EXHIBIT A-1

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 1 of 16

Gordon v. Virtumundo Inc et al Doc. 70 Att. 1

Dockets.Justia.com
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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DEFENDANT’S FIRST SET OF 

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FOR PRODUCTION TO PLAINTIFF GORDON

[NO. CV06-0204JCC] - Page 1 of 14

The Honorable John C. Coughenour

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

AT SEATTLE

JAMES S. GORDON, Jr., a married

individual, d/b/a ‘GORDONWORKS.COM’;

OMNI INNOVATIONS, LLC, a Washington

limited liability company;

Plaintiff,

v.

VIRTUMUNDO, INC, a Delaware

corporation d/b/a

ADNOWLEDGEMAIL.COM;

ADKNOWLEDGE, INC., a Delaware

corporation, d/b/a

ADKNOWLEDGEMAIL.COM; SCOTT

LYNN, an individual, and his marital

community; and JOHN DOES, 1-X,

Defendants.

No. CV06-0204JCC

DEFENDANT SCOTT LYNN’S FIRST

SET OF INTERROGATORIES AND

REQUESTS FOR PRODUCTION TO

PLAINTIFF GORDON

TO: James S. Gordon, Jr., d/b/a ‘GORDONWORKS.COM’; and

AND TO: Robert J. Siegel, Attorney for James S. Gordon, Jr.

Defendant Scott Lynn hereby propounds the following requests for production and

interrogatories to Plaintiff, pursuant to Fed. R. Civ. P. 26, 33 and 34. The requests should be

answered in full and the original returned to this office (Newman & Newman, Attorneys at Law,

LLP, 505 Fifth Avenue S., Suite 610, Seattle, Washington 98104) within 30 days after the date of

service. The requested documents should be produced for inspection and copying at the offices

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 2 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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DEFENDANT’S FIRST SET OF 

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[NO. CV06-0204JCC] - Page 2 of 14

of Newman & Newman, Attorneys at Law, LLP, 505 Fifth Avenue S., Suite 610, Seattle,

Washington 98104. You should respond to each discovery question in accordance with the

instructions and definitions set forth below. The requests for production are continuing in nature

within the meaning of Fed R. Civ. P. 26.

I. INSTRUCTIONS/DEFINITIONS

1. In answering these requests for production, You are required to furnish all

information that is available to You, not merely such information as You know of Your own

personal knowledge, including information in the possession of Your attorneys, or other persons

directly or indirectly employed by or connected with You or Your attorneys, or anyone acting on

Your behalf or otherwise subject to Your control.

2. In answering these requests for production, You are requested to make a diligent

search of Your records and of other papers and materials in the possession, custody or control of

You or Your representatives.

3. The documents requested are not privileged and are reasonably calculated to lead

to the discovery of admissible evidence. If any document is withheld from production on the

ground that its production is privileged due to the attorney-client privilege, work-product rule or

other legally recognized standard preventing its disclosure to a requesting party, then state

separately for each such document: (1) the legal basis on which You claim protection against

discovery; (2) the date of the document; (3) the nature of the document (e.g. letter); (4) the full

name, job title and employer for each author of the document; (5) the full name, job title, and

employer or principal of each addressee and named recipient of the document; (6) the full name,

job title, and employer of each person who to Your knowledge has knowledge of the

communication; and (7) in general, the substance of the document.

4. These discovery requests shall, to the fullest extent permitted by law, be deemed

continuing, so as to require You, without further request, to provide supplemental responses

within 15 days of acquiring any additional material pertaining to the subject matter of any of these

requests.

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 3 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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DEFENDANT’S FIRST SET OF 

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[NO. CV06-0204JCC] - Page 3 of 14

5. Unless otherwise specified, You are instructed to answer for the period from

January 1, 2003 to the present.

6. If You cannot answer any of the following discovery requests in full after

exercising due diligence to secure the full information to do so, so state and answer to the extent

possible, specifying Your inability to respond in full, stating whatever information or knowledge

You have concerning the unanswered portion and detailing what You did in attempting to secure

the unknown information. If You do know the name of a person or entity that may have such

information, the name, address and telephone number and the nature of the information known by

such person or entity shall be disclosed in Your response.

7. The singular form of a noun or pronoun shall be considered to include within its

meaning the plural form of the noun or pronoun so used and vice versa; the use of the masculine

form of a pronoun shall be considered to include within its meaning the feminine form of the

pronoun so used and vice versa; and the use of any tense of any verb shall be considered to

include within its meaning all other tenses of the verb.

8. The lower case form of a defined word shall be considered to include within its

meaning the capitalized form of the word and vice versa.

