online advertising year of living dangerously
Post on 15-Dec-2014
562 Views
Preview:
DESCRIPTION
TRANSCRIPT
What about it?
TV
36.8%
NEWSPAPERS
25.1%
MAGAZINES
12.8%
Surpass in 11Surpass in 11Surpass in 11Surpass in 11
Surpass in 10Surpass in 10Surpass in 10Surpass in 10 12.8%
ONLINE
10.9%
RADIO
10.2%
OUTDOOR
3.8%
CINEMA
Surpassed in 97Surpassed in 97Surpassed in 97Surpassed in 97
Surpassed in 06Surpassed in 06Surpassed in 06Surpassed in 06
Surpassed in 07Surpassed in 07Surpassed in 07Surpassed in 07
Surpass in 10Surpass in 10Surpass in 10Surpass in 10
Who AdvertisesOnline
Who AdvertisesOffline
$20.2 Billion (2007)
$25.9 Billion (2008)
$62.4 Billion (2012)
Online ad revenue
$62.4 Billion (2012)
$147 Billion (2012) (global)
And Who Doesn’t
•Political Ad Revenue Up 155% from 2004Revenue Up 155% from 2004
•But only 2.5% of $3 billion market
Uncertain Times
• Barclay’s– US ad revenue to fall approx
9% over next two years9% over next two years– Online ad revenue will
continue to grow at a slower double digit pace
• IAB– Q2 Report - $11.5B revenue
(up 15.2%)
• Behavioral
Targeting
• Key Word
Search
• CAN-SPAM
UpdateUpdate
• FTC and State
Enforcement
PAGE TWO
34343434SEATTLE’S SOGGY SODS
TELESCOPE SALES
BOOM IN ALASKAANCHORAGE. Alaska telescope retailers have reported a huge spike in telescope sales in September. According to
store owner Joe Monegan, local foreign policy experts are
buying the telescopes to watch Russia in light of its recent
invasion of Georgia. (More on Page 4)
Seattle Beacon October 14, 2008
CITY BREAKS RECORD FOR
CONSECUTIVE RAINY DAYS
SEATTLE. Forget Spain, the rain falls mainly in
Seattle as the Emerald City “enjoyed” its 34th
consecutive day of rain breaking the 1953
record. Sonny Smith, President of the Visitors
and Convention Bureau was quick to point out
that even with the record, the city still gets far
less total rain than cities such as Miami. In fact,
Seattle is not even among the top 101 cities for
total rainfall. So remember, it could be worse –
you could be in Miami.
Got Sun?
We got plenty in Palm Springswww.sunsunsun.com
PAGE TWO
34343434SEATTLE’S SOGGY SODS
TELESCOPE SALES
BOOM IN ALASKAANCHORAGE. Alaska telescope retailers have reported a huge spike in telescope sales in September. According to
store owner Joe Monegan, local foreign policy experts are
buying the telescopes to watch Russia in light of its recent
invasion of Georgia. (More on Page 4)
Seattle Beacon October 14, 2008
CITY BREAKS RECORD FOR
CONSECUTIVE RAINY DAYS
SEATTLE. Forget Spain, the rain falls mainly in
Seattle as the Emerald City “enjoyed” its 34th
consecutive day of rain breaking the 1953
record. Sonny Smith, President of the Visitors
and Convention Bureau was quick to point out
that even with the record, the city still gets far
less total rain than cities such as Miami. In fact,
Seattle is not even among the top 101 cities for
total rainfall. So remember, it could be worse –
you could be in Miami.
Got CLE?
PAGE TWO
34343434SEATTLE’S SOGGY SODS
TELESCOPE SALES
BOOM IN ALASKAANCHORAGE. Alaska telescope retailers have reported a huge spike in telescope sales in September. According to
store owner Joe Monegan, local foreign policy experts are
buying the telescopes to watch Russia in light of its recent
invasion of Georgia. (More on Page 4)
Seattle Beacon October 14, 2008
CITY BREAKS RECORD FOR
CONSECUTIVE RAINY DAYS
SEATTLE. Forget Spain, the rain falls mainly in
Seattle as the Emerald City “enjoyed” its 34th
consecutive day of rain breaking the 1953
record. Sonny Smith, President of the Visitors
and Convention Bureau was quick to point out
that even with the record, the city still gets far
less total rain than cities such as Miami. In fact,
Seattle is not even among the top 101 cities for
total rainfall. So remember, it could be worse –
you could be in Miami.
