You're viewing Docket Item 3 from the case SaleHoo Group Ltd. v. ABC Company et al. View the full docket and case details.

Download this document:




Case 2:10-cv-00671-JLR Document 3 Filed 04/20/2010 Page 1 of 2



UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON AT SEATTLE

SALEHOO GROUP LTD., a New Zealand
Limited Liability Company,





v.

Plaintiff,

ABC COMPANY, an entity of unknown
origin and/or JOHN DOE, individually,



Defendants.

Civil Action No. 10-CV-671

DECLARATION OF DAVID A. LOWE IN
SUPPORT OF MOTION FOR LEAVE TO
TAKE IMMEDIATE DISCOVERY

I, David A. Lowe, declare as follows:
1.

I am a member of BLACK LOWE & GRAHAMPLLC, an actively practicing attorney in
good standing licensed by the State of Washington (WSBA No. 24,453), counsel for Plaintiff

SaleHoo Group Ltd. (“SaleHoo”) in this case. I base this declaration either on personal

knowledge or upon my review of records kept and maintained in the ordinary course of this

litigation.
2.

SaleHoo has conducted a reasonable investigation to identify the owner of the
domain name salehoosucks.com and corresponding Internet website www.salehoosucks.com.

The domain name lists the anonymous domain name service Domains by Proxy, Inc. as the

registrant and the domain name registrar as GoDaddy.com, Inc. During its investigation,

DECLARATION OF DAVID A. LOWE IN
SUPPORT OF MOTION FOR LEAVE TO TAKE
IMMEDIATE DISCOVERY - 1
Civil Action No. 10-CV-671
SALE-6-1001P02DEC_DAL



Case 2:10-cv-00671-JLR Document 3 Filed 04/20/2010 Page 2 of 2



SaleHoo attempted to obtain the information as to the underlying owner but was unable to do so

absent legal process on these companies. I am informed that it is the policy of the registrar,

GoDaddy.com, Inc., not to disclose identity or account information absent service of legal

process. Domains by Proxy, Inc. has likewise refused to provide the identity of the owner of the
salehoosucks.com domain name absent service of legal process.

3.

According to its website “Civil Subpoena Policy,” GoDaddy.com, Inc. is

headquartered at 14455 North Hayden Road, Suite 219, Scottsdale, Arizona 85260. According to

publicly accessible Whois administrative contact records, Domains by Proxy, Inc. is located at

15111 North Hayden Road, Suite 160, Scottsdale, Arizona 85260.

4.

SaleHoo seeks to discover the owner identity and account information associated
with the offending domain name salehoosucks.com and corresponding Internet website

www.salehoosucks.com solely for purposes of protecting SaleHoo’s rights related to the claims

enumerated in the complaint in this matter.

I declare under penalty of perjury that the foregoing is true and correct.

EXECUTED this 20th day of April, 2010.


s/ David A. Lowe, WSBA No. 24,453

DECLARATION OF DAVID A. LOWE IN
SUPPORT OF MOTION FOR LEAVE TO TAKE
IMMEDIATE DISCOVERY - 2
Civil Action No. 10-CV-671
SALE-6-1001P02DEC_DAL