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EXHIBIT A
Case 2:10-cv-03738-ABC-CW Document 381-2 Filed 04/01/13 Page 2 of 61 Page ID #:13632 Janette Dockstader From: Sent: To: Cc: Subject: Attachments:
Enoch H. Liang Wednesday, September 14, 2011 11:07 AM McKown, Aaron M.; Zecchini, Paula L.
[email protected] Academy v. GoDaddy Proposal on Scheduling Proposed 90-day Extension Schedule.xls
Dear Aaron, I had a chance to speak with the team yesterday after the hearing. In order to narrow the issues that the parties have to bring to the Court’s attention, we would like to make the following proposal: 1. The Academy will agree to extend all deadlines in the case by 90 days. The revised case schedule proposed to Judge Collins is attached for your review/confirmation. Please check the dates that I propose. 2. The Academy will agree to provide fee bills from QEUS to the Academy from 2007 to present, unredacted except for clearly privileged or work product entries, i.e. those that show specifically the legal advice QEUS was providing or that show the areas of law QEUS was researching. In other words, we will endeavor to unredact those fee bills so that GoDaddy can make a determination of what domain names/websites QEUS was billing the Academy for with respect to that time entry. However, it must be clear that the Academy is not waiving its right to claim attorney‐client privilege or attorney work product in general. While GoDaddy can continue to assert its waiver arguments as set forth in its Sept. 9 Joint Stipulation, GoDaddy must agree not to argue that the Academy further waived any of its rights by providing these unredacted fee bills from 2007 to present. 3. In return, GoDaddy and the Academy will agree to take the depositions in Phoenix next week off calendar. Given the 90‐day extension of all deadlines, GoDaddy and the Academy will work together to reschedule those depositions at a later date, possibly in early November around the Christine Jones deposition. The reasoning behind the delay in these depositions is so that the Academy can review the ESI being produced within 14 days. That way, we will avoid the possibility (even if remote) that these 4 witnesses will need to be redeposed. A secondary reason is that the Academy wants to complete the Iowa depositions before proceeding with these 4 witnesses. 4. Finally, in return, we would like a short 5‐day extension of time to provide you our portion of the Joint Stipulation, i.e., until Wednesday September 21, 2011. Given the 90‐day extension, I think the time need is less pressing here. 5. However, the Academy will continue to oppose the following: a. GoDaddy’s attempt to seek pre‐filing communications between Quinn Emanuel and the Academy regarding investigation into the Academy’s claim; b. GoDaddy’s attempt to seek post‐filing communications between Quinn Emanuel and the Academy regarding Defendants and/or this lawsuit; and 1
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c. GoDaddy’s attempt to seek an additional 20 depositions to depose Registrants in the CP program.
6. As discussed yesterday, the Academy will (a) provide a revised privilege log in response to your Sept. 8, 2011 email; (b) native emails in response to your Sept. 8, 2011 email; and (c) dates for its witnesses once we receive a 30b6 notice from GoDaddy. 7. We look forward to receiving your response to the Academy’s September 9, 2011 meet and confer letter. Let me know re the foregoing proposal, Enoch
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EXHIBIT B
Case 2:10-cv-03738-ABC-CW Document 381-2 Filed 04/01/13 Page 5 of 61 Page ID #:13635 Janette Dockstader From: Sent: To: Cc: Subject:
Enoch H. Liang Thursday, September 15, 2011 3:54 PM McKown, Aaron M.; Zecchini, Paula L.
