LegalZoom Sued For Fraud, Conspiracy, and Constructive Fraud by LegalForce

E-FILED
RAJ V. ABHYANKER, SBN 233284 3/22/2019 3:31 PM

Email: raj@legalforcelaw.com Clerk of Court
WENSHENG MA, SBN 299961 Superior Court of CA,
Email: vincent@legalforcelaw.com County of Santa Clara
19CV345030
LEGALFORCE RAPC WORLDWIDE, P.C. Reviewed By: Matthew Carter
1580 W. El Camino Real, Suite 10
Mountain View, CA 94040
Telephone: (650) 965-8731
Facsimile: (650) 989-2131
Attorneys for Plaintiff,

LegalForce, Inc.
SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SANTA CLARA
LEGALFORCE, INC., Case No. 19CV345030
Plaintiff, COMPLAINT FOR:
v. 1. BREACH OF CONTRACT AND

IMPLIED COVENANT OF GOOD
LEGALZOOM.COM, INC., FAITH AND FAIR DEALING;
2. FRAUD;
Defendant. 3. CONSTRUCTIVE FRAUD; and
4. CIVIL CONSPIRACY
JURY TRIAL DEMANDED
1
INITIAL COMPLAINT
1. Plaintiff LegalForce, Inc. (“Trademarkia”, “Plaintiff”), a Delaware corporation, by and
through its counsel, for its Complaint against Defendant LegalZoom.com, Inc. (“LegalZoom”,
“Defendant”), a Delaware corporation, complains and alleges as follows:
NATURE OF ACTION
2. Trademarkia brings this action in California state court to seek redress from
LegalZoom’s breach of contract, fraud, constructive fraud, and civil conspiracy. Trademarkia
has an ongoing federal lawsuit against LegalZoom alleging trademark infringement and
cyberpiracy causes of actions (N.D. Cal. Case No. 3:18-cv-07274-MMC, filed July 16, 2018).
xhibit Z (First Amended Complaint filed on March 21, 2019). However, although certain
See E
facts stated herein have already been pled in the federal lawsuit, they are largely background
facts. The causes of actions alleged herein are purely based on California state laws and are
distinct from the causes of action pled in the federal case. Moreover, Judge Maxine M. Chesney
in the federal case has ordered that no additional new claims be added to the federal case in the
recently filed First Amended Complaint, and that order effectively necessitates that this action
be litigated in state court.
THE PARTIES
3. Trademarkia is a Delaware corporation having a principal place of business at 1580 W.
El Camino Real, Suite 9, Mountain View, CA 94040. Trademarkia is a market leader in the
field of trademark search solutions, trademark monitoring services, general legal information,
and domain name registration services. Trademarkia provides these services online at set prices,
making them readily available and affordable to small businesses and general consumers across
the United States. Since introducing its website in September 2009, Trademarkia has grown to
become the leading, nationally recognized trademark website for small businesses and
consumers.
4. LegalZoom is a Delaware corporation having a principal place of business at 101 N.
Brand Blvd., Glendale, CA 91203. LegalZoom competes with Trademarkia in trademark watch
and monitoring services. LegalZoom also has a listed office in the County of Santa Clara at 888
Villa Street, #430, Mountain View, California. (Exhibit Y).
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INITIAL COMPLAINT
5. To further its fraud and breach of contract with its competitor Trademarkia, LegalZoom
fraudulently and surreptitiously advertised the LegalZoomTrademarkia.com in the LegalZoom
Affiliate program and misdirected web traffic to LegalZoom’s homepage from
LegalZoomTrademarkia.com in violation of a written contract with Trademarkia.
JURISDICTION AND VENUE
6. This Court has general personal jurisdiction over LegalZoom because their principal
places of business are in California.
7. Venue is proper in the County of Santa Clara pursuant to Code Civ. Proc. § 395(a)
because Santa Clara is the county where “the contract in fact was entered into” and where “the
defendant or any defendant resides at the commencement of the action.” Moreover, during the
relevant time period LegalZoom maintained an office in this county.
FACTUAL ALLEGATIONS
A. The TRADEMARKIA Marks
8. Trademarkia is the owner of three U.S. federal trademark registrations:
Marks Reg. No. First Use in Goods/Services

Reg. Date Commerce date
Trademarkia Reg: 3965290 June 15, 2009 Advertising, marketing and promotion
May 24, 2011* services. (35, 42)
LegalForce Reg: 4227650 August 1, 2006 Legal services, namely, law firm
Oct. 16, 2012 services specializing in administrative,
transactional, litigation, civil and
criminal matters; legal document
preparation and research services for
attorneys; providing general
information in the field of legal services
via a global computer network. (45)
LegalForce Reg: 5642937 April 13, 2012 Providing temporary use of on-line
Trademarkia Jan. 1, 2019 non-downloadable software for
trademark searching and managing
trademark matters; Computer services,
namely, providing search engines for
obtaining trademark data from publicly
available sources. (42)
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INITIAL COMPLAINT
9. The mark TRADEMARKIA was declared incontestable through Reg. No. 3965290.
10. The marks “LEGALFORCETRADEMARKIA” “TRADEMARKIA”, and
“LEGALFORCE” are collectively referred to as the “TRADEMARKIA Marks”.
11. As a result of Trademarkia’s exclusive, extensive, continuous and nationwide use of the
TRADEMARKIA Marks, the marks have come to signify the leading provider of online
trademark search and watch services for small businesses and consumers and have achieved
such widespread public recognition that the use of the suffix “markia” anywhere in all industries
across the United States is now associated with Trademarkia.
12. As an industry leader, licensees of the Trademarkia platform have expended well over
ten million dollars promoting the need for trademark search services, educating and raising
awareness among consumers, and advertising and promoting the TRADEMARKIA Marks.
13. In order to build and maintain its status as the leading nationally-recognized brand,
Trademarkia has promoted the TRADEMARKIA Marks through advertising across the media
of video, radio, and the Internet.
14. This lawsuit is necessitated by the fact that LegalZoom is seeking to trade on the
TRADEMARKIA Marks’ fame and goodwill by registering and using the domain
LegalZoomTrademarkia.com (“Disputed Domain”) to advertise LegalZoom’s services over the
Internet.
15. Trademarkia often uses the phrase “LegalForce Trademarkia” combined together and
has used this phrase together in emails and on the web pages of Trademarkia.com every day
continuously since 2012. In addition, Trademarkia has continually owned the domain
LegalForceTrademarkia.com since 2013 and has redirected traffic from this domain to
Trademarkia.com. Further, the domain LegalForce.com is owned by Trademarkia and itself
redirects to Trademarkia.com.
16. Accordingly, Defendant must be ordered to stop its infringing activities, to pay damages
to Trademarkia in an amount to be determined at trial, and to disgorge any profits it has made as
a result of its willful and bad faith infringement of the TRADEMARKIA Marks.
17. As a direct result of LegalZoom’s infringing conduct, Trademarkia has suffered
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INITIAL COMPLAINT
threatened injury given the fact that LegalZoom was directing LegalZoomTrademarkia.com to
LegalZoom.com for years and including up through litigation between LegalZoom and
LegalForce commencing in December 2017 and continuing through all the way that a Third
Amended Complaint (TAC) was proposed which included the facts about this cybersquatting
domain on June 18, 2018 in the litigation (3:17-cv-07194-MMC). Judge Chesney in
3:17-cv-07194-MMC ruled that the facts alleged in the TAC were not related to that case,
necessitating the need for the instant lawsuit. Specifically, Trademarkia has been threatened
with harm because customers seeking for services offered by Trademarkia, such as trademark
watch services and trademark search services have been misdirected to LegalZoom.com’s
homepage which offers similar services for years, up through June 18, 2018. Moreover, the
threatened harm continues to this day, as when users go to LegalZoomTrademarkia.com as of
the filing of this First Amended Complaint, they see a message indicating that the domain may
be available (e.g., implying available for purchase) and that the “website coming soon!” (See
Exhibit C). Moreover, upon information and belief, LegalZoom continues to own the domain
LegalZoomTrademarkia.com through today, and could at any time resume misdirecting traffic
back to Legalzoom.com. (See updated Exhibit A).
18. It is not in dispute that LegalZoom listed the Disputed Domain in the LegalZoom
Affiliate program.1 LegalZoom’s actively encourages its hundreds if not thousands of
third-party affiliates who have subscription e-mail list(s), personal blogs, community
newsletters, community webzines, and small-business websites of third-parties (collectively
“Publishers”) to infringe the intellectual property rights of the TRADEMARKIA Marks through
the Disputed Domain by providing “Direct Links” on those websites incorporating the
TRADEMARKIA Marks and redirecting these users back to LegalZoom’s own website
(Exhibit K and Exhibit L). Thus, when accessing thousands of Publishers, LegalZoom paid a
commission to Publishers that advertised a hyperlink back to the Disputed Domain.
1
Specifically, LegalZoom redirected traffic from the Disputed Domain to its affiliate tracking
URLs by first redirecting to http://lztrk.com/?a=23&c=15&p=r&s1=legalzoomtrademarkia.com
and then redirecting to a tracking URLathttp://www.legalzoom.com/aff/home?utm_
source=23&utm_medium=affiliate&utm_campaign=home&cm_mmc=affiliate-_-ck-_-23-_ -na.
(See Exhibits B, D and E).
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INITIAL COMPLAINT
19. To support this contention, consider the “LegalZoom Affiliate program” as described on
the LegalZoom website in Exhibit E and associated with the hidden hyperlink snippet
“medium=affiliate&utm_campaign” on the Disputed Domain domain in Exhibit B. Under the
“LegalZoom Affiliate program”, LegalZoom offers to pay 15% to Publishers that advertise its
domains such as the Disputed Domain when a sale happens based on the inbound lead (Exhibit
E). In other words, LegalZoom offered a commission equivalent to 15% to each Publisher that
advertised the Disputed Domain as described in Exhibit H. Specifically, LegalZoom’s affiliate
FAQ describes that “[f]or each completed sale, you earn a 15% commission.” (Exhibit H). In
that FAQ, a table is provided that shows that the following commission structure when
Publishers link to LegalZoom domains including the Disputed Domain:
Product | Package Retail Price 15% Commission
Trademark | Complete Coverage $189.00 $28.35
Copyright $114.00 $17.10
Provisional Patent $199.00 $29.85
(Exhibit H)
20. The “complete coverage” trademark service advertised in conjunction with LegalZoom’s
Affiliate program for domains including the Disputed Domain is in direct competition with
Trademarkia as it implies trademark monitoring and watch services being included.
21. LegalZoom specifically requested small businesses to advertise its domains such as the
Disputed Domain on LegalZoom’s behalf. Specifically, LegalZoom wrote in their “Who we’re
looking for” section of their LegalZoom Affiliate program that they wanted websites, such as:
“
● Web marketers committed to preserving the integrity of the LegalZoom brand
● Franchise companies searching for a cost effective solution for business formation
requirements
● Esq., CPAs, CFAs & CFPs exploring value added services to their clientele
● Companies with online marketing specialists and content writing teams
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INITIAL COMPLAINT
● Companies who look for niche products and build sites to promote products
● Website owners with a strong SEO presence for legal keywords
● Sites or directories that are targeted and useful to online shoppers.” (see E
xhibit F)
to place ads for LegalZoom’s domains including the Disputed Domain.
22. Many of these businesses have visitors who know of the Trademarkia brand.
Specifically, Trademarkia is visible to more than 9 million unique visitors per year. Much of
this audience would visit websites like those that LegalZoom actively recruited to advertise the
Disputed Domain. For this reason, while damage calculation is difficult for Trademarkia to
ascertain, Trademarkia believes from 2014 through 2018, Trademarkia roughly estimates that it
has lost over $150,000 in lost profits directly attributable to LegalZoom’s use of the Disputed
Domain in addition to expectation damages for trademark licensing of the TRADEMARKIA
Marks in the amount of $120,000 per month as will later be explained herein.
23. LegalZoom’s Affiliate Program even built a number of tools to threaten Trademarkia’s
business. LegalZoom advertises “Make use of robust reporting tools to keep track of your
campaigns and conversions, help identify your customers' preferences and maximize your site's
earning potential.” (Exhibit G). To facilitate quick dissemination of LegalZoom’s Affiliate
Program, LegalZoom employed the Pepperjam advertising network service. (Exhibit D). The
Pepperjam website (www.pepperjam.com), which is advertised as the “intuitive technology
solution to discover, reach and convert high-value customers and a partner with the experience
to drive connections that create commerce” (see Exhibit I), enabled LegalZoom to market the
Disputed Domain through an unlimited number of micro-websites across the Internet to create
marketplace confusion.
24. Text ads advertising for www.legalzoomtrademarkia.com for trademark services would
appear on these micro-sites and on marketing emails which directed users to the Disputed
Domain because “Direct Link” advertising is one of the ways LegalZoom Affiliates make
money, according to their own LegalZoom Affiliate’s sign up page (Exhibit K). Through
Pepperjam, LegalZoom actively marketed and advertised the Disputed Domain to millions of
visitors to small micro-websites making up the Pepperjam affiliate network. Tellingly,
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INITIAL COMPLAINT
Pepperjam advertises itself as enabling LegalZoom to “identify and recruit high-quality
publishers” to enable LegalZoom’s “white label affiliate program.” (Exhibit I). LegalZoom
actively disseminated and marketed the Disputed Domain for years through affiliate marketing.
Pepperjam has two sides to its affiliate network, one side for ADVERTISERS like LegalZoom
(Pepperjam’s advertiser page is on Exhibit I), and the other side a page for PUBLISHERS
AND INFLUENCERS who are small micro-websites on which the TRADEMARKIA Marks
were actively promoted by LegalZoom to be placed. (Pepperjam’s publisher page is on Exhibit
J) LegalZoom sought and actually did seek to avoid paying a $120,000 licensing revenue to
Trademarkia while diluting the TRADEMARKIA Marks and confusing the public through
websites, email campaigns, blogs and other advertising vehicles of the LegalZoom Affiliate
program for the specific purpose of attracting more customers to LegalZoom and diminish the
value of the TRADEMARKIA Marks. Indeed, even the Disputed Domain having the literal
characters of the TRADEMARKIA Marks. Pepperjam has a Publisher Registration page for
LegalZoom in which it solicits ways that publishers agree to promote LegalZoom’s domains
including the Disputed Domain. It requests through checkboxes for “Promotional Methods”
different ways Publishers will advertise, including through “Web Site/Content” , “Paid Search” ,
“Email Marketing” , “Toolbar” , “Comparison Shopping”, “Video” , “Loyalty” , and most tellingly
“Direct Link” . (Exhibit K).
25. Moreover, Pepperjam’s terms for LegalZoom affiliates describe that:

