Who owns privacyprotect.org? Answer - Directi Internet Solutions, Pvt. Ltd.

8/3/2019 Who owns privacyprotect.org? Answer - Directi Internet Solutions, Pvt. Ltd.

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GINGRAS LAW OFFICE, PLLCGINGRAS LAW OFFICE, PLLCGINGRAS LAW OFFICE, PLLCGINGRAS LAW OFFICE, PLLC

3941 E. Chandler Blvd., #106-243, Phoenix, AZ 85048 ▪Tel: (480) 668-3623 Fax: (480) 248-3196

September 26, 2011

Public Interest Registry, Inc.c/o CT Corporation System4701 Cox Road, Suite 301,Glen Allen, VA 23060-6802

Public Interest Registry, Inc.1775 Wiehle Avenue, Suite 200Reston, VA, 20190

Re: Subpoena issued in Xcentric Ventures, LLC v. Karsen, Ltd., et al. United States District Court Case No. 11-cv-1055-FJM (D.Ariz.)

Dear Public Interest Registry:

I am an attorney in Phoenix, Arizona, and I represent Xcentric Ventures,LLC which operates the website www.ripoffreport.com. Enclosed please find asubpoena which requests information from you. This information is being soughtin connection with a federal copyright infringement lawsuit pending in the United

States District Court for the district of Arizona, Case No. 11-cv-1055-FJM.

As explained in the schedule attached to the subpoena, Xcentric is seekingany information that you have which may lead to the identity of theperson/persons/entity who owns and/or operates the website privacyprotect.org.It is my belief that this site is owned and operated by an Indian-based entitycalled Directi Internet Solutions Pvt. Ltd., but it is possible this may not be thecase.

In any event, please feel free to contact me with any questions you mayhave. You can reach me via telephone at (480) 668-3623, fax (480) 248-3196,

or email: [email protected]. Thank you in advance for your assistance.

VERY TRULY YOURS,

David Gingras, Esq.



Xcentric Ventures, LLC v. Karsen, Ltd., et al.Case No. 11-cv-1055 (D.Ariz.)

Subpoena to Public Interest Registry, Inc.

SCHEDULE A

GENERAL INSTRUCTIONS

1. All documents requested are to be produced in the same file or other organizational

environment in which they are maintained. For example, a document that is part of a file, docket,

or other grouping, should be physically produced together with all other documents from said

file, docket or grouping, in the same order or manner or arrangement as the original.Alternatively, as to each document and thing produced in response hereto, you shall identify the

request for production and where applicable, the interrogatory number, in response to which the

document or thing is being produced. Where a document or thing exists in hard copy andelectronic format, you shall produce both the hard and the electronic copy. Where a document

exists only in electronic format, you shall produce it electronically, as it is kept in the ordinary

course of business, including the file or other grouping in which it is electronically stored.

2. Each document is to be produced along with all drafts, without abbreviation or redaction.

3. All document requests herein are intended to embrace within their scope both non- privileged documents and documents for which privilege is claimed. If any document covered by

this request is withheld by reason of the claim of privilege, work product or other ground of non-

production, please provide a list identifying the document in question with sufficient specificityto permit a court to determine the propriety of the privilege asserted. As to any document with

respect to which you claim privilege, your response should state separately with respect to each

such document or tangible thing as to which you claim privilege:

a) the number of the request calling for the document;

b) the names of the authors;

c) the date of the document;d) the identification of all persons who have possessed, read, or reviewed the

document at any time;

e) a brief description of the nature and subject matter of the document; andf) the ground for the claimed privilege.

4. If any otherwise responsive document or thing has been, but no longer is, in the possession, custody or control of YOU, each such document is to be identified by setting forth

the following information to the extent known: (i) each addressor and addressee; (ii) the

addresses of any indicated copies or blind copies; (iii) the date, subject matter, and number of pages of the document; (iv) the identity of any attachment or appendices to the document; (v) all

persons to whom the document was distributed, shown or explained; (vi) its date of destructionor discard, manner of destruction or discard, and reasons for destruction or discard; and (vii) the

persons authorizing and carrying out such destruction or discard.

5. As to any portion of any request which refers to documents that YOU are aware of which

were at one time within the possession, custody or control of YOU but which are not now withinor subject to the possession, custody or control of YOU, identify such documents in a manner

sufficient to describe such for a subpoena duces tecum and give the name, telephone number and





address of the person last known by YOU to have been in possession, custody or control of suchdocuments.

6. In producing the requested documents, YOU are required to furnish all documents

available to it including, by way of illustration only, and not limited to, documents in the possession, custody or control, of YOU or YOUR attorneys or their consultants or investigators

or in the possession of YOUR consultants, advisors, agents or associates.

