Netquote Inc. v. Byrd

Filing 56

Attachment 9
RESPONSE to Motion re 49 MOTION for Protective Order filed by Defendant Mostchoice.com, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B-1# 3 Exhibit B-2# 4 Exhibit B-3# 5 Exhibit C# 6 Exhibit D# 7 Exhibit E# 8 Exhibit F# 9 Affidavit Declaration of Michael Levy)(Isenberg, Ryan)

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Netquote Inc. v. Byrd Doc. 56 Att. 9 Case 1:07-cv-00630-DME-MEH Document 56-10 Filed 07/27/2007 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 07-cv-00630-DME-MEH NETQUOTE INC, a Colorado corporation, Plaintiff, v. BRANDON BYRD, an internet user making use of the IP Addresses 64.136.27.226 and 64.136.26.227, and MOSTCHOICE.COM, Inc., a Georgia corporation Defendants. DECLARATION OF MICHAEL A. LEVY UNDER 28 U.S.C § 1746 I, Michael A. Levy , declare as follows: 1. I am the chairman and founder of Mostchoice.com. I am over 18 years of age. The facts herein are based upon my personal knowledge. 2. Both prior and subsequent to October, 2006 Mostchoice has sold and continues to sell insurance leads to customers that also purchase leads from Netquote. 3. In approximately January, 2006, I met with Scott Striegel and Craig Shine, President and Vice President of Netquote respectively. Prior to that conversation, Mr. Streigel executed a non-disclosure agreement on behalf of Netquote prohibiting disclosure of information learned during the meeting. 4. Without revealing the specifics, during the meeting it was discussed and agreed that the identity of the large lead purchasers were known to both Netquote and Mostchoice, and we discussed lead pricing, and other matters. Dockets.Justia.com Case 1:07-cv-00630-DME-MEH Document 56-10 Filed 07/27/2007 Page 2 of 2 5. I declare under penalty or perjury that the foregoing is true and correct to the best of my knowledge. This the 27th day of July, 2007. s/ Michael Levy Michael A. Levy

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