Video Professor, Inc. v. Amazon.com, Inc.

Filing 66

NOTICE Glossary of Terms by Plaintiff Video Professor, Inc. (Lasater, Kieran)

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 09-cv-00636-REB-KLM VIDEO PROFESSOR, INC., a Colorado corporation, Plaintiff, V. AMAZON.COM, INC., a Delaware corporation, Defendant. PLAINTIFF'S GLOSSARY OF TERMS Plaintiff Video Professor, Inc. ("VPI"), by and through its counsel, Fairfield and Woods, P.C., and pursuant to REB Civ. Practice Standard 111.1., hereby submits its Glossary of Terms, and states: 1). Organic , relevance - based, natural and free search results are used

interchangeably and refer to the search results that appear on major Internet search engines such as Google , Yahoo and MSN , as a result of an Internet user searching for a particular search term . These free results generally appear in a natural order of

relevance , with exact word matches appearing first, and, thereafter, in a descending order of relevance, other results of diminishing relevance. 2). Sponsored Link ads, Sponsored ads, D aid ads and keyword ads are used

interchangeably and refer to search results that appear above or along side of natural search results , sometimes under a banner named " Sponsored Links ." Paid ads are

generally ranked and displayed to search engine users in the order of the amount the

advertiser "bid" on the keyword or keywords searched by the Internet user which triggered the paid ad . They are generally ranked from top to bottom in the order of the amount of money "bid" for each click-through to the related Web page associated with the paid ad. Respectfully submitted this 19th day of April, 2010. FAIRFIELD AND WOODS, P.C.

s/ Kieran A. Lasater Gregory C. Smith Kieran A. Lasater 1700 Lincoln Street, Suite 2400 Denver, CO 80203 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR PLAINTIFF

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CERTIFICATE OF SERVICE I hereby certify that on the 19th day of April, 2010 , a true and correct copy of the foregoing PLAINTIFF'S GLOSSARY OF TERMS was sent CMIECF system addressed as follows: Marc C. Levy Faegre & Benson LLP 1700 Lincoln Street , Suite 3200 Denver , Colorado 80203 Email: [e-mail] S/ Julie B Julie Baling

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