defendant ryan burrage answer to righthaven copyright complaint

8/9/2019 Defendant Ryan Burrage Answer to Righthaven Copyright Complaint

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- F I t '(; - /? 92 (; ig j viz- FN 7 ff R (:' g) s Eg R vgp chlf.Jfl ) 7)i G ! t.t .,.k rt 'r IF' $ cg !y j: ctjjy )RYAN G.BURRAGE 'W ebmaster - Jerryltyburg.com- -4c--.-d--.- 2t. ltrs I a p ,- a1,Kenner, IA 70065,' sox-aw -w oz c:iF.i ..t. -.(..'. ;,(,,. caua.r. (--,o-,-,--,b-,---.---.,, a,s.-,:, :,rs- vta,4 M ling Prose RK------ - - - pppyy5

67 STAYF.R DIO IW COURT8 DISTRIG oF NEVADA910 e No.: No. zkzo-cv-ozz8311 RIGHTHAVEN L1X, a Nevada limited- QFAN NSE TO COM PIA INT AND DEM ANn I?()RJIJRY YRIAI.12 liability company,13 vs.1415 JERRY RYBURG, an Individual; and, RYAN BURM GQ16 an lndividual17 Defendants1819 PARTTF.R20 1. DefendantcRYM BURRAGED is tlze sole owner of the website in question, JerryRyburg.com, and is21 tlle only legitirnate defendant in this lawsuit. WJERRY RYBIJRG * the other defendant mentioned in tlle22 Plainh/s original complaint, is not a real person. *JERRY RYBURG'' is the nom deplum of the23 ddendant and is not a separate pelson. Therefore. RYAN BURM GE and JERRY RYBURG are one and24 the same individual.25 2. 'Ilze Defendnnt em blished the website by purchasing the domnin name Uenykyburpeome in26 November of zozo from GoDaddy.com. Additionally, private reglstration for the domain name wms27 purchased tbrough GoDaddy's private registmtion entity, DOMM NS BY PROXY, INC. 'Ihis was done to28 inhibit the publication of pemonal details on the internet.

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Case 2:10-cv-01283-GMN-RJJ Document 7 Filed 08/18/10 Page 1 of 27


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No otherparty other than this Defendant, RYAN BURRAGE, has anytbing to do w1t11 the operation andmanagement of the contents and materials on JerryRyburpcom.

JIJRISDICIAONOn or about May 26, zolo, the Ddendant did republish an article entitled QYA Keeps Watchlist efPeeved 'Davelers,'' authoredby Sherman Fredrick of the Las Ve> Review Jotlrnaltl


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Defendnnt to allegedly infringe upon the copyrkhts of the works of others. As a writer hirnself, theDefendant is committed to the enforcement of copyriglzt laws in the United State.s of merica.At no time were any stories publisbed wbere tbe Ddendant claimed authorship for a work he did notoriginally create. In the cases where storie,s were republished from RSS feeds, the original source andauthor were cited, and a Rbacklink'' was provided to the original websites.'Ihe Plaintiffseems to argue that because content originating from LVRJ, originating from tbe state ofNevada, was republished on JerryRyburpcom, that the State of Nevada wms the f'OC..II target of thewebsite. If this were the case, lhen this would necessarily be thejustification in ming THE UNITEDSTATES DISTRIW COURT OF NEVADA as the trial venue. If a trial is so warranted, a cbange of venueis hereby requested, and tlze location of such a trial should be held in New Orleans, L& wheretheDefendant owns and opemtes the website in question.Certainly, the Defendant does not andwill not forbid or target certain statms to view his website. It isnotthe ftmction of any website to willingly tIZT'II away or block tram c from spedfic regions of the counor the world without valid concern - this would be constituted as unmerited discrimination. In tbeevent tlmt a userfrom the state of Nevada did Wsit JenyRyburg.com, he/she did so bytheir ownvolition.Although the Plainliff makes mssertions that the republishing of the LVRJ story infringes copyright, it istNe epinion of the Defendant that Ms use of the article fell under the Rfair use'' clause of copyriryht lawand tlze Dkital Millennium Copyright M IDMCAI. In addition, it is not altogether uncommon for newsarticle.s to be reprintedby other entities, up to and including competing news agencies. This pradicebolds tnze in print, broadcast, and digitaltinternd) media.Although the Plaintiff makes assertion: that the republishing of the LVRJ story on JenyRyburgpcom hashanned the original source, tbe facts simply do not substantiate the daim. In fad, contzaly to thePlaintifrs claim, linking to the original sourcesfbacklinking*) is a form of promotion for the originalsource which improves, not hanns, awebsites ranking in the search engines. Please referto EXHIBITK According to Alexa.com, a website whic.h ranks other websites, Lvrj.com has a three-month globalAleexa tramc rank of 8,812 with 4,218 sites linking in. This is avely desirable ranking. On the otherhand, JenyRyburpcom has anAlexa Traflic Rnnk of 14,449,934 V,.II only one website linking in. Tlliswould indicate that even if a user was to seare.h for a specific Lvlu.com article in a search engine, the