As a service provider and online exchange, Pepperjam facilitates affiliate
marketing programs via its technology and network on the Internet. An affiliate
marketing program ("Advertiser Program") is where a Publisher or its agent
operates one or more web site(s) (domain or portion of a domain within the
Internet) and/or subscription e-mail list(s) to earn financial compensation
("Publisher Fees") for sales and or leads ("Transactions") generated from such
web site and/or email list through a click made by a customer (each, a
"Customer") on a web site or content operated by an advertiser ("Advertiser").
The Advertiser compensates the Publisher, in accordance with this Agreement
and the specifications of the applicable Advertiser Program agreed to by the
Advertiser and the Publisher under a separate agreement.
(Exhibit L).
26. It is clear that LegalZoom has threatened to harm, and actually harmed, Trademarkia’s
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INITIAL COMPLAINT
business directly as a result of this solicitation, and presumptively caused harm by actively
recruiting and listing the Disputed Domain on the Pepperjam advertising network.
27. Additionally, a clear chain of inferences can be drawn, based on the active listing,
marketing, and complexity of commission structures through the Jambone affiliate advertising
networks of the Disputed Domain on LegalZoom’s Affiliate Network, to support Plaintiff’s
claims for relief and permit the Plaintiff to determine the extent of the harm caused by
LegalZoom’s unlawful and unethical conduct with the specific intent to unfairly harm its
leading trademark competitor Trademarkia. It stands to reason that LegalZoom would capture a
larger share of the trademark market—to Plaintiff’s detriment—if they mislead consumers into
purchasing LegalZoom’s services rather than Plaintiff’s. Indeed, numerous Trademarkia
customers have been confused between LegalZoom and LegalForce Trademarkia.
28. With respect to LegalZoom causing Trademarkia’s damages, LegalZoom’s use of the
domain www.legalzoomtrademarkia.com to misdirect customers searching for LegalForce or
Trademarkia back to their own website LegalZoom.com that offered similar services as
Trademarkia.com, LegalZoom caused damages to Trademarkia in a dollar amount unknown.
29. Given the difficulty of assessing damages directly caused by LegalZoom’s use of the
www.legalzoomtrademarkia.com domain to www.legalzoom.com, Trademarkia seeks damages
under quasi contract theory and trademark infringement caused by LegalZoom’s bad faith
conduct in failing to pay to advertise the branding LEGALZOOM TRADEMARKIA for
$120,000 per month for each month following November 2011 and continuing to this day,
compensatory damages, punitive damages, and an injunction in this case. The damage period
should be between April 2014 (when LegalZoom started infringing the TRADEMARKIA
Marks through the disputed domain) and June 2018 (when LegalZoom ceased infringing the
TRADEMARKIA Marks). The entire period between April 2014 and June 2018 is 51 months
for a total of damages amount of $6,120,000 in lost expected trademark licensing revenues of
the TRADEMARKIA Marks to LegalZoom.
30. In addition to direct loss in asset value, Trademarkia’s website Trademarkia.com has
also lost brand value to LegalZoom as a direct consequence of LegalZoom misdirecting
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INITIAL COMPLAINT
customers from the Disputed Domain to LegalZoom.com starting in April 2014. Specifically,
Trademarkia’s users have shrunk from 1,575,000 users per month in April 2014 (Exhibit T) to
just 380,043 users in the last full month of February 2019 (Exhibit U). In the same period,
LegalZoom users have grown from about 1,700,000 users per month to approximately
3,953,100 visitors per month (Exhibit X). In other words, Trademarkia’s user count has shrunk
to by -75.87% of its former self after the Disputed Domain was advertised and promoted in its
LegalZoom Affiliate program by LegalZoom in April 2014, while LegalZoom’s traffic has
increased 234.54% from its former after the Disputed Domain was advertised and promoted by
LegalZoom.
31. This reflects a loss in traffic of 1,194,957 users per month (1.1 million fewer visitors per
month to Trademarkia.com). Based on the reported estimate 12% to 29% of all web traffic
being direct brand traffic (Exhibit M), between 143,394 users (12%) and 346,537 (29%) fewer
users come to the Trademarkia.com website as a direct result of the brand confusion created by
LegalZoom through the Disputed Domain. Tellingly, Trademarkia’s loss as a result of
LegalZoom’s surreptitious acts in infringing and misdirecting traffic using the
TRADEMARKIA Marks has been LegalZoom’s gain. In fact, as of April 8, 2012, when
Trademarkia and LegalZoom had just recently signed a Mutual Nondisclosure Agreement
(“NDA”), the total web traffic of Trademarkia was roughly the same as the web traffic of
LegalZoom. As of April 8, 2012, based on Amazon’s Alexa.com web ranking analytics
Trademarkia.com was the 9.275th largest website on the Internet based on the last 7 day
average, and LegalZoom was roughly equivalent in traffic and ranking. (Exhibit V)
Dramatically, as of May 21, 2019, based on Amazon’s Alexa.com web ranking analytics
Trademarkia.com had dropped to the rank of 44,929 while LegalZoom had gained ground and
become the 8,076 largest website on the Internet.
32. As a result, since venture capital valuations, potential advertising revenue, and private
money valuations for Internet companies are largely based on web traffic, Trademarkia has
directly suffered a long term drop in asset value as a direct consequence of LegalZoom’s
infringing use of the Disputed Domain to confuse the public. Therefore, Trademarkia suffered
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INITIAL COMPLAINT
lost revenue and market share, reduced asset value and increased advertising costs of unknown
value. Specifically, Trademarkia’s brand has now been indistinguishably mixed with that of its
arch-competitor LegalZoom.
33. Trademarkia roughly estimates that it has lost over $5,000,000 in lost intangible asset
valuation (lost advertising opportunities, lost venture capital equity fundraising opportunities,
lost private equity/exit valuation) through the reduction of brand equity through the trademark
infringement of the TRADEMARKIA Marks by LegalZoom’s surreptitious misappropriation of
Trademarkia’s goodwill in the TRADEMARKIA Marks for itself through its LegalZoom
Affiliate program promotion in email blasts and affiliate websites across the Internet.
B. Trademarkia’s Contractual Relationship with LegalZoom.
34. Trademarkia and LegalZoom are not strangers. In 2011, LegalZoom actively pursued an
trademark licensing negotiations over the TRADEMARKIA Marks with Trademarkia.2
Trademarkia and LegalZoom formed a legally binding NDA executed on November 16, 2011
(Exhibit Q). This NDA was hard fought with outside counsel for Trademarkia and LegalZoom
negotiating key terms over many rounds (Exhibit R, Exhibit S). After being forced to largely
accept the terms of LegalZoom’s version of the NDA after LegalZoom refused to entertain
Trademarkia’s version, LegalZoom CEO Suh even wrote in an email to Mr. Abhyanker
“Appreciate the flexibility on the NDA… lawyers can be bulldogs. ;)” (Exhibit S).
35. The purpose of the NDA was because the “parties agree there is a mutual indication of
interest and, in connection with this interest, the parties wish to explore a potential partnership
or other opportunity”. (Exhibit Q, Sec. 1). Confidential information was defined to be “any
nonpublic information that either party (the "Disclosing Party") discloses to the other party
("Receiving Party"), either directly or indirectly, in writing, orally, or by inspection of tangible
objects (including without limitation documents, prototypes, samples, plants, and equipment),
and designates as confidential or that under the circumstances surrounding disclosure ought to
2
LegalZoom’s CEO wrote to Trademarkia’s CEO on November 7, 2011: “But to be clear, we
are exploring a partnership up to and including acquisition.” In addition, that same day,
LegalZoom CFO Fred Krupica wrote “The LZ team is excited to meet and discuss the
opportunities between our companies” and “We trust that things go well tomorrow and that both
Raj and John decide to take it to the next level at which we would discuss terms, price, etc.”
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INITIAL COMPLAINT
be treated as confidential by the Receiving Party.”
36. Section 3 of the NDA required that each party:
“agrees not to:
(i) use any Confidential Information of the other party for any purpose except to evaluate
and engage in discussions concerning a potential business relationship between the
parties;
(ii) disclose any Confidential Information of the other party to third parties or to its own
employees and consultants, except employees and consultants who need the Information
to evaluate or engage in discussions about the contemplated business relationship; or
(iii) reverse engineer, disassemble. or decompile any prototypes, software, or other
tangible objects that embody the other party's Confidential Information and that are
provided to the party hereunder.” (Exhibit Q, Sec. 3) (emphasis added).
37. The term of the NDA was explained in Section 7 to “survive until the earlier of (i) such
time as all Confidential Information of the other party disclosed hereunder becomes publicly
known and generally available through no action or inaction (ii) the third anniversary of the
disclosure; provided, however, to the extent the extent that a party has disclosed information to
the other party that constitutes a trade secret under law, the Receiving Party shall protect such
trade secret(s) for as long as the information qualifies as a trade secret under applicable law.”
(Exhibit Q, Sec. 7).
38. In Section 8 of the NDA, the parties agreed that “Nothing in this Agreement is intended
to grant any rights to either party under any patent, mark, work right, copyright, trade secret,
or other intellectual property right of the other party.” (Exhibit Q, Sec. 7).
39. The same Section 8 of the NDA goes on to say “Each party agrees that any violation or
threatened violation or this Agreement may cause irreparable injury to the other party, entitling
the other party, without waiving any other rights or remedies and without posting a bond or
other security, to seek injunctive relief in addition to all legal remedies” (Exhibit Q, Sec. 8) and
that the parties agree to waive trial by jury and laws of the State of California shall apply.
40. Signatories of the NDA were John Suh, Chief Executive Officer for LegalZoom (who
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also initialed on the lower right of the page) and Raj Abhyanker, the CEO of Trademarkia, Inc.
(former business name of the plaintiff entity LegalForce, Inc.), as shown below:
(Exhibit Q)
41. On the very same day of Wednesday November 16, 2011 that the NDA with
Trademarkia was executed by John Suh, the CEO of LegalZoom, Trademarkia provided
confidential information to LegalZoom in an email at 11:25AM on Wednesday November 16,
2011 (Exhibit N) along with two confidential screenshots having licensing amounts of
$120,000 a month and $45,000 a month printed on the top cover of each mockup user interfaces
respectively (Exhibit O and Exhibit P)
42. Specifically, Trademarkia provided user interface mockups to LegalZoom senior
executives via email demonstrating what the Trademarkia website might look like if it were
rebranded as “LegalZoom Trademarkia” with an offer price of $120,000 per month in
licensing that paired combination. The email was sent to numerous members of LegalZoom’s
senior leadership including CEO John Suh, CFO Fred Krupica, General Counsel Chas
Rampenthal, VP of Attorney Services Carter Gaffney, VP of Operations Adam Thomas,
co-founder Brian Liu and others. Along with the user interface designs emailed as attachments,
Raj Abhyanker, CEO of Trademarkia wrote that day to LegalZoom’s senior management the
following on the same morning the NDA was signed by LegalZoom’s CEO :
John,
Great! ps.. Imagine.. see attached. 18 million unique visitors and more than
36 million page views a year seeing the Legalzoom brand this way.
Trademarkia now drives more than 1.5 million unique visitors and 3 million
page views. While our traffic is mostly organic, it is not diluted like Docstoc.
Mostly businesses and entrepreneurs click on Trademarkia pages, as they are
interested in a brands, trademarks, and/or products.
Our organic audience is mostly small businesses that need a lot of the services
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that Legalzoom offers. Also, with this, even more than 50% of Americans will
know the Legalzoom brand very soon! In addition, the branding should pay
for itself through increased $ sales. If you check Alexa, Trademarkia traffic
today reached 6,315 (8,700 overall worldwide and 3100 in the U.S.). By
branding LegalZoom on Trademarkia, the Legalzoom brand would be seen on
effectively twice as many pages as our traffic rankings are virtually equal now
according to Alexa. Trademarkia continues to grow very fast, and our traffic
now dwarfs Rocketlawyer, Logoworks, and we're a little bigger than even
Justia etc. We expect Trademarkia site traffic to double by this time next year
(many cool features in our pipeline!).
I've showed two options in the attached. Which one do you like?
Raj :) (Exhibit N).
43. The email was marked confidential with a note at the bottom of the email clearly stating
“This electronic transmission contains information which is confidential and/or privileged.”
(Exhibit N). In addition, to this email in Exhibit N on November 16, 2011, were attached two
screenshots as a single PDF attachment, one clearly showing a rough mockup “LegalZoom
Trademarkia” on the upper left as shown below and a price offered to LegalZoom of $120,000
per month printed on top of the mockup being offered to LegalZoom:
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Exhibit O
44. The email including the attachment above is being forensically preserved with a date
stamp from 2011 and is being produced to LegalZoom. And a second mockup showing
“Trademarkia LegalZoom” on the upper left as shown below, with a price offered to
LegalZoom of $45,000 per month:
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Exhibit P.
45. The emails and attachments above and attachments have been forensically preserved
with meta-data in tact showing date stamps from 2011 and are being produced by Trademarkia
to LegalZoom’s counsel through an outside e-discovery vendor. LegalZoom decided not to
advertise on the Trademarkia.com website and brand it through the LEGALZOOM
TRADEMARKIA branding at $120,000 per month. Thinking that Trademarkia’s trademark
licensing requirements at $120,000 per month were too high for LegalZoom, LegalZoom broke
off trademark licensing over the TRADEMARKIA Marks on December 11, 2011. Trademarkia
has therefore suffered expectation damages of $120,000 per month for all relevant time periods
for the licensing of the TRADEMARKIA Marks.
46. Less than six months later, on or about June 8, 2012, LegalZoom purchased the
abandoned domain name LegalZoomTrademarkia.com but did not use it. A couple of years
later, on or about April 21, 2014, within the 3 year term of the NDA as explained in
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Section 7 commencing on November 16, 2011, LegalZoom began diverting traffic from
LegalZoomTrademarkia.com to its website LegalZoom.com. To hide its conduct, on or
about February 28, 2015, LegalZoom implemented GoDaddy’s WHOIS privacy guard service
to hide its ownership of this domain from public view by paying a separate fee to a company
called DomainsByProxy LLC.
47. Only after being caught around June 2018 did LegalZoom stop diverting web traffic
from LegalZoomTrademarkia.com to LegalZoom.com and hiding its identity as an owner
through privacy guard. Therefore any statutory limitations should be tolled given that
LegalZoom took affirmative steps to surreptitiously conceal their ownership of the Disputed
Domain to conceal their trademark infringement scheme. (Exhibit A). Therefore, Trademarkia
could not have reasonably known about LegalZoom’s scheme of using its LegalZoom Affiliate
program to infringe the TRADEMARKIA Marks between 2015 and 2018 without forensics
discovery, which would be outside the scope of a normal course of business operations.
C. LegalZoom’s Breach of the NDA and Infringement of Trademarkia’s trademark
rights.
48. LegalZoomTrademarkia provided to LegalZoom a confidential offer of $120,000 to
license the TRADEMARKIA Marks for the benefit of LegalZoom (Exhibit N, Exhibit O,
Exhibit P). LegalZoom breached key provisions of the NDA. Specifically, LegalZoom
breached Section 3(i) of the NDA by using the Confidential Information of Trademarkia for
purposes other than “to evaluate and engage in discussions concerning a potential business
relationship” (Exhibit Q, Sec. 3(i)). In addition, LegalZoom did in fact “reverse engineer”,
“disassemble” , and “decompile” the “prototype” mockups provided to them in violation of the
NDA (Exhibit Q, Sec. 3(iii)) by first purchasing, and then encouraging hundreds of their
affiliates to advertise the literal characters of the TRADEMARKIA Marks through the express
characters of the Disputed Domain in an effort to create confusion in the marketplace as to the
source and origin of Plaintiff’s products and services.
49. Moreover, in bad faith to further demonstrate LegalZoom’s callous disregard for
Trademarkia’s intellectual property rights, LegalZoom aggressively encouraged small
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INITIAL COMPLAINT
businesses in their LegalZoom Affiliate program to infringe on Trademarkia’s trademark rights
by distributing to dozens if not hundreds of Publishers as email ads, text ads, display ads, and
more. Under the NDA, LegalZoom had no rights to the “mark, work right, copyright, trade
secret, or other intellectual property” of Trademarkia including with respect to incorporating
the TRADEMARKIA marks in domain names and related ad network advertising. (Exhibit Q,
Sec. 8).
D. Trademarkia’s Efforts of Achieving Fame in TRADEMARKIA Marks.
50. Trademarkia was founded in 2009. The Trademarkia website, available at
www.trademarkia.com, went live on or about September 15, 2009.
51. Since that time, Trademarkia has served approximately 50,000,000 (fifty million)
visitors throughout the United States, and has assisted more than 100,000 (one-hundred
thousand) small business owners in the search and monitoring of their trademark applications
from more than 80 countries. In 2017 alone, Trademarkia users placed over 10,000 orders on or
through the website.
52. Trademarkia is cited as a trusted source for corporate history and branding in at least
700 Wikipedia pages for leading brands including Disney, Samsung, Coca Cola,
Anheuser-Busch, Tesla, Kleenex, Dreamworks and hundreds of iconic brands.
53. As a result of Trademarkia’s efforts and expenditures, the TRADEMARKIA Marks
have become widely recognized by the general public of the United States as a trusted leading
news source for any new trademarks filed by celebrities, sports teams, musicians, politicians, or
big corporations.
54. Almost from Trademarkia’s inception, the TRADEMARKIA Marks have been featured
and discussed in publications and on television programs and Internet websites all over the
United States, including but not limited to on Bloomberg, FastCompany, Fox Business, New
York Times, TechCrunch, FORBES, CNBC, The World Trademark Review, TIME Magazine /
Fortune, CNN, Wall Street Journal, Washington Post, and in the ABA Journal.
55. For nearly a decade, Trademarkia has advertised extensively over the Internet and other
advertising channels. It advertises in markets throughout the country, including large consumer
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INITIAL COMPLAINT
markets such as Boston, New York, Chicago, San Francisco and Los Angeles.
56. The Trademarkia website generates hundreds of thousands of hits per week. The
TRADEMARKIA Marks are prominently displayed on Trademarkia webpages.
57. Trademarkia has achieved fame and recognition for its TRADEMARKIA Marks
through the following innovations:
○ Docketing system. Trademarkia has aggregated trademark data from nearly a dozen
countries and indexes tens of millions of trademarks daily for updates. It has become a
“docketing system” for the world, enabling, for free, thousands of entrepreneurs to be
kept up to date on deadlines for trademarks, oppositions, renewals and more. Previously,
access to such tools were reserved for wealthy corporations with access to sophisticated
tools from LexisNexis, Thomson Reuters, and others. Trademarkia has made these tools
free to the world.
○ Search Technology. Trademarkia has helped to answer the basic question that many
entrepreneurs have, which is “is my business name available to trademark”, by making a
knockout search from its databases of millions of trademarks, refreshed daily, freely
accessible from its home page, through a search engine-like search box with little
commercial advertising on its home page. As a result, Trademarkia now attracts over 23.2
million page views and approximately 9.4 million visitors to Trademarkia.com each year,
making it one of the Internet’s largest legal-oriented websites.
○ Competitive and Breaking News. Trademarkia automatically publishes free alerts for
millions of trademarks in various countries making it a leading and primary news source
for breaking business news whenever new products are soon to be released and whenever
new marketing campaigns launch across the world.
○ Catalog of American ingenuity and corporate history. Trademarkia was the first to
publicly index trademark data as old as the year 1872, making it a deep and rich
repository of American history and corporate evolution. As a result, Trademarkia is cited
as a trusted source for corporate history and branding in at least 750 Wikipedia pages for
leading brands including Coca Cola, Budweiser, Kellogg, and hundreds of iconic brands.
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INITIAL COMPLAINT
○ Innovative logo search engine. Trademarkia has built what is the Internet’s largest logo
search engine based on design code identification of trademarks, spanning over 4 million
logos that can be deeply searched by “what is inside” each logo for creative inspiration
and brand development, free of charge. As a result, thousands of branding agencies and
entrepreneurs use Trademarkia.com each month to find and discover new inspiration for
their brands.
○ Keeping trademark bullies accountable. Trademarkia has built what is the Internet’s first
catalog of large company trademark bullies, hecklers, and their victims based on the
number of trademarks they oppose, threaten to oppose, and are challenged by, through its
annual rankings of those companies that actively overextend their trademark rights. This
data is offered for free through automated annual rankings based on government data and
published annually by Trademarkia.
○ Reducing infringement of trademarks when registering domains. Trademarkia has built
the world’s first domain registration service for small businesses that automatically
checks for availability of trademark rights when registering domains, to assist in reducing
cyber-piracy claims and reducing wasteful state litigation, free of charge.
○ Global automated trademark docketing reports. Trademarkia has built automated and
semi-automated trademark reports for most of the 100+ countries through which
Trademarkia offers trademark filings. As a result, companies and entrepreneurs around
the world can uniquely and centrally harmonize trademark portfolio management and
access global trademark protection markets through a single website.
○ Trademark opposition window tracking. Trademarkia has enabled small businesses to
easily track their 30-day opposition window for trademarks filed with the USPTO in real
time through its free opposition watch service. Prior to Trademarkia, such tools were
reserved for rich corporations using expensive enterprise software by companies such as
Thomson Reuters, Wolters Kluwer, and LexisNexis.
○ Bifurcated Supply Chain Management. Trademarkia applied best manufacturing practices
to legal services by taking all non-attorney work off of attorneys’ plates and globalizing it
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INITIAL COMPLAINT
to improve quality while reducing costs.
58. The TRADEMARKIA Marks were enormously famous and distinctive at the time of
LegalZoom’s first infringing use in 2014, and continues to be through this day. Prior to
LegalZoom’s first use of the TRADEMARKIA Marks, thousands of social media posts and
tweets on Facebook and Twitter mentioned Trademarkia website in popular culture and fashion
as the source for leading brand information.
59. Trademarkia had become a leading news indicator, often cited by major media and
television as a source for breaking news prior to 2014 because it was the first to index USPTO’s
trademark records through static URLs and breadcrumbs structure. Through this technique,
Trademarkia transformed the status changes of trademark applications into breaking news
across all markets.
60. Before any new movie, book or song is released, the owner invariably secures brand
rights to the movie name through trademark protection. Fans may gravitate toward movies of
their favorite actors, studios, and sequels. The information of such newly filed trademark
applications are therefore newsworthy and such information associated with status changes is
automatically watched and monitored by Trademarkia. Thus, status changes of trademark
applications in real time can be transformed into national or international breaking news
because, for example, the general public would want to know beforehand the name of the next
Star Wars® movie. Because Trademarkia is the first to disseminate such news to the fans and
the consuming public, the TRADEMARKIA Marks have achieved widespread fame across the
United States and internationally.
61. The TRADEMARKIA Marks achieved this widespread fame across the United States,
and across many different industries and popular culture - for many years before LegalZoom’s
first infringing use. Trademarkia had become among the largest websites in the United States,
having website traffic approaching some of the largest websites on the Internet by 2014, and has
attracted millions of page views and unique visitors to its Trademarkia.com website in the years
prior.
62. The TRADEMARKIA Marks are of material importance to Trademarkia. Trademarkia
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has used the TRADEMARKIA Marks continuously for nearly a decade and has spent a large
amount of money promoting those marks.
63. Because of the invaluable goodwill that the TRADEMARKIA Marks represent, and its
importance to the company, Trademarkia aggressively protects the TRADEMARKIA Marks.
FIRST CLAIM FOR RELIEF
BREACH OF CONTRACT AND IMPLIED COVENANT OF
GOOD FAITH AND FAIR DEALING
64. Trademarkias hereby incorporate each and every paragraph set forth above as though
fully set forth at this place.
65. Trademarkia and LegalZoom formed a legally binding contract titled Mutual
Nondisclosure Agreement (“NDA”) on November 16, 2011.
66. Trademarkia provided to LegalZoom a confidential offer of $120,000 to license the
TRADEMARKIA Marks for the benefit of LegalZoom.
67. Thinking that Trademarkia’s trademark licensing requirements at $120,000 per month
were too high for LegalZoom, LegalZoom broke off trademark licensing over the
TRADEMARKIA Marks on December 11, 2011.
68. Plaintiff’s marks TRADEMARKIA and LEGALFORCE are valid, protectable
trademarks that are registered on the principal register at the USPTO. Plaintiff’s trademark
application for the mark LEGALFORCE TRADEMARKIA is registered at the USPTO. The
mark’s first use in commerce date is April 13, 2012.
69. A few months months later, on or about June 8, 2012, LegalZoom breached the NDA by
purchasing the abandoned domain name LegalZoomTrademarkia.com but did not use it.
70. A couple of years later, on or about April 21, 2014, within the 3 year term of the NDA
as explained in Section 7 commencing on November 16, 2011, LegalZoom began diverting
traffic from LegalZoomTrademarkia.com to its website LegalZoom.com.
71. LegalZoom breached key provisions of the NDA including Section 3(i) and Section
3(iii) by first purchasing, and then encouraging hundreds of their affiliates to advertise the
literal characters of the TRADEMARKIA Marks through the express characters of the Disputed
Domain in an effort to create confusion in the marketplace as to the source and origin of
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INITIAL COMPLAINT
Plaintiff’s products and services.
72. Trademarkia has therefore suffered expectation damages of $120,000 per month for all
relevant time periods for the licensing of the TRADEMARKIA Marks.
secret, or other intellectual property” of Trademarkia including with respect to incorporating
the TRADEMARKIA marks in domain names and related ad network advertising.
74. LegalZoom’s use of the TRADEMARKIA Marks as a domain name to identify
LegalZoom’s website in a manner that is likely to cause confusion and/or mistake among
internet users as to the source or sponsorship of Plaintiff’s services constitute trademark
infringement.
75. Trademarkia first discovered LegalZoom’s infringing use in April 2018. Trademarkia
could not have discovered the alleged misconduct sooner given the great lengths LegalZoom
went through to hide and mask its ownership of the Disputed Domain through privacy guard.
The ownership only became known to Trademarkia when counsel stumbled upon it through
complex forensics analysis of LegalZoom’s activities when researching for LegalZoom’s false
and misleading advertising and unfair competition violations in April 2018.
76. Trademarkia has lost significant asset value as a direct result of LegalZoom’s
infringement and deployment of the Disputed Domain. As a result of LegalZoom’s infringing
use of the TRADEMARKIA Marks, Trademarkia’s user count has shrunk to by -75.87% of its
former self after the Disputed Domain was advertised and promoted by LegalZoom, while
LegalZoom’s traffic has increased 234.54% from its former after the Disputed Domain was
advertised and promoted by LegalZoom.
month to Trademarkia.com). Based on the reported estimate 12% to 29% of all web traffic
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being direct brand traffic, between 143,394 users (12%) and 346,537 (29%) fewer users come to
the Trademarkia.com website as a direct result of the brand confusion created by LegalZoom
through the Disputed Domain.
78. Trademarkia’s loss as a result of LegalZoom’s surreptitious acts in infringing and
misdirecting traffic using the TRADEMARKIA Marks has been LegalZoom’s gain. In fact, as
of April 8, 2012, when Trademarkia and LegalZoom had just recently signed the NDA, the total
web traffic of Trademarkia was roughly the same as the web traffic of LegalZoom. As of April
8, 2012, based on Amazon’s Alexa.com web ranking analytics Trademarkia.com was the
9.275th largest website on the Internet based on the last 7 day average, and LegalZoom was
roughly equivalent in traffic and ranking.
79. Dramatically, as of May 21, 2019, based on Amazon’s Alexa.com web ranking analytics
infringing use of the TRADEMARKIA Marks in the Disputed Domain to confuse the public.
81. LegalZoom’s infringing use also has created actual confusion from customers of
Trademarkia. Steve Hidalgo, Customer Service Manager employed full time by Trademarkia,
states that he and other employees have spoken with numerous customers confused between
LEGALZOOM and LEGALFORCE TRADEMARKIA. Moreover, Hidalgo believes that
Trademarkia has lost sales because of this confusion, and that numerous Trademarkia customers
have actually been confused.
82. Linguist expert Ronald R. Butters, Professor Emeritus of English at Duke University,
believes that a reasonable person is “highly likely to be linguistically confused as to the source
and origin of LEGALZOOMTRADEMARKIA and LEGALFORCETRADEMARKIA.” It is a
well-known psycholinguistic fact that the beginnings and endings of words and phrases are of
paramount importance in distinguishing them one from another. For this reason alone, the
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INITIAL COMPLAINT
potential for linguistic confusion between the two is great: a reasonable consumer will note
LEGAL at the beginning of the marks and TRADEMARKIA at the end ... and focus little or no
attention on the one-syllable nouns zoom and force that are buried in between, as shown below:
LEGALZOOMTRADEMARKIA
LEGALFORCETRADEMARKIA
83. Consumers saw LegalZoom’s homepage LegalZoom.com when accessing
LegalZoomTrademarkia.com from 2014 through June 2018, after the related lawsuit between
the parties was filed. LegalZoom’s light-and-dark-blue logo, “legalzoom®”, was prominently
shown on the top of its homepage after users were directed to LegalZoom.com after typing
LegalZoomTrademarkia.com as the requested URL on their browsers. Since many of
Trademarkia’s customers know the TRADEMARKIA marks, it is likely that some users
directly typed the characters “www.legalforcetrademarkia.com” in the destination address bar of
their browsers without first doing a search in Google, Bing, or any search engine at all.
Tellingly, a study in 2014 suggests that 12% to 29% of all traffic to e-commerce websites like
Trademarkia.com and LegalZoom.com comes from “direct visits” based on word of mouth,
memory, face-to-face referrals, and brand identity without using any search engine (Exhibit
M).
84. In a web browser, the address bar (also location bar or URL bar) is a graphical control
element that shows the current URL. The user can type a URL into the bar to navigate to a
chosen website. Many address bars offer features like autocomplete and a list of suggestions
while the address is being typed in. This auto-completion feature bases its suggestions on the
browser's history. Some browsers have keyboard shortcuts to auto-complete an address. These
are generally configured by the user on a case-by-case basis. Address bars have been a feature
of web browsers since NCSA Mosaic, and continue through to modern browsers including
Google Chrome, Microsoft Edge, Mozilla FireFox, and others.
85. This creates even more likelihood of confusion to the consumers. Consumers are well
aware that competing providers of goods and services often buy and sell each other, such as
Amazon acquiring Whole Foods or JP Morgan merging with Chase. By placing the term
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INITIAL COMPLAINT
“LegalZoom” in front of the mark “Trademarkia”, Defendant exerted false dominion over the
Plaintiff through which a reasonable consumer would believe that LegalZoom has acquired or
merged with Trademarkia, or that LegalZoom and Trademarkia are affiliated.
86. Trademarkia extensively advertised the TRADEMARKIA Marks for the relevant time
period between 2014 and through today. Millions of Trademarkia’s users and thousands of
Trademarkia customers know Trademarkia’s services by these marks and they search the
TRADEMARKIA Marks online to reach Trademarkia’s website. Because of the demonstrated
confusion between LEGALZOOMTRADEMARKIA and LEGALFORCETRADEMARKIA,
also because LegalZoom and Trademarkia are competitors and advertise on the same
advertising platforms (e.g., Google, Bing, etc.), a consumer searching for
LegalForceTrademarkia would end up getting onto LegalZoomTrademarkia.com website,
which leads to LegalZoom.com.
87. Furthermore, because of the demonstrated confusion above and the fact that LegalZoom
and Trademarkia are in direct competition, a consumer trying to type
“legalforcetrademarkia.com” on his or her internet browser may end up typing
“legalzoomtrademarkia.com” by mistake, which leads to LegalZoom.com.
88. LegalZoom’s homepage or the various landing pages of the redirection (see Exhibit A,
Domain Tools Report) has no disclaimer which clearly labels that the website is not the website
of Trademarkia, or that the website has no association with Trademarkia, or that Trademarkia is
not acquired by or not part of LegalZoom.
89. Trademarkia is the sole and exclusive owner of the TRADEMARKIA Marks. It has
overseen, controlled, and directed goods and services marketed, advertised, promoted, and sold
under the TRADEMARKIA Marks.
90. Trademarkia has priority of use in commerce for the TRADEMARKIA Marks over
LegalZoom.
91. LegalZoom’s infringing use as alleged herein was done without the authorization or
consent of Trademarkia.
92. LegalZoom also actually advertised and promoted the Disputed Domain in commerce by
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INITIAL COMPLAINT
xhibit B.
including the Disputed Domain in its LegalZoom Affiliate program. See E
93. Such use is likely to cause initial interest confusion of consumers who are in fact
searching solely for Trademarkia and/or Trademarkia registered trademarks and is highly likely
to cause confusion, mistake and deception among the general public as to the origin of
LegalZoom’s goods and services and/or as to the sponsorship by, affiliation with, and/or
connection to Trademarkia.
94. By using Trademarkia’s registered trademarks, and by selling, offering for sale,
distributing, or advertising goods and services to the general public in connection with
Trademarkia’s registered trademarks, for profit, LegalZoom has caused and, unless enjoined by
this Court, will continue to cause a likelihood of confusion and deception of members of the
public, and additional injury to Trademarkia’s exclusive right to control, and benefit from, its
registered trademarks, as well as Trademarkia’s goodwill and reputation as symbolized by the
TRADEMARKIA Marks.
95. LegalZoom’s conduct demonstrates an intentional, willful, and malicious intent to trade
on the goodwill associated with Trademarkia’s registered trademarks to Trademarkia’s great
and irreparable injury.
96. LegalZoom has caused and is likely to continue causing substantial injury to the public
and to Trademarkia, and Trademarkia is entitled to injunctive relief and to recover all damages
sustained as a result of LegalZoom’s infringing conduct, including but not limited to
LegalZoom’s profits, Trademarkia’s actual damages, enhanced profits, treble damages, statutory
damages, costs and reasonable attorneys' fees.
97. To hide its conduct, on or about February 28, 2015, LegalZoom implemented
GoDaddy’s WHOIS privacy guard service to hide its ownership of this domain from public
view by paying a separate fee to a company called DomainsByProxy LLC.
98. By employing GoDaddy’s WHOIS privacy guard service, LegalZoom breached the
NDA and covenant of good faith and fair dealing that is implied in all contracts by attempting to
surreptitiously conceal its conduct by engaging in conduct involving dishonesty, fraud, deceit,
or reckless or intentional misrepresentation.
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INITIAL COMPLAINT
99. LegalZoom further breached the NDA by knowingly making false representations to
Trademarkia during negotiations that it had a bona fide intent to license the TRADEMARKIA
Marks, intentionally withholding material information, and violating their ethical duties, all in
an effort to deceive the Trademarkia.
100. Trademarkia has suffered consequential damages incurred in lost time, attorney’s
fees, and expenses in uncovering misconduct.
SECOND CLAIM FOR RELIEF
FRAUD
101. Trademarkia repeats each and every allegation contained in the paragraphs above
and incorporate by reference each preceding paragraph as though fully set forth herein.
102. In California, a claim of fraud requires an intentional misrepresentation, deceit, or
concealment of a material fact known to the defendant with the intention on the part of the
defendant of thereby depriving a person of property or legal rights or otherwise causing injury
under Civil Code 3294.
103. Here, LegalZoom misrepresented a material fact that it had a bona fide intent to
license the TRADEMARKIA Marks, while just months later taking actions to breach the NDA
and engage in conduct involving dishonesty by later including the Disputed Domain in the
LegalZoom Affiliate program and redirecting traffic surreptitiously by hiding its ownership of
the domain through GoDaddy’s Privacy Guard. Instead, Trademarkia allege for the reasons
stated herein that LegalZoom falsified its interest in licensing the TRADEMARKIA Marks and
partnering with Trademarkia with the specific intent to steal trade secrets fromTrademarkia.
104. Trademarkia suffered consequential damages incurred in lost time and expenses in
uncovering LegalZoom misconduct, in an amount to be proven at trial.
105. Trademarkia prays for extraordinary relief and exemplary damages, including
denying the fee in its entirety as well as punitive damages against LegalZoom.
106. Trademarkia has suffered consequential damages incurred in lost time, attorney’s
107. Defendant used the TRADEMARKIA Marks in connection with the sale and
advertising of services in a manner that is likely to cause confusion, mistake, and/or deception
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INITIAL COMPLAINT
among consumers as to the affiliation, connection, or association of LegalZoom with
Trademarkia, or as to the origin, sponsorship, or approval of LegalZoom’s products and services
by Trademarkia.
108. LegalZoom’s infringing use was intentional because LegalZoom attempts to profit
from the Disputed Domain by appending query strings to the domain forwarding URL so that it
can keep track of how much traffic actually comes from the LegalZoomTrademarkia.com
website.
109. LegalZoom’s adoption and use of the TRADEMARKIA Marks has been made
notwithstanding Trademarkia’s well-known rights in the famous TRADEMARKIA Marks and
with both actual and constructive notice of Trademarkia’s federal registration rights.
110. Displaying LegalZoom’s homepage with “legalzoom®” symbol when user accessing
web link having the TRADEMARKIA Marks is misrepresentation and is likely to cause
confusion or mistake, or to deceive as to the affiliation, connection or association of the
Disputed Domain website with Trademarkia, or as to the origin, sponsorship, or approval by
Trademarkia.
111. LegalZoom was aware of the Plaintiff’s marks and reputation before engaging in its
conduct as alleged herein. LegalZoom deliberately redirected its website
LegalZoomTrademarkia.com to its home page and included false claims of its connection to the
Trademarkia.com website, for the purpose of defrauding the Plaintiff, misappropriating its
substantial goodwill, and causing confusion, mistake and deception among Internet users and
the public.
112. As a direct and proximate result of Defendant's infringing activities, Trademarkia
has suffered irreparable injury to Trademarkia 's business, reputation, and goodwill in its
federally registered TRADEMARKIA Marks for the following reasons: (A) Trademarkia has
been threatened with harm because customers seeking for services offered by Trademarkia, such
as trademark watch services and trademark search services have been misdirected to
LegalZoom.com’s homepage which offers similar services for years, up through June 18, 2018.
(B) the threatened harm continues to this day, as when users go to LegalZoomTrademarkia.com
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INITIAL COMPLAINT
as of the filing of this First Amended Complaint, they see a message indicating that the domain
may be available (e.g., implying available for purchase) and that the “website coming soon!”
(See Exhibit C). (C) Upon information and belief, LegalZoom continues to own the domain
back to Legalzoom.com (See updated Exhibit A); and, (D) Trademarkia suffered lost revenue
and market share, reduced asset value and increased advertising costs of unknown value
because Trademarkia’s brand has now been indistinguishably mixed with that of its
THIRD CLAIM FOR RELIEF
CONSTRUCTIVE FRAUD
114. In California, any breach of duty which, without an actually fraudulent intent, gains
an advantage to the person in fault, or any one claiming under him, by misleading another to his
prejudice, or to the prejudice of any one claiming under him; or, in any such act or omission as
the law specially declares to be fraudulent, without respect to actual fraud under Civil Code
1573.
115. Here, LegalZoom misrepresented a material fact that the Ledger was created based
on contemporaneous records and was an accurate reflection of attorney’s fees and costs
incurred. Instead, Trademarkia allege for the reasons stated herein that LegalZoom
manufactured the Ledger for the specific intent to deceive the Trademarkia.
116. Trademarkia pray for extraordinary relief and exemplary damages, including
denying the fee in its entirety as well as punitive damages against LegalZoom.
117. Trademarkia have suffered consequential damages incurred in lost time, attorney’s
FOURTH CLAIM FOR RELIEF
CIVIL CONSPIRACY
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INITIAL COMPLAINT
119. Upon information and belief, LegalZoom conspired with Pepperjam to defraud and
attempted to defraud the Trademarkia by making false representations of material facts and
omissions of material facts when negotiating a license of the TRADEMARKIA Marks and
partnership opportunities.
120. Upon information and belief, the purpose of their misconduct was to cause the
Trademarkia to falsely believe that LegalZoom had a bonafide interest in working with
Trademarkia.
121. The Trademarkia has incurred significant damages, amount which will be proven at
the arbitration hearing, as well as significant attorney’s fees caused by LegalZoom’s civil
conspiracy to defraud the Trademarkia.
122. Trademarkia damages include financial loss as well as loss of goodwill, the amount
of which will be proven at trial..
REQUEST FOR RELIEF
WHEREFORE, Plaintiff requests that this Court enter judgment against LegalZoom as
follows:
A. Trademarkia seeks damages under contract theory, quasi contract theory and under
common law caused by LegalZoom’s bad faith conduct in failing to pay to advertise the
branding LEGALZOOM TRADEMARKIA for $120,000 per month for each month
following November 2011 and continuing to this day, compensatory damages and
punitive damages in this case. The damage period should be the entire period between
April 2014 (when LegalZoom started infringing the TRADEMARKIA Marks through the
disputed domain) and June 2018 (when LegalZoom ceased infringing the
TRADEMARKIA Marks) (entire period of 51 months or a total of $6,120,000);
B. Trademarkia seeks damages of lost profits estimated to be over $150,000 directly
attributable to LegalZoom’s use of the Disputed Domain;
C. Award Plaintiff pre- and post-judgment interest at the applicable rates on all amounts
awarded;
D. That the Court grant Trademarkia any other remedy to which it may be entitled under
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INITIAL COMPLAINT
state laws; and
E. Order any other such relief as the Court deems appropriate.
Respectfully submitted this Friday, March 22, 2019.
LEGALFORCE RAPC WORLDWIDE P.C.
By__/s/ Raj V. Abhyanker______

Raj V. Abhyanker
California State Bar No. 233,284
Attorney for Plaintiff:
LegalForce, Inc.
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INITIAL COMPLAINT
EXHIBIT A
Domain Report
LegalZoomtRademarkIa.com
Domain Name LegalZoomtRademarkIa.com

Prepared On March 18, 2019
Website Screenshot taken 03/27/2017

About This Report
This report documents a thorough analysis of the Internet domain name
"LegalZoomtRademarkIa.com". It draws on the extensive DomainTools dataset and aims to
deliver a comprehensive view of the domain's ownership profile, key historical events and
technically linked domain names.
All data in this Report is, or was, freely available through standard Internet DNS and query
protocols. DomainTools has not altered the data in any way from its original form, except in
certain instances to format it for readability in this Report.
Data from DomainTools is presented as-is, and as captured from the original source. We make
no representations or warranties of fitness of any kind.
About DomainTools
DomainTools offers the most comprehensive searchable database of domain name registration
and hosting data. Combined with our other data sites such as DailyChanges.com,
Screenshots.com and ReverseMX.com, users of DomainTools.com can review millions of
historical domain name records from basic Whois, and DNS information, to homepage images
and email settings. The Company's comprehensive snapshots of past and present domain name
registration, ownership and usage data, in addition to powerful research and monitoring
resources, help customers by unlocking everything there is to know about a domain name.
DomainTools is a Top 250 site in the Alexa rankings.
Reach us at memberservices@domaintools.com if you have any questions on this report.
LegalZoomtRademarkIa.com © 2019 DomainTools, LLC All Rights Reserved 2

Domain Profile
As of March 18, 2019
Ownership
Registered Owner Domains By Proxy, LLC
Owned Domains About 17124519 other domains
Email Addresses abuse@godaddy.com
legalzoomtrademarkia.com@domainsbyproxy.com
Registrar godaddy.com, llc
Registration
Created Jun 8, 2012
Expires Jun 8, 2021
Updated Mar 13, 2019
Domain Status Parked
Whois Server whois.godaddy.com
Name Servers domaincontrol.com
Network
Website IP Address 184.168.221.58
IP Location United States-Arizona-Scottsdale
Godaddy.Com Llc
IP ASN AS26496

Current Whois Record
Reported on Mar 18, 2019
Domain Name: LEGALZOOMTRADEMARKIA.COM
Registry Domain ID: 1725983466_DOMAIN_COM-VRSN
Registrar WHOIS Server: whois.godaddy.com
Registrar URL: http://www.godaddy.com
Updated Date: 2019-03-13T15:38:28Z
Creation Date: 2012-06-08T13:54:47Z
Registrar Registration Expiration Date: 2021-06-08T13:54:47Z
Registrar: GoDaddy.com, LLC
Registrar IANA ID: 146
Registrar Abuse Contact Email: abuse@godaddy.com
Registrar Abuse Contact Phone: +1.4806242505
Domain Status: clientTransferProhibited http://www.icann.org/epp#clientTransferProhibited
Domain Status: clientUpdateProhibited http://www.icann.org/epp#clientUpdateProhibited
Domain Status: clientRenewProhibited http://www.icann.org/epp#clientRenewProhibited
Domain Status: clientDeleteProhibited http://www.icann.org/epp#clientDeleteProhibited
Registry Registrant ID: Not Available From Registry
Registrant Name: Registration Private
Registrant Organization: Domains By Proxy, LLC
Registrant Street: DomainsByProxy.com
Registrant Street: 14455 N. Hayden Road
Registrant City: Scottsdale
Registrant State/Province: Arizona
Registrant Postal Code: 85260
Registrant Country: US
Registrant Phone: +1.4806242599
Registrant Phone Ext:
Registrant Fax: +1.4806242598
Registrant Fax Ext:
Registrant Email: LEGALZOOMTRADEMARKIA.COM@domainsbyproxy.com
Registry Admin ID: Not Available From Registry
Admin Name: Registration Private
Admin Organization: Domains By Proxy, LLC
Admin Street: DomainsByProxy.com
Admin Street: 14455 N. Hayden Road
Admin City: Scottsdale
Admin State/Province: Arizona
Admin Postal Code: 85260
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Admin Email: LEGALZOOMTRADEMARKIA.COM@domainsbyproxy.com
Registry Tech ID: Not Available From Registry
Tech Name: Registration Private
Tech Organization: Domains By Proxy, LLC
Tech Street: DomainsByProxy.com
Tech Street: 14455 N. Hayden Road
Tech City: Scottsdale
Tech State/Province: Arizona
Tech Postal Code: 85260

Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
Tech Email: LEGALZOOMTRADEMARKIA.COM@domainsbyproxy.com
Name Server: NS65.DOMAINCONTROL.COM
DNSSEC: unsigned
URL of the ICANN WHOIS Data Problem Reporting System: http://wdprs.internic.net/

Ownership History
Whois History for LegalZoomtRademarkIa.com
DomainTools has 44 distinct historical ownership records for LegalZoomtRademarkIa.com. The
oldest record dates Feb 8, 2010. Each record is listed on its own page, starting with the most
recent record. The date at the start of the section indicates the first time we captured the record.
The website screenshot, when available, will be the image captured as close as possible to the
record date.
About Whois History

DomainTools takes periodic snapshots of domain name Whois records and stores them for
subsequent analysis. The database contains billions of Whois records across hundreds of
millions of domains, dating back in some cases to 2001.

