Google v. Pacific Webworks

Filing 15

DECLARATION of Joseph Bajin re 12 Memorandum in Support of Motion of Ex Parte Application for Leave to Take Immediate Discovery filed by Google. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O)(Haley, George)

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Google v. Pacific Webworks Doc. 15 Case No. 2:09-cv-1068 Judge Bruce S. Jenkins CERTIFICATE OF SERVICE I hereby certify that on the 9th day of December, 2009, I caused a true and correct copy of the DECLARATION OF JOSEPH BAJIN to be served via : Christian Larsen President/Registered Agent Pacific Webworks, Inc. 230 West 400 South Salt Lake City, UT 84101 _____ U.S. Mail, postage prepaid X Hand Delivery _____ Facsimile _____ Overnight courier _____ E-Mail and/or CM/ECF By: /s/ Sherice L. Atterton TABLE OF EXHIBITS Exhibits Exhibit A Exhibit B Exhibit C Exhibit D Description List of the 2,650 unique URLs that IDiogenes has received (August, 2009 end of November, 2009) List of WHOIS information for domain names as being owned by PWW. List of URLs located within PWW's own domain names. List of Examples of the first page of certain sites which contain the same information, which suggests that templates might have been used to create them. Copies of relevant portions of the first page of such sites, which contains sites that used a similar storyline and the same photo involving a different young man depending on the site. Copies of relevant portions of the first pages of such sites, which contain a similar story line of a mother-of-two who was promoted under three different names using the same photo of a young woman holding a small girl. Copies of screenshots of the relevant portion of a small sample of Affiliate Sites that were observed displaying the same image of a $5,000 check from Google. List of examples of the "google" domain names that have hosted one or more of the reported URLs. Copies of screenshots of the relevant portions of a small sample of Affiliate Sites that promoted programs and/or kits using the name "Google". Copies of examples of relevant portions of Affiliate Sites with comments at the bottom of the site from apparent readers that include a statement claiming that new comments are no longer able to be submitted for various reasons. Copies of the relevant portions of the first pates of examples of such sites that use legitimate-sounding news websites as domain names. Copies of print outs of the first pages of independent Credit Card Processing Sites (,,, and Copies of print outs of relevant portions of the website and PWW's Credit Card Processing Site. Exhibit E Exhibit F Exhibit G Exhibit H Exhibit I Exhibit J Exhibit K Exhibit L Exhibit M #263307 v1 slc Exhibit N Copies of relevant portions of PWW's Credit Card Processing site and ensuing websites related thereto that are presented to a viewer in the course of making a purchase. Copies of printouts of the relevant portions of a sampling of other reported URLs that offered Google money-making schemes and for which IDiogenes collected information. Exhibit O 2 #263307 v1 slc

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