Kinderstart.Com, LLC v. Google, Inc.
Filing
70
Attachment 3
Memorandum in Opposition
to 60 Google's Motion for Sanctions against KinderStart and Gregory J. Yu filed byKinderstart.Com, LLC. (Attachments: #
1 Exhibit Ex 1 - Declaration of Gregory J. Yu#
2 Exhibit Ex 2 - Declaration of Titus Lin#
3 Exhibit Ex 3 - Declaration of Randall McCarley)(Yu, Gregory) (Filed on 11/17/2006) Modified on 11/29/2006 (gm, COURT STAFF).
Kinderstart.Com, LLC v. Google, Inc.
Doc. 70 Att. 3
Case 5:06-cv-02057-JF
Document 70-4
Filed 11/17/2006
Page 1 of 3
KinderStart.com LLC v. Google, Inc. C 06-2057 JF
EXHBIT 3
DECLARATION OF RANDALL McCARLEY IN SUPPORT OF PLAINTIFFS' OPPOSITION TO DEFENDANT'S MOTION FOR SANCTIONS AGAINST PLAINTIFF AND ITS LEGAL COUNSEL UNDER FED.R.CIV.P. 11
Dockets.Justia.com
Case 5:06-cv-02057-JF
Document 70-4
Filed 11/17/2006
Page 2 of 3
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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 Case No. C 06-2057 JF KINDERSTART.COM LLC, a California limited liability company, on behalf of itself and all others similarly situated, DECLARATION OF RANDALL McCARLEY IN SUPPORT OF Plaintiffs, PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION FOR v. SANCTIONS AGAINST KINDERSTART AND ITS LEGAL GOOGLE, INC., a Delaware corporation, COUNSEL UNDER FED. R. CIV. P. 11 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
DECLARATION OF RANDALL McCARLEY IN SUPPORT OF PLAINTIFFS' OPPOSITION TO DEFENDANT'S -1MOTION FOR SANCTIONS UNDER RULE 11
Case No. C 06-2057 JF
Case 5:06-cv-02057-JF
Document 70-4
Filed 11/17/2006
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were removed from view because of censorship or violation of Webmaster guidelines. Before 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 16th day of November, 2006 in Sacramento, California. By:___/s/ Randall McCarley__________________ RANDALL McCARLEY
DECLARATION OF RANDALL McCARLEY IN SUPPORT OF PLAINTIFFS' OPPOSITION TO DEFENDANT'S -2MOTION FOR SANCTIONS UNDER RULE 11
Case No. C 06-2057 JF
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