Whois Record on Dec 30, 2018
Updated Date: 2018-06-09T13:54:28Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Screenshot taken Mar 27, 2017
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Sep 22, 2018
Updated Date: 2018-06-09T13:54:28Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Jun 10, 2018
Updated Date: 2018-06-09T13:54:28Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Updated Date: 2017-01-19T19:39:04Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on May 31, 2018
Updated Date: 2017-01-19T19:39:04Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Updated Date: 2017-01-19T19:39:04Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Updated Date: 2017-01-19T19:39:04Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Apr 24, 2018
Updated Date: 2017-01-19T19:39:04Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

DNSSEC: unsigned
For complete domain details go to:

http://who.godaddy.com/whoischeck.aspx?domain=LEGALZOOMTRADEMARKIA.COM

Updated Date: 2017-01-19T19:39:04Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Updated Date: 2017-01-19T19:39:04Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Updated Date: 2017-01-19T19:39:04Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Mar 18, 2018
Updated Date: 2017-01-19T19:39:04Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Update Date: 2017-01-19T19:39:04Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Screenshot taken Jul 15, 2016
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Nov 16, 2016
Update Date: 2016-06-09T11:15:06Z
Registrant Street: 14747 N Northsight Blvd Suite 111, PMB 309
Registrant Fax Ext:
Admin Street: 14747 N Northsight Blvd Suite 111, PMB 309
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Street: 14747 N Northsight Blvd Suite 111, PMB 309
Tech Country: US
Screenshot taken Jul 15, 2016
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Update Date: 2016-06-09T11:15:06Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Screenshot taken Dec 2, 2015
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Update Date: 2015-02-26T17:52:43Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Update Date: 2015-02-26T17:52:43Z
Registrant Fax Ext:
Admin Country: US
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Tech Country: US
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Dec 8, 2015
Update Date: 2015-02-26T17:52:43Z
Registry Registrant ID:
Registrant Country: United States
Registrant Fax Ext:
Registry Admin ID:
Admin Country: United States
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Registry Tech ID:
Tech Country: United States
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Aug 24, 2015
Update Date: 2015-02-26T17:52:43Z
Registrant Fax Ext:
Registry Admin ID:
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Registry Tech ID:
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Update Date: 2015-02-26T17:52:43Z
Registrant Fax Ext:
Registry Admin ID:
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Registry Tech ID:
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Feb 28, 2015
Update Date: 2015-02-26T17:52:43Z
Screenshot taken Apr 3, 2014
Registrar Abuse Contact Phone: +1.480-624-2505
Registrant Fax Ext:
Registry Admin ID:
Admin Phone: +1.4806242599
Admin Phone Ext:
Admin Fax: +1.4806242598
Admin Fax Ext:
Registry Tech ID:
Tech Phone: +1.4806242599
Tech Phone Ext:
Tech Fax: +1.4806242598
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Jan 20, 2015
Update Date: 2014-06-02T16:19:09Z
Registrant Name: Domain Recovery
Registrant Organization: LegalZoom.com
Registrant Street: 101 N. Brand Blvd., 11th Floor
Registrant City: Glendale
Registrant State/Province: California
Registrant Fax:
Registrant Fax Ext:
Registrant Email: domainrecovery@citizenhawk.com
Registry Admin ID:
Admin Name: Domain Recovery
Admin Organization: CitizenHawk, Inc.
Admin Street: 27068 La Paz Road, Suite 104
Admin City: Aliso Viejo
Admin State/Province: California
Admin Phone: +1.9495259320
Admin Phone Ext:
Admin Fax:
Admin Fax Ext:
Admin Email: domainrecovery@citizenhawk.com
Registry Tech ID:
Tech Name: Domain Recovery
Tech Organization: CitizenHawk, Inc.
Tech Street: 27068 La Paz Road, Suite 104
Tech City: Aliso Viejo
Tech State/Province: California
Tech Phone: +1.9495259320
Tech Phone Ext:
Tech Fax:
Tech Fax Ext:
Tech Email: domainrecovery@citizenhawk.com
Name Server: NS1.A0F.NET
DNSSEC: unsigned

Whois Record on Nov 7, 2014
Update Date: 2014-06-02 11:19:09
Creation Date: 2012-06-08 08:54:47
Registrar Registration Expiration Date: 2015-06-08 08:54:47
Domain Status: clientTransferProhibited
Domain Status: clientUpdateProhibited
Domain Status: clientRenewProhibited
Domain Status: clientDeleteProhibited
Registrant Fax:
Registrant Fax Ext:
Registry Admin ID:
Admin Phone: +1.9495259320
Admin Phone Ext:
Admin Fax:
Admin Fax Ext:
Registry Tech ID:
Tech Phone: +1.9495259320
Tech Phone Ext:
Tech Fax:
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Aug 20, 2014
Update Date: 2014-06-02 11:19:09
Creation Date: 2012-06-08 08:54:47
Registrant Fax:
Registrant Fax Ext:
Registry Admin ID:
Admin Phone: +1.9495259320
Admin Phone Ext:
Admin Fax:
Admin Fax Ext:
Registry Tech ID:
Tech Phone: +1.9495259320
Tech Phone Ext:
Tech Fax:
Tech Fax Ext:
DNSSEC: unsigned

Update Date: 2014-06-02 11:19:09
Creation Date: 2012-06-08 08:54:47
Registrant Fax:
Registrant Fax Ext:
Registry Admin ID:
Admin Phone: +1.9495259320
Admin Phone Ext:
Admin Fax:
Admin Fax Ext:
Registry Tech ID:
Tech Phone: +1.9495259320
Tech Phone Ext:
Tech Fax:
Tech Fax Ext:
DNSSEC: unsigned

Update Date: 2013-05-23 12:08:38
Creation Date: 2012-06-08 08:54:47
Registrant Fax:
Registrant Fax Ext:
Registry Admin ID:
Admin Phone: +1.9495259320
Admin Phone Ext:
Admin Fax:
Admin Fax Ext:
Registry Tech ID:
Tech Phone: +1.9495259320
Tech Phone Ext:
Tech Fax:
Tech Fax Ext:
DNSSEC: unsigned

Update Date: 2013-05-23 12:08:38
Creation Date: 2012-06-08 08:54:47
Registrant Fax:
Registrant Fax Ext:
Registry Admin ID:
Admin Phone: +1.9495259320
Admin Phone Ext:
Admin Fax:
Admin Fax Ext:
Registry Tech ID:
Tech Phone: +1.9495259320
Tech Phone Ext:
Tech Fax:
Tech Fax Ext:
Name Server: NS1.CITIZENHAWK.NET
DNSSEC: unsigned

Whois Record on Feb 14, 2014 No adjacent screenshot
available for this date.
Update Date: 2013-05-23 12:08:38
Creation Date: 2012-06-08 08:54:47
Registrant Fax:
Registrant Fax Ext:
Registry Admin ID:
Admin Phone: +1.9495259320
Admin Phone Ext:
Admin Fax:
Admin Fax Ext:
Registry Tech ID:
Tech Phone: +1.9495259320
Tech Phone Ext:
Tech Fax:
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Dec 9, 2013 No adjacent screenshot
Update Date: 2013-05-23 12:08:38
Creation Date: 2012-06-08 08:54:47
Registrant Fax:
Registrant Fax Ext:
Registry Admin ID:
Admin Phone: +1.9495259320
Admin Phone Ext:
Admin Fax:
Admin Fax Ext:
Registry Tech ID:
Tech Phone: +1.9495259320
Tech Phone Ext:
Tech Fax:
Tech Fax Ext:
DNSSEC: unsigned

Whois Record on Aug 6, 2013 No adjacent screenshot
Updated Date: 2013-05-23 12:08:38
Creation Date: 2012-06-08 08:54:47
Registrar Expiration Date: 2014-06-08 08:54:47
Admin Phone: +1.9495259320
Admin Fax:
Tech Phone: +1.9495259320
Tech Fax:

Whois Record on Jun 6, 2013 No adjacent screenshot
Registered through: GoDaddy.com, LLC (http://www.godaddy.com)
Created on: 08-Jun-12
Expires on: 08-Jun-14
Last Updated on: 23-May-13
Registrant:
LegalZoom.com
101 N. Brand Blvd., 11th Floor
Glendale, California 91203
United States
Administrative Contact:
Recovery, Domain domainrecovery@citizenhawk.com
CitizenHawk, Inc.
27068 La Paz Road, Suite 104
Aliso Viejo, California 92656
United States
+1.9495259320
Technical Contact:
CitizenHawk, Inc.
United States
+1.9495259320
Domain servers in listed order:

NS1.CITIZENHAWK.NET
NS2.CITIZENHAWK.NET

Whois Record on Apr 12, 2013 No adjacent screenshot
Last Updated on: 08-Jun-12
Registrant:
LegalZoom.com
101 N. Brand Blvd., 11th Floor
Glendale, California 91203
United States
CitizenHawk, Inc.
United States
+1.9495259320
Technical Contact:
CitizenHawk, Inc.
United States
+1.9495259320

NS1.CITIZENHAWK.NET
NS2.CITIZENHAWK.NET

Whois Record on Nov 5, 2012 No adjacent screenshot
Registrant:
LegalZoom
7083 Hollywood Blvd., Suite 180
Los Angeles, California 90028
United States
CitizenHawk, Inc.
United States
+1.9495259320
Technical Contact:
CitizenHawk, Inc.
United States
+1.9495259320

NS1.CITIZENHAWK.NET
NS2.CITIZENHAWK.NET

Registrant:
LegalZoom
7083 Hollywood Blvd., Suite 180
Los Angeles, California 90028
United States

CitizenHawk, Inc.
United States
+1.9495259320
Technical Contact:
CitizenHawk, Inc.
United States
+1.9495259320

NS1.CITIZENHAWK.NET
NS2.CITIZENHAWK.NET

Registrant:
CitizenHawk, Inc.
United States

CitizenHawk, Inc.
United States
+1.9495259320
Technical Contact:
CitizenHawk, Inc.
United States
+1.9495259320

NS1.CITIZENHAWK.NET
NS2.CITIZENHAWK.NET

Whois Record on Mar 1, 2012 No adjacent screenshot
Registrant:
CitizenHawk, Inc.
United States

Created on: 06-Dec-11
Expires on: 06-Dec-12
Last Updated on: 06-Dec-11
CitizenHawk, Inc.
United States
+1.9495259320 Fax --
Technical Contact:
CitizenHawk, Inc.
United States
+1.9495259320 Fax --

NS29.DOMAINCONTROL.COM

Registrant:
CitizenHawk, Inc.
United States
Registered through: Go Daddy

CitizenHawk, Inc.
United States
+1.9495259320 Fax --
Technical Contact:
CitizenHawk, Inc.
United States
+1.9495259320 Fax --


Whois Record on Dec 8, 2011 No adjacent screenshot
Registrant:
CitizenHawk, Inc.
United States
Registered through: GoDaddy.com, Inc. (http://www.godaddy.com)

CitizenHawk, Inc.
United States
(949) 525-9320 Fax --
Technical Contact:
CitizenHawk, Inc.
United States
(949) 525-9320 Fax --


Whois Record on Apr 3, 2011 No adjacent screenshot
Domain name: legalzoomtrademarkia.com
Registrant Contact:
Reactivation Period ()
Fax:
15801 NE 24th Street
Bellevue, WA 98004
US
Reactivation Period (Reactivation-Pending@enom.com)

+1.4252744500
Fax: +1.4259744791
Bellevue, WA 98004
US
Technical Contact:
Reactivation Period (Reactivation-Pending@enom.com)

+1.4252744500
Fax: +1.4259744791
Bellevue, WA 98004
US
Status: Locked
Name Servers:
dns1.name-services.com
Creation date: 06 Feb 2010 18:12:19

Expiration date: 06 Feb 2011 18:12:19

Registration Service Provided By: Namecheap.com
Contact: support@namecheap.com
Visit: http://namecheap.com
Registrant Contact:
ABANDONED
ABANDONED ABANDONED ()
Fax:
ABANDONED
ABANDONED
ABANDONED, ABANDONED ABANDONED
US
ABANDONED
ABANDONED ABANDONED (a@a.com)
+1.5555555
Fax: +1.5555555
ABANDONED
ABANDONED
US
Technical Contact:
ABANDONED
+1.5555555
Fax: +1.5555555
ABANDONED
ABANDONED
US
Status: Locked
Name Servers:


Whois Record on Jul 23, 2010 No adjacent screenshot
Registration Service Provided By: NameCheap.com
Contact: support@NameCheap.com
Visit: http://namecheap.com
Registrant Contact:
ABANDONED
ABANDONED ABANDONED ()
Fax:
ABANDONED
ABANDONED
US
ABANDONED
+1.5555555
Fax: +1.5555555
ABANDONED
ABANDONED
US
Technical Contact:
ABANDONED
+1.5555555
Fax: +1.5555555
ABANDONED
ABANDONED
US
Status: Locked
Name Servers:
ns1.softlayer.com
ns2.softlayer.com


Registrant Contact:
self
Jolly Mathew ()
Fax:
19929 Stevens Creek
same
Cupertino, CA 95014
US
self
Jolly Mathew (jollypmathew@gmail.com)
+1.6502125124
Fax: +1.65095212521
19929 Stevens Creek
same
Cupertino, CA 95014
US
Technical Contact:
self
+1.6502125124
Fax: +1.65095212521
19929 Stevens Creek
same
Cupertino, CA 95014
US
Status: Locked
Name Servers:
ns1.softlayer.com
ns2.softlayer.com


Visit: http://www.namecheap.com
Registrant Contact:
self
Jolly Mathew ()
Fax:
19929 Stevens Creek
same
Cupertino, CA 95014
US
self
+1.6502125124
Fax: +1.65095212521
19929 Stevens Creek
same
Cupertino, CA 95014
US
Technical Contact:
self
+1.6502125124
Fax: +1.65095212521
19929 Stevens Creek
same
Cupertino, CA 95014
US
Status: Locked
Name Servers:
dns1.registrar-servers.com


Hosting History
DomainTools tracks changes to a domain name's IP address, name server and registrar. These
events can be useful signals that may indicate more macro events, including: domain name
sales, transfers or deletions; taking a site live with new content; or a change in registration or
hosting profile.
Registrar History
Date Registrar
Jun 9, 2018 GoDaddy.com
Mar 20, 2011 eNom.com
Name Server History
Event Date Action New Server Previous Server

Feb 28, 2015 Transfer domaincontrol.com a0f.net
May 21, 2014 Transfer a0f.net citizenhawk.net
Jun 9, 2012 New citizenhawk.net -
Apr 2, 2012 Delete - domaincontrol.com
Dec 8, 2011 New domaincontrol.com -
Mar 21, 2011 Delete - name-services.com
Feb 8, 2011 Transfer name-services.com softlayer.com
Feb 28, 2010 Transfer softlayer.com registrar-servers.com
Feb 8, 2010 New registrar-servers.com -
IP Address History
Event Date Action New IP Previous IP

Feb 15, 2019 Change 184.168.221.58 50.63.202.48
Jan 25, 2019 Change 50.63.202.48 50.63.202.62
Jan 5, 2019 Change 50.63.202.62 50.63.202.48
Dec 16, 2018 Change 50.63.202.48 184.168.221.44
Nov 25, 2018 Change 184.168.221.44 184.168.221.33
Nov 5, 2018 Change 184.168.221.33 50.63.202.41
Oct 17, 2018 Change 50.63.202.41 184.168.221.46
Sep 26, 2018 Change 184.168.221.46 50.63.202.49
Sep 8, 2018 Change 50.63.202.49 50.63.202.38
Aug 21, 2018 Change 50.63.202.38 184.168.221.46
Aug 3, 2018 Change 184.168.221.46 50.63.202.63
May 23, 2018 Change 184.168.221.38 184.168.221.52
May 5, 2018 Change 184.168.221.52 50.63.202.31
Mar 6, 2015 Change 50.63.202.31 198.46.51.188
Feb 8, 2015 Change 198.46.51.188 198.46.51.193
Dec 31, 2014 Change 198.46.51.193 198.46.51.188

Aug 14, 2014 Change 198.46.51.188 198.46.51.193
Aug 2, 2014 Change 198.46.51.193 198.46.51.188
Jun 27, 2014 Change 198.46.51.188 198.46.51.193
May 21, 2014 Change 198.46.51.193 198.46.51.188
Apr 15, 2014 Change 198.46.51.188 206.80.47.82
Jun 20, 2012 New 206.80.47.82 -
Apr 7, 2012 Not Resolvable - 68.178.232.100
Dec 11, 2011 New 68.178.232.100 -
Mar 30, 2011 Not Resolvable - 8.5.1.47
Feb 8, 2011 New 8.5.1.47 -
Jul 3, 2010 Not Resolvable - 208.43.136.74
Feb 28, 2010 New 208.43.136.74 -

Screenshot History
DomainTools captures snapshots of website homepages on regular intervals. This content is
useful for researchers to understand how a domain was used at various points in time. Due to the
relatively high storage costs of screenshot data, the coverage of screenshot histories is in most
cases not as thorough as Whois or hosting data, and this is especially true for dates early in a
domain's history.
DomainTools has 5 records collected between Apr 3, 2014 and Mar 27, 2017.
Mar 27, 2017 Jul 15, 2016 Dec 2, 2015
Mar 17, 2015 Apr 3, 2014

Connected Domains
Shared IP Address
DomainTools uses proprietary techniques to discover other domain names that are hosted on the
same IP address (web host) as LegalZoomtRademarkIa.com. This is a sample of up to 100
randomly-selected domains from that dataset. Access to this data provides context in cases
where knowing associated domain names has value.
The exhaustive list of connected domains by IP address is available in the Reverse IP product at
DomainTools.com.
Domain Created Registrant

accoll.com Nov 1, 2017 alpine construction
acourseinmiracles.app May 8, 2018 REDACTED FOR PRIVACY
adamsilverdirector.com Sep 22, 2016 Adamsilverdirector.com
adelaidemalynn.com Jun 8, 2016 Adelaidemalynn.com
adelphiaenterprises.ca Feb 27, 2014 Redacted for Privacy Purposes
autoagentsprovidersinc.com Apr 11, 2012 miss christian oklahoma pageants
axtt58.com Mar 22, 2018 Ge Ren
baincapiatlventure.com Mar 23, 2018 Bain Capital
beckybytes.com Mar 9, 2018 Domains By Proxy, LLC
beessentiallyinspired.com.au - Belinda Lee
bmfireprotection.us May 15, 2014 Emiliano Martinez
buyrumproast.com May 9, 2017 Domains By Proxy, LLC
caiacoley.com Dec 29, 2010 Domains By Proxy, LLC
casanrealty.org Feb 3, 2019 Domains By Proxy, LLC
cashparkingportfolio.co.uk Aug 5, 2018 Cashparkingportfolio.co.uk
cbdfirst.co Feb 2, 2019 Cbdfirst.co
cinch.mobi Jun 29, 2018 Bilet Enterprises, Inc.
clix.com.co Mar 4, 2013 J2E Tecnologia S.A.S.
colerosica.com Oct 23, 2007 Colerosica.com
comprahogar.com Jun 3, 2018 DP Design
conspiracyreport.org Jun 14, 2017 Pasquale Productions LLC
cordsofsteel.biz Oct 24, 2017 Domains By Proxy, LLC
cumplimiento.net May 27, 2016 Fernando Rodriguez
cyclefertilizers.com Feb 4, 2018 Cyclefertilizers.com
deucecarter.com Oct 16, 2016 Deucecarter.com
durvallelys.net Apr 23, 2014 Durvallelys.net
excyte.us Oct 26, 2015 Andrea Larsen
flapraiser.com Jul 6, 2006 Domains By Proxy, LLC
fontevillages.com Jan 19, 2016 Aldeia da Fonte
freewakenman.com Jan 5, 2019 Domains By Proxy, LLC
givelovewisdom.com Nov 19, 2015 Domains By Proxy, LLC
greatoutdoorsexperience.com Feb 16, 2017 Greatoutdoorsexperience.com
happypanpanvegan.com Oct 27, 2018 Gutsy Living Foods
heliumbioventures.com Sep 23, 2015 Heliumbioventures.com

henleykelly.co.uk Feb 24, 2018 Henleykelly.co.uk
huemancreative.com Feb 14, 2019 Mosaic Live
idealcarepartners.com Oct 19, 2018 Domains By Proxy, LLC
inspiraccion.net Aug 17, 2018 SiLyCorp
iwilleatclean.com Aug 11, 2016 Core Volleyball Club
kotools.com Apr 16, 2008 Domains By Proxy, LLC
kotsllc.com Apr 3, 2014 Domains By Proxy, LLC
lamaraswimwear.com Apr 2, 2018 Lamaraswimwear.com
landofapportunity.com Jul 12, 2018 Landofapportunity.com
lauritosliquors.com Jan 1, 2016 Lauritosliquors.com
lifemanufacturing.com May 29, 2017 Lifemanufacturing.com
lifeoversport.co May 13, 2016 Lifeoversport.co
lifetree.ind.in Jun 5, 2018 Lotus Industries
makeamove.com.ph - Makeamove.com.ph
milesautocentre.com Sep 15, 2017 Milesautocentre.com
mindlightllc.net Dec 19, 2016 Mindlight, LLC
msdemoschool14.com Jul 12, 2016 Msdemoschool14.com
northtexasforkliftandmachinerybuyers.com Mar 15, 2018 Domains By Proxy, LLC
offenderregistrationsystems.com Jun 2, 2016 Domains By Proxy, LLC
officespaces.asia Jan 10, 2019 Bcumen Pte Ltd
onerivetdigital.com Aug 27, 2015 Onerivetdigital.com
paigespages.life Mar 30, 2018 Domains By Proxy, LLC
pharmachem.info May 2, 2008 Pharmachem.info
phillooney.com Sep 2, 2004 Phillip Looney
phillygreatschoolscompact.com Mar 22, 2013 Philadelphia School Partnership
pitchperch.com Mar 3, 2017 Pitchperch.com
politicoincorrecto.com Jun 29, 2016 Domains By Proxy, LLC
pro-10partnersinc.com Jan 5, 2019 Pro-10partnersinc.com
productionassetsolutions.com Oct 4, 2018 Productionassetsolutions.com
prosthatshow.com Aug 28, 2018 Prosthatshow.com
proverbialhandcrafters.com Dec 10, 2016 Domains By Proxy, LLC
qualityfreight.ca Feb 10, 2010 Qualityfreight.ca
regulatedcategoryservices.com Feb 8, 2017 sage associates
restorativeproperties.com Jul 8, 2018 Domains By Proxy, LLC
rhettsteiner.com Mar 5, 2006 Domains By Proxy, LLC
rpmgt.net Feb 21, 2008 RP Management
sbdive.com Feb 1, 2017 Sbdive.com
secureuniversity.net Dec 19, 2011 Iservices Systems LLC
servilityfurnishings.com Nov 2, 2017 Servilityfurnishings.com
shareablerecipes.com Aug 5, 2017 Niche Web Properties, LLC
skennyartist.net Nov 4, 2015 Domains By Proxy, LLC
socceralliancegroup.org Dec 20, 2016 Socceralliancegroup.org
sorry1.com Jun 4, 2018 Sorry1.com
southflentrepreneurs.com Oct 21, 2017 Brand Advance
stw.life Aug 27, 2018 Domains By Proxy, LLC

sunrisepsychics.com Aug 26, 2015 Outlook Amusements
susieinglis.com Oct 21, 2015 Susieinglis.com
t55-eg.com Jan 27, 2019 ODEC Technology Solutions
tappingtoolkit.com Jul 24, 2017 Wellpower
tetonpawsranch.net Aug 16, 2017 Tetonpawsranch.net
thepharmacistconsultant.com Oct 28, 2018 Thepharmacistconsultant.com
thetrendybird.in Apr 4, 2018 -
thicklysin.com Sep 26, 2017 NYC MOB
timebound.in May 16, 2015 AC INFOTECH INC
tourismbycountry.com Oct 6, 2016 Domains By Proxy, LLC
uktmw.com Apr 27, 2017 NRG IT Ltd
usafreezone.org Jul 7, 2001 BCC
usmfydl.com Oct 17, 2018 VALOR Fight Sports Fitness
valuepakgroup.co.nz - Valuepakgroup.co.nz
vjfcufflinks.co.uk Feb 26, 2016 Vjfcufflinks.co.uk
vquestpi.org Aug 25, 2014 Vquestpi.org
wb-home.com Nov 14, 2001 Meteor Web Marketing, Inc
whererwe.online Feb 27, 2018 Whererwe.online
whiletheworldends.de - Whiletheworldends.de
worldwidewoodworker.com Aug 18, 2012 Worldwidewoodworker.com
yearsober.com Dec 17, 2010 Sober Solutions

Shared Name Server
DomainTools uses proprietary techniques to discover other domain names that are hosted on the
same name server as LegalZoomtRademarkIa.com. This is a sample of up to 100
randomly-selected domains from that dataset. Access to this data provides context in cases
where knowing associated domain names has value.
The exhaustive list of connected domains by name server is available in the Name Server Report
product at DomainTools.com.
Domain Created Registrant

480377.com Mar 21, 2018 480377.com
59fire.com Apr 21, 2005 William Walker Hose Company
837ttl.com May 15, 2017 837ttl.com
abfc.com.br Aug 23, 2018 Rodrigo Monteiro
americasbestndt.com Apr 8, 2010 Marketing VF Ltd
apisbygg.com Oct 26, 2016 Domains By Proxy, LLC
atypicweb.com Jan 22, 2018 Domains By Proxy, LLC
bahaar.org Mar 19, 2011 Domains By Proxy, LLC
belleandeve.org.uk Feb 15, 2018 Belleandeve.org.uk
bickil.com Mar 30, 2007 Bickil.com
bloomingtoncleaners.com Sep 7, 2011 Miller-Time Productions
bobcoleman.net May 21, 2002 Bobcoleman.net
bodyclogs.com May 31, 2002 Bodyclogs.com
bostonbrandingagency.com Nov 5, 2012 Millennium Integrated Marketing
brushsetko.com Nov 20, 2017 Brushsetko.com
butterfieldconcretetci.com Apr 19, 2017 Butterfield Gold Ltd
cardiffbytheseahomesforsale.com Dec 8, 2008 Domains By Proxy, LLC
careunits.com Jul 19, 2014 Intelliname LLC
cliniquedentaire-implants-charlesbourg.com Sep 21, 2010 PubliGO
clothexpress.com Sep 18, 2016 Clothexpress.com
cornerstone-litigation-services.com Mar 13, 2002 Webitize
crowdence.es - Crowdence.es
custominteriors.biz Nov 27, 2001 Custom Interiors
davidwyckoff.com Apr 21, 2007 Labette Bank
docsupport.ca Apr 19, 2010 Redacted for Privacy Purposes
donations4children.com Jan 3, 2019 Donations4children.com
elainestechnologyatitsbest.com Apr 12, 2018 Elainestechnologyatitsbest.com
envymyballs.com Feb 4, 2019 Domains By Proxy, LLC
escortyeni.com Apr 19, 2017 Domains By Proxy, LLC
faziodancecenter.com Dec 3, 2016 Domains By Proxy, LLC
fcdscorp.info May 27, 2018 Fcdscorp.info
foreignservicerealestate.com Mar 29, 2010 Foreignservicerealestate.com
fundamentalsolutionscorporation.com Sep 17, 2015 Domains By Proxy, LLC
giftofgabcenter.com Aug 22, 2017 Hiri Homes
gobestrong.com Jun 24, 2008 Gobestrong.com

goldenvalleyorthodontics.com Jan 8, 2018 Goldenvalleyorthodontics.com
golfxhub.com Jun 29, 2018 Domains By Proxy, LLC
hackberrymagazine.com Jul 16, 2018 Hackberrymagazine.com
hairandbeautyaffiliate.com Dec 16, 2018 lacoupefutur
heliumplanadvisors.com Jul 4, 2015 Heliumplanadvisors.com
highstreetgoodsco.com Jan 14, 2019 Domains By Proxy, LLC
illamore.com Feb 12, 2017 Domains By Proxy, LLC
inventorytraker.com Mar 7, 2019 Inventorytraker.com
jerseyscreenprinting.com Mar 5, 2004 One Stroke Inks
jore.vip Jun 1, 2018 REDACTED FOR PRIVACY
koriedykes.com Nov 13, 2018 Domains By Proxy, LLC
latitudesocal.com Dec 13, 2014 Latitude
leadkeys.com Feb 25, 2018 Domains By Proxy, LLC
lillyandtilly.com Jun 5, 2018 Domains By Proxy, LLC
luebyloo.net Feb 6, 2015 Luebyloo.net
makemylawpracticephonering.com Sep 28, 2018 Makemylawpracticephonering.com
minimalconsulting.com Dec 23, 2018 Minimalconsulting.com
morseperformance.ca Mar 12, 2016 Redacted for Privacy Purposes
motiv8d-st8.com May 22, 2017 Motiv8d-st8.com
mozcafesanfrancisco.com Feb 5, 2018 Menufy.com LLC
mybitblock.com Jan 5, 2014 Mybitblock.com
mywifejean.com Feb 21, 2019 OldWestGold
niallohagan.com Sep 21, 2018 Niallohagan.com
nsyncmed.com Aug 6, 2015 Domains By Proxy, LLC
octavtech.com Mar 29, 2018 Octavtech.com
osketchstudio.net Oct 31, 2012 O'Sketch Studio, LLC
piliaina.net Sep 18, 2016 Domains By Proxy, LLC
pitstopmmd.com Feb 7, 2017 Domains By Proxy, LLC
plantersand.com Jul 1, 2013 J and J
poshandpaws.com Jan 31, 2019 Poshandpaws.com
prancingbubbles.com May 8, 2017 Domains By Proxy, LLC
prodigydataservices.com Jun 17, 2015 1
purchasetailor.com Nov 10, 2017 Domains By Proxy, LLC
queenberry.farm Oct 14, 2018 Domains By Proxy, LLC
repsdpt.com Nov 22, 2016 Repsdpt.com
resurgence-gaming.org Jan 21, 2019 1999
ririoweb.com Sep 11, 2007 Grid Dynamics
riseupstl.com Jun 2, 2018 Riseupstl.com
rocketindustriesinc.com Nov 23, 2012 Rocket Industries, Inc.
sakesake-mottekoi.com Jan 30, 2019 Sakesake-mottekoi.com
savoryalmondbutter.com Jul 22, 2011 Savoryalmondbutter.com
seaislife.com Feb 7, 2018 Seaislife.com
seleserpe.com Oct 15, 2017 Domains By Proxy, LLC
septicengineeringofvermont.com Jul 18, 2011 Septicengineeringofvermont.com
serenitywealth.com Nov 29, 2011 WhoisGuard, Inc.

shobhaasar.com Oct 31, 2003 Shobha Asar Jewellery Pvt. Ltd.
solareatz.com Feb 27, 2019 Solareatz.com
spspermits.com Feb 22, 2018 Spspermits.com
steamychums.com Nov 21, 2013 SZA Trading Inc
suffragette.info Feb 19, 2017 Period Designs Ltd
tajj.co.uk Aug 27, 2018 Tajj.co.uk
team-buckley.com Feb 15, 2018 Coldwell Banker Bain
thedubaisquare.com Jan 12, 2015 NSHMI Development LLC
tracyfrick.com Feb 2, 2015 Tracyfrick.com
trumanmeatco.com Sep 14, 2015 Trumanmeatco.com
vashecare.com Jul 12, 2011 SteadMed Medical
villarealty.co.za Nov 12, 2015 Fish e Marketing (Pty) Ltd.
vv95660007.net Jan 12, 2018 Vv95660007.net
watermantechnologies.com Feb 20, 2008 Domains By Proxy, LLC
wheretogo.live Apr 7, 2018 REDACTED FOR PRIVACY
wisemenplanahead.com Sep 16, 2017 Wisemenplanahead.com
xiomarafitness.net Nov 9, 2017 Xiomarafitness.net
yinyangism.com May 25, 2018 Yin Yang Jiao inc
zclear.online Mar 1, 2017 Zclear.online
zhangyiping.info Mar 17, 2018 Zhangyiping.info

EXHIBIT B
EXHIBIT C
3/18/2019 legalzoomtrademarkia.com
it
s ge
eb
w min
co on!
so
Please check back soon to
see if the site is available.
http://legalzoomtrademarkia.com/ 1/1
EXHIBIT D
3/19/2019 Top 10 B2B Affiliate Programs For Big, Consistent Commissions
LegalZoom
LegalZoom's network of independent attorneys helps owners launch

their businesses
URL: https://www.legalzoom.com/affiliates
Commission: $15
Cookie: 30 days
LegalZoom has helped launch over 1 million businesses since 2001. Their network of
independent attorneys can help you with forming your business, naming it, legal forms,taxes,
licenses, permits, and much more. They are one of the fastest growing companies with high
visibility from their nationwide television and radio campaigns.
Their affiliate program is powered by Pepperjam. LegalZoom provides marketable products to

help drive traffic, powerful reporting tools, and monthly commission payouts. Their responsive
affiliate team is available to help optimize your campaigns.
Why Should You Promote LegalZoom: Well known brands, business legal services, high
converting marketing materials
Qualifying affiliates can earn VIP commission structure for higher earning potential.
https://onemorecupof-coffee.com/best-b2b-affiliate-programs/ 1/1
EXHIBIT E
3/19/2019 LegalZoom Affiliate Program | legalzoom.com
Join the LegalZoom Affiliate Program

