Case 2:20-cv-00470-GMS Document 1 Filed 03/04/20 Page 1 of 29
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`David G. Barker (#024657)
`dbarker@swlaw.com
`Jacob C. Jones (#029971)
`jcjones@swlaw.com
`SNELL & WILMER L.L.P.
`One Arizona Center
`400 E. Van Buren, Suite 1900
`Phoenix, Arizona 85004-2202
`Telephone: 602.382.6000
`Facsimile: 602.382.6070
`TUCKER ELLIS LLP
`David J. Steele, CA Bar No. 209797
`david.steele@tuckerellis.com
`Howard A. Kroll, CA Bar No. 100981
`howard.kroll@tuckerellis.com
`Steven E. Lauridsen, CA Bar No. 246364
`steven.lauridsen@tuckerellis.com
`515 South Flower Street
`Forty-Second Floor
`Los Angeles, CA 90071-2223
`Telephone: (213) 430-3400
`Facsimile: (213) 430-3409
`Attorneys for Plaintiffs,
`Facebook, Inc., Instagram, LLC and
`WhatsApp Inc.
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF ARIZONA
` Case No.
`Facebook, Inc., a Delaware corporation;
`Instagram, LLC, a Delaware limited liability
`COMPLAINT FOR
`company; and WhatsApp Inc., a Delaware
`CYBERSQUATTING; TRADEMARK
`corporation(cid:15)
`INFRINGEMENT; FALSE
`DESIGNATION OF ORIGIN; AND
`DILUTION
`DEMAND FOR JURY TRIAL
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`Plaintiffs,
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`v.
`Namecheap, Inc., a Delaware corporation, and
`Whoisguard, Inc., a Republic of Panama
`corporation,
`
`Defendants.
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`Plaintiffs Facebook, Inc. (“Facebook”), Instagram, LLC (“Instagram”), and
`WhatsApp Inc. (“WhatsApp”) (collectively “Plaintiffs”) by and through their attorneys,
`Tucker Ellis LLP,
`file
`their complaint against Defendants Namecheap, Inc.
`(“Namecheap), and Whoisguard, Inc. (“Whoisguard”) (collectively “Defendants”) for
`injunctive relief and damages.
`I.
`INTRODUCTION
`1.
`Cybercrime is highly dependent on Internet domain names, which are
`registered and used to send spear-phishing emails, operate malware, and engage in other
`types of online abuse. According to the Internet Corporation of Assigned Names and
`Numbers (“ICANN”), as of July 31, 2019, there were over 800,000 resolving domain
`names used for phishing, malware, spam, and botnets.
`2.
`Cybercriminals often rely on proxy services to hide their ownership and
`control of malicious domains from the public. Proxy services conceal the domain name
`registrant’s identity normally listed on publicly available domain name registration
`records. These proxy services, like the services offered by Defendants, are increasingly
`used by cybercriminals and spammers as they cycle through domain names in order to
`conceal their identities and evade detection.
`3.
`Namecheap is an ICANN-accredited domain name registrar.
`4.
`Whoisguard, which is Namecheap’s alter ego, provides a proxy service to
`Namecheap’s customers (Whoisguard and Namecheap refer to this service as
`“WhoisGuard” with a capital “G”).
`5.
`Whoisguard registers the domain name (as the registrant) and licenses the
`domain name to the individual or entity who uses the domain name (the “Licensee”).
`6.
`Whoisguard is listed as the registrant for domain names which use the
`WhoisGuard service on publicly available domain name registration records.
`7.
`Countless domain names registered by Whoisguard and licensed to
`Licensee(s) are used in connection with online abuse, including phishing, malware,
`spam and trademark infringement.
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`Despite notice, Namecheap has repeatedly failed to take “… steps to
`8.
`investigate and respond appropriately to any reports of abuse” as required by the
`ICANN Registrar Accreditation Agreement (“RAA”).
`9.
`Even when Whoisguard has received reasonable evidence of actionable
`harm caused by one of the domain names Whoisguard registered, Whoisguard has failed
`to provide the identity or contact information of its Licensee(s) to the victim of that
`harm.
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`the Internet anti-spam organization, Spamhaus.org,
`to
`According
`10.
`Namecheap was responsible for more fraudulent domain registrations than the next
`three registrars on the “Top 20” list combined. In Spamhaus’ third-quarter 2019 report,
`it explained: “The US-based domain registrar ‘Namecheap’ continued to be the favorite
`place for malware authors to register their botnet C&C domains.” In Spamhaus’ 2019
`overall report, it stated: “Namecheap was (again) the most abused registrar: Around
`25% of all botnet C&C domain names were registered through this US-based registrar.