Got Elvis?
20TH ANNUAL CRUSHED VELVET
ELVIS ART SHOW
Who needs Picasso when you can have the King?.
TICKETS ON SALE NOW
BT 1.0User Tracked by
• Website
BT 2.0• Website
• Adware Program
• Ad Network BT 2.0User Tracked by ISP
(“Deep Packet Inspection”)
Response Response Response Response
• 40% to 111% increased response due to BT (Boston.com)
RevenueRevenueRevenueRevenue
BT 1.0BT 1.0BT 1.0BT 1.0
RevenueRevenueRevenueRevenue
• 2008: $775 MM (3% of online ad spending)
• 2012: $4.4 BB (8.6% of online ad spending)
2007: A Year in the Limelight
Merger Mania
Other NewsOther NewsOther NewsOther News• AOL Accidental Release of User Search Histories
(2006)• Google Reveals Search History Kept Indefinitely• Facebook’s Beacon program• FTC Workshop on Behavioral Targeting• Consumer Groups Call for “Do Not Track” Registry
Washington Responds
FTC Proposed SelfFTC Proposed SelfFTC Proposed SelfFTC Proposed Self----Regulatory PrinciplesRegulatory PrinciplesRegulatory PrinciplesRegulatory Principles
• Notice: A consumer-friendly and prominent notice that data is used for BT
• Choice: Give consumers the ability to opt-out
• Security: Must provide reasonable security and retain only as long as needed
• Sensitive Data: Express consent for use in BT
Congressional InvestigationsCongressional InvestigationsCongressional InvestigationsCongressional Investigations
• Privacy Implications of Google-DoubleClick Merger
• Potential Microsoft-Yahoo deal
BT 2.0
Is it legal? Probably. Do I think it's a good idea and it makes sense? No. I don't think it passes the creepy factor, and this market isn't ready for stuff that doesn't pass the creepy factor. We are isn't ready for stuff that doesn't pass the creepy factor. We are not in a place where we can do dumb things and stupid things like that, even if they're effective.
-- Dave MorganTacoda Founder and former CEO
Congress Responds
• Incredible leap into the breaching of the privacy of Americans – Rep. Markeyprivacy of Americans – Rep. Markey
• Isn't that just wiretapping – Sen. Dorgan• Contemptible – Rep. Greene
• Senior House members send letters to over 30 ISPs: has your company at any time tailored . . . Internet advertising based on consumers’ Internet search, surfing, or other uses?
• ISP Response–Cancel NebuAd tests
–Will provide opt-out mechanism
• NebuAd• NebuAd–Shelves BT 2.0–Other 2.0 companies may not survive
But aren’t we But aren’t we But aren’t we But aren’t we forgetting forgetting forgetting forgetting forgetting forgetting forgetting forgetting something?something?something?something?
What about the offline world?
Reported Data Breaches Q4-07
28%
14%
Brick & Mortar
E-Commerce
Government
Education
GENERIC FOODS
We got th
e goods
for you and on you
4%
28%
26%Education
Medical & Other
GENERIC FOODS
We got th
e goods
for you and on you
Average American has 4.3 loyalty cards
Coming to a C-SPAN Near You in 2009
IAB/PWC 2007 Revenue Report
Search is the largest Search is the largest Search is the largest Search is the largest segment of online segment of online segment of online segment of online advertising . . . . advertising . . . . advertising . . . . advertising . . . .
because it produces because it produces because it produces because it produces results.results.results.results.
Case study: Provenance Hotels Case study: Provenance Hotels Case study: Provenance Hotels Case study: Provenance Hotels experienced an increase ROI of experienced an increase ROI of experienced an increase ROI of experienced an increase ROI of 2,700% through SEO and paid 2,700% through SEO and paid 2,700% through SEO and paid 2,700% through SEO and paid search.search.search.search.
Lanham Act
Section 43Any person who, on or in connection with any goods or services, or any container for goods, uses in commerceany word, term, name, symbol, or device, or any combination thereof . . . which
is likely to cause confusion . . . as to the affiliation . . . the origin, sponsorship . . .