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Lvlktcom website would be returned in the top 1.e* ts. Backlinks provide autllority to a website.W hen the Defendant and others linked to this particular LVRJ s'tory, a11 sites linking to LVRJ.COmadded autbolityto Lvlu.eom andbooked its search engine rankings.The Defendant's wee ite had, on average, oaly z8s uniquevisitors in the time specified l)y tl:e Phintiff. Inadditbn the Defenclant's website averaged 1- than zssoo page views in the time specised by the Plaintiff.Please referto EYHIBIT B.W hile JerryRyburg.com did indeed have opportunities to generate income through the use of GoogleAdsense and other Cost-per-Acquisition er Cost-rer-Action offers, no income can be connected directlyto JenyRyburpcom. Even more difficttlt, the republishing of the article on Jerlyltyburg.com cannot beconneded to any income in and of itself. There are no ways to prove or disprove that any income wasgenerated ms a result of republislling the specific LVRJ story in question.It is the Plaintiffs assertion that the Defendant is guilty of copyright infringement between the times ofM ay 26, 2olo to July 23, zolo. However, by the Plaintiffs own sworn admission, he did not own thecopyright to the said article until July 14, zolo. This would indicate that the Defendant is guilty ofalleged copyright infringement for a 9 day period, July 14, 2olo to July A3, zolo. The originalcomplaint shotlld therefore be amended ms such. Refer to Plaintils IW HIBIT 4.Taking into account the structure and nature of the Plaintiff's legal complaint, the adual damage-s, ifany, suffered by the plaintiff cover only a 9 day period, and they amount to nothing more than printingthe article from the website and sharing it with coworkers in a typical eflice environment. It Ls also theequivalent of a passer-by stopping in front of a newsstand and reading the front page of the newspaper.without antlArllly buying the newspaper.Even if the Defendant was te republish an article from the LVRJ.COm website directly, he is not onlywithin his rightxs do so, but all tusers of LvmLcom are encouraged to dojust that. Refer to RYHIBIT C.The LVRJ.COm website offem and invites its users to Gsave and Sharen a1l of itq articles no less than 19times per m icle. In addition, Lvltl.com encourages and invites its users to TfEmail This,b Gsave 'Ihis,''=print 'rhis,n and subscribe to its ?WSS feeds., n is not only puts the tlsers of Lvr .com in a quagmire,but it is tlze opinion of tlle Defendant that Lvltl.com is gttilty of entmpment, or at least setting up theusers of the Lvlu .com for a potential lawsuit. W hile tbe Lvlc com encourages and invites its users tof'share and Saveo article.s a total of 23 times per article, the LW c com will 6le a frivolous copyright

