Vulcan Golf, LLC v. Google Inc. et al

Filing 290

DECLARATION of Michael Page regarding Rule 56 statement 289 Redacted Public Version (Attachments: # 1 Exhibit A-F)(Cyrluk, Jonathan)

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Vulcan Golf, LLC v. Google Inc. et al Doc. 290 Case 1:07-cv-03371 Document 290 Filed 01/07/10 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION VULCAN GOLF, LLC, JOHN B. SANFILIPPPO & SONS, INC., BLITZ REALTY GROUP, INC., and VINCENT E. "BO" JACKSON, Plaintiffs, v. GOOGLE INC., Defendant. ) Case No. 07 CV 3371 ) ) ) ) The Honorable Blanche M. Manning ) ) ) ) ) ) ) ) ) ) ) ) ) DECLARATION OF MICHAEL H. PAGE IN SUPPORT OF GOOGLE'S MOTION FOR PARTIAL SUMMARY JUDGMENT REDACTED PUBLIC VERSION Case 1:07-cv-03371 Document 290 Filed 01/07/10 Page 2 of 3 I, Michael H. Page, declare as follows: 1. I am an attorney admitted to practice before this Court, a partner in the firm of Durie Tangri Page Lemley Roberts & Kent LLP ("Durie Tangri"), and counsel of record for defendant Google Inc. in the above-captioned matter. Unless otherwise indicated, the statements herein are of my own knowledge, and I can testify competently thereto. 2. Attached hereto as Exhibit A is a true and correct copy of a web page made available by the Illinois Secretary of State setting forth the corporate status of plaintiff Blitz Realty Group, Inc. available via a search at for "BLITZ REALTY GROUP, INC." 7. Attached hereto as Exhibit F is a list of all domain names registered to Google Inc. as of July 13, 2009. 8. During the present litigation, I have repeatedly invited Plaintiffs to avail themselves of Google's trademark policy, both orally and through correspondence. Plaintiffs have never availed themselves of Google's trademark policy. 9. During this litigation, each time Plaintiffs have identified any domain name they contend they have rights to, Google has promptly added it to the fail list. 1 Case 1:07-cv-03371 Document 290 Filed 01/07/10 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed this 22nd day of July at San Francisco, California. ______________________ Michael H. Page 2

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