It's free to join, easy to get started, and even
easier to earn money.
Overview Requirements Reporting Tools FAQs
Enjoy the Advantages of Being an Affiliate
As an affiliate, you'll have access to a wide range of marketable LegalZoom products that will help drive traffic to your website and
earn your company commissions.
Benefits Include:
Earning Money. Earn a 15% commission for every sale Powerful reporting tools. Generate customized reports
completed by a referral with real time data
VIP commissions. Qualifying affiliates have access to Payment options. Payments are processed monthly via
VIP commission structures for even more earning ACH or PayPal
potential
30-day cookie. Make money on sales made up to 30 Growth potential. Become part of the network of one of
days from the date your ad was clicked the fastest growing companies
Marketable products. Popular LegalZoom products and Dedicated support. Our responsive affiliate team is
services help drive traffic to and from your website available to help optimize your experience
High visibility. Take advantage of increased exposure Free membership. It's free to become a LegalZoom affiliate
from our nationwide television and radio campaigns
Learn about the requirements
©LegalZoom.com, Inc. All rights reserved View Site Directory
Disclaimer: Communications between you and LegalZoom are protected by our Privacy Policy but not by the attorney-client privilege or as work
product. LegalZoom provides access to independent attorneys and self-help services at your specific direction. We are not a law firm or a substitute
for an attorney or law firm. We cannot provide any kind of advice, explanation, opinion, or recommendation about possible legal rights, remedies,
defenses, options, selection of forms or strategies. Your access to the website is subject to our Terms of Use.
Start screenshare
https://www.legalzoom.com/affiliates 1/1
EXHIBIT F

Am I Qualified to Become a LegalZoom Affiliate?
If you're interested in becoming a LegalZoom Affiliate, see if you've got what it takes to join our program.
Who we're looking for:
Web marketers committed to preserving the integrity of the LegalZoom brand

Franchise companies searching for a cost effective solution for business formation requirements
Esq., CPAs, CFAs & CFPs exploring value added services to their clientele
Companies with online marketing specialists and content writing teams
Companies who look for niche products and build sites to promote products
Website owners with a strong SEO presence for legal keywords
Sites or directories that are targeted and useful to online shoppers
We are not accepting applications for companies who promote:
Coupon or incentives-only websites

Applications or adware known to overwrite cookies
Excessive use of banners with no supporting content
Flash or graphics-only websites
Websites that have no value-add content
Use of black-hat SEO tactics
Any version of spam
View Reporting tools
Start screenshare
EXHIBIT G

Stay on Top of Everything with Cutting-Edge Reporting Tools
Make use of robust reporting tools to keep track of your campaigns and conversions, help identify your customers' preferences and
maximize your site's earning potential.
Tools to help manage and drive sales:
Real time campaign reporting for up-to-the-minute data on conversions, click rates, revenue, sales volume, traffic activity and more
Full API to pull any data from the affiliate portal
Advanced pixel management lets you place and track campaigns using your own pixels
Flexible tracking reporting with easy-to-use dashboard
Integrated creative database for easy referencing and importing
iPhone and iPad App to allow you to check your stats on the move
See the FAQ
Start screenshare
EXHIBIT H

Find your Answers Fast, Here
See a list of the most common questions and answers. Don't see your question here? Email us anytime at
legalzoom@pepperjammanagement.com
What is the LegalZoom Affiliate Program?
Why should I join?
Does it cost anything to become a LegalZoom affiliate?
How do I join the affiliate program?
Interested in promoting a product or service to legalZoom customers?
Is my website eligible?
Can I become an affiliate if my website is "under construction"?
How much can I earn?
How are the commissions paid?
How do I keep track of my sales and commissions?
What is the cookie duration?
How do I report a missing order?
What happens if a customer I referred cancels a sale?
What if I'm having problems signing in?
Who can I contact for more information?
Q. What is the LegalZoom Affiliate Program?
A. The LegalZoom Affiliate Program is a way for you to earn a commission by promoting LegalZoom products using banner ads or text links within your
website. Each time a visitor clicks on a LegalZoom link on your website and completes a purchase, you'll earn money.
Q. Why should I join?
A. There are many benefits of being an affiliate! It's free to join, and earn money working with one of the fastest growing companies in the nation.
Q. Does it cost anything to become a LegalZoom affiliate?
A. No. Once you're approved, membership to the LegalZoom Affiliate Program is free.
Q. How do I join the LegalZoom Affiliate Program?
A. You will need to complete an application. We'll review your application and notify you within 5-7 business days if it is approved.
Q. Interested in promoting a product or service to LegalZoom customers?
A. If you have a product or service that would benefit LegalZoom customers please email our Business Development team at
partnerships@legalzoom.com.
Q. Is my website eligible?
A. We review each application carefully and determine your eligibility at our sole discretion. We reserve the right to reject or remove sites at any time, for
any reason. To learn more about the criteria we use in evaluating potential affiliates, please read the Requirements tab.
Q. Can I become and affiliate if my website is "under construction"?
A. If your website is not yet completed or is "under construction" send an email to legalzoom@pepperjammanagement.com with a brief description of
how you intend to promote LegalZoom (email, website, newsletter, search engines, etc.). From there, our affiliate team will be able to determine your
eligibility.
Q. How much can I earn?
A. For each completed sale, you earn a 15% commission. Government filing fees and product add-ons are not included in the calculation. Check
LegalZoom for current product pricing.
Business Formation
LLC | Express Gold $359.00 $53.85
Incorporation | Express Gold $369.00 $55.35
DBA | Standard $99.00 $14.85
Non-Profit | Express Gold $359.00 $53.85
Personal Services
Living Will | Comprehensive $49.00 $7.35
Last Will | Comprehensive $79.00 $11.85
Living Trust | Comprehensive $269.00 $40.35
Power of Attorney | Basic $35.00 $5.25
Divorce $299.00 $44.85
Name Change $139.00 $20.85
Intellectual Property
Copyright $114.00 $17.10
Q. How are commissions paid?
A. Payments are made on a Net 15 basis. For example, we'll send out a payment on July 15th for all commissions earned in June. For other billing
questions, please send an email to legalzoom@pepperjammanagement.com.
Q. How do I keep track of my sales and commissions?
A. Our system allows you to see the clicks and sales you've generated in real time. Get up-to-the-minute information on activity by selecting "Reporting"
from the side menu bar. Next, select the date range and campaigns you'd like to view.
Q. What is the cookie duration?
A. We offer a 30-day cookie duration that allows you to earn commission for up to 30 days after someone clicks on your LegalZoom ad and completes
an order.
Q. How do I report a missing order?
A. Please send an email to legalzoom@pepperjammanagement.com if you haven't received credit or payment for an order.
Q. What happens if a customer I referred cancels a sale?
A. If an order is canceled or not completed, you will not receive a commission for that transaction.
Q. What if I'm having problems signing in?
A. First, make sure you are using the correct sign in and password provided in your welcome email or you can click on the "Forgot Your Password" link.
You can find the affiliate sign in at https://www.pepperjamnetwork.com/login.php. You cannot sign in to our affiliate dashboard from the LegalZoom
homepage. If you are still having problems, email us at legalzoom@pepperjammanagement.com.
Q. Who can I contact for more information?
A. If you have any additional questions about the LegalZoom Affiliate Program, email us at legalzoom@pepperjammanagement.com.
Start screenshare
EXHIBIT I
3/19/2019 Advertisers & Brands
DISCOVER. ENGAGE. CONVERT.

Today’s concentrated marketing landscape requires a simpli ied means to diversify your digital marketing approach. You
need an intuitive technology solution to discover, reach and convert high-value customers and a partner with the experience
to drive connections that create commerce.
CORE PLATFORM FUNCTIONALITY
DISCOVER
Ascend™ leverages advertiser data and preferences to transparently identify and recruit high-quality publishers to your white
label a iliate program. Ascend’s discovery engine enables marketers to leverage our supply side database to custom curate
their own private a iliate networks (PAN).
TRACK
Ascend™ provides complete transparency and comprehensive access to your data. From standardized dashboards to integrated
fully custom reporting, Ascend provides actionable insights that will help you identify winning strategies and optimize your
program’s performance.
https://www.pepperjam.com/advertisers-and-brands 1/10
PAY
Ascend™ enables you to customize your commission strategy to align with your attribution model with full dynamic, fractional,
irst, preferred, and last click capabilities and incorporate a iliate into your overall cross-channel efforts.
PROTECT
Minimize revenue loss and protect your investment across search, social, domain, code and content with Ascend's always-on
monitoring and enforcement solution.
OPTIMIZATION TOOLS
PUBLISHER
MANAGEMENT
DYNAMIC
COMMISSIONING
ACTIONABLE
ATTRIBUTION
CAMPAIGN
CREATIVES
COMMUNICATION
BRAND
MONITORING
RICH APIS: REST BASED WEB SERVICES OPTIONS
EDUCATION & SUPPORT: ON DEMAND SELF EDUCATION AND RESOURCE

CENTER
DOWNLOAD INFO SHEET
SERVICE LEVELS
PRIME
Our platform. Your team. We’ll make sure your team are experts at leveraging Ascend™ to maximize the return on your
a iliate marketing investment.
Guided launch & onboard experience
On-demand self-education & resource center
Platform access & tools
Unlimited expert support & education
PRIME ENTERPRISE
Our Platform. Collaborative Program Management. For clients who need full time supplemental support for in-house
resources, ongoing strategic advisory, and program performance optimization assistance.
Ongoing publisher review & recommendation
Monthly publisher newsletter creation
Semi-annual strategic review
Quarterly creative review
ELITE
Comprehensive program management provided by Pepperjam.
Dedicated team of strategists
Goal establishment & review
Program strategy execution
Data-driven insights and interpretation
Weekly reviews/check-ins
Quarterly strategic review
Ongoing creative review
SEE THE PEPPERJAM DIFFERENCE FOR YOURSELF.

Having transparency means stronger execution. With Pepperjam, you have enhanced visibility into publisher pro iles and
automated publisher recommendations to ind and establish new connections. Take control and ownership of those
connections with customized dynamic commissioning rules and actionable attribution tools to maintain a holistic view of your
program's performance.
AFFILIATE 101
PUBLISHER PREVIEW
It's not the size of the publisher base, but the quality that matters most. Explore a publisher sampling below.
WANT TO BECOME AN ADVERTISER?

If you are an advertiser or brand with an established e-commerce website that sells products or services online and are
looking to amplify your brand message through publishers, you've come to the right place. Not you? Try our publisher or
agency sign-up page.
FIRST NAME*
Your irst name
LAST NAME*
Your last name
EMAIL*
Your email address
PHONE *
Your phone number
COMPANY*
Your company name
WEBSITE URL*
Your website
ANNUAL ONLINE REVENUE*
Please Select
COUNTRY*
Please Select
TITLE*
Your current title
SUBMIT
SERVICES ABOUT
Advertisers & Brands About Us
Publishers & In luencers Careers
Agencies & OPMs Leadership
News & Events
RESOURCES QUICK LINKS

Blog Ascend
Case studies Blog
Webinars Ascend login
Offering sheets
Whitepapers
Subscribe to our blog
Your email address
   
© 2018 Pepperjam LLC or its subsidiaries. All rights reserved.
Legal Notices | Privacy & Opt-Out
EXHIBIT J
3/19/2019 Publishers & Influencers
YOUR SUCCESS IS OUR SUCCESS

You’ve worked hard to make your content matter. You know your audience and how to convert browsers into buyers. We
know how to connect you with the brands your audience cares most about.
CORE PLATFORM FUNCTIONALITY
DISCOVER
Ascend™ leverages advertiser data and preferences to transparently identify and recruit high-quality publishers to your white
label a iliate program. Ascend’s discovery engine enables marketers to leverage our supply side database to custom curate
their own private a iliate networks (PAN).
TRACK
Ascend™ provides complete transparency and comprehensive access to your data. From standardized dashboards to integrated
fully custom reporting, Ascend provides actionable insights that will help you identify winning strategies and optimize your
program’s performance.
https://www.pepperjam.com/publishers-and-influencers 1/7
PAY
Ascend™ enables you to customize your commission strategy to align with your attribution model with full dynamic, fractional,
irst, preferred, and last click capabilities and incorporate a iliate into your overall cross-channel efforts.
PROTECT
Minimize revenue loss and protect your investment across search, social, domain, code and content with Ascend's always-on
monitoring and enforcement solution.
OPTIMIZATION TOOLS
MONETIZATION
FEATURES
COMMUNICATION
ACTIONABLE
ATTRIBUTION
PLACEMENT
MARKETPLACE
RICH APIS: REST BASED WEB SERVICES OPTIONS
EDUCATION & SUPPORT: ON DEMAND SELF EDUCATION AND RESOURCE

CENTER
NEW TO AFFILIATE MARKETING?

Upon discovering the world of a iliate marketing, while the opportunities are endless, getting there can feel overwhelming.
We’re here to help! Check out our publisher resources designed to get you off to a successful start.
AFFILIATE 101
WE ONLY WORK WITH BRANDS WE LOVE. AND WE THINK YOU’LL AGREE.

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© 2018 Pepperjam LLC or its subsidiaries. All rights reserved.
Legal Notices | Privacy & Opt-Out
EXHIBIT K
3/19/2019 Publisher Registration | LegalZoom
Publisher Registration
Thank you for your interest in joining the LegalZoom Affiliate Program. Please provide us with the following information.
PLEASE READ:
Acceptance to Ascend is not guaranteed. While we carefully consider every application submitted to Ascend, applications are typically rejected for the
following reasons: (1) incomplete or false contact information, (2) invalid business or personal Tax ID (US affiliates only), (3) failure to disclose promotional
methods (4) unacceptable Web site content, including promotion of activity considered illegal in the United States, and (5) an inability to verify Web site(s),
phone number(s), and e-mail(s). Therefore, to increase the likelihood of becoming an Ascend affiliate please fill out this application fully and honestly.
Fraudulent activity on Ascend is not tolerated and will result in immediate account suspension and reversal of commissions. Questions? Please contact us.
Required fields are marked with an asterisk(*)
Company Information Personal Information
Company Name * Title

Select
Primary Website URL * First Name *

http:// Add Additional Site
Primary Website Description * Last Name *
Email *
Country *
Use of your corporate e-mail is strongly encouraged. (Ex. bob@company.com)
Select Country
Password *
Address 1 *
Password must meet the following requirements:

Address 2 at least 8 characters
doesn't include sequential or repeating characters
not be common
has at least 3 of the following: Uppercase letters, Lowercase letters, Numbers,
City * Symbols
Password Confirmation *
Fax
Please retype the password for confirmation purposes.
Phone *
Payment
Secondary Phone
PayPal Address*
Please be advised that once you select your currency, it will be used
throughout your publisher account for both reporting and payment and
cannot be changed in the future. Don't have a PayPal account? Sign up
Currency *
Select
Tax Classification * Company Category
Select
Select Categories *
Customer Reach *
Select Categories
Select an option
Select up to four categories
Select the countries in which you have customer reach.
Promotional Methods
Note: The following methods cannot be changed once selected: Email Marketing, Toolbar, Direct Link, Incentive, CPA/Sub-Affiliate Network.
Web Site/Content Paid Search Email Marketing Toolbar
https://ascend.pepperjam.com/affiliate/registration.php?refid=163840&referrer=RCT-LGZ&_ga=2.208833426.1889675282.1553014258-2136074452.1… 1/2
Coupon / Value Proposition Merchant / Product Review Loyalty Direct Link
Product Feed Comparison Shopping Video Search Engine Optimization (SEO)
Incentive CPA/Sub-Affiliate Network Blog eBay
Social Shopping Pay-Per-Call Mobile Traffic Mobile/Tablet Application
Retargeting & Remarketing
Social Media Footprint
Twitter Facebook
Instagram Vine
Pinterest Snapchat
Fyuse YouTube
Google+ WeChat
Weibo
Please read through Service Agreement and check that you accept below.
11. Indemnification.
a. Publisher shall indemnify, defend, subject to Section 11(b), and hold harmless, Pepperjam and its
respective parents, subsidiaries and affiliates, and each of their respective directors, officers, employees,
agents, successors and assigns against any third-party claim, suit, action, judgment, allegations, or lawsuits
("Claims"), for any damages, fines, penalties, deficiencies, losses, liabilities, obligations, costs and expenses
(including without limitation reasonable attorneys' fees, costs related to in-house counsel time, court costs
and witness fees) (collectively "Losses") or any threatened Losses arising from or in connection with
Publisher's breach of this Agreement or intentional acts or omissions or for Claims of product liability.
b. Should any Claim give rise to Publisher's duty of indemnification under this Agreement, Pepperjam shall
notify Publisher, and Pepperjam shall have the right to assume control of the defense of any such Claim;
provided that Publisher shall reimburse Pepperjam for all costs of the defense. If Pepperjam assumes the
d f P bli h h ll ti i t i ( t P bli h ' ) b t t t l th d f f h
Exchange Publisher Service Agreement - EU
I have read and accepted the Pepperjam Publisher Service Agreement. *
I am at least 18 years of age. *
Once the application is submitted we will contact you via e-mail as soon as your application is processed, usually within 24 hours.
I'm not a robot

reCAPTCHA
Privacy - Terms
Submit
EXHIBIT L
EXCHANGE PUBLISHER SERVICE AGREEMENT - UNITED STATES
INTRODUCTION.This Exchange Publisher Service Agreement (this "Agreement") shall govern the relationship between
Pepperjam, a Pennsylvania corporation, with offices located at 7 South Main Street, Third Floor, Wilkes-Barre PA 18701
("Pepperjam"), and the party requesting the Services ("You" or "Publisher") with respect to the advertising service (the
"Service") offered through Pepperjam's exchange located at www.pepperjamnetwork.com (the "Site"). You and Pepperjam
may also be individually referred to herein as "Party" and collectively as "Parties."
TO USE OR ACCESS THE SERVICES, YOU MUST AGREE TO BE LEGALLY BOUND BY THE TERMS AND
CONDITIONS OF THIS AGREEMENT BY CLICKING "I ACCEPT" WHERE INDICATED. IF YOU DO NOT AGREE TO
THESE TERMS AND CONDITIONS, YOU HAVE NO RIGHT OR AUTHORITY TO ACCESS OR USE THE SERVICES OR
EXERCISE ANY OTHER RIGHT IN CONNECTION THEREWITH.
If You have registered for or on behalf of an entity, you are deemed to have accepted this Agreement on behalf of such entity.
To the extent Publisher is a network of third parties, then Publisher shall be responsible to ensure that such third parties
comply with the terms of this Agreement and the terms of the applicable Advertiser Program(s). If you do not agree to the
terms of this Agreement in its entirety, You are not authorized to: (a) register as a publisher; (b) use the Service; and/or (c) use
the Site, in any manner or form whatsoever. Pepperjam may, in its sole discretion, refuse to register You as a Publisher and/or
terminate Your participation in an Advertiser Program (as defined below) at any time for any reason. To the extent that the
terms of any Advertiser Program are in conflict or inconsistent with this Agreement, this Agreement shall take precedence and
control.
You agree to use the Site, the Service and any additional products and/or services offered by Pepperjam only in accordance
with this Agreement. Pepperjam reserves the right to make changes to the Site, Service and this Agreement at any time and
the revised version of the Agreement shall become effective after 30 days of being posted on the Site. Following such 30 day
period, Your continued use of the Site and/or Service after any such modification thereof shall constitute Your consent to such
modification.
EXCHANGE. As a service provider and online exchange, Pepperjam facilitates affiliate marketing programs via its technology
and network on the Internet. An affiliate marketing program ("Advertiser Program") is where a Publisher or its agent
operates one or more web site(s) (domain or portion of a domain within the Internet) and/or subscription e-mail list(s) to earn
financial compensation ("Publisher Fees") for sales and or leads ("Transactions") generated from such web site and/or e-
mail list through a click made by a customer (each, a "Customer") on a web site or content operated by an advertiser
("Advertiser"). The Advertiser compensates the Publisher, in accordance with this Agreement and the specifications of the
applicable Advertiser Program agreed to by the Advertiser and the Publisher under a separate agreement.
In consideration of the mutual covenants and agreements contained herein, the parties, intending to be legally bound, hereby
agree as follows:
1. Participation in Advertiser Programs.
a. Accessing Advertiser Programs. Publisher may apply to Advertiser Programs for the opportunity to earn Publisher Fees
by promoting Advertisers in accordance with the Advertiser Program terms and this Agreement. Once approved by the
Advertiser for acceptance into its Advertiser Program, Publisher consents to and shall be bound by the terms and conditions
of the Advertiser Program and Publisher may utilize links to Advertiser's web site or offers in accordance with the Advertiser
Program terms and this Agreement.
b. Advertiser Program Terms. The terms, conditions and other details of an Advertiser Program shall be available through
the Site. Transactions qualifying for a Publisher Fee are defined by the Advertiser, the Advertiser Program and the Site.
2. Publisher Requirements with Pepperjam.
a. Registration. To use the Site as a Publisher, You must provide Pepperjam with truthful, accurate and complete registration
information. If any such information changes, You must immediately contact Pepperjam to update Your registration
information.
b. Valid Information. Publisher agrees to provide Pepperjam and Advertiser with valid information about Publisher and
Publisher's promotional methods, and to maintain up-to-date account information, including contact information, web sites
used, ownership, and any other information requested by Pepperjam or the applicable Advertiser.
Pepperjam has the right to confirm and check the truth and accuracy of any registration information at any time.
Please note that the verification of Your registration information, specifically, name, address and tax identification number,
against a third party database may be considered under certain laws to constitute a "credit check" and You hereby consent to
any such verification process. Notwithstanding that, your participation in the Services as a publisher does not depend on Your
credit worthiness or financial stability.
If any information is determined by Pepperjam to be misleading, inaccurate or untruthful, Pepperjam may restrict, deny or
terminate Your account, Your access and use of the Services and the Site, and/or any benefits derived from Your participation
in any Advertiser Program, including the withholding or forfeit (in whole or in part) of any Publisher Fees to Pepperjam.
c. Standards. Publisher represents and warrants that all promotional means utilized by Publisher (a) will not contain
objectionable content (including but not limited to content that is misleading, illegal, and/or promoting illegal goods, services or
activities), and (b) will not mislead others. You further represent and warrant that the content of Your website and e-mails do
not promote, advocate, facilitate or otherwise include any of the following: (i) hate speech or material that discriminates on the
basis of race, ethnicity, gender, age, disability, religion or sexual orientation; (ii) investment, money-making opportunities or
advice not permitted under law; (iii) violence or profanity; (iv) pornographic, obscene, sexually explicit or related content; (v)
material that defames, abuses, is libelous, is tortuous or threatens physical harm to others; (vi) material that displays any
telephone numbers, street addresses, last names, URLs, e-mail addresses, any confidential information or any other
personally identifiable information of any third person; (vii) material that impersonates any person or entity; (viii) any indication
that any statements You make are endorsed by Pepperjam and/or an Advertiser, without Pepperjam's and/or Advertiser's
express prior written consent; (ix) promotion of illegal substances or activities (e.g., illegal narcotics, how to build a bomb,
counterfeiting money); (x); content which is inappropriate or harmful to children; (xi) promotion of terrorism or terrorist-related
activities, sedition or similar activities; (xii) software pirating (e.g., warez, hotline); (xiii) hacking or phreaking; (xiv) any material
that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the
functionality of any computer software or hardware or telecommunications equipment; (xv) any software, product or service
that is illegal or that violates the rights of a third party including, but not limited to, spyware, adware, programs designed to
send unsolicited advertisements (i.e. "spamware"), services that send unsolicited advertisements, programs designed to
initiate "denial of service" attacks, mail bomb programs and programs designed to gain unauthorized access to networks on
the Internet; (xvi) any software, product or service that harvests or collects the personal information of Internet users, whether
or not for commercial purposes, without the express consent of such users; (xvii) any spoofing, redirecting or trafficking from
other websites in an effort to gain traffic; (xviii) any content that infringes upon the intellectual property rights of any third party
or any other right including, without limitation, false advertising, unfair competition, invasion of rights of publicity or privacy;
(xix) illegal forms of gambling, contests, lotteries, raffles, or sweepstakes; (xx) any material that violates CAN-SPAM or any
similar or comparable laws in any other country or jurisdiction in which You operate; or (xxi) any illegal activity whatsoever
(including any violations of applicable U.S. state or federal law or regulation, Canadian provincial or federal law or the laws of
any other country or jurisdiction in which You operate).The Pepperjam Transparency Department may review Publisher
information, conduct and any suspected fraudulent, abusive or otherwise illegal content or activity. Any validated breach of
this Section is grounds for immediate termination of this Agreement, forfeit of Publisher Fees, and deactivation of Publisher's
account.
d. Promotional Method Restrictions. Publisher agrees that it shall comply with all laws and regulations and will not engage
in spamming, unlawful mass emailing or any unapproved emailing or in any way fail to comply with the CAN SPAM Act of
2003, 15 U.S.C. 7701, et seq., as amended, or any comparable laws, rules or regulations in any country from or to which
Publisher is accessing the Site or the Services or participating in any Advertiser Program, that govern email marketing and
advertising. Publisher agrees that its promotional activities will not infringe on the Advertiser's intellectual property rights,
including but not limited to copyright and trademark rights.
Publisher shall not perform trademark bidding or direct linking on search engines including on Google, Yahoo and MSN, when
the applicable Advertiser Program prohibits such activity. By "direct linking" this agreement refers to sending traffic directly
from the search engine to the Advertiser website without use of an intermediary landing page.
Pepperjam reserves the right at any time to further restrict what activities are considered valid and will entitle Publisher to
Publisher Fees under this Agreement. Pepperjam reserves the right to withhold, refuse or withdraw approval of any websites,
email distribution lists and/or marketing channels for any reason, whatsoever, in Pepperjam's sole discretion. Only Publisher's
websites, e-mail distribution lists or other marketing channels that have been reviewed and approved by Pepperjam may be
utilized in connection with the Site and Service.
e. Creative and Tags. Publisher shall not alter, modify or otherwise change the creative content, links and code used to
create the advertisements, text link, banner ad or coupon ("Creative"), or any Creative-related feature, that it obtains access
to in connection with any Advertiser Program in any manner whatsoever, without Pepperjam's prior express written consent.
PUBLISHER AGREES TO REVIEW THE AVAILABILITY OF CREATIVE THAT IT HAS PLACED WITHIN ITS MEDIA ON A
DAILY BASIS. IT IS THE PUBLISHER'S RESPONSIBILITY TO CHANGE CREATIVE WITHIN ITS MEDIA WHEN THE
CREATIVE IS NO LONGER AVAILABLE ON THE SITE. Pepperjam ASSUMES NO RESPONSIBILITY TO NOTIFY
PUBLISHER WHEN A SPECIFIC CREATIVE IS NO LONGER AVAILABLE ON THE SITE.
In addition, Site integration tags and tracking pixels ("Tags") included in the Creative or otherwise incorporated may not be
altered under any circumstances. Pepperjam employs a testing system to determine whether You have removed or altered
the Tags. Altering, removing or disabling Tags may jeopardize Your ability to be paid for Transactions and is grounds for
immediate termination of Your Publisher account, with or without notice. You will not, nor knowingly permit any person to,
activate Creatives or inflate the amount of Transactions through any deceptive or misleading practice, method or technology
including, but not limited to, the use of any spyware, device, program, robot, Iframes, hidden frames, redirects, spiders,
computer script or other automated, artificial or fraudulent methods designed to appear like an individual, real live person
performing an Transaction.
f. Personally Identifiable Information of Visitors. Publisher represents and warrants that Publisher will not enable the
tracking code to collect personally identifiable information of Customers or potential Customers that would allow You to
personally identify such Customer or potential Customer.
g. Privacy Policies. You will ensure that any and all websites employed by You in connection with Your participation in any
Advertiser Programs will feature an easy-to-understand privacy policy, linked, at a minimum, conspicuously from such
website's home page, with a link that contains the word "Privacy", "Legal", "Terms" or similar language. Such privacy policy
shall, in addition to the disclosures about Your privacy practices, identify the collection, disclosure and use of any information
related to an end user that You provide or may provide to Pepperjam and to any Advertiser or other websites or persons.
Such privacy policy shall also provide information on your use of tracking devices, such as but without limitation to, cookies,
including tracking devices enabled by Pepperjam at your request on your behalf. Your website will also include, where
required, information regarding the removal of cookies and other tracking devices.
h. PEPPERJAM REMEDIES. IN ADDITION TO ANY REMEDIES AVAILABLE TO Pepperjam OR THE APPLICABLE

