GREAT SOCIALIST PEOPLE'S LIBYAN ARAB JAMAHIRIYA et al v. MISKI

Filing 1

COMPLAINT against AHMAD MISKI ( Filing fee $ 350 receipt number 4616000655.)filed by GREAT SOCIALIST PEOPLE'S LIBYAN ARAB JAMAHIRIYA, EMBASSY OF THE LIBYAN ARAB JAMAHIRIYA. (Attachments: # 1 Civil Cover Sheet)(td, )

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Civil Division
GREAT SOCIALIST PEOPLE’S
LIBYAN ARAB JAMAHIRIYA
2600 Virginia Avenue, N.W., Suite 705
Washington, DC 20037-1925

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and
EMBASSY OF THE LIBYAN ARAB JAMAHIRIYA
2600 Virginia Avenue, N.W., Suite 705
Washington, DC 20037-1925
Plaintiffs,
vs.
AHMAD MISKI
972 Mount Holly Drive
Annapolis, Maryland 21401
Defendant.
COMPLAINT

Plaintiff Great Socialist People’s Libyan Arab Jamahiriya and Plaintiff Embassy
of the Libyan Arab Jamahiriya, by and through their attorneys, J.P. Szymkowicz, John T.
Szymkowicz and the Law Firm of Szymkowicz & Szymkowicz, LLP, sues Defendant
Ahmad Miski and requests that this Honorable Court:
a.

order the forfeiture and cancellation of the domain names “embassyoflibya.org,”

“libyaembassy.com,” “libyaembassy.org” and “libyanembassy.com” that have been
registered by Defendant Ahmad Miski pursuant to 15 U.S.C. § 1125 (d) (1) (C);
b.

order

that

the

“embassyoflibya.org,”

ownership

and

registration

“libyaembassy.com,”

of

the

domain

“libyaembassy.org”

names
and

“libyanembassy.com” be transferred to Plaintiff Great Socialist People’s Libyan Arab

Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya pursuant to 15 U.S.C. §
1125 (d) (1) (C);
c.

order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya the sum equal to
Defendant Miski’s profits from the use of the domain names “embassyoflibya.org,”
“libyaembassy.com,” “libyaembassy.org” and “libyanembassy.com” pursuant to 15
U.S.C. § 1117 (a) (1), or alternatively, order Defendant Ahmad Miski to pay Plaintiff
Great Socialist People’s Libyan Arab Jamahiriya and Plaintiff Embassy of the Libyan
Arab Jamahiriya statutory damages of Four Hundred Thousand Dollars ($400,000.00)
pursuant to 15 U.S.C. § 1117 (d);
d.

order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya the sum equal to
Plaintiff Great Socialist People’s Libyan Arab Jamahiriya’s and Plaintiff Embassy of the
Libyan Arab Jamahiriya’s damages from Defendant Miski’s use of the domain names
“embassyoflibya.org,”

“libyaembassy.com,”

“libyaembassy.org”

and

“libyanembassy.com” which Plaintiff Great Socialist People’s Libyan Arab Jamahiriya
and Plaintiff Embassy of the Libyan Arab Jamahiriya estimate to be at least One Million
Dollars ($1,000,000.00) pursuant to 15 U.S.C. § 1117 (a) (2), or alternatively, order
Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan Arab
Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya statutory damages of
Four Hundred Thousand Dollars ($400,000.00) pursuant to 15 U.S.C. § 1117 (d);
e.

order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya its reasonable
costs in prosecuting the instant action pursuant to 15 U.S.C. §1117 (a) (3); and

2

f.

order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya its reasonable
attorneys’ fees in prosecuting the instant action pursuant to 15 U.S.C. 1117 (a).
Jurisdiction
1.

This Honorable Court has jurisdiction over the claims presented in the instant

Complaint pursuant to 28 U.S.C. § 1330 as Plaintiff Great Socialist People’s Libyan Arab
Jamahiriya is a “foreign state” and Plaintiff Embassy of the Libyan Arab Jamahiriya is an
“agency or instrumentality” of a “foreign state.”
2.

This Honorable Court also has jurisdiction over the claims presented in the instant

Complaint pursuant to 15 U.S.C. 1121 (a) as the instant action concerns Defendant
Ahmad Miski’s registration and use of the domain names “embassyoflibya.org,”
“libyaembassy.com,” “libyaembassy.org” and “libyanembassy.com.”
Venue
3.

Venue is proper in this Honorable Court pursuant to 28 U.S.C. §1391 (b) as the

District of Columbia is the judicial district in which a substantial part of the events or
omissions giving rise to the claim occurred or a substantial part of the property that is the
subject of the instant action is situated, specifically the Embassy of the Libyan Arab
Jamahiriya.
Parties
4.

Plaintiff Great Socialist People’s Libyan Arab Jamahiriya [hereinafter the

“Libyan Government”] is a “foreign state” as defined in 28 U.S.C. § 1603 (a) that
operates in the United States of America through its embassy located in the Watergate
complex in Washington, DC.

3

5.

As defined in 28 U.S.C. § 1603 (b), Plaintiff Embassy of the Libyan Arab

Jamahiriya is an “agency or instrumentality” of a “foreign state,” namely the Great
Socialist People’s Libyan Arab Jamahiriya, as Plaintiff Embassy of the Libyan Arab
Jamahiriya is a “separate legal person, corporate or otherwise” or “an organ of a foreign
state or political subdivision thereof.”
6.