Civil Liability
affiliation . . . the origin, sponsorship . . . of his or her goods . . . by another person
in commercial advertising . . . misrepresents the nature, characteristics, qualities, or geographic origin of [the] goods
is likely to cause dilution by blurring or . . . tarnishment of the famous mark, regardless of the presence or absence of actual or likely confusion
[A] mark shall be deemed to bein use in commerce—
(1) on goods whenon goods whenon goods whenon goods when . . . . . . . . . . . . placed in any manner on the goods or their containers or the displays associated therewith or on the tags or labels affixed thereto, or if the nature of the goods makes such placement impracticable, then on documents associated with the goods or their sale…
(2) on serviceson serviceson serviceson services whenwhenwhenwhen it is used or displayed in the sale or advertising of services and the services are rendered in commerce…
ONE VIEW: Keyword bidding not use in commerce since it “is
strictly internal, and, because such use is not communicated to
the public, the use does not indicate source or origin of the mark”
You Are Here
Use in Commerce
Only the Second Circuit has found that an $8.6 billion industry is not involved in commerce.commerce.
Does Bidding on Competitor’s
Trademark Constitute
Infringement?
Likelihood of confusion Likelihood of confusion Likelihood of confusion Likelihood of confusion among judgesamong judgesamong judgesamong judgesamong judgesamong judgesamong judgesamong judges
Initial Interest Confusion
Use of another trademark “in a manner calculated to capture initial consumer attention, even though no actual sale is though no actual sale is finally completed as a result of the confusion.”Brookfield Communications Inc. v. West Coast Entertainment Corp., 174 F.3d 1036 (9th Cir. 1999).
B Tal
• Improperly Benefits From Goodwill of Trademark
• False Detour From Information Super-highway– Analogy to false detour sign directing
consumers to take wrong exit. “Unable to
Rationale
consumers to take wrong exit. “Unable to locate West Coast, but seeing the Blockbuster store right by the highway entrance, they may simply rent there..” Brookfield Communications, Inc. v. West Coast Entertainment Corp., 174 F.3d 1036, 1062 (9th Cir. 1999)
• Bait and Switch– “Initial interest confusion can be viewed
as a variation on the practice of ‘bait and switch.’” 3 J. Thomas McCarthy, McCarthy on
Trademarks & Unfair Competition § 23:26 (4th ed. 2003).
“The initial interest confusion confusion doctrine is a mess."
Counterpoint
• Not a Detour, Merely a Lane ChangeNot a Detour, Merely a Lane ChangeNot a Detour, Merely a Lane ChangeNot a Detour, Merely a Lane Change– Web surfers are accustomed to false starts
and are unlikely to be dissuaded when they end up at the wrong site. Chatam Int'l v. Bodum, Inc., 157 F.Supp.2d 549, 559 ED PA 2001).
• No different than supermarket placing No different than supermarket placing No different than supermarket placing No different than supermarket placing store brand next to branded productsstore brand next to branded productsstore brand next to branded productsstore brand next to branded products.store brand next to branded productsstore brand next to branded productsstore brand next to branded productsstore brand next to branded products.– FragranceNet.com, Inc. v. FragranceX.com,
et al. No. 06-CV-2225 (JFB)(ART)(E.D.N.Y., June 12, 2007)
• Legally Significant Confusion?Legally Significant Confusion?Legally Significant Confusion?Legally Significant Confusion?– “The [District] court’s refusal to enter the
‘initial interest confusion’ thicket is well taken given the unlikelihood of ‘legally significant’ confusion.” Hasbro Inc. v. Clue Computing, Inc., 232 F.3d 1, 2 (1st Cir. 2000).
• No Liability If Trademark No Liability If Trademark No Liability If Trademark No Liability If Trademark Not DisplayedNot DisplayedNot DisplayedNot Displayed– Keyword advertising is a “use in commerce,” but cannot confuse consumers if the ultimate search results do not
Non-Doctrine Standard
consumers if the ultimate search results do not display plaintiff’s trademarks. J.G. Wentworth SSC Ltd v. Settlement Funding LLC, No. 06-0597 (E.D. Pa. Jan. 4, 2007).
CAN-SPAM Act of 2003
CAN-SPAM IS . . .
• An anti-fraud and disclosure statute
• Applies to an email where the “primary purpose” is commercial advertisement or
CAN-SPAM DOES NOT . . .