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infringement Iawsuit against its users, if t.1* follow Lvr 's diredions and invitations to Y hare andSaveo articles published on their website.Tbe Plaintiffasserts in the original complaint that the Y efendants did not seek permission, in anymanner, to reproduce, display, or otherwise exploit the Work.o and N'be Defendants were not grantedpermission, in any manner, te reproduce, display, or otherwise exploit the work, sedion 2o of thisresponse indicate.s and prw es otherwise. Even though the Defendnnt did not directly publislz the workfrom LvlU.com, and it was indirectly published through KSS s'yndication, the Defendant was still underhis right to republish the article, as evidenced by the total of 23 invitations to do so on the originalsource website, Lvlll.com . Refer to EXHIBIT C. These invitatiomq and encouragements to V ave andShare'' the article absolve the Defendant from the need to Gseek pennission* and/or bave permissiongmnted from LVRJ to Greproduce, display, or otherwise expleit the W ork.olt is the opinion of the Defendant that this lawsuit is entirely predatory, flivolous, and an abuse of theUnited States Justice System. W hile the defendant acknowledges G atthe Plaintiffis notbound by lawto issue a Rcease and desistn Ietter when alleged infringement is found, it is the common legal etiquetteand and process to begin V t.IZ a *cemse and desisto letten Had such a Gcemse and desiste order beenoffered, the Defendant would have cooperated and obliged accordingly. 'I'he opinion of the Ddendant isthat in not isstting a Gcease and desistr order prior to filing this lawsuit, the Plaintifrs sudden Sling of alawsuit alleging copyrir/tt infringement is unethical, immoral, improper, and indicates a stlspiciottsmotivation to do so. In addition, the opinion of the Defendant is that the adions of the Plandffareexactly what give.s Rtrial lawyersn a bad name-It is the opinion of the Defendnnt the Plaintiff Ls engaged in a shakedown or extortion opem tion, V tIZthe express purpose of abtusing the legal system to extort or shakedown webmasters and bloggers whorepublish content from the LVRJ in accordance w1t11 Rfair usen and DMCA In the majority of cases,induding that of the Defendant, victims of the Plaintiff's witch hunt are bloggers and webm asters whogenerate very little revenue, if any, from their sites. At the current rate of lawsuits being Gled againstwebmasters by th1 Plaintiff, THE UNITED STATES DIS'I'RIW COURT OF NEVADA V II necessarllybedogged andbogged down w1t.11 many similar Iawsuits. The Plaintitfis operating w1*11 exyedation thatthc vidims af his Mcopm gbt trolling* operation * 1 settle out ef court mther than absorb the costs offighting tbis matter. This is simply an effort bythe Plaintiff, Rigbthaven, LIX, in collusion w1t11 the

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LVRJ, to extort settlements for allegedly minor infringements fm m unsuspeding webmasters andbloggem who lackthe means and funds to fight such a frivolous lawsuits. In tlleae cases, manybloggersand webmasteo w111 choose to pay tbe settlement in lieu of the Iidiculous statutory damage claim sbythe Plaintiff.

Dated this 9* day of Augtlst, 2o1o

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1 RYAN G BUXM GEW ebmaster - JenyRyburpcom2 74 Coronado AveKenner, IA 7oo6s3 504-339-1902rvanoz l-vanbxlr-ag-zqliA, tllerhvtlllllakel'sci'vahoo.com4 ' ' JYo,*567 STATKS D'SY R'W COURT8 DISTRIW OF NW ADA910 e No.: No. m lo-cv-ozz8:41 1 RIGHTHAVEN LLC, a Nevada limited- RFNN NSE #rO COM PI.M NT AND DRM ANR FORJURY YRIAI.12 liabilrtycompany,13 Vs.1415 JERRY RYBURG, an Individual; and, RYAN BURRAGE,16 an Individual17 Defendants1819 PAXW FA20 Defendantck'fM BURM GE') is Ge sole owner of tlle website in question, JerryRyburg.com, and is21 the only legitimnte defendnnt in this lawsuit. WJERRY RYBURG * the otber defendant m entioned in the22 Plaintiff's original complaint, is not a real person. RJERRY RYBURGN is the nom de plum of tlze23 ddendnnt and is not a sepamte person. n erefore, RYAN BURRAGE and JERRY RYBURG are one and24 the same individual.25 2. 'lhe Defendant e> blished the website by purchasing tlze domain name Q enyRyburpcom'' in26 November of zolo from GoDaddy.com. Additionally, private reglstradon fortbe domain name was27 purchased through GoDadd/s private registration entity, DOMMNS BY PROXY, INC. 'Ilzis was done to28 inhibitthe publication of personal details on the internet.



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No other party otherthan this Defendant, RYAN BURM GE, has anythingto do with the operation andmanagement of the contents and materials on JerryRybuzg.com.