9. Whenever it is necessary to bring within the scope of these requests information

that otherwise might be construed to be outside their scope, “any” should be understood to

include and encompass “all”; and “all” should be understood to include and encompass “any”; and

“or” should be understood to include and encompass “and,” and “and” should be understood to

include and encompass “or.”

10. "AOMs" shall refer to the e-mails with respect to which You seek damages from

Defendants in this lawsuit.

11. “Communications” means any written communication, conversation, note, SMS,

instant message, email, letter, correspondence or exchange of document. When identifying or

referencing a communication, identify the date of the communication, the location or means of

communication, the parties and witnesses to the communication, and the substance of the

communication. When identifying or referencing an exchange of more than one communication,

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 4 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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DEFENDANT’S FIRST SET OF 

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[NO. CV06-0204JCC] - Page 4 of 14

include each document in the exchange.

12. The term “Defendants” means the above-captioned defendants in this lawsuit.

13. The terms "document" and "documents" mean and include any kind of written,

typewritten, or printed material whatsoever, any kind of graphic material, and any computer

readable media including, without limitation, and papers, agreements, contracts, notes,

applications, memoranda, correspondence, instant message exchange, SMS communications,

studies, working papers, letters, telegrams, invoices, personal diaries, journals, reports, records,

books, forms, indexes, transcriptions and recordings, magnetic tapes, video tapes, wire

recordings, disks and printed cards, data sheets, data processing cards, calendars, interoffice

memoranda, minutes and records of any sorts of meetings, financial statements, financial

calculations, estimates, reports of telephone or other oral conversations, appointment books,

maps, drawings, charts, graphs, photographs, and all other writings and recordings of every kind,

however produced or reproduced, whether signed or unsigned. The terms "document" and

"documents" include, without limitation, originals and all file copies and other copies that are not

identical to the original no matter how or by whom prepared, and all drafts prepared in connection

with any documents, whether used or not. If the original of any document is not in Your

possession, custody or control, a copy of that document should be produced. 

14. The term “identify,” when used in connection with a document, means to state the

date on which the document was prepared, the author of the document, and any and all

recipient(s) of the document.

15. The term “identify,” when used in connection with an individual, means to state

the individual’s full current name, to state the individual’s full current residential address, full

current business address, email address, instant messaging name, and the individual’s telephone

numbers.

16. The use of the words “include(s)” and “including” should be construed to mean

without limitation.

17. The term “person” includes both individuals and business entities.

18. The term “Plaintiffs” means the above-captioned plaintiffs in this lawsuit.. 

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 5 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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[NO. CV06-0204JCC] - Page 5 of 14

19. The terms “present” or “presently” refer to the date of service of these

interrogatories and shall continue through resolution of this litigation.

20. The term “Responses” refers to Your responses and/or answers to interrogatories

and/or requests for production.

21. The phrase "relating to" means consisting of, summarizing, describing, reflecting,

or referring to in any way.

22. “You” means JAMES S. GORDON, Jr., d/b/a ‘GORDONWORKS.COM,’ Your

agents, affiliates and subsidiaries.

23. Defendants will move to preclude You from presenting evidence regarding

responsive matters You have failed to set forth in Your responses.

II. INTERROGATORIES

INTERROGATORY NO. 1: Identify each and every e-mail address to which

You contend (as alleged in Paragraph 4.1.3 of Your First Amended Complaint) that

“[D]efendants sent at least one (1) separate item of electronic mail to the Plaintiffs to an

address most likely harvested from domain name registration and/or by other means of

anonymous internet information harvesting.”

ANSWER:

INTERROGATORY NO. 2: Identify each and every web hosting service,

internet service provider, or other provider of online services from whom You have

purchased, leased, or otherwise obtained services in relation to Your operation of the

‘GORDONWORKS.COM’ domain.

ANSWER:

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 6 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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DEFENDANT’S FIRST SET OF 

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[NO. CV06-0204JCC] - Page 6 of 14

INTERROGATORY NO. 3: Please identify all internet domain names

registered in Your name or on Your behalf since January 1, 2003 as well as the dates of

such registration and, if applicable, the dates on which such registrations expired.

ANSWER:

INTERROGATORY NO. 4: Please explain the purpose and scope of Your

“doctoral studies” (as referred to in Paragraph 9 of Your Answers to Interrogatories) and

their relation to Your use of the ‘GORDONWORKS.COM’ domain.

ANSWER:

INTERROGATORY NO. 5: Please identify any filters, software, or other

system used by You to prevent or reduce the receipt of unsolicited commercial email.

