Yellowone Investments v. Verizon Communications, Inc et al

Filing 11

RESPONSE in Opposition re 8 MOTION to Dismiss VERIZON COMMUNICATION INC. filed by Yellowone Investments. (Attachments: # 1 Affidavit Friedland Declaration# 2 Exhibit 1# 3 Exhibit 2# 4 Exhibit 3# 5 Exhibit 4# 6 Exhibit 5# 7 Exhibit 6a# 8 Exhibit 6b)(Friedland, Michael)

Case 2:06-cv-00475-TJW

Document 11

Filed 02/26/2007

Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

YELLOWONE INVESTMENTS, an English Wales corporation Plaintiff

Case No. 2-06-CV-475 TJW Hon. T. John Ward

VERIZON COMMICATIONS, INC. , a
Delaware corporation, IDEARC INORMATION SERVICES, INC. a Delaware corporation
Defendants.

DECLARA TION OF MICHAEL K. FRIEDLAND IN SUPPORT OF
YELLOW ONE

INVESTMENTS OPPOSITION TO VERION MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION
Michael K. Friedland, declare as follows:
I am a partner with the law firm of Knobbe, Martens, Olson & Bear, LLP, counsel

of record for Plaintiff Yellowone Investments ("Yellowone ) in the above-captioned case. I have

personal knowledge of the matters set forth herein, and if I am called upon to testify, I could and
would testify competently thereto.

Attached hereto as Exhibit 1 is a true and correct copy of the results of a search on
the whois. net web site for registration data for the superpages. com web site. This search was run
on February 9, 2007 ,

the date on which we received

the motion to

dismiss by Verizon

Communications Inc. ("VCI") and the affdavit of Ms. Schapker.

Attached hereto as Exhibit 2 is a true and correct copy of the results of a search on
the whois. net web site for registration data for the verizonwireless. com web site. This search was
run on January 25

2007.

Attached hereto as Exhibit 3 is a true and correct copy of a press release obtained

Dockets.Justia.co

Case 2:06-cv-00475-TJW

Document 11

Filed 02/26/2007

Page 2 of 2

from the website

ww.verizon. com on

February 9

2007.

Attached hereto as Exhibit 4 is a true and correct copy of an informational page on

WHOIS services obtained from the web site of ICAN, the Internet Corporation for Assigned
Names and Numbers.
Attached hereto as Exhibit 5 is a true and correct copy of a

web page from

ww. verizon. com regarding Verizon Communications.
Attached hereto as Exhibit 6 is a true and correct copy of a document identified

Verizon Communications Inc. March 14,
Commission , which was downloaded from the

2006 10-K

fiing with

the

Securities and Exchange

ww.verizon. com web site.

I declare under penalty of perjury that the foregoing is true and correct.
Executed this 26th day of February, 2007, at Irvine, California.

Isl Michael K. Friedland Michael K. Friedland

CERTIFICA TE OF SERVICE

The undersigned hereby certifies that all counsel of record who are deemed to have DECLARATION OF consented to electronic service are being served with a MICHAEL K. INVESTMENTS OPPOSITION TO VERION MOTION TO DISMISS FOR LACK OF PERSONAL
copy of this YELLOW ONE FRIEDLAND IN SUPPORT OF JURISDICTION

via the

Court' s

CM/CF

system per Local Rule CV- 5(a)(3) on

February 26 2007.
Isl Michael K. Friedland Michael K. Friedland
3418457 021207