`It’s the third consecutive year that Namecheap has held the pole position in our annual
`ranking of most abused domain registrars.”
`11.
`In 2018, Internet security expert Brian Krebs, who writes extensively on
`cybersecurity matters, reported on a so-called sextortion email scam that was making its
`way around the Internet. Krebs reviewed the domain names used in the scams and
`noted: “most were registered at the end of May 2018 through domain registrar
`Namecheap.”
`12.
`One such example Krebs discussed in his 2018 report involved
`uscourtsgov.com and numerous other domain names that were used in connection with
`a ransomware scam that was perpetrated by sending out spam emails. These domain
`names were registered through Namecheap.
`13. Whoisguard and its alter ego, Namecheap, has and continues to register,
`as the registrant, domain names used for malicious activity, including phishing and
`online fraud. Many of these domain names infringed and continue to infringe on
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`Plaintiffs’ trademarks.
`14. Whoisguard and Namecheap, as its alter ego, with a bad faith intent to
`profit from Plaintiffs’ trademarks, registered (as the registrant), trafficked in (as the
`licensor), and/or used domain names that are identical or confusingly similar to
`Plaintiffs’ trademarks in violation of 15 U.S.C. § 1125.
`15.
`Namecheap and Whoisguard agreed in the Domain Name Registration
`Agreement that, “if [Whoisguard] license[s] the use of the domain name registered to
`[Whoisguard] to a third party, [Whoisguard] nonetheless remain[s] the domain name
`holder of record, and remain[s] responsible for all obligations under this Agreement,
`including but not limited to … ensuring non-infringement of any third party intellectual
`property rights or other rights.”
`16.
`Namecheap and Whoisguard also agreed that Whoisguard, as the
`Registered Name Holder, shall accept liability for harm caused by wrongful use of the
`Registered Name, unless it discloses the current contact information provided by the
`licensee and the identity of the licensee.
`17.
`Plaintiffs have sent multiple notices to Whoisguard providing reasonable
`evidence of actionable harm and requesting that Whoisguard disclose the identity and
`current contact information for the relevant Whoisguard’s Licensees.
`18. Whoisguard failed to disclose the identity and current contact information
`for the Licensees and, therefore, Whoisguard and Namecheap, as its alter ego, have
`agreed to accept liability for the harm caused by the use of the domain names.
`19.
`Plaintiffs seek damages and injunctive relief against Defendants to stop
`their ongoing unlawful and harmful conduct, pursuant to the Lanham Act and the Anti-
`Cybersquatting Consumer Protection Act, 15 U.S.C. § 1125.
`II.
`THE PARTIES
`20.
`Plaintiff Facebook, Inc. is a Delaware corporation with its principal place
`of business in Menlo Park, California.
`21.
`Plaintiff Instagram, LLC is a Delaware limited liability company with its
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`principal place of business in Menlo Park, California.
`22.
`Plaintiff WhatsApp Inc. is a Delaware corporation with its principal place
`of business in Menlo Park, California.
`23.
`Defendant Namecheap, Inc. is a Delaware corporation with its principal
`place of business in Phoenix, Arizona.
`24.
`Defendant Whoisguard, Inc. is a Republic of Panama corporation with its
`principal place of business in Phoenix, Arizona.
`25.
`At all times material to this action, Namecheap and Whoisguard have
`been and continue to be instrumentalities and alter egos of each other. Namecheap is
`also the direct participant in the actions of Whoisguard as alleged in this Complaint.
`III.
`JURISDICTION AND VENUE
`26.
`The Court has federal question jurisdiction over the federal causes of
`action alleged in this complaint pursuant to 28 U.S.C. § 1331.
`27.
`The Court has general jurisdiction over Namecheap because its principal
`place of business is in Phoenix, Arizona. Namecheap further operates its datacenters in
`Arizona, both its headquarters and employees are in Arizona, and Namecheap specifies
`Arizona in the forum selection clauses in its contracts.
`28.
`The Court has personal jurisdiction over Whoisguard because the business
`of Whoisguard is to provide services to Namecheap in Arizona. Further, Whoisguard’s
`principal place of business is in Phoenix, Arizona. Whoisguard further operates its
`datacenters in Arizona, both its headquarters and employees are in Arizona, and
`Whoisguard specifies Arizona in the forum selection clauses in its contracts.
`29.
`Namecheap and Whoisguard have entered into one or more contracts for
`domain name registration services and proxy services used in connection with
`Defendants’ unlawful scheme; a material term of these contracts was Defendants’
`agreement to submit to the Court’s jurisdiction. A copy of Namecheap’s Domain Name
`Registration Agreement (including the referenced agreements which form part of the
`agreement) is attached to this Complaint as Exhibit 1. A copy of Whoisguard’s proxy
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`service agreement, titled Namecheap WHOIS Proxy Agreement (“Whoisguard’s Proxy
`Agreement”) is attached to this Complaint as Exhibit 2.