Plaintiff Embassy of the Libyan Arab Jamahiriya in Washington, DC performs

many, if not most, of the diplomatic functions typically performed by a sovereign
nation’s embassy in Washington, DC.
7.

Defendant Ahmad Miski is believed to be an adult who resides in the State of

Maryland.
8.
names

Defendant Ahmad Miski is believed to be the owner of record of the domain
“embassyoflibya.org,”

“libyaembassy.com,”

“libyaembassy.org”

and

“libyanembassy.com.”
9.

Defendant Ahmad Miski is believed to be the individual who benefits from third

parties’ use of the domain names “embassyoflibya.org,” “libyaembassy.com,”
“libyaembassy.org” and “libyanembassy.com.”1
Domain Names at Issue
10.

The four domain names at issue in the instant case, “embassyoflibya.org,”

“libyaembassy.com,” “libyaembassy.org” and “libyanembassy.com” all “point to” the
same “home page.”2

1

A printout of the “WHOIS” record for each of these domain names is attached to
the instant Complaint as Exhibit 1.
2

A printout of this “home page” is attached to the instant Complaint as Exhibit 2.
4

Defendant Miski’s Misuse of Plaintiffs’ Marks
11.

On the “home page” that the four domain names at issue link to, Defendant Miski

describes that
1.

We will authenticate the document from the Department of State.

2.

We will certify the document from the Chamber of Commerce.

3.

We will legalize the document from the Libyan embassy in

Washington, DC.
12.

For performing these services, Defendant Miski charges fees that begin at $95.00.

13.

Pursuant to 15 U.S.C. § 1125 (c) (2) (A), the terms “Embassy of Libya,” “Libya

Embassy” and “Libyan Embassy” are “famous marks” that are widely recognized by the
general consuming public of the United States as a designation of the source of the goods
or services of the marks’ owners, Plaintiff Great Socialist People’s Libyan Arab
Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya.
14.

Pursuant to 15 U.S.C. § 1125 (c) (2) (B), the terms “Embassy of Libya,” “Libya

Embassy” and “Libyan Embassy” are “famous marks” that are similar to the marks used
by Defendant Miski to link to his website, “embassyoflibya.org,” “libyaembassy.com,”
“libyaembassy.org” and “libyanembassy.com,” and thus, Defendant Miski’s use of these
marks impairs the distinctiveness of Plaintiff Great Socialist People’s Libyan Arab
Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya’s marks “Embassy of
Libya,” “Libya Embassy” and “Libyan Embassy.”
Count I – Violation of 15 U.S.C. § 1125 (a) (1) (A)
15.

The allegations contained in Paragraphs 1-14 of the instant Complaint are

incorporated herein as if fully stated.

5

16.

By registering the domain names, “embassyoflibya.org,” “libyaembassy.com,”

“libyaembassy.org” and “libyanembassy.com” and linking a common webpage to all of
these domain names that advertises Defendant Miski’s services for a fee, Defendant
Miski has used in commerce any word, term, name, symbol or device or any combination
thereof, or any false designation of origin, false or misleading description of fact, or false
or misleading representation of fact, which is likely to cause confusion, or to cause
mistake, or to deceive as to the affiliation, connection, or association of Defendant Miski
with Plaintiff Great Socialist People’s Libyan Arab Jamahiriya and Plaintiff Embassy of
the Libyan Arab Jamahiriya, or as to the origin, sponsorship, or approval of Defendant
Miski’s goods, services or commercial activities by Plaintiff Great Socialist People’s
Libyan Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya pursuant
to 15 U.S.C. § 1125 (a) (1) (A).
17.

As a direct and proximate result of Defendant Miski’s registration of the above-

referenced domain names and linkage to Defendant Miski’s website, Plaintiff Great
Socialist People’s Libyan Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab
Jamahiriya have suffered damages, including, but not limited to the dilution of its marks
“Embassy of Libya,” “Libya Embassy” and “Libyan Embassy.”
WHEREFORE, Plaintiff Great Socialist People’s Libyan Arab Jamahiriya and
Plaintiff Embassy of the Libyan Arab Jamahiriya respectfully requests that this
Honorable Court:
a.

Order the forfeiture and cancellation of the domain names “embassyoflibya.org,”

“libyaembassy.com,” “libyaembassy.org” and “libyanembassy.com” that have been
registered by Defendant Ahmad Miski pursuant to 15 U.S.C. § 1125 (d) (1) (C);
6

b.

Order

that

“embassyoflibya.org,”

the

ownership

and

registration

“libyaembassy.com,”

of

the

domain

“libyaembassy.org”

names
and

“libyanembassy.com” be transferred to Plaintiff Great Socialist People’s Libyan Arab
Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya pursuant to 15 U.S.C. §
1125 (d) (1) (C);
c.

Order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya the sum equal to
Defendant Miski’s profits from the use of the domain names “embassyoflibya.org,”
“libyaembassy.com,” “libyaembassy.org” and “libyanembassy.com” pursuant to 15
U.S.C. § 1117 (a) (1), or alternatively, order Defendant Ahmad Miski to pay Plaintiff
Great Socialist People’s Libyan Arab Jamahiriya and Plaintiff Embassy of the Libyan
Arab Jamahiriya statutory damages of Four Hundred Thousand Dollars ($400,000.00)
pursuant to 15 U.S.C. § 1117 (d);
d.

