AMERICAN SOCIETY FOR TESTING AND MATERIALS et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 98

REPLY to Opposition re #86 MOTION for Protective Order filed by AMERICAN SOCIETY FOR TESTING AND MATERIALS. (Attachments: #1 Declaration of Jordana S. Rubel, #2 Exhibit 1, #3 Exhibit 2 [UNDER SEAL], #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6 [UNDER SEAL])(Fee, J.) Modified event title on 4/3/2015 (znmw, ).

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN SOCIETY FOR TESTING
AND MATERIALS d/b/a/ ASTM
INTERNATIONAL;
NATIONAL FIRE PROTECTION
ASSOCIATION, INC.; and
AMERICAN SOCIETY OF HEATING,
REFRIGERATING, AND AIR
CONDITIONING ENGINEERS,

Case No. 1:13-cv-01215-TSC-DAR

Plaintiffs/
Counter-Defendants,
v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant/
Counter-Plaintiff.
DECLARATION OF JORDANA S. RUBEL
I, Jordana S. Rubel, declare pursuant to 28 U.S.C. § 1746 as follows:
1.

I am an attorney admitted to practice in the District of Columbia and I am an

associate with the law firm of Morgan Lewis & Bockius LLP, counsel of record for Plaintiff
American Society for Testing and Materials (“ASTM”).
2.

Attached as Exhibit 1 is a true and correct copy of a document produced by

Defendant Public.Resource.Org, Inc. that is Bates stamped PRO_00166616-00166618.
3.

Attached as Exhibit 2 is a true and correct copy of a document produced by

ASTM in this litigation that is Bates stamped ASTM003490-003500. This document
demonstrates the process through which ASTM members register a work item through ASTM’s
online system.

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4.

Attached as Exhibit 3 is a true and correct copy of one of ASTM’s standards,

D1835-97, the Standard Specification for Liquefied Petroleum (LP) Gases, that was produced by
ASTM in this litigation that is Bates stamped ASTM000726-000729. The standard is published
with ASTM’s trademarks on it and with a copyright notice identifying ASTM as the copyright
owner.
5.

Attached as Exhibit 4 is a true and correct copy of the online form that individuals

complete when they become members of ASTM. This document was produced by ASTM in this
litigation and is Bates stamped ASTM001801-001813.
6.

Attached as Exhibit 5 is a true and correct copy of the online form that individuals

complete when they renew their membership to ASTM. This document was produced by ASTM
in this litigation and is Bates stamped ASTM001792-001800.
7.

Attached as Exhibit 6 is a true and correct copy of an example of the paper form

that individuals complete when they renew their membership to ASTM. This document was
produced by ASTM in this litigation and is Bates stamped ASTM036510-036511.
I declare under penalty of perjury that the foregoing is true and correct.

Executed this 2nd day of April, 2015.

/s/ Jordana S. Rubel
Jordana S. Rubel

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