A TRISDIG IONOn or about May 26, zolo, the Defendant did republish an article entitled G'I'SA Keem W atchlist ofPeeved Travelers,o authored by Shennan Fredrick of the Ixs Vegas Review JourmaltiLvlW 'l.The article in question was not published bythe Defendant directly, ms it was automatically syndicatedthrough Re.aI Simple Syndicationtltss). The source of the Rss Feed was infowars.com andprisonplanet.com. n erefore, the original publisher, LVRJ, was syndicated to infowars.com andprisonplanet.com, which was then automatically syndicated on JenyRybttrg.com .The originator of the material, LVRJ, was credited at a1l times, up to and including a linkbackto theoriginal source, LVN .C.Om.At all times, the Defendant had m oper means to be cxmtacted in the event of any O pyrigllt infringementand/or other concerns.On or about July 23, zolo, the Defendant was conuded via email purported to be from Domains byProxy, Inc, stating that there was a possible legal issue regarding the domain name, JenyRyburg.com .Erroneously believing the email to be a common ''phishingn scam, the defendant ignored the emailcompldely. See FNHIBIT D.On or about July 23, uoto, and independent of tlzis lawsuit tbe Defendant had already completelydeleted a11 content on JenyRyburpcom to explore a new subjective fonnat to the website. The websiteis still under consmzdion ms of present.

FACTSThe Defendant owns and operated a website JenyRyburg.com, which aggregated news storie.s andofered original commentam mostly on news stories whic,h were already common knowledge. Originalcommentary and original editorials on popular news stories were frequent and were written from alibertarian, constimtionalist standpoint, In addition, many stories were automatically syndicated,asmentionedbefore, through RSS feeds of news sites and/orblogs. It is common practice on the internetfor news sites and blogs te encourage users to Gsubscribe'' to their respective WSS Feeds.At no time was it the intent of the Defendant to defraud cause harm, misrepreesent, intercept websitetrafsc, profit, or exploit the LVRJ, Lvlu .com, or its related stories It was also not the intent of the

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Defendant to allegedly infringe upon tbe copyrlrshts of the works of others. As a writer himself, theDefendant is committed to the enforcement of copyright laws in the United States of America.At no time were any stolies publislzed where the Defendant claimed authorship for a workhe did notoriginally create. In the cases where stories were republished from KSS feedsy the original source andauthor were cited, and a ''backlinkn wms provided to the original websites.The Plaintiff seems to argue that becatlse content originating from LVRJ, originating from the state ofNevada, was republished on JenyRyburg.com, that the State of Nevada was the focal target of thewebsite. If this were 1he case, then this would necessarily be the justification in using'rl'lE UNFIEDSIWTES DISTRIW COURT OP NEVADA as tbe trial venue. If a trial is so warranted, a change of venueis hereby requested, and the location of such a trial should be held in New Orleans, W where theDefendant owns and operates the website in question.Certainly, the Defendant does not and will not forbid or target celtain sute-s to view his website It isnot the function of any website to willinglyturn away or block traffic from specific regions of the colmor tlze world without valid concern - this would be constim ted ms unmerited discrimination. In theevent that a user from the state of Nevada did visit JenyRyburpcom, he/she did so l)y his/her ownvolition,Altho!zgh the Plaintiffnmkes assertions that the republishing of the LVRJ story infringes copynght, it isthe opinion of the Defendant that his use of the artiele fell under tlze ufair ttseo clause of copyright 1awand the Digibal Millennium Copyright ActIDMCAI. In addition, it is not altogether tmcommon for newsarticles to be reprinted by other entities, up to and including competing news agencies. This pradiceImlds tnze in print, broadcast, and digitaltinternet) media.Although the Plaintiff makes assertions that the republishing of the LVRJ story on JenyRybuq .com hasharmed tlze orisnal sotlrce, tbe facts simplydo not mzbstantiate the claim. In fad, contrary to thePlaintifrs claim, linking to the original sourcelebacklinkinT) ks a fonn of promotion forthe originalsource whicb improves, not harms, a websites ranking in the searcb ensnes. Please referto EYHTRI'F.4. According to Alexmcom, a website which zanks other websites, Lvrj.com has a three-month globalAlexa traiiic rank of 8,812 with 4,218 sites linking in. n is is a very desirable ranking. On the otherhand, JerryRyburg.com hms an Alexa 'rraffic Rank of 14,449,934 w1t11 only one website linMng in. 'fhiswould indicate that even if a user was to searc.h for a specific LVRJ.COm article in a search engine, the