Order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya the sum equal to
Plaintiff Great Socialist People’s Libyan Arab Jamahiriya’s and Plaintiff Embassy of the
Libyan Arab Jamahiriya’s damages from Defendant Miski’s use of the domain names
“embassyoflibya.org,”

“libyaembassy.com,”

“libyaembassy.org”

and

“libyanembassy.com” which Plaintiff Great Socialist People’s Libyan Arab Jamahiriya
and Plaintiff Embassy of the Libyan Arab Jamahiriya estimate to be at least One Million
Dollars ($1,000,000.00) pursuant to 15 U.S.C. § 1117 (a) (2), or alternatively, order
Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan Arab
Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya statutory damages of
Four Hundred Thousand Dollars ($400,000.00) pursuant to 15 U.S.C. § 1117 (d);
7

e.

Order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya its reasonable
costs in prosecuting the instant action pursuant to 15 U.S.C. §1117 (a) (3); and
f.

Order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya its reasonable
attorneys’ fees in prosecuting the instant action pursuant to 15 U.S.C. 1117 (a).
Count II – Violation of 15 U.S.C. § 1125 (a) (1) (B)
18.

The allegations contained in Paragraphs 1-14 of the instant Complaint are

incorporated herein as if fully stated.
19.

By registering the domain names, “embassyoflibya.org,” “libyaembassy.com,”

“libyaembassy.org” and “libyanembassy.com” and linking a common webpage to all of
these domain names that advertises Defendant Miski’s services for a fee, Defendant
Miski has used in commerce any word, term, name, symbol or device or any combination
thereof, or any false designation of origin, false or misleading description of fact, or false
or misleading representation of fact, which, in commercial advertising or promotion,
misrepresents the nature, characteristics, qualities or geographic origin of Defendant
Miski’s goods, services or commercial activities and implies that these goods, services or
commercial activities are sponsored or approved by Plaintiff Great Socialist People’s
Libyan Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya pursuant
to 15 U.S.C. § 1125 (a) (1) (B).
20.

As a direct and proximate result of Defendant Miski’s registration of the above-

referenced domain names and linkage to Defendant Miski’s website, Plaintiff Great
Socialist People’s Libyan Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab

8

Jamahiriya have suffered damages, including, but not limited to the dilution of its marks
“Embassy of Libya,” “Libya Embassy” and “Libyan Embassy.”
WHEREFORE, Plaintiff Great Socialist People’s Libyan Arab Jamahiriya and
Plaintiff Embassy of the Libyan Arab Jamahiriya respectfully requests that this
Honorable Court:
a.

Order the forfeiture and cancellation of the domain names “embassyoflibya.org,”

“libyaembassy.com,” “libyaembassy.org” and “libyanembassy.com” that have been
registered by Defendant Ahmad Miski pursuant to 15 U.S.C. § 1125 (d) (1) (C);
b.

Order

that

“embassyoflibya.org,”

the

ownership

and

registration

“libyaembassy.com,”

of

the

domain

“libyaembassy.org”

names
and

“libyanembassy.com” be transferred to Plaintiff Great Socialist People’s Libyan Arab
Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya pursuant to 15 U.S.C. §
1125 (d) (1) (C);
c.

Order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya the sum equal to
Defendant Miski’s profits from the use of the domain names “embassyoflibya.org,”
“libyaembassy.com,” “libyaembassy.org” and “libyanembassy.com” pursuant to 15
U.S.C. § 1117 (a) (1), or alternatively, order Defendant Ahmad Miski to pay Plaintiff
Great Socialist People’s Libyan Arab Jamahiriya and Plaintiff Embassy of the Libyan
Arab Jamahiriya statutory damages of Four Hundred Thousand Dollars ($400,000.00)
pursuant to 15 U.S.C. § 1117 (d);
d.

Order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya the sum equal to
Plaintiff Great Socialist People’s Libyan Arab Jamahiriya’s and Plaintiff Embassy of the
9

Libyan Arab Jamahiriya’s damages from Defendant Miski’s use of the domain names
“embassyoflibya.org,”

“libyaembassy.com,”

“libyaembassy.org”

and

“libyanembassy.com” which Plaintiff Great Socialist People’s Libyan Arab Jamahiriya
and Plaintiff Embassy of the Libyan Arab Jamahiriya estimate to be at least One Million
Dollars ($1,000,000.00) pursuant to 15 U.S.C. § 1117 (a) (2), or alternatively, order
Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan Arab
Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya statutory damages of
Four Hundred Thousand Dollars ($400,000.00) pursuant to 15 U.S.C. § 1117 (d);
e.

Order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya its reasonable
costs in prosecuting the instant action pursuant to 15 U.S.C. §1117 (a) (3); and
f.

Order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya its reasonable
attorneys’ fees in prosecuting the instant action pursuant to 15 U.S.C. 1117 (a).
Count III – Violation of 15 U.S.C. § 1125 (d) (1) (A)
21.

The allegations contained in Paragraphs 1-14 of the instant Complaint are

incorporated herein as if fully stated.
22.