• “Can Spam” – except for wireless spam
• Include a “Do Not Email Registry”
• Impose an “ADV” advertisement or promotion of a product or service
• Impose an “ADV” labeling requirement
• Create a general private right of action
• Have a volume requirement
CAN-SPAM Principal Requirements
From line must
identify initiator
Subject line must not be deceptive.
Adult Messages must provide notice.
UCE must be
identified
as
Postal Address for AdvertiserRequires Working Opt-Out
Mechanism for Advertiser
as
“advertisement”
Regulatory Timeline
2004: FTC Final Rule on Adult LabelingFCC CAN-SPAM Rules
2005: FTC (1) Final Rule on Primary Purpose
of Email; and (2) Proposed Discretionary Rules
2006:
2007:
2008: FTC Final Discretionary Rules
Discretionary Regs
Definition of Valid Physical Address• Accurately registered P.O. Box allowed• Accurately registered P.O. Box allowed
Opt-Out Requests Conditions or Expiration• Cannot impose any conditions on opt-out requests
– (e.g, fee or provide information)• Abandons proposal to reduce processing time to 3 days• Rejects call for expiration period for opt-out requests
Must Be a Sender Under CAN-SPAM
• Name must be in the “From” Line
Designated Sender Rule
CAN-SPAM
Cannot designate Non-Sender
Line
• Must be Responsible for CAN-SPAM compliance
• Dropped requirement that Designated Sender be in control of the content or the mailing list used
“Sender” Liability• FTC unsuccessful in seeking strict liability
• Advertiser liable if “actual knowledge, or by consciously avoiding knowing” about affiliate knowing” about affiliate violations– Hypertouch v. Kennedy-Western UniversityStrict anti-spam policies and policing of affiliates defeated allegation of intent.
– ASIS Internet Services v. Opt-In Global, Inc. No duty to investigate
CAN-SPAM Plaintiffs
• FTC
• State AGs
• Internet Access Service Provider (IASP)Provider (IASP)– Adversely Effected by Violation
• No Consumer Private No Consumer Private No Consumer Private No Consumer Private Right of ActionRight of ActionRight of ActionRight of Action
Is the IASP Remedy a Trojan Horse?
Hypertouch v. KennedyHypertouch v. KennedyHypertouch v. KennedyHypertouch v. Kennedy----Western Western Western Western UniversityUniversityUniversityUniversity
•Small, free service can qualify....
•Concern that Hypertouch is a professional plaintiff can only be professional plaintiff can only be addressed by Congress
•Opens door to litigation by anti-spam activists as faux-IASPs
Hypertouch and its principal have filed approx. 40 cases under CAN-SPAM and/or California law
Is Gordon a Proper Plaintiff?
• Gordon v. VirtumundoGordon v. VirtumundoGordon v. VirtumundoGordon v. Virtumundo
– Continued to use other people's e-mail addresses to collect spam . . . for generating lawsuit-fueled revenue
– No harm related to
• Bandwidth
• Hardware
• Internet connectivity, network integrity
• Overhead, staffing or equipment costs
No!
• Not Plaintiff Congress had in mind – must demonstrate substantial harm
Followed in Cal Followed in Cal Followed in Cal Followed in Cal Federal CourtFederal CourtFederal CourtFederal Court
ASIS Internet Services v. ASIS Internet Services v. ASIS Internet Services v. ASIS Internet Services v. substantial harm
• Awards Defendant Attorneys’ Fees – suit “ill-motivated, unreasonable, and frivolous”
ASIS Internet Services v. ASIS Internet Services v. ASIS Internet Services v. ASIS Internet Services v. OPTIN Global OPTIN Global OPTIN Global OPTIN Global (N.D. Cal. 2008)(N.D. Cal. 2008)(N.D. Cal. 2008)(N.D. Cal. 2008)
CAN-SPAM PREEMPTS ALL STATE REGULATION OF EMAIL EXCEPTSTATE LAWS
• Regulating falsity or deception in email
• Not specific to email, including State trespass, contract, or tort law; or
• Other State laws to the extent that those laws relate to acts of fraud or computer crime
• Misrepresentation must be material
• States cannot dictate form of from line – Cannot prohibit use of multiple domains.
– Not misleading to use non-corporate address where domain may be checked using “Who Is”
State Preemption
Case Law
• State regulation must be based on traditional notions of fraud
• First Amendment requires that it not impinge non-commercial email
Preemption’s Back Door?
