Unites States v. Pokerstars, et al

Filing 221

MEMORANDUM OF LAW in Support re: 220 MOTION to Stay In Rem Claims As To Domain Defendants.. Document filed by Commonwealth of Kentucky, ex. rel. J. Michael Brown, Secretary, Justice and Public Safety Cabinet. (Attachments: # 1 Exhibit Second Amended Complaint, # 2 Exhibit Order Of Seizure Of Domain Names, # 3 Exhibit Findings Of Fact & Conclusions Of Law, # 4 Exhibit Service Letter to GoDaddy, # 5 Exhibit Service Letter to Network Solutions, # 6 Exhibit Service Letter to Nom-IQ, # 7 Exhibit Service Letter to Register.com, # 8 Exhibit Notice of Filing Registrar Certificate, # 9 Exhibit Opinion & Order, # 10 Exhibit iMEGA I Opinion, # 11 Exhibit iMEGA II Opinion, # 12 Exhibit Order Of Forfeiture Of Domain Defendants)(Lycan, David)

HURT, CROSBIE & MAY PLLC
William C. Hurt, Jr.
Scott A. Crosbie
William H. May, III
Michael D. Kalinyak
Steven Lenarz
Matthew R. Malone
Aaron D. Reedy

THE EQUUS BUILDING
127 WEST MAIN STREET
LEXINGTON, KENTUCKY 40507

D. Eric Lycan *
Jennifer S. Scutchfield *
* Of Counsel

Telephone - [phone]
Facsimile - [phone]

September 19, 2008
Via email: [e-mail]
Nom-iq Ltd. dba COM LAUDE
116 Long Acre London WC2E 9SU
United Kingdom
Attention: Nom-iq Ltd. dba COM LAUDE
The Franklin Circuit Court of the Commonwealth of Kentucky has ordered that certain domains
be transferred to the Commonwealth of Kentucky pursuant to the case captioned Commonwealth
of Kentucky ex rel. J Michael Brown, Secretary, Justice and Public Safety Cabinet v. 141
Internet Domain Names. Of the domains at issue, one (1) is registered through Nom-iq Ltd. dba
COM LAUDE:
pokerstars.com
The Court requires that Nom-iq Ltd. dba COM LAUDE take the following steps immediately:
The domain names shall be immediately transferred by their respective Registrars
to an account of the Plaintiff, Commonwealth of Kentucky, at each Registrar or, if
Plaintiff so specified, to such other Registrar as Plaintiff may designate. The
domain names' configurations shall otherwise remain unchanged. The domain
names shall not subsequently be transferred, moved, cancelled or otherwise
affected except by instruction of the Plaintiff or this Court pursuant to KRS
528.100 and/or KRS 500.090.
Attached please find a copy of the court's order.

You can reach us by email to: [e-mail] or by contacting the following
attorneys:
William H. May, III
William C. Hurt, Jr.
Aaron D. Reedy
Hurt, Crosbie & May, PLLC
127 West Main Street
Lexington, Kentucky 40507
859-254-0000
Please confirm when the transfer is complete.
Thank you.
ATTORNEYS FOR COMMONWEALTH
OF KENTUCKY
BY:

BY:

DEL/pab

/S/ D. ERIC LYCAN
D. Eric Lycan
Hurt, Crosbie & May, PLLC
127 West Main Street
Lexington, Kentucky 40507

/S/ ROBERT M. FOOTE
Robert M. Foote
Mark A. Bulgarelli
Foote, Meyers, Meilke & Flowers, LLC
28 North First Street, Suite 2
Geneva, Illinois 60134
[phone]