By registering the domain names, “embassyoflibya.org,” “libyaembassy.com,”

“libyaembassy.org” and “libyanembassy.com” and linking a common webpage to all of
these domain names, Defendant Miski has, without regard to the goods or services of the
parties, a bad faith intent to profit from the marks owned by Plaintiffs, specifically, the
marks “Embassy of Libya,” “Libya Embassy” and “Libyan Embassy” pursuant to 15
U.S.C. § 1125 (d) (1) (A) (ii).

10

23.

By registering the domain names, “embassyoflibya.org,” “libyaembassy.com,”

“libyaembassy.org” and “libyanembassy.com” and linking a common webpage to all of
these domain names, Defendant Miski has registered, trafficked in or used domain names
that are identical or confusingly similar to Plaintiffs’ marks that were distinctive or
famous at the time Defendant Miski registered these domain names, specifically, the
marks “Embassy of Libya,” “Libya Embassy” and “Libyan Embassy” pursuant to 15
U.S.C. § 1125 (d) (1) (A) (ii) (I) and 15 U.S.C. § 1125 (d) (1) (A) (ii) (I).
24.

By registering the domain names, “embassyoflibya.org,” “libyaembassy.com,”

“libyaembassy.org” and “libyanembassy.com” and linking a common webpage to all of
these domain names, Defendant Miski has registered, trafficked in or used domain names
that are identical or confusingly similar to Plaintiffs’ marks that is a trademark, word or
other name protected by reason of section 706 of title 18 of the United States Code or
section 220506 of title 36 of the United States Code pursuant to 15 U.S.C. § 1125 (d) (1)
(A) (ii) (III).
25.

As a direct and proximate result of Defendant Miski’s registration of the above-

referenced domain names and linkage to Defendant Miski’s website, Plaintiff Great
Socialist People’s Libyan Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab
Jamahiriya have suffered damages, including, but not limited to the dilution of its marks
“Embassy of Libya,” “Libya Embassy” and “Libyan Embassy.”
WHEREFORE, Plaintiff Great Socialist People’s Libyan Arab Jamahiriya and
Plaintiff Embassy of the Libyan Arab Jamahiriya respectfully requests that this
Honorable Court:

11

a.

Order the forfeiture and cancellation of the domain names “embassyoflibya.org,”

“libyaembassy.com,” “libyaembassy.org” and “libyanembassy.com” that have been
registered by Defendant Ahmad Miski pursuant to 15 U.S.C. § 1125 (d) (1) (C);
b.

Order

that

“embassyoflibya.org,”

the

ownership

and

registration

“libyaembassy.com,”

of

the

domain

“libyaembassy.org”

names
and

“libyanembassy.com” be transferred to Plaintiff Great Socialist People’s Libyan Arab
Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya pursuant to 15 U.S.C. §
1125 (d) (1) (C);
c.

Order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya the sum equal to
Defendant Miski’s profits from the use of the domain names “embassyoflibya.org,”
“libyaembassy.com,” “libyaembassy.org” and “libyanembassy.com” pursuant to 15
U.S.C. § 1117 (a) (1), or alternatively, order Defendant Ahmad Miski to pay Plaintiff
Great Socialist People’s Libyan Arab Jamahiriya and Plaintiff Embassy of the Libyan
Arab Jamahiriya statutory damages of Four Hundred Thousand Dollars ($400,000.00)
pursuant to 15 U.S.C. § 1117 (d);
d.

Order Defendant Ahmad Miski to pay Plaintiff Great Socialist People’s Libyan

Arab Jamahiriya and Plaintiff Embassy of the Libyan Arab Jamahiriya the sum equal to
Plaintiff Great Socialist People’s Libyan Arab Jamahiriya’s and Plaintiff Embassy of the
Libyan Arab Jamahiriya’s damages from Defendant Miski’s use of the domain names
“embassyoflibya.org,”

“libyaembassy.com,”

“libyaembassy.org”

and

“libyanembassy.com” which Plaintiff Great Socialist People’s Libyan Arab Jamahiriya
and Plaintiff Embassy of the Libyan Arab Jamahiriya estimate to be at least One Million
Dollars ($1,000,000.00) pursuant to 15 U.S.C. § 1117 (a) (2), or alternatively, order
12

Exhibit 1

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Domain ID:D103553410-LROR
Domain Name:EMBASSYOFLIBYA.ORG
Created On:25-Dec-2003 13:12:11 UTC
Last Updated On:06-Apr-2006 14:22:32 UTC
Expiration Date:25-Dec-2007 13:12:11 UTC
Sponsoring Registrar:eNom, Inc. (R39-LROR)
Status:OK
Registrant ID:0156837D12C3576E
Registrant Name:Ahmad Miski
Registrant Street1:972 Mt. Holly Dr.
Registrant Street2:
Registrant Street3:
Registrant City:Annapolis
Registrant State/Province:MD
Registrant Postal Code:21401
Registrant Country:US
Registrant Phone:[phone]
Registrant Phone Ext.:
Registrant FAX:
Registrant FAX Ext.:
Registrant Email:[e-mail]
Admin ID:0156837D12C3576E
Admin Name:Ahmad Miski
Admin Street1:972 Mt. Holly Dr.
Admin Street2:
Admin Street3:
Admin City:Annapolis
Admin State/Province:MD
Admin Postal Code:21401
Admin Country:US
Admin Phone:[phone]
Admin Phone Ext.:
Admin FAX:
Admin FAX Ext.:
Admin Email:[e-mail]
Tech ID:0156837D12C3576E
Tech Name:Ahmad Miski
Tech Street1:972 Mt. Holly Dr.
Tech Street2:
Tech Street3:
Tech City:Annapolis
Tech State/Province:MD
Tech Postal Code:21401
Tech Country:US
Tech Phone:[phone]