[email protected] RE: Academy v. GoDaddy Proposal on Scheduling
Sorry if I was not clear. The proposal is your FIRST understanding below. In other words, the Academy is agreeable to extending the fact discovery cut‐off by 90 days, provided that AMPAS can seek guidance from the Court to add additional DN’s discovered in the time period up to 60 days before the new fact discovery cut‐off, i.e., as the Court noted in the original scheduling order in October 2010. GoDaddy, of course, will have the right to oppose anything that AMPAS files with the Court on this issue. Enoch From: McKown, Aaron M. [mailto:
[email protected]] Sent: Thursday, September 15, 2011 3:40 PM To: 'Enoch H. Liang'; Zecchini, Paula L. Cc:
[email protected] Subject: RE: Academy v. GoDaddy Proposal on Scheduling
Enoch, I want to make sure that I understand your point regarding No.1 as it appears inconsistent with me and ultimately, I'm not sure I understand what you are proposing. First, you say that you are agreeable provided AMPAS can seek guidance from the Court to add additional domain names discovered in the next 90 days (assuming we do not extend the cutoff?). Then, you say that either party should have the right to seek guidance regarding handling of additional domain names (assuming we don't extend the cutoff?). I'm not certain I understand what we would be agreeing to that would ultimately be any different than agreeing to extend the deadline for new domain names. My proposal below was to provide certainty so that the parties can prepare for and finalize their discovery efforts. It is not at all uncommon for parties to agree to extend certain deadlines while not agreeing to extend others, especially where certain deadlines have already passed. I was stating below that in light of the fact that the deadline to add domain names has now passed, that should not be a date included in the 90-day extension. The 90day extension issue arose as part of Defendants' meet and confer efforts before filing a motion with the Court. If we were to file a motion to continue in order to conduct additional discovery relating to the contributory cybersquatting claim, we would not be asking the Court to continue the claims deadline. In fact, our position would be that the claims deadline has passed and should not be extended. AMPAS has had nearly 18 months to identify additional domain names, 2 extensions of the deadline, and has served 2 supplements since filing this lawsuit. That is more than ample time to identify the universe of domain names at issue in this case. The biggest problem, which necessitate this discussion in the first place, was that by allowing AMPAS to add a contributory cybersquatting claim, we now need to take third-party depositions, including several overseas once service is effectuated through the time consuming Hague process. By continually moving the claims deadline, we will not be able to finalize our efforts to conduct third party discovery, particularly if newly named registrants live abroad, thereby likely requiring us to seek another extension. Of course, if we seek a further extension and that extension includes another extension of the claims deadline, we could be repeating the same cycle all over again. In order to avoid this 1
Case 2:10-cv-03738-ABC-CW Document 381-2 Filed 04/01/13 Page 6 of 61 Page ID #:13636 scenario, it makes much more sense to exclude the new claims/domain names deadline from the 90-day extension as that date has passed and AMPAS has had ample time to identify. Regards, Aaron Aaron M. McKown Bryan Cave LLP 3161 Michelson Drive, Ste 1500 Irvine, CA 92612 Direct Line: 949.223.7134 Facsimile: 949.223.7100
[email protected]
From: Enoch H. Liang [mailto:
[email protected]] Sent: Thursday, September 15, 2011 3:02 PM To: McKown, Aaron M.; Zecchini, Paula L. Cc:
[email protected] Subject: RE: Academy v. GoDaddy Proposal on Scheduling
Dear Aaron, Our comments are below. From: McKown, Aaron M. [mailto:
[email protected]] Sent: Thursday, September 15, 2011 2:09 PM To: 'Enoch H. Liang'; Zecchini, Paula L. Cc:
[email protected] Subject: RE: Academy v. GoDaddy Proposal on Scheduling
Enoch, I had a chance to discuss the terms of your proposal below with my client. We are amenable to the proposal as follows: 1. The 90-day continuance is acceptable, including the dates you proposed, with one exception -- the deadline to add new domain names to this lawsuit. We received AMPAS' second supplement yesterday, which was the deadline to add. At this point, there is no date to continue as the deadline has passed. The parties have considerable discovery upcoming, including depositions, so having certainty regarding the universe of domain names is critical so that these witnesses can adequately prepare. AMPAS has had nearly a year and a half to identify and name additional domain names. It is now appropriate to cut off any additional names in light of yesterday's deadline. We are amenable to agreeing to #1, provided that neither side is agreeing that AMPAS canNOT seek Court guidance on its ability to identify additional infringing domain names (should any pop up in the Parking Programs in the next 90 days). The original scheduling order (attached) gave AMPAS until 60 days before the fact discovery cut‐off to identify additional infringing domain names. If the fact discovery cut‐off is extended 90 days, then AMPAS should have the right to identify additional infringing domain names. 2
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Our proposal is—notwithstanding the 90‐day continuance, either party can seek guidance from the Court on this issue and brief this issue if necessary. If that works, please send over a proposed Joint Stipulation.