`30.
`Venue is proper with respect to each of the Defendants pursuant to
`28 U.S.C. §1391(b)(1) because Defendants reside in this judicial district. Venue is also
`proper in this judicial district pursuant to 28 U.S.C. §1391(b)(2) because a substantial
`part of the events and omissions giving rise to the claims alleged occurred in this
`district. In the alternative, venue is proper in this judicial district pursuant to
`28 U.S.C. §1391(b)(3) because Defendants are subject to the Court’s personal
`jurisdiction.
`IV.
`FACTUAL ALLEGATIONS
`Background on Plaintiffs and their Trademarks
`A.
`31.
`Amongst other products and services, Facebook offers a social networking
`website and mobile application that enables its users to create their own personal
`profiles and connect with each other on their personal computers and mobile devices.
`32.
`Facebook owns the exclusive rights to numerous trademarks and service
`marks to provide its online services, including the distinctive FACEBOOK wordmark
`and stylized mark, having used the marks in connection with its services since at least as
`early as 2004.
`33.
`In addition to its extensive common law rights, Facebook owns numerous
`United States registrations for its FACEBOOK marks including, but not limited to:
`a. United States Registration Number 3,122,052; and
`b. United States Registration Number 3,881,770.
`Copies of these registration certificates are attached to this Complaint as
`34.
`Exhibit 3. Facebook’s common law and registered trademarks are collectively referred
`to as the “Facebook Trademarks.”
`35.
`Facebook’s use of the Facebook Trademarks in interstate commerce has
`been extensive, continuous, and substantially exclusive. Facebook has made, and
`continues to make, a substantial investment of time, effort, and expense in the
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`promotion of Facebook and the Facebook Trademarks. As a result of Facebook’s efforts
`and use, the Facebook Trademarks are famous (and have been famous since at least as
`early as 2011) as they are recognized within the US and around the world as signifying
`high quality, authentic goods and services provided by Facebook.
`36.
`Facebook owns the exclusive rights to the distinctive FB wordmark,
`having used the marks in connection with its services since at least as early as 2014.
`37.
`In addition to its extensive common law rights, Facebook owns numerous
`United States registrations for its FB marks including, but not limited to:
`a. United States Registration Number 4,659,777;
`b. United States Registration Number 4,764,764;
`c. United States Registration Number 4,782,234; and
`d. United States Registration Number 4,782,235
`Copies of these registration certificates are attached to this Complaint as
`38.
`Exhibit 4. Facebook’s common law and registered trademarks are collectively referred
`to as the “FB Trademarks.”
`39.
`Facebook’s use of the FB Trademarks in interstate commerce has been
`extensive, continuous, and substantially exclusive. Facebook has made, and continues to
`make, a substantial investment of time, effort, and expense in the promotion of
`Facebook and the FB Trademarks.
`40.
`Instagram offers a photo and video sharing and editing service, mobile
`application, and social network. Instagram users can choose to share their photos and
`videos with their followers online.
`41.
`Instagram owns the exclusive rights to the distinctive INSTAGRAM
`wordmark and stylized mark, having used the marks in connection with its goods and
`services since at least as early as 2010.
`42.
`In addition to its extensive common law rights, Instagram owns numerous
`United States registrations for the INSTAGRAM marks including, but not limited to:
`a. United States Registration Number 4,795,634;
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`b. United States Registration Number 4,146,057;
`c. United States Registration Number 4,756,754;
`d. United States Registration Number 5,566,030;
`e. United States Registration Number 4,170,675;
`f. United States Registration Number 4,856,047;
`g. United States Registration Number 4,822,600;
`h. United States Registration Number 4,827,509;
`i. United States Registration Number 4,863,595; and
`j. United States Registration Number 5,019,151.
`Copies of these registration certificates are attached to this Complaint as
`43.
`Exhibit 5. Instagram’s common law and registered trademarks are collectively referred
`to as the “Instagram Trademarks.”
`44.
`Instagram’s use of the Instagram Trademarks in interstate commerce has
`been extensive, continuous, and substantially exclusive. Instagram has made, and
`continues to make, a substantial investment of time, effort, and expense in the
`promotion of Instagram and the Instagram Trademarks. As a result of Instagram’s
`efforts and use, the Instagram Trademarks are famous (and have been famous since at
`least as early as 2014) as they are recognized within the US and around the world as
`signifying high quality, authentic goods and services provided by Instagram.