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Web Site
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Title:
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Meta
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Description: Embassy In Washington Dc Usa
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Keywords:
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Embassy,Libya Export,Libya Washington Embassy,Libya Adoption
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e-mail, telephone, or facsimile; or (2) enable high volume, automated, electronic
processes that apply to Network Solutions (or its computer systems). The compilation,
repackaging, dissemination or other use of this Data is expressly prohibited without the
prior written consent of Network Solutions. You agree not to use high-volume, automated,
electronic processes to access or query the WHOIS database. Network Solutions
reserves all rights and remedies it now has or may have in the future, including, but not
limited to, the right to terminate your access to the WHOIS database in its sole
discretion, for any violations by you of these terms of use, including without limitation, for
excessive querying of the WHOIS database or for failure to otherwise abide by these
terms of use. Network Solutions reserves the right to modify these terms at any time.

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11/28/06 1:47 PM

WHOIS Search provides domain registration information from Network Solutions

http://www.networksolutions.com/whois/results.jsp?whoistoken=0

© Copyright 2006 Network Solutions. All rights reserved.

3 of 3

11/28/06 1:47 PM

WHOIS Search provides domain registration information from Network Solutions

http://www.networksolutions.com/whois/results.jsp?whoistoken=3

Welcome J.P. Szymkowicz!

Your cart is empty

WHOIS Search Results
Who's Hosting Your Web Site?
Get a FREE domain renewal with an annual hosting package.

WHOIS Record For

Need More Info?

Contact us today!

libyaembassy.com

CALL 1-800-361-5712

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=-=-=-=
Visit AboutUs.org for more information about LIBYAEMBASSY.COM
AboutUs: LIBYAEMBASSY.COM
Contact: [e-mail]
Domain name: LIBYAEMBASSY.COM
Administrative Contact:
Ahmad Miski ([e-mail])
+1.4107575544
Fax: [phone]
972 Mt. Holly Dr.
Annapolis, MD 21401
US
Technical Contact:
Ahmad Miski ([e-mail])
+1.4107575544
Fax: [phone]
972 Mt. Holly Dr.
Annapolis, MD 21401
US
Registrant Contact:
Ahmad Miski ([e-mail])
+1.4107575544
Fax: [phone]
972 Mt. Holly Dr.
Annapolis, MD 21401
US
Status: Locked
Name Servers:
ns1.4fs.com
ns2.4fs.com
Creation date: 13 Dec 2002 14:36:17
Expiration date: 13 Dec 2007 14:36:17
=-=-=-=
The data in this whois database is provided to you for information
purposes only, that is, to assist you in obtaining information about or
related to a domain name registration record. We make this information
available "as is," and do not guarantee its accuracy. By submitting a
whois query, you agree that you will use this data only for lawful
purposes and that, under no circumstances will you use this data to: (1)
enable high volume, automated, electronic processes that stress or load
this whois database system providing you this information; or (2) allow,
enable, or otherwise support the transmission of mass unsolicited,
commercial advertising or solicitations via direct mail, electronic
mail, or by telephone. The compilation, repackaging, dissemination or
other use of this data is expressly prohibited without prior written
consent from us.

BUY THE AVAILABLE EXTENSIONS
FOR THIS DOMAIN NAME

libyaembass...

.info

libyaembass...

.biz

libyaembass...

.tv

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.cc

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.ws

libyaembass...

.bz

libyaembass...

.vg

libyaembass...

.gs

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.ms

We reserve the right to modify these terms at any time. By submitting
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Version 6.3 4/3/2002

1 of 2

11/28/06 1:48 PM

WHOIS Search provides domain registration information from Network Solutions

The previous information has been obtained either directly from the registrant or a
registrar of the domain name other than Network Solutions. Network Solutions,
therefore, does not guarantee its accuracy or completeness.

http://www.networksolutions.com/whois/results.jsp?whoistoken=3

SEARCH AGAIN

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Data as of:

ENOM, INC.
64.38.10.78 (ARIN & RIPE IP search)
US(UNITED STATES)
Domain Name
Apache 1
REGISTRAR-LOCK
Active
no listings
see listings
Libya Embassy Legalization, Libya Embassy Certification,
Libya Legalization,Libya certification, Libya appostile,Libya
appostil,Libya appostille,Libya apostil,Libya apostill,Libya
apostille
Embassy Legalization And Certification Of Legal Documents
From Libya Embassy In Washington Dc Usa
Libya Embassy Legalization, Libya Embassy Certification,
Libya Legalization,Libya certification, Libya appostile,Libya
appostil,Libyaappostille,Libya apostil,Libya apostill,Libya
apostille,Libya Embassy,Libya Export,Libya Washington
Embassy,Libya Adoption
No
No
Not available
12-Jun-2006