ADVERTISER, PUBLISHER SHALL FORFEIT ANY AND ALL PUBLISHER FEES DURING THE PERIOD IN WHICH
PUBLISHER WAS IN VIOLATION OF THIS AGREEMENT.
3. Pepperjam's Services.
a. Access to Site and Service. Advertiser Program data compiled by Pepperjam including, but not limited to, numbers and
calculations regarding Transactions and associated Publisher Fees ("Program Data"), will be calculated by Pepperjam
through the use of Pepperjam proprietary tracking technology and shall be final and binding on You. Any questions regarding
the Program Data must be submitted in writing within fourteen (14) days of initial appearance in the tracking system;
otherwise the Program Data will be deemed to be accurate and accepted by You. Publisher understands and agrees that on
occasion the Service and/or the Site may be inaccessible, unavailable or inoperable. Pepperjam will attempt to provide the
Service on a continuous basis, but is under no obligation to provide the Service or maintain the availability of the Site on a
continuous or uninterrupted basis. Pepperjam's failure to deliver the Service because of technical difficulties does not
represent a failure to meet the obligations of this Agreement.
b. Tracking Publisher Fees. Pepperjam shall track actual Publisher Fees that should be credited to Publisher's account.
Pepperjam may, from time to time in its sole discretion, apply an estimated amount of Publisher Fees if there is a verified error
in Advertiser's tracking code.
c. Access to Tracking and Reporting Tools. Pepperjam shall provide Publisher with access to tracking and reporting tools
via the Site, and to other various support services that may be updated from time to time on the Site.
d. Support. Support for Publisher's program is available by contacting Pepperjam and reaching the appropriate person or
support services.
e. Payment of Publisher Fees. Subject to other provisions in this Agreement, Pepperjam shall credit Publisher's account
with a Publisher Fee for each qualifying Transaction in accordance with the Advertiser's payout rate and Advertiser Program
terms. On or around the 1st and 15th day of each calendar month, Pepperjam will credit to Publisher any positive balance in
Publisher's account for Transactions reported for the applicable period. Pepperjam shall have no obligation to make payment
of any Publisher Fees for which payment has not cleared to Pepperjam of all monies due to Pepperjam, including for all
Publisher Fees owed by such Advertiser to all of Advertiser's Publishers. If Pepperjam receives partial payment Pepperjam
may apply such partial payment first against the fees due to Pepperjam from such Advertiser and Publisher agrees that it
shall pursue any and all legal remedies only against the applicable Advertiser that has not made funds available to pay sums
due and owing to Publisher for Publisher Fees earned in connection with a particular Advertiser Program, subject to the terms
and conditions of the applicable Advertiser Program.
All Publisher Fees will be paid in US Dollars ($US). Notwithstanding anything contained herein to the contrary, no Publisher
Fees will be issued for any amounts due to Publisher that total less than twenty-five dollars ($25.00) ("Payment Threshold").
Every Publisher must have a unique, valid taxpayer identification number, valid Social Security Number, or other applicable
unique government identification. Publisher shall be responsible for all applicable taxes.
An Advertiser may request that Pepperjam, or Pepperjam may on its own initiative, debit from the Publisher Fees an amount
equal to a Publisher Fee previously credited to Publisher's account where: (a) a return or cancellation has been made with
respect to the applicable product and/or service; (b) there is an instance of a duplicate, fraudulent or incomplete entry or other
similar error with respect to a Customer order; (c) there are Transactions that do not comply fully with the terms of this
Agreement or the applicable Advertiser Program; (d) there is non-receipt of payment from, or refund of payment to, the
Customer that entered into the subject Transaction; (e) there is any failure on the part of the Publisher to comply with this
Agreement and or applicable Advertiser Program terms; or (f) any other amounts paid in error or due Advertiser from
Publisher (collectively referred to as a "Reversal"). Unless otherwise set forth in the applicable Advertiser Program, Reversals
requested by an Advertiser in accordance with this Section for Customer refunds and chargebacks may be applied up to sixty
(60) days after the end of the month in which the applicable Publisher Fee was earned ("Reversal Period"). For the
avoidance of doubt, there is no time restriction on any other Reversals. Advertiser may request that the payment of a
Publisher Fee be postponed for one (1) payment cycle where: (i) Advertiser is verifying a lead (for Advertiser Programs in
which lead generation is a component of the Transaction); (ii) Advertiser has a product return policy that allows the underlying
purchaser to return the product during the Reversal Period; or (iii) the applicable Advertiser Program provides for such a
postponement. The number or amount of Transactions, credits for payments and debits for Reversals, as calculated by
Pepperjam, shall be final and binding on Publisher.
You acknowledge that, with respect to any Advertiser Program, Your entitlement to any compensation reported with respect to
any tracked activity (if such activity is reported) stems solely from the terms of your agreement with the relevant Advertiser
and that such Advertiser is solely responsible for its payment.
f. Fraud. Pepperjam monitors traffic, Transactions, Publisher Fees and other Advertiser Program-related activities for potential
fraud. If Pepperjam suspects that Your account has been used in a fraudulent manner, Your account may be deactivated
effective immediately and with no notice to You pending further investigation. Pepperjam reserves sole judgment in
determining fraud and You agree to be bound by any and all such determinations. It is the obligation of Publisher to prove to
Pepperjam that it has NOT engaged in fraud. If you are unable to provide Pepperjam with satisfactory evidence that You have
not engaged in fraud within seven (7) days of Your Publisher Fees being placed in "Pending or Delayed Status," then
Pepperjam may terminate Your account and cancel payment on the applicable Publisher Fees, at its sole discretion and
without any further obligations to You. For the avoidance of doubt, if You add Transactions, or inflate Transactions, through
the use of fraudulent means of traffic generation, as determined solely by Pepperjam, You will forfeit all of the Publisher Fees
related to that Advertiser Program, and Your account may be terminated effective immediately.
g. Use of Site and Services. You may not use the Site or the Service in connection with aggregating, soliciting or recruiting
Advertisers, other publishers, other sites or other persons to form or join a marketing, advertising or similar network.
4. Proprietary Rights.
a. Linking to Advertisers. For each Advertiser Program that Publisher has applied to and been accepted to, the Advertiser is
granting to Publisher the right to link to the Advertiser's web site or web offers in accordance with the Advertiser Program
terms and this Agreement.
b. Pepperjam's Use of Publisher's Information. Publisher authorizes Pepperjam to utilize Publisher's otherwise protected
information subject to the provisions of Section 5 below related to confidentiality of Publisher's identification and marketing
data.
c. License Grant to Publisher. Subject to this Agreement and the terms of the applicable Advertiser Program, Pepperjam
grants to Publisher a revocable, non-transferable, royalty free, license to use the Site and the applicable tracking code.
Publisher may not remove or alter any copyright, service marks or trademark notices. Pepperjam reserves any and all rights
not explicitly granted in the Agreement.
5. Confidentiality.
Each Party will take commercially reasonable actions designed to protect the Confidential Information of the other Party from
misappropriation and unauthorized use or disclosure, and at a minimum, will take precautions at least as great as those taken
to protect its own confidential information of a similar nature. The receiving Party may disclose Confidential Information of the
disclosing Party to the extent necessary to comply with applicable Law. Upon request of the other Party, or in any event upon
any termination or expiration of this Agreement, each Party will return to the other or destroy all materials, in any medium,
which contain, embody, reflect or reference all or any part of any Confidential Information of the other Party. This Agreement
shall be the Confidential Information of Pepperjam.
Either Party will be entitled to seek preliminary and/or permanent injunctive relief from any violation or threatened violation of
this Section 5 without the necessity of proving actual damages or posting any bond or other security.
"Confidential Information" means all confidential and/or proprietary information and documents furnished or disclosed by or
on behalf of a Party or its affiliates, no matter when or how furnished or disclosed. Confidential Information includes, without
limitation, (a) all nonpublic information relating to a Party's or its affiliates' technology, business plans, agreements,
promotional and marketing activities, finances and other business affairs, and (b) all third party information that a Party or its
affiliates is obligated to keep confidential. Confidential Information may be contained in tangible materials, such as drawings,
data, specifications, reports and computer programs, or may be in the nature of unwritten knowledge. Confidential Information
does not include any information that (w) has become publicly available without breach of this Agreement, (x) can be shown
by documentation to have been known to the receiving Party at the time of its receipt from the disclosing Party or its affiliates,
(y) is received from a third party who did not acquire or disclose such information by a wrongful or tortious act, or (z) can be
shown by documentation to have been independently developed by the receiving Party without reference to any Confidential
Information.
6. Notices.
Except as provided elsewhere herein, Publisher must send all notices relating to this Agreement in writing via overnight mail
or fax: (a) to Pepperjam, 7 South Main Street, Third Floor, Wilkes-Barre PA 18701 with a copy to Pepperjam;, Attn: Legal
Department, 7 South Main Street, Third Floor, Wilkes-Barre PA 18701. All notices from Pepperjam shall be sent to the
address submitted by You when You sign up for the Service.
7. Term.
The Agreement shall commence upon Pepperjam's acceptance of Your publisher application and remain in effect until
terminated as set forth herein.
8. Termination.
Either party may terminate this agreement at any time. In addition, Pepperjam reserves the right, in its sole and absolute
discretion, to terminate an Advertiser Program, suspend Your participation in an Advertiser Program and/or remove any
Creatives at any time for any reason. Pepperjam also reserves the right to terminate Your access to the Site at any time.
Termination notice may be provided via e-mail and will be effective immediately. Upon termination, Publisher agrees to
immediately remove from its Publisher website(s) any and all Creatives, Pepperjam code or other intellectual property made
available to Publisher in connection with its performance under the Agreement. The representations, warranties and those
obligations that by their terms and context show the Parties intended them to survive the termination of this Agreement for
any reason, including provisions governing confidentiality, ownership, indemnification and liability, shall survive the expiration
or earlier termination of this Agreement.
9. Representations and Warranties.
The Parties hereby acknowledge and agree that Publisher is solely responsible for the method in which the Creatives are
disseminated. You represent and warrant that You will not engage in any activities that violate any Advertiser Program's terms
and conditions. Moreover, You represent and warrant that: (a) Your Publisher website and/or Publisher e-mails are
represented by a legitimate second-level domain name (e.g. yoursite.com is acceptable; however, a shared server, e.g.,
sharedsite.com/yoursite, is not acceptable); (b) Your Publisher website is not offered as a part of a community-based website
personal entry or personal page; (c) Your Publisher website and Publisher e-mails do not incentivize users to click on
Creatives, including by awarding users cash, points, prizes, and/or contest or sweepstake entries or any other incentives
("Incentives"); (d) Your Publisher Website is not hosted by a free service and is fully functional at all times and at all levels (no
"under construction" Publisher Websites or any sections thereof are permissible); (e) You will place or use the Creatives only
with the intention of delivering valid Transactions as determined by, and for the benefit of, the applicable Advertiser; (f) You
will not violate guidelines of any search engines being utilized; (g) You will not allow the Creatives to be placed on any non-
Publisher website without the prior express written consent of Pepperjam and the applicable Advertiser; (h) You will not use
any Creatives or any other Advertiser Program terms and/or content in connection with aggregating, soliciting or recruiting
other Publishers, Advertisers, other websites or other persons to form or join an affiliate marketing, advertising or similar
network for the purpose of engaging in business of the type conducted by Pepperjam; (i) You will not redirect traffic to a
website other than the website specifically listed by the applicable Advertiser; (j) Your performance under this Agreement shall
not in any way violate or infringe upon any third party rights, including rights regarding ownership, trade secrets, trademarks,
copyright or patents; (k) You shall protect, promote and preserve the goodwill associated with the Advertiser trade name and
any Customer relationships in connection with its performance hereunder; (l) in performing Your obligations and exercising
Your rights under this Agreement, You shall comply with all applicable laws (and all changes in laws) relating to or affecting
this Agreement or the work to be performed hereunder, and (m) You shall obtain and maintain all permits, licenses, and
consents required in connection therewith.
10. Limitation of Liabilities.
PEPPERJAM WILL NOT BE LIABLE (WHETHER IN CONTRACT, WARRANTY, TORT (INCLUDING, BUT NOT LIMITED TO,
NEGLIGENCE), PRODUCT LIABILITY OR OTHER THEORY), TO YOU OR ANY OTHER PERSON OR ENTITY FOR COST
OF COVER, LOST PROFITS, LOSS OF BUSINESS, DATA OR REPUTATION OR FOR ANY INDIRECT, INCIDENTAL,
SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES ARISING OUT OF THIS AGREEMENT.
PEPPERJAM'S AGGREGATE LIABILITY ARISING UNDER OR WITH RESPECT TO THIS AGREEMENT WILL IN NO
EVENT EXCEED FIFTY PERCENT (50%) OF THE TOTAL FEES PAID OR ACCRUED BY YOU TO PEPPERJAM DURING
THE THREE (3) MONTHS PRIOR TO THE EVENT GIVING RISE TO SUCH LIABILITY.
THE SITE AND THE SERVICE ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS AND ALL WARRANTIES,
EXPRESS AND IMPLIED, ARE DISCLAIMED (INCLUDING, WITHOUT LIMITATION, THE DISCLAIMER OF ANY
WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT OF INTELLECTUAL PROPERTY AND/OR FITNESS FOR A
PARTICULAR PURPOSE). THE SITE AND THE SERVICE MAY CONTAIN BUGS, ERRORS, PROBLEMS OR OTHER
LIMITATIONS. PEPPERJAM HAS NO LIABILITY, WHATSOEVER, TO PUBLISHER OR ANY THIRD PARTY, FOR
PUBLISHER'S USE OF, OR INABILITY TO USE, THE SITE OR THE SERVICE AND PEPPERJAM DISCLAIMS ANY AND
ALL WARRANTIES, EXPRESS AND IMPLIED, THAT PUBLISHER'S USE OF SAME WILL BE UNINTERRUPTED OR
ERROR-FREE OR THAT ANY OF THE ADVERTISER PROGRAMS WILL BE AVAILABLE TO PUBLISHER. PEPPERJAM
SHALL NOT BE RESPONSIBLE FOR THE FAILURE OR OTHER ACTS OR OMISSIONS OF ANY ADVERTISER.
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EXHIBIT M
3/20/2019 Organic Search is Responsible for 64% of Web Traffic
 SEO  Content  Marketing Stories  For Executives  Conductor Homepage
 Research
Organic Search Is Actually 


STAY UP TO DATE
Responsible for 64% of Your Get just one email a month packed with the
best of organic marketing.
Web Traf c (Thought *

Email Address *
Experiment) SIGN UP
By Nathan Safran  July 10, 2014
Groupon recently published a study showing 60% of their ‘direct’ tra c is actually
organic search tra c. With this new nding in mind, Conductor updated an earlier
study of 310 million visits and reallocated 60% of the study’s ‘direct’ visits to organic
search. The original study showed that 47% of visits were organic search; the updated
study suggests that organic search tra c might be responsible for closer to 64% of
website tra c.
Lots of interesting content on digital marketing is published every day, but a recent
article was amongst one of the most interesting (for many reasons!) I’ve ever read.
In Experiment Shows Up To 60% Of “Direct” Tra c Is Actually Organic Search,

Groupon’s Director of Product Management, who heads their organic search, detailed a
recent experiment where he completely deindexed Groupon from Google for 6
hours.
He did this, he explained, for the sake of SEO experimentation, and implies that it was
done because he and his team suspected that organic search Google Analytics metrics
are vastly being undercounted by bucketing a signi cant portion into the ‘direct visits’
bucket.
https://www.conductor.com/blog/2014/07/organic-search-actually-responsible-64-web-traffic/ 1/6
After deindexing the site from Google, e ectively turning o the spigot of Google
 SEO
tra c, he measured  Content
the degree to which direct Marketing
 visits Stories
decreased.  For Executives  Conductor Homepage
The ndings: direct visits dropped by 60%. This implies that 60% of direct tra c, is, in
fact, organic search tra c.
This implies that 60% of direct traf c, is, in fact, organic search
traf c.
The reason for this signi cant discrepancy is, as the author explains, due to a mix of
factors. Here are a few:
Browsers don’t always accurately report where the visitor came from
Encryption of website search tra c a ects the count
Older versions of Apple iOs report as ‘direct’
Whatever the reason, it seems clear that Groupon’s research has e ectively empirically
proven that a very substantial portion of direct tra c is in fact organic search.
Applying Adjusted Allocation to Conductor

Research on Web Visit Distribution
We released research not long ago that looked at more than 310 million visits. The study
concluded that 47% of tra c came from organic search. Nearly a third (29%) was
attributed to direct visits.
Given that insight and data into website tra c’s true breakdown can be hard to come
by and given that to my knowledge, an experiment of this kind, is unprecedented, we
wanted to see what would happen to our breakdown of web tra c if we were to plug
the conclusions of Groupon’s study into our data.
64% of Website Visitors Come from Organic

Search
By taking 60% of visits originally attributed to ‘direct’ and reallocating them to ‘organic
search’, organic search went from 47% of all visits to 64%. Direct visits dropped from
29% of visits to 12%. This signi cant discrepancy—17% separates the ‘before’ and ‘after’
allocations should be enough to give marketers pause—and question the assumptions
on which their digital strategy lies.
Organic Search is Responsible for a far Greater

Percentage of Website Traf c than Originally
Thought
The question of what percentage of our overall website tra c comes from organic
search is an important one. In fact, there is arguably no single more important piece of
information a search practitioner or marketing executive can have in budgeting,
headcount or strategy decisions. Improving organic search has implications on not only
paid search but now direct even if it is just a tracking measure.
In fact, there is arguably no single more important piece of

information a search practitioner or marketing executive can
have in budgeting, headcount or strategy decisions.
By plugging Groupon’s research into Conductor’s research on website tra c

distribution, it is clear that organic search is likely responsible for a far greater
percentage of site tra c than originally thought.
About the Author: Nathan Safran
Nathan is the Director of Research at Conductor and

leads Conductor’s research and content team. Nathan is
a monthly columnist at Search Engine Land and Search
Engine Watch. Nathan’s research on digital marketing
has been widely covered in both industry publications
and mainstream media such as Techcrunch, Venture Beat and the
Washington Post. Prior to joining Conductor, Nathan was an analyst at
Forrester Research.
 
The Ultimate Guide to Web Presence Management
Learn how to be intentional about putting the right content in

front of the right customer at the right time with this guide to
WPM.

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Adam Dince • 5 years ago

Yo Nathan. We're exploring this on our e-commerce sites
too. Especially since we have long ugly URLs :). I'll keep you
posted.
2△ ▽ • Reply • Share ›
free clipart > Adam Dince • 2 years ago

He did this, he explained, for the sake of SEO
experimentation, and implies that it was done
because he and his team suspected that organic
search Google Analytics metrics are vastly being
undercounted by bucketing a significant portion into
the ‘direct visits’ bucket.
Nathan Safran > Adam Dince • 5 years ago

Great, would love to hear what you find. (maybe a
follow up guest post? :)
october 2017 calendar > Nathan Safran

• 2 years ago
Do not what?
Adam Dince > Nathan Safran • 5 years ago

Sure.. let's see how quickly our analytics team
is able to lock down the test. I'm trying to
convince my boss to let us do a test the same
way that Groupon did, but don't know how
successful I'll be :).
Charity Mod > Adam Dince • 5 years ago

Sounds interesting...
△ ▽ • Reply • Share ›
Henry Scudder • 4 years ago

Nathan, Have you seen any statistics on how much of that
organic search is local vesus generic national? EG:
Ci i ti W b d i j t bd i b t
Cincinnati Web design vesus just web design but on a
national basis. Local clients often have trouble with local
organic search and it it is hard to find details on it as far as
how many people use it overall. I know they do, but how do
you prove that?
In other words, how much of the searche traffic come from

local searches? Any research that you know of?
Clipart Basketball > Henry Scudder • 2 years ago

Browsers don’t always accurately report where the
visitor came from
ashish t • 4 years ago

I heard it's because if you're signed into a google account,
google will reclassify the searches done as direct to keep
them anonymous (unsigned-in searches show their
keywords so appear in the Organic search, signed-in are
anonymized into Direct). Not sure how true that is, but I see
a distinct difference between GA organic search numbers
and Webmaster Tools organic search numbers.
Jason • 5 years ago

The 60% from Groupon was just for long URLs (and not
even all long URLs), so applying it to a whole site would
likely end up moving too much traffic from Direct to Organic.
I wrote a full analysis of this on my blog here:
https://www.quantable.com/o... if you want to check that out.
Nathan Safran > Jason • 5 years ago

Hey Jason,
Perhaps, it's hard to know for sure the percentage of

direct traffic that is actually organic search--this post
was intended primarily as a thought experiment--
what happens if we plug Groupon's findings into a
large data set of web traffic.
Either way, thanks for the comment.

Jason > Nathan Safran • 5 years ago

Hi Nathan,
That makes sense, thanks for the follow-up! I
did get that what you were saying was
basically a "what-if" scenario, I just wanted to
point out that Groupon's 60% number was
just for a small subset of their pages. What I
was trying to derive in my article was the
amount of Organic traffic that might slip
through tracking in general, so you could plug
that number into any site's overall traffic
shares breakdown to try and get whatever the
60% equivalent is for a particular site.
David Lieder > Jason • 4 years ago
Ready to Reach Your Customers Organically?

Let us show you how we work with leading brands to grow tra c and increase revenue.
See a Live Demo
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EXHIBIT N
3/20/2019 LegalForce, Inc. Mail - Imagine.. (branding)
Sarah Goll <sarah@trademarkia.com>
Imagine.. (branding)
Raj V. Abhyanker <raj@rajpatent.com> Wed, Nov 16, 2011 at 11:25 AM
To: John Suh <jsuh@legalzoom.com>
Cc: Vivian Chace <vchace@legalzoom.com>, Chas Rampenthal <chasr@legalzoom.com>, Fred Krupica
<fkrupica@legalzoom.com>, Adam Thomas <adamt@legalzoom.com>, Brian Liu <bliu@legalzoom.com>, Carter Gaffney
<cgaffney@legalzoom.com>, Dan Goldman <dgoldman@legalzoom.com>, Sarah Goll <sarah@trademarkia.com>, Dongxia
Liu <dongxia@trademarkia.com>, Hairong Lei <hlei@trademarkia.com>, "clifford@trademarkia.com"
<clifford@trademarkia.com>, Elizabeth Oliner <liz@rajpatent.com>
John,
Great! ps.. Imagine.. see attached. 18 million unique visitors and more than 36 million page views a year seeing the
Legalzoom brand this way. Trademarkia now drives more than 1.5 million unique visitors and 3 million page views.
While our traffic is mostly organic, it is not diluted like Docstoc. Mostly businesses and entrepreneurs click on
Trademarkia pages, as they are interested in a brands, trademarks, and/or products.
Our organic audience is mostly small businesses that need a lot of the services that Legalzoom offers. Also, with this,
even more than 50% of Americans will know the Legalzoom brand very soon! In addition, the branding should pay for
itself through increased $ sales. If you check Alexa, Trademarkia traffic today reached 6,315 (8,700 overall worldwide
and 3100 in the U.S.). By branding LegalZoom on Trademarkia, the Legalzoom brand would be seen on effectively twice
as many pages as our traffic rankings are virtually equal now according to Alexa. Trademarkia continues to grow very
fast, and our traffic now dwarfs Rocketlawyer, Logoworks, and we're a little bigger than even Justia etc. We expect
Trademarkia site traffic to double by this time next year (many cool features in our pipeline!).
Raj :)
On Wed, Nov 16, 2011 at 10:34 AM, John Suh <jsuh@legalzoom.com> wrote:
Great. Look forward to seeing everyone from the Trademarkia team!
John Suh | CEO
323.962.8600 xtn 3888| Fax 323.790.1993 | jsuh@legalzoom.com

www.legalzoom.com | 101 N. Brand Blvd., 11th Floor, Glendale, CA 91203
This transmission may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is
strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply email and delete all copies of this
message.
https://mail.google.com/mail/u/5?ik=4608060f70&view=pt&search=all&permmsgid=msg-f%3A1385663352343435334&simpl=msg-f%3A13856633523… 1/5
LegalZoom is not an attorney and can only provide self help services at your specific direction. LegalZoom.com, Inc. is a registered and bonded legal document
assistant, #0104, Los Angeles County (exp. 12/11). Prices, features, terms and conditions are subject to change without notice.
P Go Green! Print this email only when necessary. Thanks for helping LegalZoom be environmentally responsible.
From: Raj V. Abhyanker [mailto:raj@rajpatent.com]

Sent: Wednesday, November 16, 2011 10:03 AM
To: John Suh; Vivian Chace
Cc: Chas Rampenthal; Fred Krupica; Adam Thomas; Brian Liu; Carter Gaffney; Dan Goldman; Sarah Goll; Dongxia
Liu; Hairong Lei; clifford@trademarkia.com; Elizabeth Oliner
Subject: Re: Partnership, next steps
Vivian and John,
We'll come 2pm to 5pm on Monday per your email below. To make the meeting more productive, and since it is our
understanding that we now have a NDA in place, the following individuals from the Trademarkia team will be coming
along with me. They are experts in their respective areas, and in most cases know more than I do about Trademarkia's
synergies with Legalzoom :
1. Dongxia Liu, CTO and co-founder of Trademarkia (can speak to how technology integration can work to ensure
smooth operational processes of handling Legalzoom IP matters)
2. Sarah Goll, Head of Operations and RAPC coordinator for Trademarkia (can speak to separation of attorney/client
privilege, operational issues, customer service management best practices)
3. Clifford Si, lead paid search specialist for Trademarkia (can speak to details of our paid search campaign
management, opportunities to synergizing, international campaign possibilities for patents/trademarks)
4. Hairong Lei, Executive Vice President, international and foreign markets for Trademarkia (can speak to foreign
counsel management, international coordination for patents and trademarks in 55 countries).
5. Liz Oliner, Client Relations Attorney lead for RAPC (can speak about on the way the law firm interacts with
Trademarkia and builds our client relations practice with attorneys).
I have copied them on this email, looking forward to it!
Kind regards,
Raj
---------- Forwarded message ----------

From: Vivian Chace <vchace@legalzoom.com>
Date: Tue, Nov 15, 2011 at 11:33 AM
Subject: RE: Partnership, next steps
To: Raj Abhyanker <raj@rajpatent.com>
Dear Mr. Abhyanker,
Will any of these options work for your schedule while in LA? Tuesday 9:30am-12:30pm or 3:00pm-
6:00pm or Monday 2:00pm-5:00pm?
Thank you,
Vivian
On Tue, Nov 15, 2011 at 11:27 AM, John Suh <jsuh@legalzoom.com> wrote:
Raj,
If you’re in town Monday and Tuesday, let’s definitely meet up. Vivian, can you coordinate a time?
To flesh out a business partnership, let’s set up time with the following folks:
· Dan Goldman (IP legal architect)
· Carter Gaffney (VP, Attorney Services)
· Adam Thomas (VP, Operations)
· Brian Liu
I think we can make a lot of headway in a 2-3 hour session.
John
From: Raj Abhyanker [mailto:raj@rajpatent.com]

Sent: Monday, November 14, 2011 7:01 PM
To: John Suh
Cc: Chas Rampenthal; Fred Krupica; Vivian Chace
Subject: Partnership, next steps
Good talking this afternoon John. Sorry for the phone quality woes. Let me know when you want to meet next as a
follow up. Per our discussion, agenda for next meeting:
1. Figuring out a legal service plan for IP to have OAs, patents and trademarks through RAPC. Id like to ideally do this
on a cost plus basis for you and cancel our entire $90K a month trademark ad spend so that we both stop double
bidding, and depend solely on direct organic and raise price to $169 per class. We did not talk of this possibility on the
call, but We can hadle all initial filings for Legalzoom as well though RAPC on a pure cost plus basis that way.
2. International Trademarks and PCT/national phase patents- explore. Big $ making potential.
3. Explore legalzoom handling all incorporations, llcs through upcoming Trademarkia feature.
4. New! Explore giving Legalzoom exclusive branding on the more than 3 million monthly page views and more than
1.5 million unique visitors on Trademarkia. (just thought of this possibility).
Thoughts?
Next week, I'm driving with my family to parent's house in Phoenix for Thanksgiving. I'll be in the LA area Monday and
Tuesday if you would like to meet then. Alternatively, we can meet here in here this week, or the week after next. I'm
planning on taking a vacation the week of December 14 to the big island of Hawaii. Other than that, I'm free whenever
you want to follow up.
Hopefully this can be the start of a long, and mutually beneficial business relationship.
Respectfully,
Raj
408-398-3126 cell
Sent from my iPhone
--
Raj Abhyanker
Partner
Raj Abhyanker P.C.

Legal Protection for Global Innovation
Professional Law Corporation
1580 W. El Camino Real Suite 8
650-965-8731 (office)
United States. United Kingdom. China. India. France.

www.rajpatent.com
http://www.linkedin.com/pub/raj-abhyanker/0/41/73
Quora Answers : http://www.quora.com/Raj-Abhyanker-1
About RALLP - Raj Abhyanker P.C. is a leading intellectual property and corporate law firm, providing high-quality
patent, trademark, and business legal services to multinational and venture backed clients.
This electronic transmission contains information which is confidential and/or privileged. The information is intended for
use only by the individual or entity named above. If you are not the intended recipient (or the employee or agent
responsible for delivering this information to the intended recipient), you are hereby notified that any use,
dissemination, distribution, or copying of this communication is prohibited. If you have received this information in error,
please notify me by electronic mail and delete all copies of the transmission. Thank you.
--
Raj Abhyanker
Partner
Raj Abhyanker P.C.

650-965-8731 (office)

www.rajpatent.com
About RALLP - Raj Abhyanker P.C. is a leading intellectual property and corporate law firm, providing high-quality patent,
trademark, and business legal services to multinational and venture backed clients.
This electronic transmission contains information which is confidential and/or privileged. The information is intended for
use only by the individual or entity named above. If you are not the intended recipient (or the employee or agent
responsible for delivering this information to the intended recipient), you are hereby notified that any use, dissemination,
distribution, or copying of this communication is prohibited. If you have received this information in error, please notify me
by electronic mail and delete all copies of the transmission. Thank you.
idea-legalzoomtrademarkia.pdf
100K
EXHIBIT O
$120,000 per month:
Trademarkia
EXHIBIT P
$45,000 per month:
3/18/2019 Exhibit cover sheet (by letter) - Google Docs
EXHIBIT Q
https://docs.google.com/document/d/1NCqe2TBDZ_519CZyI9TvTwJK8EazkcaDDaN7P5NJgcs/edit 18/38
MUTUAL NONDISCLOSU RE AGREEMENT
This Mutual Nondisclosure Agreement (the "Agreement") is entered into as of the last date of e~ecution set forth below, and is made by and
between l egaIZoom,com. Inc., a Delaware corporation whOse principal address is 101 N. Brand Blvd., l1 tt> Floor, Glendalo, CA 91203 and Trademarkia.
Inc., a Delaware co rporation dIbIa Tradema l1da.com whose principal address is 1580 W_ EICamino Real Suite 10, Mounl ain View, CA 94040.
IN CONSIDERATION OF THE MUTUAL PROMISES AND CO VENANT S CONTAINED IN THIS AGREEMENT AND THE MUTUAL
DISCLOSURE OF CONFIDENTI AL INFORMATION, the parties hereto agree as follows '
1. ~. The parties agree there is a mutual indication of interest and, in 4. No Obligation. Nothin g herein Obligates either party to proceed with any
connection with this interest, the panies wish to e)(plore a potential transaction between them, and each party reseNes the right, in its sole
partnership or other opportuni ty (Itle "Purpose"). In connection will'l the discretion. to terminate the diSCUSsions contemplated by this Agreement
Purpose. each party may disclose to the other certain confidential technical co ncerning the business opportunity. if any, and to cea se further disclosures,
and business inlormation lhat the Disclosing Party (as defined below) wants commu nications, or other activities under this Agreement upon wrinen notice
the Ae<::eiving Party (as defined below) to treat as confidential. to the other party.
2. ·Confidential Information" means any noopublic information that either 5, No Warranty, ALL CONFIDENTIAL INFORMATION IS PROVIDED "AS
party (the "DiscIOSUl9 Pany") discloses to the other party ("Receiving Party"J, 1$," NEITHER PARTY MAKES ANY W ARRANTIES, EXPRE SS, IMPLIED,
either directly or indirectly, in writing, orally, or by inspection 01 tangible OR OTHERWISE, REGARDING THE ACCURACY, COMPLETENESS. OR
obj ects (including without limitation documents, prototypes, samples, plants, PERFORMANCE OF ANY SUCH INFORMATION.
and equipment), and designates as con fidential Of that under the
circum stances surrounding disclosure ought 10 be treated as con fidential by 6. Relurn of Materi als. All documents and other tangible objects containing
the Receiving Party. Except as otherwise indicated in this Agreement, the or representing Confidential Information thaI have been disclosed by either
term "Di sclosillQ Party' includes all AMiliates of the Disclosing Party and. porty 10 the olher party. and all copies thereot that are in the possession 01
except as otherwise indicated. the term "Receil/ing Party" includes all the other party , shall be and remain the property 01 the Disclosing Party. AI
Affil iates 0 1 the Re<::eiving Party . An "A ffiliate" is any person, pannership. joint the Disclosing Party's reques\, the Receiving Party shall promptly return or
venture. corpora tion , or other form of enterprise. domestic or loreign, destroy all such documents or Objects.
including, without limitation, subsidiaries lIlat directly or indirectly contrOl, are
controlled by. o r are under common contrOl wi th a jAlrty. Confidential 7. Ifllm. The obligations of each Receil/ing Party hereunde r shall sUNil/o
Information communicated orally Shall be considered Contiden1iallnlormation until the earl ier of (I) such time as all Confidential Information of the other
if such information is confirmed in writing as being Confidential Information party disclosed hereunder becomes publicly known and generally available
within a reasonable time after the initial disclosure. through no action Of Inaction 01 Ihe Raceil/ing Party: or (ii) lIle th ird
annive rsary of the disclosure: provided, however, to the extent that a party
Confidential Information Shall not, howev er, include any inform ation which (i) has disclosed information to the other party that cons titutes a trade secre t
was or becomes publicly known and generall y al/ailable belore the Disclosing under la w, the Receiving Party shall protect such trade secret(s) lor as long
Party made its disclosure: (ii) was or becomes publicly known and generally as the in formation qualifies as a trade secret under applicable law.
available after disclosure by the Disclosing Party \0 the Receiving Party
through no action or inaction of the Receil/ing Party: (iii) was known by the B. Miscellaneous. The parties agree not to disclose their participation in this
Receiving Party before disclosure by the Disclosing Party. as Shown by the undertaking. the e)(islence or te rms and CQnditions of the Agreement, or the
Receiving Party's files and records immediately prior to the time of fact that discussions are being held. Nothing in this Agreement is intended
disclosure: (iv) is obtained by the Aeceivlng Party from a third party withou t a to grant any rights to aither party under any patent, mark, work right,
breach of such third party's obligations at confidentiality; (v) is independently copyright, trade secret, or olher intellectual property right of the other party.
devcloped or acquired by the Recell/ing Party. as shown by dOCuments and This Agreement does not grant any party any rights in or to the Confidential
other competent evideoce in the Aeceiving Party's possession: or (I/i) Is Information of the other party except as e)(pressly set forth herein. Each
required by law 10 be disclosed by the Receiving Party, provided that Ihe party agrees Ihat any \lio lation or threatened violation 01 this Agreement
Receil/ing Party glvcs the Disclosing Party prompt written notice of such may cause irreparable injury to the other party, entitling the other party,
requirement Pfior to such disclosul e, and assists the Disclosing Party in without waiving any other rights or remedies and without posting a bond or
obtaining an order protecting the information from public disclosure. other security, to se ek injunctive relief in t II legal remedies. This
A,,,,,m,,,' shall be governed by Ihe of Cali forni a
3. Non-use and Nondisclosure ' Maintenance of Contidentialily. Each party to its conflict of laws
agrees not to: (i) use any Confidential Informalion of the other party lor any
purpose e_cepl 10 evaluate and engage in discussions concerning a potential
bUSiness relationship between the parties: (ii) disclose any Confidential
Information of the other party to th ird parties or to its own employees and
consultants. e_cept employees and consultants wh o need the Information to
evaluate or engage in discussions about the contemplated business
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prototypes, software, or other tangible objects that embody the other party's parties agree that all i (other than summary
Confi dential Information and th aI are provided to the party hereunder. EaCh out of or rela ting to this Agreement shall be resolved by
party shall take reasonable measures to protect the secrecy of and aI/aid a judicial pursuant 10 California Code 0 1 Civil Procedure § 63B at
disclosure and unauthorized use 0 1 the other party's Confidential Information seq. This Agreement shall bind and inure to the bene fit of the parties and
Witlloul limiting the loregoing, each party shali lake at least those measures it their successors and assigns. This Agreement is Ihe complete and
lakes 10 prOl ect il s own most highly CQnfidential information and shall ensure e_cluslve expression 01 the parties' agreement with respec t 10 the subject
that its employees with access 10 the Olher party's Confidential Information maner hereof. Any tailure to enforce any provision of this Agreement shall
hal/e signed a non-use and nondisclosure agreement, similar in content to not constitute a waiver thereof or of any other provision. No waiver of a
the provisions of this Agreement before disclosing Contidenlial Iniormation to bre ach, fail ure of any COndition, or any right or remedy conl ained in Of
such employees. Neither party shall make any copios of the other party's gran ted by the provisions of this Agreement will be ellective unless it is in
Confidential Information wit hout the prior writt en permission of the Disclosing writing and signed by the party waiving Ihe breach. failure, right. or rem edy.
Party, Each party shall reproduce the olher party's proprietary rights notices No amendment to this Agreement will be eHective unless il is in writ ing and
on any SUCh approved copies. in the same manner in wh ich such notices si gned by both parties.
were set forth in or on the Ol'iginal.
Accepted and agreed to by the parties.
LEG AUOOM. TRAOEMARKIA, INC.
Signature' Signa ture:

~~
Print Name . Print Name: ( \?~
Title: Title: I Ch
Date: Dale: l \ I'" II!
3/18/2019 Exhibit cover sheet (by letter) - Google Docs
EXHIBIT R
https://docs.google.com/document/d/1NCqe2TBDZ_519CZyI9TvTwJK8EazkcaDDaN7P5NJgcs/edit 19/38
3/20/2019 LegalForce, Inc. Mail - Re: follow up
Clifford Si <clifford@trademarkia.com>
Re: follow up
Raj Abhyanker <raj@rajpatent.com> Tue, Nov 8, 2011 at 7:38 AM
Cc: Daniel Hansen <dhansen@mh-llp.com>, Chas Rampenthal <chasr@legalzoom.com>, Fred Krupica
<fkrupica@legalzoom.com>
Hi John,
Thanks for letting me know. I'll cancel my flight today. Let me know if and when you want to re-engage. As I mentioned,
we are in active talks right now with Thompson, Rocketlawyer, Google, and a number of venture capitalists. We intend to
make a firm decision on our future direction in the coming months.
Kind regards,
Raj
Sent from my iPhone
On Nov 7, 2011, at 10:36 PM, John Suh <jsuh@legalzoom.com> wrote:
Raj,
Perhaps we're moving too fast. This is the first and only time in 10 years I remember a jury trial becoming a
sticking point in an NDA.
Let's cancel tomorrow rather than rush into something where we're not comfortable. I'm flying to New York
on Wednesday, and Fred is in London next week. Let's resume conversations at a more measured pace.
John
From: Daniel Hansen <dhansen@mh-llp.com>

Date: Mon, 7 Nov 2011 22:53:36 -0600
To: Chas Rampenthal <chasr@legalzoom.com>
Cc: "raj@rajpatent.com" <raj@rajpatent.com>, Fred Krupica <fkrupica@legalzoom.com>, John Suh
<jsuh@legalzoom.com>
Subject: RE: follow up
Dear Chas,
Thank you for your email.
By way of context, John invited Raj to meet with Fred and him on short notice and have asked to see
Trademarkia’s and Raj’s law firm’s confidential information with a goal towards, in John’s words, exploring
“a partnership including but not limited to an acquisition.”
We revised your form NDA and accepted 2 of the 3 comments back. I think we’ve been reasonable. Jury
trial is a fundamental right and our client feels its waiver is not appropriate in this context. The parties can
always waive it later if the circumstances warrant.
https://mail.google.com/mail/u/4?ik=3de3c2e5ec&view=pt&search=all&permmsgid=msg-f%3A1384924297984617410&simpl=msg-f%3A13849242979… 1/5
Attached are the final forms (one for Trademarkia and one for Raj’s firm). Note that we added a bilateral
attorneys fees clause at the end of Section 8, as is typical.
Let us know if Raj should cancel his flight.
Best regards,
Dan
Daniel R. Hansen
Managing Partner
Montgomery & Hansen, LLP
525 Middlefield Road, Suite 250
Menlo Park, CA 94025
(650) 331-7003 (direct)
(650) 331-7001 (fax)
(650) 867-4179 (cell)
dhansen@mh-llp.com
<image001.jpg>
_______________________________
This e-mail message is for the sole use of the intended recipient(s) and may contain confidential and
privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are
not the intended recipient, please contact the sender by reply e-mail, and destroy all copies of the
original message. To ensure compliance with requirements imposed by the IRS, we inform you that any
tax advice contained in this communication, unless expressly stated otherwise, was not intended or
written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the
Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related
matter(s) addressed herein.
From: Chas Rampenthal

To: Daniel Hansen
Cc: raj@rajpatent.com; Fred Krupica; John Suh
Dan –
Having read your comments below, we s ll prefer a bench trial in a B2B dispute over a mutual NDA. If
this were pre-2005 (before the Gra on case), we could have a simple jury waiver clause. Since CA law
does not currently allow pre-dispute waivers, the only choices are arbitra on or Cal. Civ. Code 683
(judicial reference). The only reason that the judicial reference language is in there is if we would not
mutually agree to have a regular judge try the case (it is a fallback clause). I am not a fan of arbitra ng
disputes like this – all too o en arbitrators punt and refuse to make the hard decisions that a judge will.
If your concern was over the judicial reference language, then you need not be too concerned. If there
is a more fundamental disconnect over wan ng a jury, then that is a different issue. For the la er, we
will need to talk before your client wastes me traveling to LA. I am on my cell, 310-709-1430 for a
couple more hours if you need to discuss this.
Chas Rampenthal
General Counsel
LegalZoom.com, Inc.
From: Vivian Chace

To: Chas Rampenthal
Subject: FW: follow up
Importance: High
Chas, please advise.
Thank you,
Vivian
From: Daniel Hansen

To: Vivian Chace
Cc: Raj V. Abhyanker (raj@rajpatent.com); Fred Krupica; John Suh
Dear Vivian,
We’re OK with the changes in Sec on 2 (confirma on on oral disclosure) and 7 (with 5yrs) but prefer to
keep the jury trial. I disagree that’s standard. Please revise Sec on 8 and circulate in final for signature.
Best regards,
Dan
Daniel R. Hansen
Managing Partner
(650) 331-7003 (direct)
(650) 331-7001 (fax)
(650) 867-4179 (cell)
dhansen@mh-llp.com
<image001.jpg>
_______________________________
privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are
not the intended recipient, please contact the sender by reply e-mail, and destroy all copies of the
original message. To ensure compliance with requirements imposed by the IRS, we inform you that any
tax advice contained in this communication, unless expressly stated otherwise, was not intended or
written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the
Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related
matter(s) addressed herein.
From: John Suh

To: Fred Krupica; Daniel Hansen; Vivian Chace; Raj V. Abhyanker; Jessica Farinas
Cc: Sarah Goll
Daniel,
Haven’t heard anything back on Fred’s email. But to be clear, we are exploring a partnership up to and
including acquisi on.
Since we have had no financial informa on, it would be premature to put forward an LOI.
Perhaps we should explore strategy and qualita ve issues tomorrow, discuss top level financials, and
save the exchange of detailed financials / valua on for a later date.
John
John Suh | CEO

<image002.png>
EXHIBIT S
3/20/2019 LegalForce, Inc. Mail - Fwd: Executed NDA
Fwd: Executed NDA

Raj V. Abhyanker <raj@rajpatent.com> Thu, Nov 17, 2011 at 3:28 PM
To: clifford@trademarkia.com

From: Raj V. Abhyanker <raj@rajpatent.com>
Date: Thu, Nov 17, 2011 at 3:28 PM
Subject: Fwd: Executed NDA
To: sarah <sarah@rajpatent.com>, Dongxia Liu <dongxia@rajpatent.com>, Hairong Lei <hlei@trademarkia.com>

From: Chas Rampenthal <chasr@legalzoom.com>
Date: Thu, Nov 17, 2011 at 3:21 PM
Subject: RE: Executed NDA
To: "Raj V. Abhyanker" <raj@rajpatent.com>, Daniel Hansen <dhansen@mh-llp.com>
Here you go!
Sent: Wednesday, November 16, 2011 2:47 PM

To: Chas Rampenthal; Daniel Hansen
Subject: Re: Executed NDA
thanks Chas. Please copy your friend Dan. Copying Dan. Thanks, Raj
On Wed, Nov 16, 2011 at 2:34 PM, Chas Rampenthal <chasr@legalzoom.com> wrote:
I finally got my hands on it. I’m scanning it into our system. As soon as I get a copy, I’ll shoot it over. Take care.

Sent: Wednesday, November 16, 2011 11:33 AM
To: Chas Rampenthal
Cc: Sarah; Jessica Farinas
Subject: Re: Executed NDA
Chas,
I had a nice call with John on Monday in reliance on the executed NDA since you did not indicate below otherwise that it was not
signed. Please fax an executed one back to me when you get a chance. Look forward to meeting you in person next week!
Raj
On Mon, Nov 14, 2011 at 12:31 PM, Chas Rampenthal <chasr@legalzoom.com> wrote:
Raj - I'm in DC right now, returning to the office tomorrow afternoon. I'll contact John about this.
Sent from my iPhone
On Nov 14, 2011, at 12:29, "Raj Abhyanker" <raj@rajpatent.com> wrote:
Hi Chas,
I hope that you had a nice weekend. I am scheduled to talk with John at 3pm today. I don't have the executed NDA yet.
Can you send it back to me executed at this email or via fax at 6509892131. No rush, I will talk with John today in
reliance on the fact you have executed it.
Kind regards,
Raj
Ps. I saw your and your legal team's videos on the Legalzoom website this weekend. Looks like you have a very
intelligent and dynamic team!
Sent from my iPhone
On Nov 7, 2011, at 6:58 PM, Chas Rampenthal <chasr@legalzoom.com> wrote:
Dan –
Having read your comments below, we still prefer a bench trial in a B2B dispute over a mutual
NDA. If this were pre-2005 (before the Grafton case), we could have a simple jury waiver
clause. Since CA law does not currently allow pre-dispute waivers, the only choices are
arbitration or Cal. Civ. Code 683 (judicial reference). The only reason that the judicial reference
language is in there is if we would not mutually agree to have a regular judge try the case (it is a
fallback clause). I am not a fan of arbitrating disputes like this – all too often arbitrators punt
and refuse to make the hard decisions that a judge will.
If your concern was over the judicial reference language, then you need not be too concerned.
If there is a more fundamental disconnect over wanting a jury, then that is a different issue. For
the latter, we will need to talk before your client wastes time traveling to LA. I am on my cell,
310-709-1430 for a couple more hours if you need to discuss this.
Chas Rampenthal
General Counsel
LegalZoom.com, Inc.
From: Vivian Chace

To: Chas Rampenthal
Importance: High
Thank you,
Vivian
From: Daniel Hansen

To: Vivian Chace
Dear Vivian,
We’re OK with the changes in Section 2 (confirmation on oral disclosure) and 7 (with 5yrs) but
prefer to keep the jury trial. I disagree that’s standard. Please revise Section 8 and circulate in
final for signature.
Best regards,
Dan
Daniel R. Hansen
Managing Partner
(650) 331-7003 (direct)
(650) 331-7001 (fax)
(650) 867-4179 (cell)
dhansen@mh-llp.com
<image001.jpg>
_______________________________
privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not
the intended recipient, please contact the sender by reply e-mail, and destroy all copies of the original
message. To ensure compliance with requirements imposed by the IRS, we inform you that any tax
advice contained in this communication, unless expressly stated otherwise, was not intended or written to
be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal
Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related matter(s)
addressed herein.
From: John Suh

To: Fred Krupica; Daniel Hansen; Vivian Chace; Raj V. Abhyanker; Jessica Farinas
Cc: Sarah Goll
Daniel,
Haven’t heard anything back on Fred’s email. But to be clear, we are exploring a partnership up
to and including acquisition.
Since we have had no financial information, it would be premature to put forward an LOI.
Perhaps we should explore strategy and qualitative issues tomorrow, discuss top level
financials, and save the exchange of detailed financials / valuation for a later date.
John
John Suh | CEO

<image003.png>
--
Raj Abhyanker
Partner
Raj Abhyanker P.C.

650-965-8731 (office)

www.rajpatent.com
About RALLP - Raj Abhyanker P.C. is a leading intellectual property and corporate law firm, providing high-quality patent, trademark,
and business legal services to multinational and venture backed clients.
This electronic transmission contains information which is confidential and/or privileged. The information is intended for use only by the
individual or entity named above. If you are not the intended recipient (or the employee or agent responsible for delivering this
information to the intended recipient), you are hereby notified that any use, dissemination, distribution, or copying of this communication
is prohibited. If you have received this information in error, please notify me by electronic mail and delete all copies of the transmission.
Thank you.
--
Raj Abhyanker
Partner
Raj Abhyanker P.C.

650-965-8731 (office)

www.rajpatent.com
Thank you.
--
Raj Abhyanker
Partner
Raj Abhyanker P.C.

650-965-8731 (office)

www.rajpatent.com
Thank you.
--
Raj Abhyanker
Partner
Raj Abhyanker P.C.

650-965-8731 (office)

www.rajpatent.com
Thank you.
2 attachments
NDA - Raj Abhyanker, Inc. 11-08-2011 [EXECUTED].pdf
600K
Trademarkia_LegalZoom_NDA_11.16.11.pdf
602K
3/20/2019 LegalForce, Inc. Mail - Partnership, next steps
Partnership, next steps

Raj Abhyanker <raj@rajpatent.com> Mon, Nov 14, 2011 at 7:00 PM
Cc: Chas Rampenthal <chasr@legalzoom.com>, Fred Krupica <fkrupica@legalzoom.com>, Vivian Chace <vchace@legalzoom.com>
Good talking this afternoon John. Sorry for the phone quality woes. Let me know when you want to meet next as a follow up. Per our
discussion, agenda for next meeting:
1. Figuring out a legal service plan for IP to have OAs, patents and trademarks through RAPC. Id like to ideally do this on a cost plus
basis for you and cancel our entire $90K a month trademark ad spend so that we both stop double bidding, and depend solely on direct
organic and raise price to $169 per class. We did not talk of this possibility on the call, but We can hadle all initial filings for Legalzoom
as well though RAPC on a pure cost plus basis that way.
2. International Trademarks and PCT/national phase patents- explore. Big $ making potential.
3. Explore legalzoom handling all incorporations, llcs through upcoming Trademarkia feature.
4. New! Explore giving Legalzoom exclusive branding on the more than 3 million monthly page views and more than 1.5 million unique
visitors on Trademarkia. (just thought of this possibility).
Thoughts?
Next week, I'm driving with my family to parent's house in Phoenix for Thanksgiving. I'll be in the LA area Monday and Tuesday if you
would like to meet then. Alternatively, we can meet here in here this week, or the week after next. I'm planning on taking a vacation
the week of December 14 to the big island of Hawaii. Other than that, I'm free whenever you want to follow up.
Hopefully this can be the start of a long, and mutually beneficial business relationship.
Respectfully,
Raj
408-398-3126 cell
Sent from my iPhone
Sorry, Raj. Our day got rescheduled and is packed.
Appreciate the flexibility on the NDA… lawyers can be bulldogs. ;)
Let me look things over and get a list of ques ons together. Let’s rap first thing on Monday. Vivian?
John
John Suh | CEO

<image002.png>
message.
LegalZoom is not an attorney and can only provide self help services at your specific direction. LegalZoom.com, Inc. is a registered and bonded legal document assistant,
#0104, Los Angeles County (exp. 12/11). Prices, features, terms and conditions are subject to change without notice.
P Go Green! Print this email only when necessary. Thanks for helping LegalZoom be environmentally
responsible.

Sent: Tuesday, November 08, 2011 1:01 PM
To: John Suh
Cc: Chas Rampenthal; Fred Krupica
Subject: Re: Trademarkia and RAPC financial stats, high level
John,
I really don't want to get hung up over jury issue in the NDA. Let's involve my outside counsel Dan Hansen and other
members of our company only when the time is right. He is a bulldog, but really is looking out for my best interests. I
trust you - and that is what is most important to me. Here is your original NDAs, signed by me.
This being said, I really prefer discussing your questions in person or over teleconference than through long winded
emails/responses. Perhaps we can do a teleconference today from 2 to 6 instead of face to face, and you can email to
me your questions in advance?
I can give you a conference line dial in number if you prefer. I also have a number of questions I'd like to ask you to
make sure we are a mutually good fit if you are serious about things. Among these questions are :
1. Most recent valuations (for both preferred stock (Kleiner) and common stock (options))
2. Revenue run rate
3. Margins and profitability %
4. Liquidation stack (how much value is ahead of the common stock)
5. Is liquidation preference participating or non-participating
6. Plan to raise any other money?
7. Expected exit and when? If IPO, has Legalzoom hired bankers?
8. Have Legalzoom done other acquisitions? If so, what was the structure?
9. Any other acquisitions expected?

10. Most recent financials.
Look forward to exploring further.
Raj
On Tue, Nov 8, 2011 at 12:21 PM, John Suh <jsuh@legalzoom.com> wrote:
Raj,
I appreciate the sharing of info, but I think we should only proceed with an NDA in place. Chas informed
me that without a signed NDA, there can be no agreement in principle because we have no mechanism for
resolving a disagreement.
I’ll ask everyone to delete your email unless you feel comfortable sharing this outside of an NDA.
If you want to proceed, Fred and I can fashion a list of questions for exploring the opportunity and think in
broad terms about valuation / structure.
John
John Suh | CEO

<image003.png>
message.
LegalZoom is not an attorney and can only provide self help services at your specific direction. LegalZoom.com, Inc. is a registered and bonded legal document assistant,
#0104, Los Angeles County (exp. 12/11). Prices, features, terms and conditions are subject to change without notice.
P Go Green! Print this email only when necessary. Thanks for helping LegalZoom be environmentally responsible.

Sent: Tuesday, November 08, 2011 11:20 AM
To: John Suh
Cc: Chas Rampenthal; Fred Krupica
Subject: Re: Trademarkia and RAPC financial stats, high level
also.. a few more things to note :
The firm/Trademarkia is highly profitable at steady state (if no new investments in strategic growth) with EBITA of over
20%.
Also, our paid search budget is a small fraction of our revenues, at about $720,000 to $1M per year.
Raj
On Tue, Nov 8, 2011 at 9:52 AM, Raj V. Abhyanker <raj@rajpatent.com> wrote:
John,
Here are high level financial stats, which might help your internal discussions.
2011 - As a percentage, Trademarkia sales accounted for about $3.5M of the expected $5.5M RAPC revenue this
year. (1.9M non trademarkia directly). This means 63% of RAPC revenue is expected to be through Trademarkia this
year. This does not include approximately $7M in government fees.
2010 - In 2010, Trademarkia sales were about $1.5M of the $3.1M in RAPC revenue. (1.6M non trademarkia
directly). This means 48% of RAPC revenue was through Trademarkia that year.
2009- In 2009, Trademarkia sales were about $215K as the site launched September 15, 2009. The RAPC revenue
that year was of the $1.35M in RAPC revenue. (1,2M non trademarkia directly). This means 15% of RAPC
revenue was through Trademarkia that year.
For a historical perspective, RAPC revenues in 2005 (firm started August 15, 2005) was 215K, in 2006, it was 739K, in
2007 it was 929K, 2008 it was 1.08K. Trademarkia was not born yet during those years.
I own 100% of RAPC and approximately 70% of Trademarkia on a fully diluted basis.
I can send to you details behind each of these numbers once we have a NDA in place. All the other parties we are
talking with have accepted our jury requirement terms in the NDA.
If Trademarkia and the RAPC business interests you further based on the information above and your internal
discussions, please send to me a serious LOI, and I can explore waiving the jury term in the NDA.
Alternatively, perhaps your counsel can agree to our jury requirements for the NDA absent the LOI. I can send to
you detailed information to substantiate each of the summary points above at that time.
I think you now have enough information to take the next step should you want to. I'm available to talk on my cell at
anytime, 408-398-3126.
Kind regards,
Raj
Please note: the disclosure in this email is subject to the agreement in principle that we have on all other terms of the
unsigned NDA.
On Tue, Nov 8, 2011 at 7:38 AM, Raj Abhyanker <raj@rajpatent.com> wrote:
Hi John,
Thanks for letting me know. I'll cancel my flight today. Let me know if and when you want to re-engage. As I mentioned,
we are in active talks right now with Thompson, Rocketlawyer, Google, and a number of venture capitalists. We intend to
make a firm decision on our future direction in the coming months.
Kind regards,
Raj
Sent from my iPhone
Raj,
Perhaps we're moving too fast. This is the first and only time in 10 years I remember a jury trial becoming a
sticking point in an NDA.
Let's cancel tomorrow rather than rush into something where we're not comfortable. I'm flying to New York
on Wednesday, and Fred is in London next week. Let's resume conversations at a more measured pace.
John
From: Daniel Hansen <dhansen@mh-llp.com>

Date: Mon, 7 Nov 2011 22:53:36 -0600
To: Chas Rampenthal <chasr@legalzoom.com>
Cc: "raj@rajpatent.com" <raj@rajpatent.com>, Fred Krupica <fkrupica@legalzoom.com>, John
Suh <jsuh@legalzoom.com>
Dear Chas,
Thank you for your email.
By way of context, John invited Raj to meet with Fred and him on short notice and have asked to see
Trademarkia’s and Raj’s law firm’s confidential information with a goal towards, in John’s words, exploring “a
partnership including but not limited to an acquisition.”
We revised your form NDA and accepted 2 of the 3 comments back. I think we’ve been reasonable. Jury
trial is a fundamental right and our client feels its waiver is not appropriate in this context. The parties can
always waive it later if the circumstances warrant.
Attached are the final forms (one for Trademarkia and one for Raj’s firm). Note that we added a bilateral
attorneys fees clause at the end of Section 8, as is typical.
Let us know if Raj should cancel his flight.
Best regards,
Dan
Daniel R. Hansen
Managing Partner
(650) 331-7003 (direct)
(650) 331-7001 (fax)
(650) 867-4179 (cell)
dhansen@mh-llp.com
<image001.jpg>
_______________________________
privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not
the intended recipient, please contact the sender by reply e-mail, and destroy all copies of the original
message. To ensure compliance with requirements imposed by the IRS, we inform you that any tax
advice contained in this communication, unless expressly stated otherwise, was not intended or written to
be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal
Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related matter(s)
addressed herein.
From: Chas Rampenthal

To: Daniel Hansen
Cc: raj@rajpatent.com; Fred Krupica; John Suh
Dan –
Having read your comments below, we still prefer a bench trial in a B2B dispute over a mutual
NDA. If this were pre-2005 (before the Grafton case), we could have a simple jury waiver
clause. Since CA law does not currently allow pre-dispute waivers, the only choices are
arbitration or Cal. Civ. Code 683 (judicial reference). The only reason that the judicial reference
language is in there is if we would not mutually agree to have a regular judge try the case (it is a
fallback clause). I am not a fan of arbitrating disputes like this – all too often arbitrators punt
and refuse to make the hard decisions that a judge will.
If your concern was over the judicial reference language, then you need not be too concerned.
If there is a more fundamental disconnect over wanting a jury, then that is a different issue. For
the latter, we will need to talk before your client wastes time traveling to LA. I am on my cell,
310-709-1430 for a couple more hours if you need to discuss this.
Chas Rampenthal
General Counsel
LegalZoom.com, Inc.
From: Vivian Chace

To: Chas Rampenthal
Importance: High
Thank you,
Vivian
From: Daniel Hansen

To: Vivian Chace
Dear Vivian,
We’re OK with the changes in Section 2 (confirmation on oral disclosure) and 7 (with 5yrs) but
prefer to keep the jury trial. I disagree that’s standard. Please revise Section 8 and circulate in
final for signature.
Best regards,
Dan
Daniel R. Hansen
Managing Partner
(650) 331-7003 (direct)
(650) 331-7001 (fax)
EXHIBIT T
EXHIBIT U
EXHIBIT V
Screen Capture from April 8, 2012
Amazon Alexa - Traffic Rankings
Trademarkia v. LegalZoom traffic comparison
EXHIBIT W
Screen Capture from March 21, 2019
Amazon Alexa - Traffic Rankings
Trademarkia v. LegalZoom traffic comparison
3/21/2019 nimbus screenshot app print
chrome-extension://bpconcjcammlapcogcnnelfmaeghhagj/edit.html 3/3
EXHIBIT X
screenshot-www.alexa.com-2019.03.21-18-12-00
https://www.alexa.com/comparison#?sites=legalzoom.com&sites=trademarkia.com
21.03.2019
EXHIBIT Y
3/22/2019 LegalZoom - Google Maps
LegalZoom
Map data ©2019 Google 200 ft
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1.5 ★ ★ · 17 reviews
Legal Services
888 Villa St #430, Mountain View, CA 94041
9WVC+P3 Mountain View, California
legalzoom.com
(800) 773-0888
Add missing information
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4
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"The price is comparable and it will actually get done."
"Legalzoom refuses to complete the work."
"They were good enough to refund my money but then

charged me a year later."
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3 reviews
★ ★ ★ ★ ★ 6 months ago
I used LegalZoom to help complete the processing of
two DBA's. The initial online process to submit an
application was good. However, it went down hill
from there. It was suppose to take only 7-10 business
days to complete step 3 of the process after
LegalZoom received the notarized forms to send to
the county. I would follow up weekly to get an update
and I would always get the same generic response
(while being put on hold for at least a total hold time
of 15-20 minutes) that my forms are waiting for return
approval from the county clerk's o ce. Three weeks
gone by and I was nally able to have my issue
escalated and researched. It turns out my forms were
sent to the wrong place and then it was also missing
a requirement (certi cate of good standing) that
LegalZoom should have known about. Now, my
original notarized forms were lost by LegalZoom and
they are having me resend back to them. I started the
process in mid July and here were are in late
September trying to get back to step 3. The
"customer service" team never has answers, they
always put you on hold for "3 to 5" minutes", I can
never get anyone that actually looks at these forms to
speak to, and I have asked for a manager to reach
back to me and they never have. I would have moved
forward with somewhere else, but I don't want to
loose out on the money and time I have already spent
with LegalZoom. I wish there was a way to give
negative star reviews. They are at least a -10
Like Share
John Larkin
10 reviews
★ ★ ★ ★ ★ a month ago
There is a lot I don't know, but learning a long the way.
Business package gives you options that you may not
have know you needed.
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HughesNet High Speed Internet

7 reviews
★ ★ ★ ★ ★ a month ago
They advertise trademark registration etc and taking
care of everything. Months later I get notice from the
USPTO trademark o ce they need more information
and then I sent to Legalzoom to complete. Legalzoom
refuses to complete the work. They are rip off and
scam and only want your money. They then ask for
more money from attorneys. I advise NEVER do
business with them!!!
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EXHIBIT Z
3/21/2019 FAC - DomainDispute-LegalZoom-
Case 3:18-cv-07274-MMC Document 58 Filed March20-2019 - GooglePage
03/21/19 Docs 1 of 37
RAJ V. ABHYANKER, SBN 233284

Email: raj@legalforcelaw.com
WENSHENG MA, SBN 299961
Email: vincent@legalforcelaw.com
LEGALFORCE RAPC WORLDWIDE, P.C.

