopher Jhang

-2DECLARATION OF M. CHRISTOPHER JHANG CASE NO. 05-03649
[41063-0023/BY062740.011]