2. We agree not to use or otherwise argue that the production of unredacted fee bills itself constitutes a waiver of any privilege understanding that we continue to maintain that AMPAS' claim of incurring attorneys' fees for investigating its claims in this action as a basis for standing under 17200 is what constitutes a waiver, which we will continue to pursue as set forth in the Joint Stipulation provided last week. Fine.
3. We are agreeable to taking the depositions next week off calendar and for rescheduling them for a mutually convenient time after the completion of the next and final round of Iowa depositions. However, given my upcoming calendar, I don't anticipate that we'll be able to travel to Iowa and Phoenix for a week or so each within the next 60 days. In light of the 90-day continuance, and in order to minimize expenses, perhaps we should consider continuing Ms. Jones' deposition for a later date to proceed in conjunction with the ones that were scheduled for next week. Fine. We can continue the Christine Jones deposition to a mutually agreeable date so we don’t have to travel to Phoenix multiple times.
4. We are agreeable to the 5-day continuance you requested provided you are willing to grant a similar request in the future. Of course. I understand that we have worked together on continuances for Joint Stips in the past and will continue to do so going forward.
5. I understand AMPAS' intent to maintain its challenge to those matters and agree that nothing in this proposal constitutes a waiver of AMPAS' position with respect thereto. Ok. 6. Thank you. Please provide a date for Ms. Clarke's deposition at your earliest convenience. November 7 or 8 work. Send us a depo notice with the date that you pick. 7. I am working on the response now. Your letter was longer than I anticipated so I will likely not have a response for you until Monday. Ok.
Please confirm our agreement at your earliest convenience so that I can cancel pre-arranged travel plans, notify our Phoenix office to cancel the conference rooms, and inform the witnesses that they will not need to attend depositions next week. Regards, Aaron Aaron M. McKown Bryan Cave LLP 3161 Michelson Drive, Ste 1500 Irvine, CA 92612 Direct Line: 949.223.7134 Facsimile: 949.223.7100
[email protected]
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Case 2:10-cv-03738-ABC-CW Document 381-2 Filed 04/01/13 Page 8 of 61 Page ID #:13638 From: Enoch H. Liang [mailto:
[email protected]] Sent: Wednesday, September 14, 2011 11:07 AM To: McKown, Aaron M.; Zecchini, Paula L. Cc:
[email protected] Subject: Academy v. GoDaddy Proposal on Scheduling
Dear Aaron, I had a chance to speak with the team yesterday after the hearing. In order to narrow the issues that the parties have to bring to the Court’s attention, we would like to make the following proposal: 1. The Academy will agree to extend all deadlines in the case by 90 days. The revised case schedule proposed to Judge Collins is attached for your review/confirmation. Please check the dates that I propose. 2. The Academy will agree to provide fee bills from QEUS to the Academy from 2007 to present, unredacted except for clearly privileged or work product entries, i.e. those that show specifically the legal advice QEUS was providing or that show the areas of law QEUS was researching. In other words, we will endeavor to unredact those fee bills so that GoDaddy can make a determination of what domain names/websites QEUS was billing the Academy for with respect to that time entry. However, it must be clear that the Academy is not waiving its right to claim attorney‐client privilege or attorney work product in general. While GoDaddy can continue to assert its waiver arguments as set forth in its Sept. 9 Joint Stipulation, GoDaddy must agree not to argue that the Academy further waived any of its rights by providing these unredacted fee bills from 2007 to present. 3. In return, GoDaddy and the Academy will agree to take the depositions in Phoenix next week off calendar. Given the 90‐day extension of all deadlines, GoDaddy and the Academy will work together to reschedule those depositions at a later date, possibly in early November around the Christine Jones deposition. The reasoning behind the delay in these depositions is so that the Academy can review the ESI being produced within 14 days. That way, we will avoid the possibility (even if remote) that these 4 witnesses will need to be redeposed. A secondary reason is that the Academy wants to complete the Iowa depositions before proceeding with these 4 witnesses. 4. Finally, in return, we would like a short 5‐day extension of time to provide you our portion of the Joint Stipulation, i.e., until Wednesday September 21, 2011. Given the 90‐day extension, I think the time need is less pressing here. 5. However, the Academy will continue to oppose the following: a. GoDaddy’s attempt to seek pre‐filing communications between Quinn Emanuel and the Academy regarding investigation into the Academy’s claim; b. GoDaddy’s attempt to seek post‐filing communications between Quinn Emanuel and the Academy regarding Defendants and/or this lawsuit; and 4
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GoDaddy’s attempt to seek an additional 20 depositions to depose Registrants in the CP program.