ANSWER:

INTERROGATORY NO. 6: Please identify the type(s) and/or brand(s) of

“auto-responder” software applications that You used to generate the complaint messages

contained in the mailbox files produced in Your First Supplemental Responses to

Defendant’s First Discovery Requests on September 11, 2006.Please identify any service

you provide that enables users to access content, information, electronic mail, or other

services offered over the Internet. For each such service, please identify the users to

whom you provide that service (including their address, email and phone number), the

nature of the service, the consideration paid for the service.

ANSWER:

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 7 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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DEFENDANT’S FIRST SET OF 

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[NO. CV06-0204JCC] - Page 7 of 14

INTERROGATORY NO. 7: Please identify (including date, subject line, sender

email and recipient email) any AOM that you contend was initiated by Defendants that

contained, or were accompanied by header information that was materially false or

misleading. For each such AOM, please explain how the header information was

materially false or misleading.

ANSWER:

INTERROGATORY NO. 8: Please identify (including date, subject line, sender

email and recipient email) any AOM that you contend was initiated by Defendants that

did not contain a clearly and conspicuously displayed functioning return email address or

Internet-based mechanism that a recipient may have used to submit, in a manner specified

in the message, a reply email message or other form of Internet-based communication

requesting not to receive future commercial email messages at the email address where

the message was received. For each such AOM, please explain the basis upon which you

make such contention.

ANSWER:

INTERROGATORY NO. 9: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that the Defendants had actual or fairly implied knowledge that the subject headings of

the messages would be likely to mislead a reasonable recipient, under the circumstances,

about a material fact regarding the subject or content matter of the message. For each

such AOM, please explain how the subject headings are likely to mislead a reasonable

recipient.

ANSWER:

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 8 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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DEFENDANT’S FIRST SET OF 

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[NO. CV06-0204JCC] - Page 8 of 14

INTERROGATORY NO. 10: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that Your users attempted to request, using a mechanism specified in the AOM, to not

receive some or any commercial email from the Defendant and subsequent transmission

by that Defendant was made to that user more than 10 business days after the receipt of

such request. For each such AOM, please explain the basis upon which you make such

contention.

ANSWER:

INTERROGATORY NO. 11: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that did not provide clear and conspicuous identification that the message was an

advertisement or solicitation. For each such AOM, please explain the basis upon which

you make such contention.

ANSWER:

INTERROGATORY NO. 12: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that did not provide clear and conspicuous identification of the opportunity to decline to

receive further commercial emails from the message's sender via the methods specified in

the message. For each such AOM, please explain the basis upon which you make such

contention.

ANSWER:

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 9 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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DEFENDANT’S FIRST SET OF 

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[NO. CV06-0204JCC] - Page 9 of 14

INTERROGATORY NO. 13: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that did not include the valid physical postal address of either the person who initiated the

message or the person whose product, service, or Internet website is advertised in the

message. For each such AOM, please explain the basis upon which you make such

contention.

ANSWER:

INTERROGATORY NO. 14: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that were sent to email addresses obtained using an automated means of generating email

addresses by combining names, letters, or numbers into numerous permutations. For each

such AOM, please explain the basis upon which you make such contention.

ANSWER:

INTERROGATORY NO. 15: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that used a third party's Internet domain name without permission of the third party, or

otherwise misrepresented or obscured any information in identifying that message's point

of origin or transmission path. For each such AOM, please explain the nature of the

alleged misrepresentation or obscured information.

ANSWER:

INTERROGATORY NO. 16: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 10 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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DEFENDANT’S FIRST SET OF 

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[NO. CV06-0204JCC] - Page 10 of 14

that contained false or misleading information in the subject line. For each such AOM,

please explain how the subject line is false or misleading.

ANSWER:

INTERROGATORY NO. 17: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that sought to solicit, request, or take any action to induce a person to provide personally

identifying information by representing oneself, either directly or by implication, to be

another person, without that person's approval or authority. For each such AOM, please

explain the basis upon which you make such contention.

ANSWER:

INTERROGATORY NO. 18: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that were sent to email addresses obtained using an automated means from an Internet

website or proprietary online service operated by another person that included, at the time

the address was obtained, a notice stating that the website or service would not give, sell,

or transfer addresses maintained by such website or online service to any other party for

the purposes of initiating email messages. For each such AOM, please explain the basis

upon which you make such contention.

ANSWER:

INTERROGATORY NO. 19: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that contained offers or promotions for prizes which the promoter knew or had reason to

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 11 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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DEFENDANT’S FIRST SET OF 

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[NO. CV06-0204JCC] - Page 11 of 14

know would not be available in a sufficient quantity based on the reasonably anticipated

response to the offer. For each such AOM, please explain the basis upon which you

make such contention.

ANSWER:

INTERROGATORY NO. 20: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that contained offers or promotions for prizes which were not available for immediate

delivery to the recipient for which the recipient was given a rain check which could not

be honored within thirty days and the promoter or sponsor failed to mail the recipient a

valid check for the verifiable retail value of the prize. For each such AOM, please

explain the basis upon which you make such contention.