• Utah/Michigan Utah/Michigan Utah/Michigan Utah/Michigan Child Registry LawsChild Registry LawsChild Registry LawsChild Registry Laws– Makes sending prohibited email a “computer crime”
– Free Speech Coalition, Inc. v. Shurtleff,Utah Federal Court refused to enjoin law finding it fell within exception for finding it fell within exception for computer crime • DOJ filed brief supporting this position
• New Colorado Spam LawNew Colorado Spam LawNew Colorado Spam LawNew Colorado Spam Law– Makes violation of CAN-SPAM a violation of state deceptive practices and computer fraud laws
– Is this a backdoor to creating private right of action under CAN-SPAM?
AB 2950
• Pushed by anti-spam activists who have filed over 100 suits
• Wish list
– Advertiser liability
– Prohibiting use of multiple domains
– Tactics to evade email filters
– Expand Plaintiffs to include District & City Attorneys
– Venue
– Restore Statute of Limitations to 3 Years
AB 2950
• Pushed by anti-spam activists who have filed over 100 suits
• Wish list
– Advertiser liability
– Prohibiting use of multiple domains
– Tactics to evade email filters
– Expand Plaintiffs to include District & City Attorneys
– Venue
– Restore Statute of Limitations to 3 Years
www ≠ Wild West West
Increased State Enforcement
� The Majors� New York
Continues to be activist post-Spitzer
under Andrew Cuomo
� Texas
80 Arrests First Three Years
� Washington
Five spyware lawsuits since 2005
� New Kids on the Block� Florida
Established in 2007. Investigating 10 companies over “Free ” promotions
� Kansas
Launched in September 2007
FTC & State Enforcement
•Deceptive Advertising– The High Cost of “Free”
•Unfair Practices•Unfair Practices– Data Security – will impose sanctions if security not adequate for type and volume of data collected
– Drive by Downloads
FTC Consent Decrees
QUALIFICATIONS TO “FREE” OFFERS QUALIFICATIONS TO “FREE” OFFERS QUALIFICATIONS TO “FREE” OFFERS QUALIFICATIONS TO “FREE” OFFERS
MUST:MUST:MUST:MUST:
• Be in the same colorcolorcolorcolor,,,, font, and
size and within close proximity
• Disclose if purchase required• Disclose if purchase required
• Disclose all monetary and non-
monetary (e.g., credit card
application) obligations a consumer
is likely to incur to obtain the
advertised gift.
• All zones must be “above the fold” / visible to consumer w/o scrolling
• All font types must conform to Web Standard size equivalencies
Florida 3 Zone Standard
• W3C Color Contrast standard applies to all disclosures in all zones (125 min.)
• All disclosures must be visible at all times throughout the order path
Tallahassee Three Step
• Zone 1 Zone 1 Zone 1 Zone 1 –––– Price and Price and Price and Price and Term ($9.99 per Term ($9.99 per Term ($9.99 per Term ($9.99 per month) month) month) month)
• Must be disclosed entirely within 125 pixels in any direction from the cell submit field and the P.I.N. code submit field.
Zone 2Zone 2Zone 2Zone 2---- Types of Content Types of Content Types of Content Types of Content (Ringtones and Other Text (Ringtones and Other Text (Ringtones and Other Text (Ringtones and Other Text Services)Services)Services)Services)
• Must be disclosed no greater than 20 pixels from the Offer Description (Get 10 Bonus Ringtones)
code submit field.• 12pt. minimum font size• Must be disclosed in
numerical format 0-9 and include $ and without any other text except price/term
Ringtones)
• Other Text Services can be no smaller than 50% of the font size of the Offer
• Description (Get 10 Bonus Ringtones) Minimum font size is 20pt.
Zone 3 Zone 3 Zone 3 Zone 3 –––– Age / Other T’s and Age / Other T’s and Age / Other T’s and Age / Other T’s and C’sC’sC’sC’s
• Age description must be above T’s and C’s. Minimum 12pt. font size.