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Lvltl.com website would be lvturned in the top results before JerryRyburg.com would appear.Backlinkq provide authority to a website. W hen the Defendant and others linked to tllis particular LVRTstory, a11 sites linking to Lv'RJ.com added autholityto LVRJ.C'Om and boos-ted its search enginerankings.The Defendant's website had, on average, only 285 unique visitors in the time specified by the Plaintiff.In addition, the Defendnnt's website averaged le-ss than 2,500 page views in the time specified bythePlaintiff. Please refer to RYHIBH B.w hile JenyRyburpcom did indeed have opportunities to generate income tllrour,h the use of GoogleAdsense and other Cost-per-Acquisition or Cost-per-Artion og'rs no income can l)e conneded directlyto JerryRyburpcom. Even more di cult, the republksbing of tbe article on Jerryltyburg.com cannotbeconneded to any income in and of itself. 'rhere are no ways to prove or disprove that any income wasgenerated as a reattlt of republishing the specisc LVRJ story in question.It is tbe Plaintiff's assertion tbat the Defendant is plilty of copyright infringementbetween the times ofMay 26, 2o1o to July 23, 2010. However, bytlle Plaintifl's own s'worn admission, he did not own thecopyright to the said article tmtil July 14, zolo. 'rhis would indicate that the Defendant is guilty ofalleged copyrirsht infringement for a 9 day period, Jttly 14, 2o1o to July 2a,zolo. The originalcomplaint should therefore be amended ms such. Refer to Plaintifrs MM HBH '4.Taking into accotmt the stntcture and nahlre of the Plaintils legal complaint, the adual dmnages,ifany, sttffered bythe Plaintiffcover only a 9 day period, and th% amount to nothing more than printingthe article from the website and sharing it with coworkers in a typical omce environment. lt is also theequivalent of a pmsser-by stopping in front of a newsstand and reading the frtmt page of the newspam r,without actually buying the newspaper.Even if the Defendant wms to republish aa article from tlle LVK1com website directly, be is not onlywithin his rights do so, but all users of Lvlll.com are encouraged to do just that. Refer to RFFHBITC.The Lvlttl.com website offers and invites its users to Gsave and Sharex 21 of iys articles no less tlmn 19times per article. In addition, LvllAcom encouru e.s and invite.s its users to 'iEmail TlzisyM aSave n Lqye''Print This,'' and subscribe to its ':IISS feetls.* This not only puts tlle lssers of LW tl.com in a quagmire,but it is the opinion of the Defendant that Lvlc com Lq gtzilty of entrapment,or at least setting up thelzsers of he Lvlu.com for a potential lawsuit. W hile the LvKLCOm encouragea and invites its users to

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1 GSIIaI'e and Saven artides a total of 23 times per article, the Lvlu.com will flle a flivolous copyright2 infringement lawsuit against its ltsers, if tht'y follow Lvlu's diredions alld invitations to ushare and3 Saveo articles published on their website.4 22. The Plaintiff asserts in tlle original complaint that tbe Gllefendants did not seek permission, in any5 manner, to reproduce, display, or otherwkse exploit the Work,/ and 'The Defendants were not granted6 pennission, in any manner, to reproduce, display, or otherwise exploit the work'' Section 21 of th17 response indirates and proves otherwise. Even though tlle Defendant did not diredly publish the work8 from LVRJ.com, and it was indirectly publksbed tllrough RSS syndication, the Defendant was still under9 his right to republish the article, ms evidenced by the total of 23 invitations to do so on the original10 source website, LvltJ.com. Refer to BFHIBIT c. These invitations and encouragementq to Msave and1 l Sharer the article absolve the Defendant from the need to Gseek permission* and/or have permission12 granted from LVRJ to Greproduce, O play, or otherwise exploit the W orkM13 23. It is the opinion of tbe Defendantthat this lawsuit is entirely predatom fdvoloas, and an abuse of the14 United States Justice System. W hile the defendant acknowledges that tlze Plaintiff is not botmd by 1aw15 to issue a ''cemse and desiste letter wben alleged infringement is fountk it is Ge common legal etiquette16 and process to begin with a 'Ecease and deaisl'' letter. Had such a Gcemse and desistA order been offered,17 the Defendant would have cooperated and obliged accordingly. 'I'he opinion of the Defendant is that in18 not issuing a Gcease and de-sistm order prior to filins this lawsuit, the Plainti/s sudden fling of a lawsuit