1580 W. El Camino Real, Suite 10
Telephone: (650) 965-8731
Facsimile: (650) 989-2131
Attorneys for Plaintiff,

LegalForce, Inc.
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
LEGALFORCE, INC., a Delaware Case No. 3:18-cv-07274-MMC

corporation,
FIRST AMENDED COMPLAINT FOR:
Plaintiff,
1. TRADEMARK INFRINGEMENT, 15
v. U.S.C. § 1114;
2. TRADEMARK INFRINGEMENT, 15
LEGALZOOM.COM, INC., a Delaware U.S.C. § 1125(a);
corporation, 3. CYBERPIRACY, 15 U.S.C. § 1125(d);
and
Defendant. 4. TRADEMARK INFRINGEMENT,
CALIFORNIA COMMON LAW.
JURY TRIAL DEMANDED
1
FIRST AMENDED COMPLAINT
CASE NO.: 3:18-cv-07274-MMC
https://docs.google.com/document/d/13T3xnzT8xHFSJcXv4i4FD19zfS9DShpPmsoQNUTkBuQ/edit# 1/37
03/21/19 Docs 2 of 37
1. Plaintiff LegalForce, Inc. (“Trademarkia”, “Plaintiff”), a Delaware corporation, by and

through its counsel, for its Complaint against Defendant LegalZoom.com, Inc. (“LegalZoom”,
“Defendant”), a Delaware corporation, complains and alleges as follows:
NATURE OF ACTION
2. Trademarkia brings this action to stop LegalZoom’s unlawful conduct of cyberpiracy
and infringement of Trademarkia’s trademarks, which has caused Trademarkia significant
monetary damage and harm to Trademarkia’s brand and reputation, and has caused significant
consumer confusion as to the commercial source of Trademarkia’s services.
THE PARTIES
3. Trademarkia is a Delaware corporation having a principal place of business at 1580 W.
El Camino Real, Suite 9, Mountain View, CA 94040. Trademarkia is a market leader in the field
of trademark search solutions, trademark monitoring services, general legal information, and
domain name registration services. Trademarkia provides these services online at set prices,
making them readily available and affordable to small businesses and general consumers across
the United States. Since introducing its website in September 2009, Trademarkia has grown to
become the leading, nationally recognized trademark website for small businesses and
consumers.
4. LegalZoom is a Delaware corporation having a principal place of business at 101 N.
Brand Blvd., Glendale, CA 91203. LegalZoom competes with Trademarkia in trademark watch
and monitoring services. To gain competitive advantage over its competitors including
Trademarkia, LegalZoom egregiously registers domains with similar names, redirecting the
domain traffic to LegalZoom’s homepage LegalZoom.com, and infringe on competitors’
trademarks.
JURISDICTION AND VENUE
5. This Court has subject matter jurisdiction over this action under 28 U.S.C. §§ 1331 and
1338 because this action arises under the laws of the United States, and because it involves
allegations regarding trademark violations.
6. This Court has supplemental jurisdiction over the state law claim under 28 U.S.C. §
2
03/21/19 Docs 3 of 37
1367 because it arises from the same nucleus of operative facts as the federal claims.
7. This Court has general personal jurisdiction over LegalZoom because LegalZoom’s
principal place of business is in California.
8. Venue is proper in the United States District Court for the Northern District of California
because of a Dkt. 27 order of Case 2:18-cv-06147-ODW-GJS filed in the United States District
Court for the Central District of California.
FACTUAL ALLEGATIONS
A. The TRADEMARKIA Marks
9. Trademarkia is the owner of three U.S. federal trademark registrations:
Marks Reg. No. First Use in Goods/Services

Reg. Date Commerce date
Trademarkia Reg: 3965290 June 15, 2009 Advertising, marketing and

May 24, 2011* promotion services. (35, 42)
LegalForce Reg: 4227650 August 1, 2006 Legal services, namely, law firm
Oct. 16, 2012 services specializing in
administrative, transactional,
litigation, civil and criminal matters;
legal document preparation and
research services for attorneys;
providing general information in the
field of legal services via a global
computer network. (45)
LegalForce Reg: 5642937 April 13, 2012 Providing temporary use of on-line
Trademarkia Jan. 1, 2019 non-downloadable software for
trademark searching and managing
trademark matters; Computer
services, namely, providing search
engines for obtaining trademark data
from publicly available sources. (42)
10. The mark TRADEMARKIA was declared incontestable through Reg. No. 3965290.
11. The marks “LEGALFORCETRADEMARKIA” “TRADEMARKIA”, and
“LEGALFORCE” are collectively referred to as the “TRADEMARKIA Marks”.
3
03/21/19 Docs 4 of 37
12. As a result of Trademarkia’s exclusive, extensive, continuous and nationwide use of the
TRADEMARKIA Marks, the marks have come to signify the leading provider of online
trademark search and watch services for small businesses and consumers and have achieved
such widespread public recognition that the use of the suffix “markia” anywhere in all industries
across the United States is now associated with Trademarkia.
13. As an industry leader, licensees of the Trademarkia platform have expended well over
ten million dollars promoting the need for trademark search services, educating and raising
awareness among consumers, and advertising and promoting the TRADEMARKIA Marks.
14. In order to build and maintain its status as the leading nationally-recognized brand,
Trademarkia has promoted the TRADEMARKIA Marks through advertising across the media
of video, radio, and the Internet.
15. This lawsuit is necessitated by the fact that LegalZoom is seeking to trade on the
TRADEMARKIA Marks’ fame and goodwill by registering and using the domain
LegalZoomTrademarkia.com (“Disputed Domain”) to advertise LegalZoom’s services over the
Internet.
16. Trademarkia often uses the phrase “LegalForce Trademarkia” combined together and
has used this phrase together in emails and on the web pages of Trademarkia.com every day
continuously since 2012. In addition, Trademarkia has continually owned the domain
LegalForceTrademarkia.com since 2013 and has redirected traffic from this domain to
Trademarkia.com. Further, the domain LegalForce.com is owned by Trademarkia and itself
redirects to Trademarkia.com.
17. Accordingly, Defendant must be ordered to stop its infringing activities, to pay damages
to Trademarkia in an amount to be determined at trial, and to disgorge any profits it has made as
a result of its willful and bad faith infringement of the TRADEMARKIA Marks.
18. As a direct result of LegalZoom’s infringing conduct, Trademarkia has suffered
threatened injury given the fact that LegalZoom was directing LegalZoomTrademarkia.com to
LegalZoom.com for years and including up through litigation between LegalZoom and
LegalForce commencing in December 2017 and continuing through all the way that a Third
4
03/21/19 Docs 5 of 37
Amended Complaint (TAC) was proposed which included the facts about this cybersquatting
domain on June 18, 2018 in the litigation (3:17-cv-07194-MMC). Judge Chesney in
3:17-cv-07194-MMC ruled that the facts alleged in the TAC were not related to that case,
necessitating the need for the instant lawsuit. Specifically, Trademarkia has been threatened
with harm because customers seeking for services offered by Trademarkia, such as trademark
watch services and trademark search services have been misdirected to LegalZoom.com’s
homepage which offers similar services for years, up through June 18, 2018. Moreover, the
threatened harm continues to this day, as when users go to LegalZoomTrademarkia.com as of
the filing of this First Amended Complaint, they see a message indicating that the domain may
be available (e.g., implying available for purchase) and that the “website coming soon!” (See
Exhibit C). Moreover, upon information and belief, LegalZoom continues to own the domain
back to Legalzoom.com. (See updated Exhibit A).
19. It is not in dispute that LegalZoom listed the Disputed Domain in the LegalZoom
Affiliate program.1 LegalZoom’s actively encourages its hundreds if not thousands of
third-party affiliates who have subscription e-mail list(s), personal blogs, community
newsletters, community webzines, and small-business websites of third-parties (collectively
“Publishers”) to infringe the intellectual property rights of the TRADEMARKIA Marks through
the Disputed Domain by providing “Direct Links” on those websites incorporating the
TRADEMARKIA Marks and redirecting these users back to LegalZoom’s own website
(Exhibit K and Exhibit L). Thus, when accessing thousands of Publishers, LegalZoom paid a
commission to Publishers that advertised a hyperlink back to the Disputed Domain.
20. To support this contention, consider the “LegalZoom Affiliate program” as described on
the LegalZoom website in Exhibit E and associated with the hidden hyperlink snippet
“medium=affiliate&utm_campaign” on the Disputed Domain domain in Exhibit B. Under the
1
Specifically, LegalZoom redirected traffic from the Disputed Domain to its affiliate tracking
URLs by first redirecting to http://lztrk.com/?a=23&c=15&p=r&s1=legalzoomtrademarkia.com
and then redirecting to a tracking URLathttp://www.legalzoom.com/aff/home?utm_
source=23&utm_medium=affiliate&utm_campaign=home&cm_mmc=affiliate-_-ck-_-23-_ -na.
(See Exhibits B, D and E).
5
03/21/19 Docs 6 of 37
“LegalZoom Affiliate program”, LegalZoom offers to pay 15% to Publishers that advertise its
domains such as the Disputed Domain when a sale happens based on the inbound lead (Exhibit
E). In other words, LegalZoom offered a commission equivalent to 15% to each Publisher that
advertised the Disputed Domain as described in Exhibit H. Specifically, LegalZoom’s affiliate
FAQ describes that “[f]or each completed sale, you earn a 15% commission.” (Exhibit H). In
that FAQ, a table is provided that shows that the following commission structure when
Publishers link to LegalZoom domains including the Disputed Domain:
Copyright $114.00 $17.10
(Exhibit H)
21. The “complete coverage” trademark service advertised in conjunction with LegalZoom’s
Affiliate program for domains including the Disputed Domain is in direct competition with
Trademarkia as it implies trademark monitoring and watch services being included.
22. LegalZoom specifically requested small businesses to advertise its domains such as the
Disputed Domain on LegalZoom’s behalf. Specifically, LegalZoom wrote in their “Who we’re
looking for” section of their LegalZoom Affiliate program that they wanted websites, such as:
“
● Web marketers committed to preserving the integrity of the LegalZoom brand
● Franchise companies searching for a cost effective solution for business formation
requirements
● Esq., CPAs, CFAs & CFPs exploring value added services to their clientele
● Companies with online marketing specialists and content writing teams
● Companies who look for niche products and build sites to promote products
● Website owners with a strong SEO presence for legal keywords
● Sites or directories that are targeted and useful to online shoppers.” (see Exhibit F)
6
03/21/19 Docs 7 of 37
to place ads for LegalZoom’s domains including the Disputed Domain.

23. Many of these businesses have visitors who know of the Trademarkia brand.
Specifically, Trademarkia is visible to more than 9 million unique visitors per year. Much of this
audience would visit websites like those that LegalZoom actively recruited to advertise the
Disputed Domain. For this reason, while damage calculation is difficult for Trademarkia to
ascertain, Trademarkia believes from 2014 through 2018, Trademarkia roughly estimates that it
has lost over $150,000 in lost profits directly attributable to LegalZoom’s use of the Disputed
Domain in addition to expectation damages for trademark licensing of the TRADEMARKIA
Marks in the amount of $120,000 per month as will later be explained herein.
24. LegalZoom’s Affiliate Program even built a number of tools to threaten Trademarkia’s
business. LegalZoom advertises “Make use of robust reporting tools to keep track of your
campaigns and conversions, help identify your customers' preferences and maximize your site's
earning potential.” (Exhibit G). To facilitate quick dissemination of LegalZoom’s Affiliate
Program, LegalZoom employed the Pepperjam advertising network service. (Exhibit D). The
Pepperjam website (www.pepperjam.com), which is advertised as the “intuitive technology
solution to discover, reach and convert high-value customers and a partner with the experience
to drive connections that create commerce” (see Exhibit I), enabled LegalZoom to market the
Disputed Domain through an unlimited number of micro-websites across the Internet to create
marketplace confusion.
25. Text ads advertising for www.legalzoomtrademarkia.com for trademark services would
appear on these micro-sites and on marketing emails which directed users to the Disputed
Domain because “Direct Link” advertising is one of the ways LegalZoom Affiliates make
money, according to their own LegalZoom Affiliate’s sign up page (Exhibit K). Through
Pepperjam, LegalZoom actively marketed and advertised the Disputed Domain to millions of
visitors to small micro-websites making up the Pepperjam affiliate network. Tellingly,
Pepperjam advertises itself as enabling LegalZoom to “identify and recruit high-quality
publishers” to enable LegalZoom’s “white label affiliate program.” (Exhibit I). LegalZoom
actively disseminated and marketed the Disputed Domain for years through affiliate marketing.
7
03/21/19 Docs 8 of 37
Pepperjam has two sides to its affiliate network, one side for ADVERTISERS like LegalZoom
(Pepperjam’s advertiser page is on Exhibit I), and the other side a page for PUBLISHERS
AND INFLUENCERS who are small micro-websites on which the TRADEMARKIA Marks
were actively promoted by LegalZoom to be placed. (Pepperjam’s publisher page is on Exhibit
J) LegalZoom sought and actually did seek to avoid paying a $120,000 licensing revenue to
Trademarkia while diluting the TRADEMARKIA Marks and confusing the public through
websites, email campaigns, blogs and other advertising vehicles of the LegalZoom Affiliate
program for the specific purpose of attracting more customers to LegalZoom and diminish the
value of the TRADEMARKIA Marks. Indeed, even the Disputed Domain having the literal
characters of the TRADEMARKIA Marks. Pepperjam has a Publisher Registration page for
LegalZoom in which it solicits ways that publishers agree to promote LegalZoom’s domains
including the Disputed Domain. It requests through checkboxes for “Promotional Methods”
different ways Publishers will advertise, including through “Web Site/Content”, “Paid Search”,
“Email Marketing”, “Toolbar”, “Comparison Shopping”, “Video”, “Loyalty”, and most tellingly
“Direct Link”. (Exhibit K).
26. Moreover, Pepperjam’s terms for LegalZoom affiliates describe that:

As a service provider and online exchange, Pepperjam facilitates affiliate
marketing programs via its technology and network on the Internet. An affiliate
marketing program ("Advertiser Program") is where a Publisher or its agent
operates one or more web site(s) (domain or portion of a domain within the
Internet) and/or subscription e-mail list(s) to earn financial compensation
("Publisher Fees") for sales and or leads ("Transactions") generated from such
web site and/or email list through a click made by a customer (each, a
"Customer") on a web site or content operated by an advertiser ("Advertiser").
The Advertiser compensates the Publisher, in accordance with this Agreement and
the specifications of the applicable Advertiser Program agreed to by the
Advertiser and the Publisher under a separate agreement.
(Exhibit L).
27. It is clear that LegalZoom has threatened to harm, and actually harmed, Trademarkia’s
business directly as a result of this solicitation, and presumptively caused harm by actively
recruiting and listing the Disputed Domain on the Pepperjam advertising network.
28. Additionally, a clear chain of inferences can be drawn, based on the active listing,
8
03/21/19 Docs 9 of 37
marketing, and complexity of commission structures through the Jambone affiliate advertising
networks of the Disputed Domain on LegalZoom’s Affiliate Network, to support Plaintiff’s
claims for relief and permit the Plaintiff to determine the extent of the harm caused by
LegalZoom’s unlawful and unethical conduct with the specific intent to unfairly harm its
leading trademark competitor Trademarkia. It stands to reason that LegalZoom would capture a
larger share of the trademark market—to Plaintiff’s detriment—if they mislead consumers into
purchasing LegalZoom’s services rather than Plaintiff’s. Indeed, numerous Trademarkia
customers have been confused between LegalZoom and LegalForce Trademarkia.
29. With respect to LegalZoom causing Trademarkia’s damages, LegalZoom’s use of the
domain www.legalzoomtrademarkia.com to misdirect customers searching for LegalForce or
Trademarkia back to their own website LegalZoom.com that offered similar services as
Trademarkia.com, LegalZoom caused damages to Trademarkia in a dollar amount unknown.
30. Given the difficulty of assessing damages directly caused by LegalZoom’s use of the
www.legalzoomtrademarkia.com domain to www.legalzoom.com, Trademarkia seeks damages
under quasi contract theory and trademark infringement caused by LegalZoom’s bad faith
conduct in failing to pay to advertise the branding LEGALZOOM TRADEMARKIA for
$120,000 per month for each month following November 2011 and continuing to this day,
statutory damages of $100,000, punitive damages, and an injunction only in this case. The
damage period should be between April 2014 (when LegalZoom started infringing the
TRADEMARKIA Marks through the disputed domain) and June 2018 (when LegalZoom
ceased infringing the TRADEMARKIA Marks). The entire period between April 2014 and
June 2018 is 51 months for a total of damages amount of $6,120,000 in lost expected trademark
licensing revenues of the TRADEMARKIA Marks to LegalZoom.
31. In addition to direct loss in asset value, Trademarkia’s website Trademarkia.com has
also lost brand value to LegalZoom as a direct consequence of LegalZoom misdirecting
customers from the Disputed Domain to LegalZoom.com starting in April 2014. Specifically,
Trademarkia’s users have shrunk from 1,575,000 users per month in April 2014 (Exhibit T) to
just 380,043 users in the last full month of February 2019 (Exhibit U). In the same period,
9
Case 3:18-cv-07274-MMC Document 58 Filed March20-2019
03/21/19- Google Docs 10 of 37
Page
LegalZoom users have grown from about 1,700,000 users per month to approximately
3,953,100 visitors per month (Exhibit X). In other words, Trademarkia’s user count has shrunk
to by -75.87% of its former self after the Disputed Domain was advertised and promoted in its
LegalZoom Affiliate program by LegalZoom in April 2014, while LegalZoom’s traffic has
increased 234.54% from its former after the Disputed Domain was advertised and promoted by
LegalZoom.
month to Trademarkia.com). Based on the reported estimate 12% to 29% of all web traffic being
direct brand traffic (Exhibit M), between 143,394 users (12%) and 346,537 (29%) fewer users
come to the Trademarkia.com website as a direct result of the brand confusion created by
LegalZoom through the Disputed Domain. Tellingly, Trademarkia’s loss as a result of
LegalZoom’s surreptitious acts in infringing and misdirecting traffic using the
TRADEMARKIA Marks has been LegalZoom’s gain. In fact, as of April 8, 2012, when
Trademarkia and LegalZoom had just recently signed a Mutual Nondisclosure Agreement
(“NDA”), the total web traffic of Trademarkia was roughly the same as the web traffic of
LegalZoom. As of April 8, 2012, based on Amazon’s Alexa.com web ranking analytics
Trademarkia.com was the 9.275th largest website on the Internet based on the last 7 day
average, and LegalZoom was roughly equivalent in traffic and ranking. (Exhibit V)
Dramatically, as of May 21, 2019, based on Amazon’s Alexa.com web ranking analytics
infringing use of the Disputed Domain to confuse the public. Therefore, Trademarkia suffered
lost revenue and market share, reduced asset value and increased advertising costs of unknown
value. Specifically, Trademarkia’s brand has now been indistinguishably mixed with that of its
10
Page
34. Trademarkia roughly estimates that it has lost over $5,000,000 in lost intangible asset
valuation (lost advertising opportunities, lost venture capital equity fundraising opportunities,
lost private equity/exit valuation) through the reduction of brand equity through the trademark
infringement of the TRADEMARKIA Marks by LegalZoom’s surreptitious misappropriation of
Affiliate program promotion in email blasts and affiliate websites across the Internet.
B. Trademarkia’s Contractual Relationship with LegalZoom.
35. Trademarkia and LegalZoom are not strangers. In 2011, LegalZoom actively pursued an
trademark licensing negotiations over the TRADEMARKIA Marks with Trademarkia.2
Trademarkia and LegalZoom formed a legally binding NDA executed on November 16, 2011
(Exhibit Q). This NDA was hard fought with outside counsel for Trademarkia and LegalZoom
negotiating key terms over many rounds (Exhibit R, Exhibit S). After being forced to largely
accept the terms of LegalZoom’s version of the NDA after LegalZoom refused to entertain
Trademarkia’s version, LegalZoom CEO Suh even wrote in an email to Mr. Abhyanker
“Appreciate the flexibility on the NDA… lawyers can be bulldogs. ;)” (Exhibit S).
36. The purpose of the NDA was because the “parties agree there is a mutual indication of
interest and, in connection with this interest, the parties wish to explore a potential partnership
or other opportunity”. (Exhibit Q, Sec. 1). Confidential information was defined to be “any
nonpublic information that either party (the "Disclosing Party") discloses to the other party
("Receiving Party"), either directly or indirectly, in writing, orally, or by inspection of tangible
objects (including without limitation documents, prototypes, samples, plants, and equipment),
and designates as confidential or that under the circumstances surrounding disclosure ought to
be treated as confidential by the Receiving Party.”
37. Section 3 of the NDA required that each party:
“agrees not to:
2
LegalZoom’s CEO wrote to Trademarkia’s CEO on November 7, 2011: “But to be clear, we
are exploring a partnership up to and including acquisition.” In addition, that same day,
LegalZoom CFO Fred Krupica wrote “The LZ team is excited to meet and discuss the
opportunities between our companies” and “We trust that things go well tomorrow and that both
Raj and John decide to take it to the next level at which we would discuss terms, price, etc.”
11
Page
(i) use any Confidential Information of the other party for any purpose except to evaluate
and engage in discussions concerning a potential business relationship between the
parties;
(ii) disclose any Confidential Information of the other party to third parties or to its own
employees and consultants, except employees and consultants who need the Information
to evaluate or engage in discussions about the contemplated business relationship; or
(iii) reverse engineer, disassemble. or decompile any prototypes, software, or other tangible
objects that embody the other party's Confidential Information and that are provided to
the party hereunder.” (Exhibit Q, Sec. 3) (emphasis added).
38. The term of the NDA was explained in Section 7 to “survive until the earlier of (i) such
time as all Confidential Information of the other party disclosed hereunder becomes publicly
known and generally available through no action or inaction (ii) the third anniversary of the
disclosure; provided, however, to the extent the extent that a party has disclosed information to
the other party that constitutes a trade secret under law, the Receiving Party shall protect such
trade secret(s) for as long as the information qualifies as a trade secret under applicable law.”
(Exhibit Q, Sec. 7).
39. In Section 8 of the NDA, the parties agreed that “Nothing in this Agreement is intended
to grant any rights to either party under any patent, mark, work right, copyright, trade secret,
or other intellectual property right of the other party.” (Exhibit Q, Sec. 7).
40. The same Section 8 of the NDA goes on to say “Each party agrees that any violation or
threatened violation or this Agreement may cause irreparable injury to the other party, entitling
the other party, without waiving any other rights or remedies and without posting a bond or
other security, to seek injunctive relief in addition to all legal remedies” (Exhibit Q, Sec. 8) and
that the parties agree to waive trial by jury and laws of the State of California shall apply.
41. Signatories of the NDA were John Suh, Chief Executive Officer for LegalZoom (who
also initialed on the lower right of the page) and Raj Abhyanker, the CEO of Trademarkia, Inc.
(former business name of the plaintiff entity LegalForce, Inc.), as shown below:
12
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(Exhibit Q)
42. On the very same day of Wednesday November 16, 2011 that the NDA with
Trademarkia was executed by John Suh, the CEO of LegalZoom, Trademarkia provided
confidential information to LegalZoom in an email at 11:25AM on Wednesday November 16,
2011 (Exhibit N) along with two confidential screenshots having licensing amounts of
$120,000 a month and $45,000 a month printed on the top cover of each mockup user interfaces
respectively (Exhibit O and Exhibit P)
43. Specifically, Trademarkia provided user interface mockups to LegalZoom senior
executives via email demonstrating what the Trademarkia website might look like if it were
rebranded as “LegalZoom Trademarkia” with an offer price of $120,000 per month in
licensing that paired combination. The email was sent to numerous members of LegalZoom’s
senior leadership including CEO John Suh, CFO Fred Krupica, General Counsel Chas
Rampenthal, VP of Attorney Services Carter Gaffney, VP of Operations Adam Thomas,
co-founder Brian Liu and others. Along with the user interface designs emailed as attachments,
Raj Abhyanker, CEO of Trademarkia wrote that day to LegalZoom’s senior management the
following on the same morning the NDA was signed by LegalZoom’s CEO :
John,
Great! ps.. Imagine.. see attached. 18 million unique visitors and more than
36 million page views a year seeing the Legalzoom brand this way.
Trademarkia now drives more than 1.5 million unique visitors and 3 million
page views. While our traffic is mostly organic, it is not diluted like Docstoc.
Mostly businesses and entrepreneurs click on Trademarkia pages, as they are
interested in a brands, trademarks, and/or products.
Our organic audience is mostly small businesses that need a lot of the services
that Legalzoom offers. Also, with this, even more than 50% of Americans will
know the Legalzoom brand very soon! In addition, the branding should pay
for itself through increased $ sales. If you check Alexa, Trademarkia traffic
13
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today reached 6,315 (8,700 overall worldwide and 3100 in the U.S.). By
branding LegalZoom on Trademarkia, the Legalzoom brand would be seen on
effectively twice as many pages as our traffic rankings are virtually equal now
according to Alexa. Trademarkia continues to grow very fast, and our traffic
now dwarfs Rocketlawyer, Logoworks, and we're a little bigger than even
Justia etc. We expect Trademarkia site traffic to double by this time next year
(many cool features in our pipeline!).
Raj :) (Exhibit N).
44. The email was marked confidential with a note at the bottom of the email clearly stating
“This electronic transmission contains information which is confidential and/or privileged.”
(Exhibit N). In addition, to this email in Exhibit N on November 16, 2011, were attached two
screenshots as a single PDF attachment, one clearly showing a rough mockup “LegalZoom
Trademarkia” on the upper left as shown below and a price offered to LegalZoom of $120,000
per month printed on top of the mockup being offered to LegalZoom:
14
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Exhibit O
45. The email including the attachment above is being forensically preserved with a date
stamp from 2011 and is being produced to LegalZoom. And a second mockup showing
“Trademarkia LegalZoom” on the upper left as shown below, with a price offered to LegalZoom
of $45,000 per month:
Exhibit P.
46. The emails and attachments above and attachments have been forensically preserved
with meta-data in tact showing date stamps from 2011 and are being produced by Trademarkia
to LegalZoom’s counsel through an outside e-discovery vendor. LegalZoom decided not to
advertise on the Trademarkia.com website and brand it through the LEGALZOOM
TRADEMARKIA branding at $120,000 per month. Thinking that Trademarkia’s trademark
licensing requirements at $120,000 per month were too high for LegalZoom, LegalZoom broke
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off trademark licensing over the TRADEMARKIA Marks on December 11, 2011. Trademarkia
has therefore suffered expectation damages of $120,000 per month for all relevant time periods
for the licensing of the TRADEMARKIA Marks.
47. Less than six months later, on or about June 8, 2012, LegalZoom purchased the
abandoned domain name LegalZoomTrademarkia.com but did not use it. A couple of years
later, on or about April 21, 2014, within the 3 year term of the NDA as explained in
Section 7 commencing on November 16, 2011, LegalZoom began diverting traffic from
LegalZoomTrademarkia.com to its website LegalZoom.com. To hide its conduct, on or
about February 28, 2015, LegalZoom implemented GoDaddy’s WHOIS privacy guard service
to hide its ownership of this domain from public view by paying a separate fee to a company
called DomainsByProxy LLC.
48. Only after being caught around June 2018 did LegalZoom stop diverting web traffic
from LegalZoomTrademarkia.com to LegalZoom.com and hiding its identity as an owner
through privacy guard. Therefore any statutory limitations should be tolled given that
LegalZoom took affirmative steps to surreptitiously conceal their ownership of the Disputed
Domain to conceal their trademark infringement scheme. (Exhibit A). Therefore, Trademarkia
could not have reasonably known about LegalZoom’s scheme of using its LegalZoom Affiliate
program to infringe the TRADEMARKIA Marks between 2015 and 2018 without forensics
discovery, which would be outside the scope of a normal course of business operations.
C. LegalZoom’s Breach of the NDA and Infringement of Trademarkia’s trademark rights.
49. LegalZoomTrademarkia provided to LegalZoom a confidential offer of $120,000 to
license the TRADEMARKIA Marks for the benefit of LegalZoom (Exhibit N, Exhibit O,
Exhibit P). LegalZoom breached key provisions of the NDA. Specifically, LegalZoom
breached Section 3(i) of the NDA by using the Confidential Information of Trademarkia for
purposes other than “to evaluate and engage in discussions concerning a potential business
relationship” (Exhibit Q, Sec. 3(i)). In addition, LegalZoom did in fact “reverse engineer”,
“disassemble”, and “decompile” the “prototype” mockups provided to them in violation of the
NDA (Exhibit Q, Sec. 3(iii)) by first purchasing, and then encouraging hundreds of their
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affiliates to advertise the literal characters of the TRADEMARKIA Marks through the express
characters of the Disputed Domain in an effort to create confusion in the marketplace as to the
source and origin of Plaintiff’s products and services.
secret, or other intellectual property” of Trademarkia including with respect to incorporating the
TRADEMARKIA marks in domain names and related ad network advertising. (Exhibit Q, Sec.
8).
D. Trademarkia’s Efforts of Achieving Fame in TRADEMARKIA Marks.
51. Trademarkia was founded in 2009. The Trademarkia website, available at
www.trademarkia.com, went live on or about September 15, 2009.
52. Since that time, Trademarkia has served approximately 50,000,000 (fifty million)
visitors throughout the United States, and has assisted more than 100,000 (one-hundred
thousand) small business owners in the search and monitoring of their trademark applications
from more than 80 countries. In 2017 alone, Trademarkia users placed over 10,000 orders on or
through the website.
53. Trademarkia is cited as a trusted source for corporate history and branding in at least 700
Wikipedia pages for leading brands including Disney, Samsung, Coca Cola, Anheuser-Busch,
Tesla, Kleenex, Dreamworks and hundreds of iconic brands.
54. As a result of Trademarkia’s efforts and expenditures, the TRADEMARKIA Marks have
become widely recognized by the general public of the United States as a trusted leading news
source for any new trademarks filed by celebrities, sports teams, musicians, politicians, or big
corporations.
55. Almost from Trademarkia’s inception, the TRADEMARKIA Marks have been featured
and discussed in publications and on television programs and Internet websites all over the
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United States, including but not limited to on Bloomberg, FastCompany, Fox Business, New
York Times, TechCrunch, FORBES, CNBC, The World Trademark Review, TIME Magazine /
Fortune, CNN, Wall Street Journal, Washington Post, and in the ABA Journal.
56. For nearly a decade, Trademarkia has advertised extensively over the Internet and other
advertising channels. It advertises in markets throughout the country, including large consumer
markets such as Boston, New York, Chicago, San Francisco and Los Angeles.
57. The Trademarkia website generates hundreds of thousands of hits per week. The
TRADEMARKIA Marks are prominently displayed on Trademarkia webpages.
58. Trademarkia has achieved fame and recognition for its TRADEMARKIA Marks through
the following innovations:
○ Docketing system. Trademarkia has aggregated trademark data from nearly a dozen
countries and indexes tens of millions of trademarks daily for updates. It has become a
“docketing system” for the world, enabling, for free, thousands of entrepreneurs to be
kept up to date on deadlines for trademarks, oppositions, renewals and more. Previously,
access to such tools were reserved for wealthy corporations with access to sophisticated
tools from LexisNexis, Thomson Reuters, and others. Trademarkia has made these tools
free to the world.
○ Search Technology. Trademarkia has helped to answer the basic question that many
entrepreneurs have, which is “is my business name available to trademark”, by making a
knockout search from its databases of millions of trademarks, refreshed daily, freely
accessible from its home page, through a search engine-like search box with little
commercial advertising on its home page. As a result, Trademarkia now attracts over 23.2
million page views and approximately 9.4 million visitors to Trademarkia.com each year,
making it one of the Internet’s largest legal-oriented websites.
○ Competitive and Breaking News. Trademarkia automatically publishes free alerts for
millions of trademarks in various countries making it a leading and primary news source
for breaking business news whenever new products are soon to be released and whenever
new marketing campaigns launch across the world.
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○ Catalog of American ingenuity and corporate history. Trademarkia was the first to
publicly index trademark data as old as the year 1872, making it a deep and rich
repository of American history and corporate evolution. As a result, Trademarkia is cited
as a trusted source for corporate history and branding in at least 750 Wikipedia pages for
leading brands including Coca Cola, Budweiser, Kellogg, and hundreds of iconic brands.
○ Innovative logo search engine. Trademarkia has built what is the Internet’s largest logo
search engine based on design code identification of trademarks, spanning over 4 million
logos that can be deeply searched by “what is inside” each logo for creative inspiration
and brand development, free of charge. As a result, thousands of branding agencies and
entrepreneurs use Trademarkia.com each month to find and discover new inspiration for
their brands.
○ Keeping trademark bullies accountable. Trademarkia has built what is the Internet’s first
catalog of large company trademark bullies, hecklers, and their victims based on the
number of trademarks they oppose, threaten to oppose, and are challenged by, through its
annual rankings of those companies that actively overextend their trademark rights. This
data is offered for free through automated annual rankings based on government data and
published annually by Trademarkia.
○ Reducing infringement of trademarks when registering domains. Trademarkia has built
the world’s first domain registration service for small businesses that automatically
checks for availability of trademark rights when registering domains, to assist in reducing
cyber-piracy claims and reducing wasteful federal litigation, free of charge.
○ Global automated trademark docketing reports. Trademarkia has built automated and
semi-automated trademark reports for most of the 100+ countries through which
Trademarkia offers trademark filings. As a result, companies and entrepreneurs around
the world can uniquely and centrally harmonize trademark portfolio management and
access global trademark protection markets through a single website.
○ Trademark opposition window tracking. Trademarkia has enabled small businesses to
easily track their 30-day opposition window for trademarks filed with the USPTO in real
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time through its free opposition watch service. Prior to Trademarkia, such tools were
reserved for rich corporations using expensive enterprise software by companies such as
Thomson Reuters, Wolters Kluwer, and LexisNexis.
○ Bifurcated Supply Chain Management. Trademarkia applied best manufacturing practices
to legal services by taking all non-attorney work off of attorneys’ plates and globalizing it
to improve quality while reducing costs.
59. The TRADEMARKIA Marks were enormously famous and distinctive at the time of
LegalZoom’s first infringing use in 2014, and continues to be through this day. Prior to
LegalZoom’s first use of the TRADEMARKIA Marks, thousands of social media posts and
tweets on Facebook and Twitter mentioned Trademarkia website in popular culture and fashion
as the source for leading brand information.
60. Trademarkia had become a leading news indicator, often cited by major media and
television as a source for breaking news prior to 2014 because it was the first to index USPTO’s
trademark records through static URLs and breadcrumbs structure. Through this technique,
Trademarkia transformed the status changes of trademark applications into breaking news
across all markets.
61. Before any new movie, book or song is released, the owner invariably secures brand
rights to the movie name through trademark protection. Fans may gravitate toward movies of
their favorite actors, studios, and sequels. The information of such newly filed trademark
applications are therefore newsworthy and such information associated with status changes is
automatically watched and monitored by Trademarkia. Thus, status changes of trademark
applications in real time can be transformed into national or international breaking news
because, for example, the general public would want to know beforehand the name of the next
Star Wars® movie. Because Trademarkia is the first to disseminate such news to the fans and
the consuming public, the TRADEMARKIA Marks have achieved widespread fame across the
United States and internationally.
62. The TRADEMARKIA Marks achieved this widespread fame across the United States,
and across many different industries and popular culture - for many years before LegalZoom’s
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first infringing use. Trademarkia had become among the largest websites in the United States,
having website traffic approaching some of the largest websites on the Internet by 2014, and has
attracted millions of page views and unique visitors to its Trademarkia.com website in the years
prior.
63. The TRADEMARKIA Marks are of material importance to Trademarkia. Trademarkia
has used the TRADEMARKIA Marks continuously for nearly a decade and has spent a large
amount of money promoting those marks.
64. Because of the invaluable goodwill that the TRADEMARKIA Marks represent, and its
importance to the company, Trademarkia aggressively protects the TRADEMARKIA Marks.
FIRST CLAIM FOR RELIEF
TRADEMARK INFRINGEMENT
15 U.S.C. § 1114
65. Trademarkia repeats each and every allegation contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
66. Plaintiff’s marks TRADEMARKIA and LEGALFORCE are valid, protectable
trademarks that are registered on the principal register at the USPTO. Plaintiff’s trademark
application for the mark LEGALFORCE TRADEMARKIA is registered at the USPTO. The
mark’s first use in commerce date is April 13, 2012.
67. Trademarkia and LegalZoom formed a legally binding contract titled Mutual
Nondisclosure Agreement (“NDA”) on November 8, 2011.
68. Trademarkia provided to LegalZoom a confidential offer of $120,000 to license the
TRADEMARKIA Marks for the benefit of LegalZoom.
69. Thinking that Trademarkia’s trademark licensing requirements at $120,000 per month
were too high for LegalZoom, LegalZoom broke off trademark licensing over the
TRADEMARKIA Marks on December 11, 2011.
70. In June 2012, LegalZoom purchased the Disputed Domain which contains Plaintiff’s
mark TRADEMARKIA. The domain name is confusingly similar to Plaintiff’s own website,
LegalForceTrademarkia.com, and Plaintiff’s combined mark LEGALFORCE
TRADEMARKIA. In April 2014, LegalZoom began to redirect traffic from the Disputed
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Domain to its own homepage LegalZoom.com.