Online Gambling
US: Online gambling/ads are illegal
• Google, Microsoft & Yahoo: $31.5 million settlement with DOJ (Dec. 2007)
• DotNet sites are illegal unless– There are no web links to an online – There are no web links to an online gambling site; and
– Home page has disclaimer stating the site is purely educational
Online Gambling Liberalization in Europe
• Still highly regulated
Antigua v. United States
WTO Battle over Online Gambling
• WTO: To the extent online gambling was allowed within the U.S. (some states permit online gambling for horse racing), foreign companies were entitled to equal access to this market
• Awarded $21MM/yr in damages which may be recouped by suspending IP protection for US goods– US-Antigua negotiations ongoing
• EU may bring similar claim– Damages in billions– Decision expected by end of the year
Selected Cases I
Keyword AdvertisingKeyword AdvertisingKeyword AdvertisingKeyword AdvertisingUse In CommerceUse In CommerceUse In CommerceUse In Commerce
• NO: Rescuecom Corp. v. Google, Inc., 456 F.Supp.2d 393 (N.D.N.Y., September 28, 2006)
• YES: Playboy Enterprises, Inc. v. Netscape Communications Corp.. 354 F.3d 1020 (9th Cir., Jan. 14, 2004)14, 2004)
Initial Interest Confusion DoctrineInitial Interest Confusion DoctrineInitial Interest Confusion DoctrineInitial Interest Confusion Doctrine
• Brookfield Communications Inc. v. West Coast Entertainment Corp., 174 F.3d 1036 (9th Cir. 1999).
Questioned byQuestioned byQuestioned byQuestioned by• Chatam Int'l v. Bodum, Inc., 157 F.Supp.2d 549, 559 (ED PA 2001).• FragranceNet.com, Inc. v. FragranceX.com, et al. No. 06-CV-2225 (JFB)(ART)(E.D.N.Y.,
June 12, 2007)• Hasbro Inc. v. Clue Computing, Inc., 232 F.3d 1, 2 (1st Cir. 2000).
Selected Cases II
CANCANCANCAN----SPAM ACTSPAM ACTSPAM ACTSPAM ACT
Preemption
• Omega World Travel, Inc. v. Mummagraphics, Inc., 469 F.3d 348 (4th Cir. 2006)
• Kleffman v. Vonage Holding Corp., Case No. CV 07-2406GAFJWJX (C.D. Cal. May 23, 2007)
• Gordon v. Virtumundo, Inc., Case No. 06-0204-JCC (W.D. Wash. May 15, 2007)
• Virginia v. Jaynes, No. 062388 (Va. September 12,2008)
IASP Standing• ASIS Internet Services, v. Optin Global, Inc., 2008 WL 1902217 (N.D. Cal. March 27, 2008 )
• Hypertouch v. Kennedy-Western University, 2006 WL 648688 (N.D. Cal. 2006)
No Strict Liability
• US v. Impulse Marketing, No. CV05-1285RSL (W.D. Wash. June 8, 2007)
• US v. Cyberheat, 2007 U.S. Dist. LEXIS 15448 (N.D. Ariz. 2007)
Selected Cases III
Online Gambling
• United States – Measures Affecting The Cross-border Supply Of Gambling And Betting Services. Recourse to Article 21.5 of the DSU by Antigua and Barbuda, Report of the Panel, World Trade Organization, WT/DS285/RW (07-1209), March 30, 2007.
FTC GuidelinesFTC Guidelines
• Dot Com Disclosures: Information About Online Advertising
• Advertising and Marketing on the Internet: The Rules of the Road
• FTC Policy Statement Regarding Advertising Substantiation
• FTC Guides Against Deceptive Pricing
Bennet KelleyBennet KelleyBennet KelleyBennet Kelley
Bennet Kelley is founder of the Internet Law Center in Santa
Monica where he helps clients navigate the challenges of the digital
economy. He has been active in many of the hottest Internet issues
over the past decade including cyber squatting, internet marketing
and promotions, online gambling, net neutrality, privacy and spam.
Bennet is the Vice-Chair of the California State Bar's Cyberspace
Committee and is a regular contributor to the Journal of Internet
Law. Bennet worked in-house with companies such as ETM Law. Bennet worked in-house with companies such as ETM
Entertainment Network, SpeedyClick.com and ValueClick prior to
launching the Internet Law Center.
The Internet Law Center’s newsletter, Monday Memo, recently was
named one of the top 100 Internet Law resources..
Contact: Internet Law Center 100 Wilshire Blvd, Suite 950Santa Monica, CA 90401310-452-0401bkelley@internetlawcenter.net
www.InternetLawCenter.net
top related