.19 alleging co t infringement is undhical, imm oral, improper, and indicates a suspicious motivation20 to do so. In addition, the opinion of the Defendant is tllat the actions of the Plantiffare exactly what2 l $ve.s Rtrial lawyel< a bad name. In the event that the Plaintiff and/er LVRJ are not familiar w1t11 the22 fonnat of a T'cease and desist'' letter, I have provided a template for their use. Refer to EYHIBU F.23 24. It is the opinion of the Defendant the Plaintiffis engaged in a shakedown or extortion operation,V t.IZ24 the e.xprerxs purpose of abusing the legal system to extort or shakedown webmastel.s and bloggers who25 republish content from the LVRJ in accordance Vt.II Rfair use' and DMCA. In the majority of cases,26 including that of tlze Defendant, vidixns of tlze Plaintiffs witch hunt are bloggers and webm asters who27 generate veU little revenue, if any, from their sites. At the current l'ate of lawsuit being filed agains't28 webmasters by this Plaintiff, THE SFATES DISTRIW COURT OF NEVADA will necessarily be

clogged and bogged down M4t.1: many similar lawsuits. Tlle Plaintiffis operating with expectation that

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the victims of his ucopyrigbt trolling'' opemtion will settle out of court, mther tha11 absorb the cos'ts offighting thks matter. This is simply an effort bythe Plaintiff, Righthaven, L1X, in collusion with theLVRJ, to extort settlementq for allegedly minor infringements from unsuspedingwebmmsters andbloggem wbo lacktbe means azd ftmds to fight such frivolous lawsuits. In these case.s, many bloggersand webmasters will choose to paythe settlement in lieu of the ridictllous statutory damage claims bythe Plaintiff.

OFFER FOR SR IVT.EMENTThe Defendant did indeed publisb an artide en bis website entitled '''IYA Keeps W atchlist of Peeved'lwvelers/ and the copyright for the said atticle wa.s sraated to the Plaintiff oa July 1.4, zoto. TheDefendant republished the article under the impression that in providing reciprocal links and creditingtbe original source, his republishing of the article constimted Gfair tuse* tmderthe copyright laws of theUSA and DM CA- witlzout admitting any improper activities or maliciou intent the Defendant offers tosettle this lawsuit forthe sum of $10.87. The sum amount constitutes Goose M sense revenue of $7.92generated on or about the dates of July 14, 2o1o - July 23, zototrefer to RMHIBITEI pllzs the $2.95that the LVEJ charges to access and gain rights to an arcbived article. Upon acceptance of settlement,the Defendant also ensures tbe Plaintifftlmt Ne will not tzse or refer to any material published in theLVRJ or anything else which belongs to the Plaintiff.

PRAYEXIn tbe event that the Plaintiff does not accept the ofer for settlement in section 25 of this document,then the Defendant respedfully requests that the Court dismiss this lawsuit without prejudice. If thePlaintifffails to make a counter-offer or peuists in having a trial byjtuy, tbe Defendant still requeslsthat this lawsuit be dismissed without prejudice. The burden of proof, in this case, is on tlte Plaintiff.Seeing tbat the Plnindffmade no efforts whatsoever to resolve tbis issue before filing this lawsuit, andseeing the evidence that the LVRJ openly and adively encourages its users to USII- and Savee itswerks, it is the opinion of the Defendantthatthe Courtwill side withthe defense in this ma/er. 'l'heclaims concerning damages bythe Plaintiffare greatly exaggerated, not based on fad, and the fads inthis cmse do not warrant the concern or time for this or any other Court

