Kinderstart.Com, LLC v. Google, Inc.

Filing 69

Attachment 2
Cross MOTION for Sanctions Against Google, Inc. and David H. Kramer filed by Kinderstart.Com, LLC. Motion Hearing set for 1/19/2007 09:00 AM in Courtroom 3, 5th Floor, San Jose. (Attachments: # 1 Exhibit Ex 1 - Declaration of Titus Lin# 2 Exhibit Ex 2 - Declaration of Randall McCarley# 3 Exhibit Ex 3 - Request for Judicial Notice# 4 Exhibit Ex 4 - Declaration of Gregory J. Yu)(Yu, Gregory) (Filed on 11/16/2006)

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Kinderstart.Com, LLC v. Google, Inc. Doc. 69 Att. 2 Case 5:06-cv-02057-JF Document 69-3 Filed 11/16/2006 Page 1 of 3 KinderStart.com LLC v. Google, Inc. C 06-2057 JF EXHBIT 2 Declaration of Randall McCarley In support of Plaintiff's Motion for Sanctions Against Google, Inc. and its Legal Counsel under Rule 11 Dockets.Justia.com Case 5:06-cv-02057-JF Document 69-3 Filed 11/16/2006 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 Gregory J. Yu (State Bar No. 133955) GLOBAL LAW GROUP 2015 Pioneer Court, Suite P-1 San Mateo, CA 94403 Telephone: (650) 570-4140 Facsimile: (650) 570-4142 E-mail: glgroup [at] inreach [dot] com Attorney for Plaintiffs and Proposed Class and Subclasses UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION KINDERSTART.COM LLC, a California Case No. C 06-2057 JF limited liability company, on behalf of itself and all others similarly situated, DECLARATION OF RANDALL McCARLEY IN SUPPORT OF Plaintiffs, PLAINTIFF'S MOTION FOR SANCTIONS AGAINST GOOGLE, INC. v. AND ITS LEGAL COUNSEL DAVID H. KRAMER UNDER FED. R. CIV. P. 11 GOOGLE, INC., a Delaware corporation, Defendant. I, RANDALL McCARLEY, HEREBY DECLARE AS FOLLOWS: 1. 2. I am sole proprietor of a firm called 14th Colony based in Sacramento, California. For the past 10 years, I have worked with numerous clients and their Websites to determine if their sites are designed in a way and manner to make them appealing, user-friendly, and accessible through a search engine. 3. Since 1999, I have regularly used the search engine of Google at www.google.com multiple times each week on various topics. I have used the engine for both personal reasons and client-related reasons. For client work, I carefully examine key word search engine results pages generated by Google's engine. In all of my searches with Google's engine within the U.S., I have never seen on a search engine results page any notice that the certain search results were removed from view because of censorship or violation of Webmaster guidelines. Before DECLARATION OF RANDALL McCARLEY IN SUPPORT OF PLAINTIFFS' MOTION FOR SANCTIONS AGAINST GOOGLE UNDER RULE 11 -1- Case No. C 06-2057 JF Case 5:06-cv-02057-JF Document 69-3 Filed 11/16/2006 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 September 22, 2006, I communicated to Plaintiffs' counsel by telephone the foregoing information about my search engine use and experience. I DECLARE UNDER PENALTY OF PERJURY, that the above is based on my personal knowledge, except for those matters above stated on information and belief. Executed on this 19th day of October, 2006 in Sacramento, California. By:___/s/ Randall McCarley__________________ RANDALL McCARLEY DECLARATION OF RANDALL McCARLEY IN SUPPORT OF PLAINTIFFS' MOTION FOR SANCTIONS AGAINST GOOGLE UNDER RULE 11 -2- Case No. C 06-2057 JF

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