Search by:
Domain Name
NIC Handle
IP Address

for your domain name registration be included in a public database known as WHOIS. To
learn about actions you can take to protect your WHOIS information visit
www.internetprivacyadvocate.org.
NOTICE AND TERMS OF USE: You are not authorized to access or query our WHOIS
database through the use of high-volume, automated, electronic processes or for the
purpose or purposes of using the data in any manner that violates these terms of use.
The Data in Network Solutions' WHOIS database is provided by Network Solutions for
information purposes only, and to assist persons in obtaining information about or related
to a domain name registration record. Network Solutions does not guarantee its
accuracy. By submitting a WHOIS query, you agree to abide by the following terms of
use: You agree that you may use this Data only for lawful purposes and that under no
circumstances will you use this Data to: (1) allow, enable, or otherwise support the
transmission of mass unsolicited, commercial advertising or solicitations via direct mail,
e-mail, telephone, or facsimile; or (2) enable high volume, automated, electronic
processes that apply to Network Solutions (or its computer systems). The compilation,
repackaging, dissemination or other use of this Data is expressly prohibited without the
prior written consent of Network Solutions. You agree not to use high-volume, automated,
electronic processes to access or query the WHOIS database. Network Solutions
reserves all rights and remedies it now has or may have in the future, including, but not
limited to, the right to terminate your access to the WHOIS database in its sole
discretion, for any violations by you of these terms of use, including without limitation, for
excessive querying of the WHOIS database or for failure to otherwise abide by these
terms of use. Network Solutions reserves the right to modify these terms at any time.

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2 of 2

11/28/06 1:48 PM

WHOIS Search provides domain registration information from Network Solutions

http://www.networksolutions.com/whois/results.jsp?whoistoken=5

Welcome J.P. Szymkowicz!

Your cart is empty

WHOIS Search Results

WHOIS Record For

Need More Info?

Contact us today!

libyaembassy.org

CALL 1-800-361-5712

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NOTICE: Access to .ORG WHOIS information is provided to assist persons in
determining the contents of a domain name registration record in the Public Interest
Registry
registry database. The data in this record is provided by Public Interest Registry
for informational purposes only, and Public Interest Registry does not guarantee its
accuracy. This service is intended only for query-based access. You agree
that you will use this data only for lawful purposes and that, under no
circumstances will you use this data to: (a) allow, enable, or otherwise
support the transmission by e-mail, telephone, or facsimile of mass
unsolicited, commercial advertising or solicitations to entities other than
the data recipient's own existing customers; or (b) enable high volume,
automated, electronic processes that send queries or data to the systems of
Registry Operator or any ICANN-Accredited Registrar, except as reasonably
necessary to register domain names or modify existing registrations. All
rights reserved. Public Interest Registry reserves the right to modify these terms at any
time. By submitting this query, you agree to abide by this policy.
Domain ID:D94762049-LROR
Domain Name:LIBYAEMBASSY.ORG
Created On:12-Mar-2003 12:33:46 UTC
Last Updated On:05-Mar-2006 11:53:14 UTC
Expiration Date:12-Mar-2007 12:33:46 UTC
Sponsoring Registrar:eNom, Inc. (R39-LROR)
Status:OK
Registrant ID:0156837D12C3576E
Registrant Name:Ahmad Miski
Registrant Street1:972 Mt. Holly Dr.
Registrant Street2:
Registrant Street3:
Registrant City:Annapolis
Registrant State/Province:MD
Registrant Postal Code:21401
Registrant Country:US
Registrant Phone:[phone]
Registrant Phone Ext.:
Registrant FAX:
Registrant FAX Ext.:
Registrant Email:[e-mail]
Admin ID:0156837D12C3576E
Admin Name:Ahmad Miski
Admin Street1:972 Mt. Holly Dr.
Admin Street2:
Admin Street3:
Admin City:Annapolis
Admin State/Province:MD
Admin Postal Code:21401
Admin Country:US
Admin Phone:[phone]
Admin Phone Ext.:
Admin FAX:
Admin FAX Ext.:
Admin Email:[e-mail]
Tech ID:0156837D12C3576E
Tech Name:Ahmad Miski
Tech Street1:972 Mt. Holly Dr.
Tech Street2:
Tech Street3:
Tech City:Annapolis
Tech State/Province:MD
Tech Postal Code:21401
Tech Country:US
Tech Phone:[phone]

1 of 3

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.biz

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.bz

libyaembass...

.vg

libyaembass...

.gs

libyaembass...

.tc

libyaembass...

.ms

11/28/06 1:48 PM

WHOIS Search provides domain registration information from Network Solutions

Tech Phone Ext.:
Tech FAX:
Tech FAX Ext.:
Tech Email:[e-mail]
Name Server:NS1.4FS.COM
Name Server:NS2.4FS.COM
Name Server:
Name Server:
Name Server:
Name Server:
Name Server:
Name Server:
Name Server:
Name Server:
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SEARCH AGAIN

Enter a search term:
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Search by:
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IP Address

The previous information has been obtained either directly from the registrant or a
registrar of the domain name other than Network Solutions. Network Solutions, therefore,
does not guarantee its accuracy or completeness.
Show underlying registry data for this record