As discussed yesterday, the Academy will (a) provide a revised privilege log in response to your Sept. 8, 2011 email; (b) native emails in response to your Sept. 8, 2011 email; and (c) dates for its witnesses once we receive a 30b6 notice from GoDaddy. 7. We look forward to receiving your response to the Academy’s September 9, 2011 meet and confer letter.
6.
Let me know re the foregoing proposal, Enoch
This electronic message is from a law firm. It may contain confidential or privileged information. If you received this transmission in error, please reply to the sender to advise of the error and delete this transmission and any attachments. IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein. bcllp2011
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EXHIBIT C
Case 2:10-cv-03738-ABC-CW Document 381-2 Filed 04/01/13 Page 11 of 61 Page ID #:13641
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LEE TRAN & LIANG APLC James M. Lee, California Bar No. 192301 Enoch H. Liang, California Bar No. 212324 601 South Figueroa Street, Suite 4025 Los Angeles, CA 90017 Telephone: (213) 612-3737 Facsimile: (213) 612-3773 E-mail: jm](?1~ltlcounsel.com; ehl(a)tlcounsel.com
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Attorneys for Plaintiff Academy of Motion Pictures Arts and Sciences
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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
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ACADEMY OF MOTION PICTURE ARTS AND SCIENCES, a California nonprofit corporation, Plaintiff,
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v.
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GODADDY.COM, INC., a Delaware corporation; THE GODADDY GROUP INC., a Delaware corporation; DOMAINS BY PROXY, INC., a Delaware Corporation; GREENDOMAINMARKET.COM, an unknown entity; BDS, an unknown entity; and XPDREAMTEAM LLC, a California limited liability corporation,
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________D __ e[i_e_n_d_an_t_s_.-----------~
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Case No. CVIO 3738 ABC (CW) ADDITIONAL INFRINGING DOMAIN NAMES IDENTIFIED BY PLAINTIFF ACADEMY OF MOTION PICTURE ARTS AND SCIENCES
rPursuant to June 9, 201 1 Court Order] Action filed: May 18, 2010
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TO THE DEFENDANTS AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Plaintiff the Academy of Motion Picture Arts and Sciences hereby identifies the following additional infringing domain names. Should the Comi later extend the discovery deadlines in this matter, Plaintiff reserves the right to identify additional infringing domain names 60 days before the new discovery cut-off.