71. LegalZoom breached key provisions of the NDA including Section 3(i) and Section
3(iii) by first purchasing, and then encouraging hundreds of their affiliates to advertise the literal
characters of the TRADEMARKIA Marks through the express characters of the Disputed
Domain in an effort to create confusion in the marketplace as to the source and origin of
Plaintiff’s products and services.
72. Trademarkia has therefore suffered expectation damages of $120,000 per month for all
relevant time periods for the licensing of the TRADEMARKIA Marks.
secret, or other intellectual property” of Trademarkia including with respect to incorporating the
TRADEMARKIA marks in domain names and related ad network advertising.
74. LegalZoom’s use of the TRADEMARKIA Marks as a domain name to identify
LegalZoom’s website in a manner that is likely to cause confusion and/or mistake among
internet users as to the source or sponsorship of Plaintiff’s services constitute trademark
infringement.
75. Trademarkia first discovered LegalZoom’s infringing use in April 2018. Trademarkia
could not have discovered the alleged misconduct sooner given the great lengths LegalZoom
went through to hide and mask its ownership of the Disputed Domain through privacy guard.
The ownership only became known to Trademarkia when counsel stumbled upon it through
complex forensics analysis of LegalZoom’s activities when researching for LegalZoom’s false
and misleading advertising and unfair competition violations in April 2018.
76. Trademarkia has lost significant asset value as a direct result of LegalZoom’s
infringement and deployment of the Disputed Domain. As a result of LegalZoom’s infringing
use of the TRADEMARKIA Marks, Trademarkia’s user count has shrunk to by -75.87% of its
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former self after the Disputed Domain was advertised and promoted by LegalZoom, while
LegalZoom’s traffic has increased 234.54% from its former after the Disputed Domain was
advertised and promoted by LegalZoom.
month to Trademarkia.com). Based on the reported estimate 12% to 29% of all web traffic being
direct brand traffic, between 143,394 users (12%) and 346,537 (29%) fewer users come to the
Trademarkia.com website as a direct result of the brand confusion created by LegalZoom
through the Disputed Domain.
78. Trademarkia’s loss as a result of LegalZoom’s surreptitious acts in infringing and
misdirecting traffic using the TRADEMARKIA Marks has been LegalZoom’s gain. In fact, as
of April 8, 2012, when Trademarkia and LegalZoom had just recently signed the NDA, the total
web traffic of Trademarkia was roughly the same as the web traffic of LegalZoom. As of April
8, 2012, based on Amazon’s Alexa.com web ranking analytics Trademarkia.com was the
9.275th largest website on the Internet based on the last 7 day average, and LegalZoom was
roughly equivalent in traffic and ranking.
79. Dramatically, as of May 21, 2019, based on Amazon’s Alexa.com web ranking analytics
infringing use of the TRADEMARKIA Marks in the Disputed Domain to confuse the public.
81. LegalZoom’s infringing use also has created actual confusion from customers of
Trademarkia. Steve Hidalgo, Customer Service Manager employed full time by Trademarkia,
states that he and other employees have spoken with numerous customers confused between
LEGALZOOM and LEGALFORCE TRADEMARKIA. Moreover, Hidalgo believes that
Trademarkia has lost sales because of this confusion, and that numerous Trademarkia customers
have actually been confused.
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82. Linguist expert Ronald R. Butters, Professor Emeritus of English at Duke University,
believes that a reasonable person is “highly likely to be linguistically confused as to the source
and origin of LEGALZOOMTRADEMARKIA and LEGALFORCETRADEMARKIA.” It is a
well-known psycholinguistic fact that the beginnings and endings of words and phrases are of
paramount importance in distinguishing them one from another. For this reason alone, the
potential for linguistic confusion between the two is great: a reasonable consumer will note
LEGAL at the beginning of the marks and TRADEMARKIA at the end ... and focus little or no
attention on the one-syllable nouns zoom and force that are buried in between, as shown below:
LEGALZOOMTRADEMARKIA
LEGALFORCETRADEMARKIA
83. Consumers saw LegalZoom’s homepage LegalZoom.com when accessing
LegalZoomTrademarkia.com from 2014 through June 2018, after the related lawsuit between
the parties was filed. LegalZoom’s light-and-dark-blue logo, “legalzoom®”, was prominently
shown on the top of its homepage after users were directed to LegalZoom.com after typing
LegalZoomTrademarkia.com as the requested URL on their browsers. Since many of
Trademarkia’s customers know the TRADEMARKIA marks, it is likely that some users directly
typed the characters “www.legalforcetrademarkia.com” in the destination address bar of their
browsers without first doing a search in Google, Bing, or any search engine at all. Tellingly, a
study in 2014 suggests that 12% to 29% of all traffic to e-commerce websites like
Trademarkia.com and LegalZoom.com comes from “direct visits” based on word of mouth,
memory, face-to-face referrals, and brand identity without using any search engine (Exhibit M).
84. In a web browser, the address bar (also location bar or URL bar) is a graphical control
element that shows the current URL. The user can type a URL into the bar to navigate to a
chosen website. Many address bars offer features like autocomplete and a list of suggestions
while the address is being typed in. This auto-completion feature bases its suggestions on the
browser's history. Some browsers have keyboard shortcuts to auto-complete an address. These
are generally configured by the user on a case-by-case basis. Address bars have been a feature
of web browsers since NCSA Mosaic, and continue through to modern browsers including
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Google Chrome, Microsoft Edge, Mozilla FireFox, and others.

85. This creates even more likelihood of confusion to the consumers. Consumers are well
aware that competing providers of goods and services often buy and sell each other, such as
Amazon acquiring Whole Foods or JP Morgan merging with Chase. By placing the term
“LegalZoom” in front of the mark “Trademarkia”, Defendant exerted false dominion over the
Plaintiff through which a reasonable consumer would believe that LegalZoom has acquired or
merged with Trademarkia, or that LegalZoom and Trademarkia are affiliated.
86. Trademarkia extensively advertised the TRADEMARKIA Marks for the relevant time
period between 2014 and through today. Millions of Trademarkia’s users and thousands of
Trademarkia customers know Trademarkia’s services by these marks and they search the
TRADEMARKIA Marks online to reach Trademarkia’s website. Because of the demonstrated
confusion between LEGALZOOMTRADEMARKIA and LEGALFORCETRADEMARKIA,
also because LegalZoom and Trademarkia are competitors and advertise on the same
advertising platforms (e.g., Google, Bing, etc.), a consumer searching for
LegalForceTrademarkia would end up getting onto LegalZoomTrademarkia.com website, which
leads to LegalZoom.com.
87. Furthermore, because of the demonstrated confusion above and the fact that LegalZoom
and Trademarkia are in direct competition, a consumer trying to type
“legalforcetrademarkia.com” on his or her internet browser may end up typing
“legalzoomtrademarkia.com” by mistake, which leads to LegalZoom.com.
88. LegalZoom’s homepage or the various landing pages of the redirection (see Exhibit A,
Domain Tools Report) has no disclaimer which clearly labels that the website is not the website
of Trademarkia, or that the website has no association with Trademarkia, or that Trademarkia is
not acquired by or not part of LegalZoom.
89. Trademarkia is the sole and exclusive owner of the TRADEMARKIA Marks. It has
overseen, controlled, and directed goods and services marketed, advertised, promoted, and sold
under the TRADEMARKIA Marks.
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LegalZoom.
91. LegalZoom’s infringing use as alleged herein was done without the authorization or
consent of Trademarkia.
92. LegalZoom also actually advertised and promoted the Disputed Domain in commerce by
including the Disputed Domain in its LegalZoom Affiliate program. See Exhibit B.
93. Such use is likely to cause initial interest confusion of consumers who are in fact
searching solely for Trademarkia and/or Trademarkia registered trademarks and is highly likely
to cause confusion, mistake and deception among the general public as to the origin of
LegalZoom’s goods and services and/or as to the sponsorship by, affiliation with, and/or
connection to Trademarkia.
94. By using Trademarkia’s registered trademarks, and by selling, offering for sale,
distributing, or advertising goods and services to the general public in connection with
Trademarkia’s registered trademarks, for profit, LegalZoom has caused and, unless enjoined by
this Court, will continue to cause a likelihood of confusion and deception of members of the
public, and additional injury to Trademarkia’s exclusive right to control, and benefit from, its
registered trademarks, as well as Trademarkia’s goodwill and reputation as symbolized by the
TRADEMARKIA Marks.
95. LegalZoom’s conduct demonstrates an intentional, willful, and malicious intent to trade
on the goodwill associated with Trademarkia’s registered trademarks to Trademarkia’s great and
irreparable injury.
96. LegalZoom has caused and is likely to continue causing substantial injury to the public
and to Trademarkia, and Trademarkia is entitled to injunctive relief and to recover all damages
sustained as a result of LegalZoom’s infringing conduct, including but not limited to
LegalZoom’s profits, Trademarkia’s actual damages, enhanced profits, treble damages, statutory
damages, costs and reasonable attorneys' fees under 15 U.S.C. §§ 1114, 1116 and 1117.
SECOND CLAIM FOR RELIEF
15 U.S.C. § 1125(a)
97. Trademarkia repeats each and every allegation contained in the paragraphs above and
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incorporate by reference each preceding paragraph as though fully set forth herein.
98. Defendant used the TRADEMARKIA Marks in connection with the sale and advertising
of services in a manner that is likely to cause confusion, mistake, and/or deception among
consumers as to the affiliation, connection, or association of LegalZoom with Trademarkia, or
as to the origin, sponsorship, or approval of LegalZoom’s products and services by
Trademarkia.
99. LegalZoom’s infringing use was intentional because LegalZoom attempts to profit from
the Disputed Domain by appending query strings to the domain forwarding URL so that it can
keep track of how much traffic actually comes from the LegalZoomTrademarkia.com website.
100. LegalZoom’s adoption and use of the TRADEMARKIA Marks has been made
notwithstanding Trademarkia’s well-known rights in the famous TRADEMARKIA Marks and
with both actual and constructive notice of Trademarkia’s federal registration rights under 15
U.S.C. § 1072.
101. The Lanham Act prohibits any false or misleading description or representation,
including words or other symbols tending falsely to describe or represent the same, made in
connection with any goods or services entered into commerce.
102. Displaying LegalZoom’s homepage with “legalzoom®” symbol when user accessing
web link having the TRADEMARKIA Marks is misrepresentation and is likely to cause
confusion or mistake, or to deceive as to the affiliation, connection or association of the
Disputed Domain website with Trademarkia, or as to the origin, sponsorship, or approval by
Trademarkia.
103. LegalZoom was aware of the Plaintiff’s marks and reputation before engaging in its
conduct as alleged herein. LegalZoom deliberately redirected its website
LegalZoomTrademarkia.com to its home page and included false claims of its connection to the
Trademarkia.com website, for the purpose of harassing the Plaintiff, misappropriating its
substantial goodwill, and causing confusion, mistake and deception among Internet users and
the public.
104. As a direct and proximate result of Defendant's infringing activities, Trademarkia has
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suffered irreparable injury to Trademarkia 's business, reputation, and goodwill in its federally
registered TRADEMARKIA Marks for the following reasons: (A) Trademarkia has been
threatened with harm because customers seeking for services offered by Trademarkia, such as
trademark watch services and trademark search services have been misdirected to
LegalZoom.com’s homepage which offers similar services for years, up through June 18, 2018.
(B) the threatened harm continues to this day, as when users go to LegalZoomTrademarkia.com
as of the filing of this First Amended Complaint, they see a message indicating that the domain
may be available (e.g., implying available for purchase) and that the “website coming soon!”
(See Exhibit C). (C) Upon information and belief, LegalZoom continues to own the domain
back to Legalzoom.com (See updated Exhibit A); and, (D) Trademarkia suffered lost revenue
and market share, reduced asset value and increased advertising costs of unknown value
because Trademarkia’s brand has now been indistinguishably mixed with that of its
105. LegalZoom’s wrongful conduct has been willful and malicious. Plaintiff is entitled to
recover LegalZoom’s profits, as well as Trademarkia’s actual damages, enhanced profits and all
damages, costs and reasonable attorneys' fees under 15 U.S.C. §§ 1114, 1117.
106. If LegalZoom’s infringement is permitted to continue, the Plaintiff faces the risk of
irreparable harm. The Plaintiff’s remedy at law is not by itself adequate to remedy LegalZoom’s
actions, and irreparable harm suffered by Trademarkia will continue unless this Court enjoins
LegalZoom. Trademarkia therefore is entitled to injunctive relief pursuant to 15 U.S.C. § 1116.
THIRD CLAIM FOR RELIEF
CYBERPIRACY IN VIOLATION OF
15 U.S.C.A. § 1125(D)(1)
108. LegalZoom registered the Disputed Domain and used it to redirect visitors to its own
legalzoom.com website.
109. LegalZoom attempts to profit from the Disputed Domain by appending query strings
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3
to the domain forwarding URL so that it can keep track of how much traffic actually comes
from the LegalZoomTrademarkia.com website.
110. By appending query strings (the text after the question mark) to the tracking URL,
LegalZoom tracked how many redirections are sent to the LegalZoomTrademarkia.com domain.
This enabled LegalZoom to offer monetary commissions to third parties who refer customers to
LegalZoomTrademarkia.com. LegalZoom knowingly and purposefully used tracking scripts and
software to keep track of how much in commissions it must pay out to third parties for referrals
to the LegalZoomTrademarkia.com website, and sought revenue collected from these referrals.
In summary, WayBackMachine provides a forensic money trail of this history, where
LegalZoom redirected LegalZoomTrademarkia.com to multiple internal tracking URL links.
This clearly demonstrates LegalZoom’s attempt and intent to profit from the Disputed Domain
and its active promotion of the domain to third parties who were offered commissions to divert
traffic from LegalZoomTrademarkia.com to LegalZoom.com.
111. The LegalZoomTrademarkia.com Domain is nearly identical to and confusingly
similar to Plaintiff’s distinctive TRADEMARKIA Marks, and to the Plaintiff’s registered
domains LegalForce.com and Trademarkia.com.
112. Upon information and belief, LegalZoom consciously and willfully registered
LegalZoomTrademarkia.com, which is confusingly similar to the TRADEMARKIA Marks, in a
deliberate attempt to capitalize on the goodwill associated with the TRADEMARKIA Marks.
By offering similar services over the same channels of commerce to the same group of
customers under confusingly similar marks, LegalZoom is intentionally attempting to capitalize
on the hard-earned fame and reputation of the TRADEMARKIA Marks. Defendant’s actions are
willful and unlawful, are calculated to deceive consumers, and will irreparably harm the
valuable goodwill Trademarkia has built up over almost the past decade as a result of hard work
and considerable investment of time and money.
113. LegalZoom intentionally misleads consumers into thinking that they are going to
Trademarkia’s website when they enter LegalZoomTrademarkia.com (confusingly similar to
3
See https://en.wikipedia.org/wiki/Query_string.
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LegalForceTrademarkia.com and the “LegalForce Trademarkia” mark), or that LegalZoom has

acquired or merged with Trademarkia, or that LegalZoom and Trademarkia are affiliated. By
these acts LegalZoom intentionally trades on Trademarkia’s fame and goodwill in defiance of
the law.
114. LegalZoom has bad faith intent to profit from the Disputed Domain. Bad faith is
evidenced by, inter alia, their breach of the NDA, their registration of the domain after the
success of the Plaintiff’s Trademarkia.com website and LegalForce.com website, their
redirecting of the LegalZoomTrademarkia.com domain to LegalZoom.com, and their
description now saying “website coming soon!” “Please check back soon to see if the site is
available.” The word “available” indicates that LegalZoom may soon sell this domain now that
it has been caught.
115. LegalZoom’s bad faith intent is further demonstrated by the following:
● LegalZoom purchased LegalZoomTrademarkia.com six months after the
acquisition talk, during which the idea of the “LegalZoom Trademarkia” brand
name was presented by Trademarkia to LegalZoom. See infra Section B
“Abbreviated Background”.
● LegalZoom has no trademark or IP rights in or to the TRADEMARKIA Marks.
The Disputed Domain incorporates the intellectual property rights in the
trademarks and trade names “Trademarkia” literally and exactly into the domain
name.
● LegalZoom purchased the domain after the TRADEMARKIA Marks were
already distinctive, had achieved significant international fame, and were
registered as U.S. trademarks.
● Plaintiff LegalForce, Inc. had a previous business name of “Trademarkia, Inc.”
when LegalZoom registered the Disputed Domain in 2012. The Disputed
Domain directly infringed on the legal name of Plaintiff.
● LegalZoom attempted to profit from affiliate payment relationships by tracking
the URL when redirecting traffic from the Disputed Domain to its homepage.
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● LegalZoom later admitted to its wrongful conduct by offering to transfer, sell, or

assign the Disputed Domain to third parties—after being caught by the Plaintiff
in April 2018, LegalZoom quickly updated the Disputed Domain to state “Please
check back soon to see if the site is available.”
● LegalZoom intended to harm the goodwill represented by the TRADEMARKIA
Marks for commercial gain. It intended to tarnish and disparage the
TRADEMARKIA Marks by creating a likelihood of confusion as to the source,
sponsorship, affiliation and endorsement of LegalZoom.com by Plaintiff.
● LegalZoom misled the public by concealing its ownership of the Disputed
Domain shortly after it started to divert traffic to LegalZoom.com. On or about
February 28, 2015, LegalZoom implemented GoDaddy’s WHOIS privacy guard
service to hide its ownership of the Disputed Domain from public view by
paying a separate fee to a company called DomainsByProxy LLC.4
● LegalZoom has registered domains related to at least one other major competitor
Intuit.com and misdirected traffic to LegalZoom.com.
● LegalZoom registered multiple domain names which LegalZoom knew were
identical or confusingly similar to the marks of others. These marks were already
distinctive at the time of registration, or were dilutive of famous marks such as
uspxo.com, intuitincorporation.com, and pfriceline.com.
116. LegalZoom's actions constitute cyberpiracy in violation of the Trademarkia’s rights
under 15 U.S.C. § 1125(d)(1). These actions have been knowing, deliberate, willful, intentional,
and flagrantly malicious in light of the Trademarkia’s rights and global fame.
117. Pursuant to 15 U.S.C. § 1117, Trademarkia is further entitled to treble damages and
attorneys’ fees and costs.
118. LegalZoom’s cyberpiracy in violation of 15 U.S.C. § 1125(d)(1) is a direct and
proximate cause of LegalZoom’s unjust enrichment in an amount not yet ascertained.
119. It should be noted that for dozens of other domains owned by LegalZoom such as
4
It should be noted that LegalZoom has over 50 domains in which they do not actively hide
their contact information. (Last checked April 2018).
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LegalZoom.com or “legalzoom.cm”, LegalZoom leaves the domain registrant information

available for public search. In contrast, LegalZoom selectively applies privacy guard—so that
domain registrant information is not publicly searchable—to other domains it owns such as
LegalZoomTrademarkia.com and IntuitIncorporation.com. These domains contain trademarks
of LegalZoom’s competitors and LegalZoom redirects these domains to its home page
LegalZoom.com. Additionally, LegalZoom owns and blocks from public view
“legalzoom-quickbooks”, “legalzoom-quickbooks2.com”, “legalzoom-quickbooks3.com”, and
“legalzoom-quickbooks4.com”, which correspond to the trademark of Intuit, Inc.’s popular
software Quickbooks.
120. LegalZoom knew its infringing conduct is unlawful because it has been involved in
trademark infringement litigations in the past as both plaintiff and defendant. Moreover, upon
information and belief, LegalZoom was asked to reassign a wide range of domains associated
with Priceline.com over domains it owned on and redirected.5 Additionally, LegalZoom
continues to create confusion between itself and the United States Patent and Trademark Office
(“USPTO”) which owns www.uspto.gov by registering and redirecting www.uspxo.com to
LegalZoom.com for many years.
121. Pursuant to 15 U.S.C. § 1117(d), Trademarkia may elect, at any time before final
judgment is entered by the trial court, to recover, instead of actual damages and profits for
Trademarkia violation of 15 U.S.C. § 1125(d)(1), an award of statutory damages up to $100,000
per domain name, as the Court considers just.
122. Accordingly, Trademarkia is entitled to recover restitution for LegalZoom’s unjust
enrichment in an amount to be determined at trial.
123. If LegalZoom’s cyberpiracy in violation of 15 U.S.C. § 1125(d)(1) is permitted to
5
At one point, LegalZoom owned domains associated with its competitor Priceline.com LLC
including pfriceline.com, pricelihne.com, pricelinde.com, pricelineairfaredeals.com,
pricelineairline.com, pricelineauctions.com, pricelinediscounts.com, pricelinehostels.com,
pricelinehoteldeals.com, pricelinehotles.com, pricelineoffer.com, pricelineplanetickets.com,
pricelinepromos.com, pricelinerates.com, pricelinesale.com, pricelinfe.com, pricelinle.com,
pricelinq.com, priceljine.com, pricelpine.com, priceluine.com, priclline.com, pricneline.com,
pricseline.com, pridceline.com, prifceline.com, prijceline.com, and prikceline.com.
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continue, Trademarkia faces the risk of irreparable harm. Plaintiff’s remedy at law is not by
itself adequate to remedy LegalZoom’s actions, and irreparable harm suffered by Trademarkia
will continue unless this Court enjoins LegalZoom. Trademarkia therefore is entitled to
protection by injunctive relief, including forfeiture or cancellation of the
LegalZoomTrademarkia.com domain or transfer of the LegalZoomTrademarkia.com domain
name to Trademarkia.
FOURTH CLAIM FOR RELIEF
CALIFORNIA COMMON LAW
125. Trademarkia is the sole and exclusive owner of the trademark rights in the
TRADEMARKIA Marks.
LegalZoom.
127. By its acts as described above, Defendant has created a likelihood of confusion,
mistake, and/or deception among consumers as to affiliation; connection, or association with
Trademarkia or as to the origin, sponsorship, or approval of Defendant's products and services
by Trademarkia.
128. Absent injunctive relief, Trademarkia has no means by which to control Defendant's
infringing activities. Trademarkia is thus entitled to preliminary and permanent injunctive relief
prohibiting Defendant from continuing to commit such acts.
129. In performing the conduct described herein, on information and belief, Defendant
acted with oppression and malice, intending to injure Trademarkia and wrongfully advantage
itself at Trademarkia’s expense. Trademarkia is entitled to an award of compensatory and
punitive damages against Defendant, in an amount to be determined at trial.
REQUEST FOR RELIEF
WHEREFORE, Plaintiff requests that this Court enter judgment against LegalZoom as
follows:
33
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A. That LegalZoom and its respective agents, officers, employees, representatives, licensees,
franchisees, successors, assigns, attorneys and all other entities and persons acting for,
with, through or under authority from Defendant, and each of them, be preliminarily and
permanently enjoined from: (a) using the TRADEMARKIA Marks, service marks, and
trade names, or any colorable imitation thereof; (b) using any trademark that imitates or is
confusingly similar to or in any other way similar to any of the TRADEMARKIA Marks
or that is likely to cause confusion, mistake, deception, or public misunderstanding as to
the origin of Trademarkia' s products or its connectedness to Defendant; (c) using any
trademark or service mark that is confusingly similar to the distinctiveness of any of the
TRADEMARKIA Marks;
B. Trademarkia seeks damages under quasi contract theory and trademark infringement
caused by LegalZoom’s bad faith conduct in failing to pay to advertise the branding
LEGALZOOM TRADEMARKIA for $120,000 per month for each month following
November 2011 and continuing to this day, statutory damages of $100,000, punitive
damages, and an injunction only in this case. The damage period should be the entire
period between April 2014 (when LegalZoom started infringing the TRADEMARKIA
Marks through the disputed domain) and June 2018 (when LegalZoom ceased infringing
the TRADEMARKIA Marks) (entire period of 51 months or a total of $6,120,000);
C. Trademarkia seeks damages of lost profits estimated to be over $150,000 directly
attributable to LegalZoom’s use of the Disputed Domain;
D. Trademarkia seeks damages for loss intangible brand asset value of over $5,000,000 in
the form of lost brand goodwill, brand confusion, lost advertising opportunities, lost
venture capital equity fundraising opportunities, lost private equity/exit valuation through
the reduction of brand equity through the trademark infringement of the
TRADEMARKIA Marks by LegalZoom’s surreptitious misappropriation of
Affiliate program promotion in email blasts and affiliate websites across the Internet;
E. An order that LegalZoom permanently abandon the registration of
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LegalZoomTrademarkia.com Domain (and any other similar domains owned or acquired

by LegalZoom);
F. That LegalZoom be required to file with the Court and serve on Trademarkia within thirty
(30) days after the entry of the injunction, a declaration under oath setting forth in detail
the manner and form in which LegalZoom has complied with the injunction;
G. That, pursuant to 15 U.S.C. § 1117, LegalZoom be held liable for all damages suffered by
Trademarkia resulting from the acts alleged herein including compensatory and punitive
damages against LegalZoom in an amount to be proven at trial;
H. That, pursuant to 15 U.S.C. § 1117, LegalZoom be compelled to account to Trademarkia
for any and all profits derived by LegalZoom from its illegal acts complained of herein;
I. That Plaintiff be awarded their costs and expenses of this action against LegalZoom,
including their reasonable attorneys’ fees necessarily incurred in bringing and pressing
this case, as provided in 15 U.S.C. § 1117(a).
J. That Plaintiff be awarded treble damages to the fullest extent available under the law.
K. An award of LegalZoom’s profits from their infringing conduct;
L. Award Plaintiff pre- and post-judgment interest at the applicable rates on all amounts
awarded;
M. An award of statutory damages up to $100,000 per domain name in violation of 15
U.S.C. § 1125(d)(1) per 15 U.S.C. § 1117(d) if elected by Trademarkia instead of actual
damages and profits, as the Court considers just;
N. Grant permanent injunctive relief to prevent the recurrence of the violations for which
redress is sought in this Complaint;
O. That the Court grant Trademarkia any other remedy to which it may be entitled as
provided for in 15 U.S.C. §§ 1116 and 1117 or under all applicable federal or state laws;
and
P. Order any other such relief as the Court deems appropriate.
Respectfully submitted this Thursday, March 21, 2019.
35
Page

Raj V. Abhyanker
Attorney for Plaintiff:
LegalForce, Inc.
36
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JURY TRIAL DEMAND
Plaintiff hereby requests a trial by jury on all issues so triable in this matter.
Respectfully submitted this Thursday, March 21, 2019.

Raj V. Abhyanker
Attorneys for Plaintiff:
LegalForce, Inc.
37
JURY TRIAL DEMAND
Plaintiff hereby requests a trial by jury on all issues so triable in this matter.
Respectfully submitted this Friday, March 22, 2019.

Raj V. Abhyanker
Attorneys for Plaintiff:
LegalForce, Inc.
33
INITIAL COMPLAINT

LegalZoom Sued For Fraud, Conspiracy, and Constructive Fraud by LegalForce

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LegalZoom Sued For Fraud, Conspiracy, and Constructive Fraud by LegalForce

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E-FILED

RAJ V. ABHYANKER, SBN 233284 3/22/2019 3:31 PM

Attorneys for Plaintiff,

SUPERIOR COURT OF THE STATE OF CALIFORNIA

LEGALFORCE, INC., Case No. 19CV345030

Plaintiff, COMPLAINT FOR:

v. 1. BREACH OF CONTRACT AND

JURY TRIAL DEMANDED

Marks Reg. No. First Use in Goods/Services

Product | Package Retail Price 15% Commission

Trademark | Complete Coverage $189.00 $28.35

Copyright $114.00 $17.10

Provisional Patent $199.00 $29.85

25. Moreover, Pepperjam’s terms for LegalZoom affiliates describe that:

Respectfully submitted this Friday, March 22, 2019.

LEGALFORCE RAPC WORLDWIDE P.C.

By__​/s/ Raj V. Abhyanker​______

Domain Name LegalZoomtRademarkIa.com

Website Screenshot taken 03/27/2017

Reach us at memberservices@domaintools.com if you have any questions on this report.

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About Whois History

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For complete domain details go to:

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Domain servers in listed order:

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Domain servers in listed order:

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Domain servers in listed order:

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Registered through: GoDaddy.com, LLC (http://www.godaddy.com)

By/s/ Raj V. Abhyanker____