7. Each withheld document shall be given an index number for the simplification of

identification. The schedule shall be sufficiently detailed to permit Plaintiff to determine whether

to make a motion with respect thereto.

8. The obligation to provide the information sought by these document requests is

continuing within the terms of Rule 26(e) of the Federal Rules of Civil Procedure.

9. If YOU object that a term or phrase is ambiguous or indefinite, then provide itsunderstanding of the term or phrase and respond accordingly, as if that term or phrase has been

so defined.

10. If YOU are aware that a document or group of documents responsive to these requests

once existed, but has been destroyed or discarded, YOU are directed to state when the documentor group of documents was destroyed or discarded, why the document or group of documents

was destroyed or discarded, the person most knowledgeable about the content of the document(s)

and the circumstances under which the document or group of documents was destroyed or discarded.

11. Color copies of documents are to be produced where color is necessary to interpret or understand the contents.

12. If, after exercising reasonable diligence, YOU are unable to determine the existence of

any documents or things falling within a production request, YOU are requested to so state inany written response.

13. These requests for documents and things are submitted for purposes of discovery only,and nothing contained herein shall be taken as an admission of relevance, or as a manner of any

objections to the admissibility at trial, or of any evidence or information requested or furnished

in response thereto.





DEFINITIONS

As used herein, unless the context in which it appears clearly suggests otherwise, each of the

following terms has the meaning set forth below:

1. The term “YOU” means PUBLIC INTEREST REGISTRY, INC., and all of its agents,related companies, representatives, employees, experts, investigators, insurers, consultants,

attorneys or anyone acting on behalf of the foregoing, including without limitation,

2. The term “communication” shall mean any transmission of information of any kind,orally, electronically, in writing or in any other manner, at any time or place and under any

circumstances whatsoever.

3. The term “document” refers to any written or recorded matter as described in Rule 34 of

the Federal Rules of Civil Procedure including, without limitation, all writings, drawings, charts, photographs and recordings and shall include the original and every non identical copy, draft or reproduction in the possession, custody or control of YOU. The definition also includes

information stored or recorded by any electronic means, including, without limitation, in a

computer, hard drive, server compact disc, floppy disk, diskette, tape, record, cassette, electronicmail or voice mail, any other electronic recording or other data compilation from which

information can be obtained or translated, or any matters defined in Rule 1001 of the Federal

Rules of Evidence. Any such document bearing on any sheet (front or back), margin, attachment

or enclosure thereof, any marks, such as, without limitation, initials, stamped initials, comments,or notations of any character, which are not part of the original text or reproduction thereof, is to

be considered and produced as a separate document.

4. The phrase “all documents” means every document, as defined herein, which is known to

you, within your possession, custody or control, or that can be located or discovered by

reasonably diligent efforts. If you know of the existence, past or present, of any documents or things requested below, but are unable to produce such documents or things because they are not

presently in your possession, custody, or control, you shall so state and shall identify such

documents or things, and the person who has possession, custody or control of the documents or

things.

5. The terms “relating to” and “concerning” shall mean directly or indirectly referring to,

reflecting, describing, pertaining to, arising out of or in connection with, or in any way legally,

logically, or factually connecting with the matter addressed. These terms mean, withoutlimitation, any reference or relationship that either (i) provides information with respect to the

subject of inquiry or (ii) might lead to persons who, or documents which, might possess or contain information with respect to the subject of inquiry.





6. The terms “record” and “reflect” mean and include “constituting,” or “referring” to,”“pertaining to,” “evidencing,” “describing,” or “has anything to do with” and in each instance

directly or indirectly. These terms mean, without limitation, any reference or relationship that

either: (i) provides information with respect to the subject of inquiry or (ii) might lead to persons

who, or documents which, might possess or contain information with respect to the subject of inquiry.

7. The terms “all” and “each” shall both be construed as all and each.

8. The connectives “and” and “or” shall be construed either disjunctively or conjunctively

as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside its scope.

9. The use of the singular form of any word includes the plural and vice-versa.





PRODUCTION REQUESTS

1.) Produce any and all DOCUMENTS YOU have which reflect the true

identity (including name, address, telephone, fax, email, and any other contact information) of the current owner (and any/all past owners) of the

domain name: privacyprotect.org.

2.) To the extent not already answered in response to Item #1 above, produceany and all DOCUMENTS YOU have which reflect the true identity

(including name, address, telephone, fax, email, and any other contact

information) of the current and any/all past operator(s) of

privacyprotect.org.

3.) Produce copies of any contracts between YOU and the current and any/all past owner(s) and/or operator(s) of privacyprotect.org.

Who owns privacyprotect.org? Answer - Directi Internet Solutions, Pvt. Ltd.

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