Rosetta Stone LTD v. Google Inc.

Filing 114

Declaration of Cory Louie re 112 MOTION for Summary Judgment (portions filed under seal) by Google Inc.. (Frieden, Jonathan) Modified text on 3/30/2010 re Received under seal copy in black binder on 3/29/10 ( UNDER SEAL) (klau, ).

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
(Alexandria Division)
ROSETTA STONE LTD.
Plaintin�
CIVIL ACTION NO.1 :0gev736

v.

(GBL 1

TCl3)

GOOGLE INC.
Defendant.

DECLARATION OF CORY Loum
I, Cory Louie, hereby declare:
I am over the age of 18 and serve as Trust & Safety Manager at Google Inc.

I.

("Google"). I have held this position Illr approximately 3 112 years. In my capacity as Trust &
Safety Manager, I am responsible Illr the protection of Googlc revenue, users and brand.
I maintain and advance the trust, safety and security of Goog1c's global products and services by
managing significant risk, abuse and fraud issues through invcstigations, cducation,
enforcement and collaboration. I am Iilmiliar with Goog!c's overall elTorts to manage risk, abuse
fi·aud, security and enIl1rcement issues. I am also familiar with various advertising scrvices
offered by Google, including the Google AdWords program ("AdWords )
"

.

Except where

otherwise indicated, the following is based on personal knowledge, and if called as a witness, I
could and would compctently testify thereto.
2.

One of my responsibilities as Trust and Safety Manager is to address the source of

risk, abuse, fraud issues on a wide rangc of Google products and services, including the
distribution of counterfeit goods and dcveloping strategy to identify individuals or groups
conducting the activity using Google AdWords and disrupt their c1Torts.

01980.61656/3,103551.1

3.
.
4.

5.

O]n{).616S(l/3403551 1

6.

I declare under penalty of perjury that the foregoing is true and correct. Executed on
March 26, 2010.

Cory Louie

01980.6165613403551 . 1