ANSWER:

INTERROGATORY NO. 21: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that contained offers or promotions for prizes for which a rain check was issued and the

person named as being responsible for the rain check failed to honor and the sponsor then

failed to fulfill the rain check within thirty days. For each such AOM, please explain the

basis upon which you make such contention.

ANSWER:

INTERROGATORY NO. 22: Please identify (including date, subject line,

sender email and recipient email) any AOM that you contend was initiated by Defendants

that contained offers or promotions for prizes which failed to state, clearly and

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 12 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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conspicuously, printed in type at least as large as the typeface used in the standard text of

the offer: "If you receive a rain check in lieu of the prize, you are entitled by law to

receive the prize, an item of equal or lesser value, or the cash equivalent of the offered

prize within thirty days of the date on which you claimed the prize." For each such

AOM, please explain the basis upon which you make such contention.

ANSWER:

INTERROGATORY NO. 23: Please identify (including date, subject line,

sender email and recipient email) any damages alleged by you as a result of an AOM you

contend was initiated by Defendants that violated RCW 19.170 et seq. For each such

AOM, please explain the basis upon which you make such contention.

ANSWER:

III. REQUESTS FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 1: REQUEST FOR PRODUCTION NO.

1: Please produce for inspection all documents evidencing notices included on websites

or online services from which You allege that Defendants obtained e-mail addresses for

recipients at your domain using automated means which stated at the time the address

was obtained that the operator of such website or online service will not give, sell, or

otherwise transfer addresses maintained by such website or online service to any other

party for the purposes of initiating, or enabling others to initiate, electronic messages.

RESPONSE:

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 13 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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REQUEST FOR PRODUCTION NO. 2: Please produce for inspection all

documents relating to any agreements, contracts, or relationships which You may have

had with website hosting services, internet service providers, or other providers of online

services in relation to your use of the domain name GORDONWORKS.COM.

RESPONSE:

REQUEST FOR PRODUCTION NO. 3: Please produce for inspection all

documents relating to Your configuration and customization of the “auto-responder” files

used to generate the messages contained in the mailbox files produced in Your First

Supplemental Responses to Defendant’s First Discovery Requests on September 11,

2006.

RESPONSE:

Interrogatories and Requests for Production dated this 15th day of November, 2006.

NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

By:

Derek A. Newman, WSBA No. 26967

Roger M. Townsend, WSBA No. 25525

Attorneys for Defendants

505 Fifth Avenue South, Suite 610

Seattle, Washington 98104

phone: (206) 274-2800

fax: (206) 274-2801

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 14 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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VERIFICATION

I, _________________, have read the foregoing Responses to DEFENDANT LYNN’S

FIRST INTERROGATORIES & REQUESTS FOR PRODUCTION, know the contents thereof,

and believe the same to be true.

Dated this ______ day of ____________________, 2006.

________________________________

SUBSCRIBED AND SWORN TO before me this _____ day of ____________, 2006.

Printed Name: 

NOTARY PUBLIC in and for the State of 

_________, residing at 

My Commission Expires: 

CERTIFICATION

The undersigned attorney for Plaintiff has reviewed the foregoing Responses to

DEFENDANT LYNN’S FIRST INTERROGATORIES & REQUESTS FOR PRODUCTION,

and certifies that they are in compliance with Civil Rules 26 and 34. 

DATED: _______________________, 2006.

By: _____________________________

 Attorneys for James S. Gordon, Jr.

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 15 of 16
NEWMAN & NEWMAN,

ATTORNEYS AT LAW, LLP

505 Fifth Ave. S., Ste. 610

Seattle, Washington 98104

(206) 274-2800

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CERTIFICATE OF SERVICE 

CERTIFICATE OF SERVICE

 The undersigned hereby certifies that on this 15th day of November, 2006, I 

caused the foregoing DEFENDANT SCOTT LYNN’S FIRST SET OF

INTERROGATORIES AND REQUESTS FOR PRODUCTION TO PLAINTIFF

GORDON AND CERTIFICATE OF SERVICE to be served via the methods listed below on

the following party

Via Email and Fax to:

Robert Siegel, Esq.

Merkle Siegel & Friedrichsen, P.C.

Email: bob@msfseattle.com

Fax: 206-624-0717

 

I declare under penalty of perjury under the laws of the United States and the State of 

Washington that the forgoing is true and correct and that this declaration was executed on 

November 15th, 2006, at Seattle, Washington.

_____________________________

Diana Au

Case 2:06-cv-00204-JCC Document 70-2 Filed 12/21/2006 Page 16 of 16