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Dated this 9 day of Augus't, 201o

yan Burrage74 Coronado AveKenner, IA 700651-504-339-1902



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8/11/2010 Untiee M mentFmm: gerleralrrwlrww ll#dolmilsbwrov .com (genemlnurmmr@domnlrtqbyprov com)To: ther [email protected]: Frt J+ 23, 2010 9*027 AMCc:Subyct: Possibk I.ae> Irxs KTJERRYRYBIJRG.COM DBP CIAIM # 563876Dear Cotomer,Dolmks By Proxy tlxreik'der :DBP') 1= dkcbsed your contact klfornutbnto the party lkted bebw, persectkm 4 of% DomalnNanx ProxyAgee= e qpu//vm s'.sectrenaxnet.ncl/cdshor/lea l azreements/show doc.asp?paxeid=domah nameproxw&proa id=domainsbvprox'vs with respect to the domain rbqrruJERRYRYBIJRG.COM .DBP b rmt abk to ad onyoe behalfh thk nntter. Pkase be aware tlut Tsubpo- edy DBP wlprovze anreq sted ktfornxttm' nwe reason atxl wiEclw ge anadmmtq' tative fee for tlx doctmxnt prodte nPlase direct any qtrstbrs to tlx comphinant's representative:J. Clkarks Coons, Esq.Assbtant General Cot> elRIGHFIIAVEN LYConquktador sinoss Park9960 W est Cheyenne Avenue, Suke 2 101.- Vegas, NV 89129702.527.5900 (* 111)Sizcerely,N . KellyO& e ofthe C- FaIM a F rD onmkw By Proxy llx .



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8/11/2010G oogle Adsense

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July 14, 2010 - July sa. as Repolt Template: Enter n- name...23, 2010To ls 1 ,742 12Date Paqe impressions Clicks Paqe CTR Paqe eCPM (:DW ednesday, July 14, 2010 286 3 1.05% $5.54Thuday, July 15, 2010 272 4 1.47% $9.15Friday, July 16. 2010 212 2 0.M % $4.81Saturday, July 17, 2010 131 1 0.76% $2.08Sunday, July 18. 2010 135 0 0.00% $0.00Monday, July 19, 2010 171 2 1.17% $14.85Tuesday, July 20, 2010 124 0 0.00% $0.00Wednesday, July 21, 2010 136 0 0.00% $0.12

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SA M P LE T'C SA S S A N DLE TTE R ''E SIS T

Dear Inamel:lt has com e to m y attention that you have m ade an unauthorized use of my copyrighted workentitled (name of workl (the ''W ork'') in the preparation of a work derived therefrom. l havereserved aII rights in the Work, first published in (date), (and have registered copyrighttherein). Your work entitled (name of infringing workl is essentially identical to the Work andclearly used the Work as its basis. IGive a few examples that illustrate dired copying.lAs you neither asked for nor received permission to use the W ork as the basis for Iname ofinfringing work) nor to make or distribute copies, including eledronic copies, of same, Ibelieve you have willfully infringed my rights under 17 U.S.C. Section 101 et seq. and couldbe Iiable for statutory damages as high as $150,000 as set forth in Sedion 504(c)(2) therein.I demand that you immediately cease the use and distribution of aII infringing works derivedfrom the W ork, and aII copies, including eledronic copies, of same, that you deliver to me, ifapplicable, aII unused, undistributed copies of same, or destroy such copies immediately andthat you desist from this or any other infringem ent of my rights in the future. If I have notreceived an amrmative response from you by (date give them about 2 weeksl indicating thatyou have fully complied with these requirements, I shall take fudher adion against you.Very truly yours,(Your Name)



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74 Coronado AveKenner.LA 700655(/4439-19:2- F i t i: .; - ik t( t) : l ' )- t7. :1 fl R .' (- S E R 0 11' ($ : j.@ '*.i ' .r ''!t g'' g j j' ; CF RE0i)2212 lt$ l 8 #D 1: obi; L ;',' ' l t',: '',i X # t N 'i' C 0 U R T. ? ' .r)1'j i 1:T' 0F HL VADAEIY .-- PFPIJIY

August 16, 2010United States Dislrict Court of NevadaAU N: De eting Dept.333 Las Vegas Blvd Southl-as Vegas, NV 89101Re: Cmse N o. 2:10-> -01283Dear Sir or Me am:EnclrmM is my resronse to the Iawsulfiled against me in the United States Distrid Coud of Nevada byRMhthaven, LLC.Please file accordingly.Sincerely,

Case 2:10-cv-01283-GMN-RJJ Document 7-1 Filed 08/18/10 Page 1 of 1

defendant ryan burrage answer to righthaven copyright complaint

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