IP Address:
64.38.10.78 (ARIN & RIPE IP search)
IP Location:
US(UNITED STATES)
Record Type:
Domain Name
Server Type:
Apache 1
Web Site Status: Active
DMOZ
no listings
Y! Directory:
see listings
Secure:
No
E-commerce:
No
Traffic Ranking: Not available
Data as of:
14-Jun-2005
for your domain name registration be included in a public database known as WHOIS. To
learn about actions you can take to protect your WHOIS information visit
www.internetprivacyadvocate.org.
NOTICE AND TERMS OF USE: You are not authorized to access or query our WHOIS
database through the use of high-volume, automated, electronic processes or for the
purpose or purposes of using the data in any manner that violates these terms of use.
The Data in Network Solutions' WHOIS database is provided by Network Solutions for
information purposes only, and to assist persons in obtaining information about or related
to a domain name registration record. Network Solutions does not guarantee its
accuracy. By submitting a WHOIS query, you agree to abide by the following terms of
use: You agree that you may use this Data only for lawful purposes and that under no
circumstances will you use this Data to: (1) allow, enable, or otherwise support the
transmission of mass unsolicited, commercial advertising or solicitations via direct mail,
e-mail, telephone, or facsimile; or (2) enable high volume, automated, electronic
processes that apply to Network Solutions (or its computer systems). The compilation,
repackaging, dissemination or other use of this Data is expressly prohibited without the
prior written consent of Network Solutions. You agree not to use high-volume, automated,
electronic processes to access or query the WHOIS database. Network Solutions
reserves all rights and remedies it now has or may have in the future, including, but not
limited to, the right to terminate your access to the WHOIS database in its sole
discretion, for any violations by you of these terms of use, including without limitation, for
excessive querying of the WHOIS database or for failure to otherwise abide by these
terms of use. Network Solutions reserves the right to modify these terms at any time.

PerformanceClicks™ from
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$299.00 design fee

Domain Names | Web Hosting | Web Design | SSL Certificates | Sell Online | Email Security | Pay Per Click | Online Marketing
Design a Website | Search Engine Optimization | Custom Logo Design | Press Release Services | Email Account | Web Analytics

© Copyright 2006 Network Solutions. All rights reserved.

2 of 3

11/28/06 1:48 PM

WHOIS Search provides domain registration information from Network Solutions

3 of 3

http://www.networksolutions.com/whois/results.jsp?whoistoken=5

11/28/06 1:48 PM

WHOIS Search provides domain registration information from Network Solutions

http://www.networksolutions.com/whois/results.jsp?whoistoken=7

Welcome J.P. Szymkowicz!

Your cart is empty

WHOIS Search Results
Who's Hosting Your Web Site?
Get a FREE domain renewal with an annual hosting package.

WHOIS Record For

Need More Info?

Contact us today!

libyanembassy.com

CALL 1-800-361-5712

Services from Network Solutions:

CONTACT a sales
consultant

Certified Offer Service - Let us help you get this domain name!
SSL Certificates - Get peace of mind with a secure certificate.
Site Confirm Seals - Display a security seal and gain visitor trust.

=-=-=-=
Visit AboutUs.org for more information about LIBYANEMBASSY.COM
AboutUs: LIBYANEMBASSY.COM
Contact: [e-mail]
Domain name: LIBYANEMBASSY.COM
Administrative Contact:
Ahmad Miski ([e-mail])
+1.4107575544
Fax: [phone]
972 Mt. Holly Dr.
Annapolis, MD 21401
US
Technical Contact:
Ahmad Miski ([e-mail])
+1.4107575544
Fax: [phone]
972 Mt. Holly Dr.
Annapolis, MD 21401
US
Registrant Contact:
Ahmad Miski ([e-mail])
+1.4107575544
Fax: [phone]
972 Mt. Holly Dr.
Annapolis, MD 21401
US
Status: Locked
Name Servers:
ns1.4fs.com
ns2.4fs.com
Creation date: 10 Feb 2003 13:22:11
Expiration date: 10 Feb 2007 13:22:11
=-=-=-=
The data in this whois database is provided to you for information
purposes only, that is, to assist you in obtaining information about or
related to a domain name registration record. We make this information
available "as is," and do not guarantee its accuracy. By submitting a
whois query, you agree that you will use this data only for lawful
purposes and that, under no circumstances will you use this data to: (1)
enable high volume, automated, electronic processes that stress or load
this whois database system providing you this information; or (2) allow,
enable, or otherwise support the transmission of mass unsolicited,
commercial advertising or solicitations via direct mail, electronic
mail, or by telephone. The compilation, repackaging, dissemination or
other use of this data is expressly prohibited without prior written
consent from us.
We reserve the right to modify these terms at any time. By submitting
this query, you agree to abide by these terms.
Version 6.3 4/3/2002

1 of 2

BUY THE AVAILABLE EXTENSIONS
FOR THIS DOMAIN NAME

libyanembas...

.net

libyanembas...

.info

libyanembas...

.biz

libyanembas...

.tv

libyanembas...

.us

libyanembas...

.cc

libyanembas...

.ws

libyanembas...

.bz

libyanembas...

.vg

libyanembas...

.gs

libyanembas...

.tc

libyanembas...