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ADDITIONAL INFRINGING DOMAIN NAMES IDENTIFIED BY PLAINTIFF
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ADDITIONAL INFRINGING DOMAIN NAMES 2
WWW.201 lTHEOSCARS.COM
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WWW.2012ACADEMYAWARDS.COM
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WWW.20 13ACADEMY A WARDS.COM
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WWW.24HOURSA TOSCARS.COM
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WWW.24HOURSATTHEOSCARS.COM
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WWW.20SCARS.COM
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WWW.ACADEMY A WARDS2011 WINNERS. COM
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WWW.ACADEMY A WARDS2012WINNERS.COM
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WWW.ALLOSCAR.COM
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WWW.ALLOSCARWINNERS.COM
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WWW.BILL YCRYSTAL2012ACADEMYA WARDS.COM
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WWW.BILL YCRYST AL20 120SCARS.COM
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WWW.LISTOFACADEMY A WARDW1NNERS.COM
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WWW.MYOSCARORNOT.COM
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WWW.MYOSCARSORNOT.COM
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WWW.NIGHT ATOSCARS.COM
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WWW.OSCARBUZ.COM
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WWW.OSCARCAP.COM
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WWW.OSCARGOODIEBAGS.COM
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WWW.OSCARIMAGES.COM
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WWW.OSCARMOMINEE.COM
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WWW.OSCARMOMINEES.COM
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WWW.OSCARMONLINE.COM
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WWW.OSCARMOVIEPOSTERS.COM
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WWW.OSCARREDCARPET.COM
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WWW.OSCARS-EMPORIUM.COM
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WWW.OSCARWINNERS2009.COM -2ADDITIONAL INFRINGING DOMAIN NAMES IDENTIFIED BY PLAINTIFF
Case 2:10-cv-03738-ABC-CW Document 381-2 Filed 04/01/13 Page 13 of 61 Page ID #:13643
WWW.OSCARWINNERS2012.COM 2
WWW.OSCARWINNINGMOVIES.COM
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WWW.THEOSCARS20 11.COM
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WWW.TWOOSCARS.COM
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DATED: December 12, 2011
&
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for Plaintiff ACADEMY OF MOTION PICTURE ARTS AND SCIENCES
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BOIES, SCHILLER & FLEXNER, LLP Stumi Singer (pro hac vice) David Nelson (pro hac vice) Josh Riley (pro hac vice 401 East Las Olas Blvd., Suite 1200 Fmi Lauderdale, FL 33301 Telephone: (954) 356-0011 Facsimile: (954) 356-0022 E-mail :
[email protected];
[email protected] Attorneys for Plaintiff ACADEMY OF MOTION PICTURE ARTS AND SCIENCES
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FOOTE, MEYERS, MIELKE & FLOWERS LLC Robert M. Foote (pro hac vice) Kathleen Chavez (pro hac vice) Matthew Herman (pro hac vice) 3 North Second Street, Suite 300 St. Charles, IL 60174 Telephone: (630) 232-6333 Facsimile: (630) 845-8982
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ADDITIONAL INFRINGING DOMAIN NAMES JDENTJFJED BY PLAINTIFF
Case 2:10-cv-03738-ABC-CW Document 381-2 Filed 04/01/13 Page 14 of 61 Page ID #:13644
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E-mail:
[email protected];
[email protected];
[email protected] Attorneys for Plaintiff ACADEMY OF MOTION PICTURE ARTS AND SCIENCES
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10 I1
12 13 14 15 16 17 18 19
20 21 22 23 24 25 26 27 28 -4ADDJTJONAL INFRINGING DOMAIN NAMES IDENTIFIED BY PLAINTIFF
Case 2:10-cv-03738-ABC-CW Document 381-2 Filed 04/01/13 Page 15 of 61 Page ID #:13645
CERTIFICATE OF SERVICE
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l hereby certify that on December 12, 2011, I caused a copy of the
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foregoing document to be served pursuant to the Federal Rules of Civil
4
Procedure upon the counsel listed below, via-electronic mail and via pre-
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paid U.S. First-Class Mail, by placing the same in an envelope correctly
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addressed, sealed and with postage fully prepaid thereon, and depositing
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the same in the United States Post Office Box in the City of St. Charles,
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Illinois.
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12 13 14 15 16 17
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]9 20 21
BRYAN CAVE LLP Gregory D. Trimarche, Esq. Aaron M. McKown, Esq. Paula L. Zecchini, Esq. 3161 Michelson Dr., Suite 1500 Irvine, California 92612-4414 Email: gregory.
[email protected] [email protected] [email protected]
BRYAN CAVE LLP Kara Cenar, Esq. 161 Nmih Clark Street, Suite 4300 Chicago, IL 60601-3315 Email:
[email protected]
GODADDY.COM, INC./DOMAINS BY PROXY, INC.
Christine Jones, Esq. Kelly Lewis, Esq. 14455 North Hayden Road Scottsdale, AZ 85260 Email:
[email protected];
[email protected]
22 I ce1iify under penalty of pe1jury under the laws of the United States
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of America that the foregoing is true
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12,2011.
on December
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ADDITIONAL INFRINGING DOMAIN NAMES IDENTIFIED BY PLAINTIFF
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EXHIBIT D
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