.ms

11/28/06 1:49 PM

WHOIS Search provides domain registration information from Network Solutions

The previous information has been obtained either directly from the registrant or a
registrar of the domain name other than Network Solutions. Network Solutions,
therefore, does not guarantee its accuracy or completeness.

http://www.networksolutions.com/whois/results.jsp?whoistoken=7

SEARCH AGAIN

Enter a search term:

Show underlying registry data for this record
e.g. networksolutions.com
Current Registrar:
IP Address:
IP Location:
Record Type:
Server Type:
Lock Status:
Web Site Status:
DMOZ
Y! Directory:
Web Site Title:

Meta Description:

Meta Keywords:
Secure:
E-commerce:
Traffic Ranking:
Data as of:

ENOM, INC.
64.38.10.78 (ARIN & RIPE IP search)
US(UNITED STATES)
Domain Name
Apache 1
REGISTRAR-LOCK
Active
no listings
see listings
Libya Embassy Legalization, Libya Embassy Certification,
Libya Legalization,Libya certification, Libya appostile,Libya
appostil,Libya appostille,Libya apostil,Libya apostill,Libya
apostille
Embassy Legalization And Certification Of Legal Documents
From Libya Embassy In Washington Dc Usa
Libya Embassy Legalization, Libya Embassy Certification,
Libya Legalization,Libya certification, Libya appostile,Libya
appostil,Libyaappostille,Libya apostil,Libya apostill,Libya
apostille,Libya Embassy,Libya Export,Libya Washington
Embassy,Libya Adoption
No
No
Not available
12-Jun-2006

Search by:
Domain Name
NIC Handle
IP Address

for your domain name registration be included in a public database known as WHOIS. To
learn about actions you can take to protect your WHOIS information visit
www.internetprivacyadvocate.org.
NOTICE AND TERMS OF USE: You are not authorized to access or query our WHOIS
database through the use of high-volume, automated, electronic processes or for the
purpose or purposes of using the data in any manner that violates these terms of use.
The Data in Network Solutions' WHOIS database is provided by Network Solutions for
information purposes only, and to assist persons in obtaining information about or related
to a domain name registration record. Network Solutions does not guarantee its
accuracy. By submitting a WHOIS query, you agree to abide by the following terms of
use: You agree that you may use this Data only for lawful purposes and that under no
circumstances will you use this Data to: (1) allow, enable, or otherwise support the
transmission of mass unsolicited, commercial advertising or solicitations via direct mail,
e-mail, telephone, or facsimile; or (2) enable high volume, automated, electronic
processes that apply to Network Solutions (or its computer systems). The compilation,
repackaging, dissemination or other use of this Data is expressly prohibited without the
prior written consent of Network Solutions. You agree not to use high-volume, automated,
electronic processes to access or query the WHOIS database. Network Solutions
reserves all rights and remedies it now has or may have in the future, including, but not
limited to, the right to terminate your access to the WHOIS database in its sole
discretion, for any violations by you of these terms of use, including without limitation, for
excessive querying of the WHOIS database or for failure to otherwise abide by these
terms of use. Network Solutions reserves the right to modify these terms at any time.

PerformanceClicks™ from
Network Solutions
Create and manage your
online advertising from as
low as $125/month plus $99
one time set-up fee

Need to get your business
online?
Our professional designers
can build a custom Web site
for your business.
$49.95/month, plus a
$299.00 design fee

Domain Names | Web Hosting | Web Design | SSL Certificates | Sell Online | Email Security | Pay Per Click | Online Marketing
Design a Website | Search Engine Optimization | Custom Logo Design | Press Release Services | Email Account | Web Analytics

© Copyright 2006 Network Solutions. All rights reserved.

2 of 2

11/28/06 1:49 PM

Exhibit 2

Libya Embassy Legalization, Libya Embassy Certification, Libya Legalization,Libya certification,...

http://www.libyaembassy.com/

Legalization and Certification of Documents from
Libya Embassy in Washington DC
Required
Documents:

All documents have to be certified from the the secretary of state where they were notarized. Federal
documents are ready to send to us.
1.

We will authenticate the document from the Department of State.

2.

We will certify the document from the Chamber of Commerce.

3.

Procedure:

We will legalize the document from the Libyan embassy in Washington DC.

Approximate turn
around time:

Three to five business days.
Send company check or money order for the total of the following fees payable to the order of "Arab American
Chamber of Commerce".
1.

Our service fee . {$95.00}

2.

Department of State fee . {$7.00}
Chamber of Commerce certification fee. {$25.00}

Charges and
Payment methods:

3.

4.

Libya Liaison Office fee. {$40.00} (For most types of documents)
Article of Incorporation fee is $300
Agency Agreement fee is $300
Power of Attorney fee is $100
In case that you have an Invoice or a certificate of Origin please click here.

Charges for
additional
documents:

Each additional document cost $45.00 for the service fee plus the charges noted in # 2-4 above.

If you are using FedEx, -DHL-, -UPS
Mailing:

Please send your documents to:
Arab American Chamber of Commerce
972 Mt. Holly Dr. Annapolis MD 21409
We do not accept USPS Priority Mail.
We accept regular mail, but we do not recommend or guarantee.
AACC is not responsible for damaged, delayed or lost mail.

If you need further assistance, e-mail your request to: [e-mail] .We will respond within
24 hours. Or, you can contact us at: 1-888-939-ARAB or [phone] for instant assistance.
*Disclaimer: This website was created by Arab American Chamber of Commerce to facilitate certifications of documents intended for use in Libya. The country of
Libya does not have an embassy in the United States. Arab American Chamber of Commerce is not affiliated with the Libyan Liaison office in Washington DC,
or the Libyan mission office in New York.

1 of 1

11/28/06 1:42 PM