`45. WhatsApp offers a private messaging service provided both for mobile
`devices and desktop computers.
`46. WhatsApp owns the exclusive rights to several trademark and service
`marks including the distinctive WHATSAPP trademark, having used the mark in
`connection with its goods and services since at least as early as 2009.
`47.
`In addition to its extensive common law rights, WhatsApp owns
`numerous United States registrations for the WHATSAPP mark including, but not
`limited to:
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`a. United States Registration Number 3,939,463;
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`b. United States Registration Number 4,083,272;
`c. United States Registration Number 5,492,738; and
`d. United States Registration Number 5,520,108.
`Copies of these registration certificates are attached to this Complaint as
`48.
`Exhibit 6. WhatsApp’s common law and registered trademarks are collectively referred
`to as the “WhatsApp Trademarks.”
`49. WhatsApp’s use of the WhatsApp Trademarks in interstate commerce has
`been extensive, continuous, and substantially exclusive. WhatsApp has made, and
`continues to make, a substantial investment of time, effort, and expense in the
`promotion of WhatsApp and the WhatsApp Trademarks. As a result of WhatsApp’s
`efforts and use, the WhatsApp Trademarks are inextricably linked with the products and
`services offered by WhatsApp.
`50.
`The Facebook Trademarks, FB Trademarks, Instagram Trademarks and
`WhatsApp Trademarks are collectively referred to as “Plaintiffs’ Trademarks.”
`B. Whoisguard is the Registrant of the Domain Names
`51.
`Namecheap is accredited by ICANN and subject to ICANN’s RAA. A
`copy of the RAA is attached to this Complaint as Exhibit 7.
`52. Whoisguard provides a domain registration proxy service: Whoisguard
`registers a domain name in its own name and, as the registrant and owner of the domain
`name, licenses the domain name to one of its Licensees for that Licensee’s use.
`53. Whoisguard’s Proxy Agreement provides, “[b]y subscribing to the
`Namecheap WHOIS Privacy Protection Services . . . you [the Licensee] are engaging
`Whoisguard to administer and register each domain name controlled by you . . . in the
`name of WhoisGuard.” See Exhibit 2.
`54.
`Namecheap explains on its website that, “[t]he only potential drawback of
`domain privacy comes down to ownership. Technically the domain name registrant
`owns the website (in the eyes of ICANN), not you.” A copy of Namecheap’s webpage
`with this text highlighted is attached as Exhibit 8.
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`As the registrant of the registered domain names, Whoisguard’s contact
`55.
`information is listed as that of the registrant in the WHOIS directory. The WHOIS
`directory contains important information about domain names, including the identity
`and contact information for the registrant of the domain name.
`56. Whoisguard agreed, when it registered the domain names pursuant to the
`domain name registration agreement, that “if [Whoisguard] license[s] the use of the
`domain name registered to [Whoisguard] to a third party, [Whoisguard] nonetheless
`remain[s] the domain name holder of record, and remain[s] responsible for all
`obligations under this Agreement … .” See Exhibit 1.
`Namecheap is Responsible for the Actions of Whoisguard, its
`C.
`Alter Ego
`At all times material to this action, Whoisguard was the alter ego of
`57.
`Namecheap. The acts of Whoisguard were in the scope of such relationship. In doing
`the acts and failing to act as alleged in this Complaint, each Defendant acted with the
`knowledge, permission, and the consent of each of the other Defendant, and each
`Defendant aided and abetted the other Defendant in the acts or omissions alleged in this
`Complaint.
`58. Whoisguard is not a separate autonomous entity from Namecheap.
`59.
`Namecheap controls certain business operations of Whoisguard. For
`example, Namecheap describes the service as “WhoisGuard by Namecheap.” An
`annotated screen capture of Namecheap’s webpage is attached as Exhibit 9. Whoisguard
`provides a domain name registration proxy service on behalf of Namecheap.
`60.
`The WhoisGuard service is integrated within Namecheap’s own website,
`and Namecheap’s customers obtain the WhoisGuard service directly from their
`Namecheap user account. A copy of Namecheap’s support page for the question: “How
`do I enable WhoisGuard for my domain?” is attached to this Complaint as Exhibit 10.
`61.
`There is no charge for the WhoisGuard service. Namecheap simply
`provides Namecheap’s WhoisGuard service to its customers as a part of Namecheap’s
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`regular service. See Exhibit 9.
`62.
`In the past when Whoisguard was served with reasonable evidence of
`actionable harm and a request for Whoisguard’s Licensees’ information, Namecheap,
`instead of Whoisguard, provided the responsive information concerning the Whoisguard
`Licensee to the noticing party. As discussed further in this Complaint, Namecheap and
`Whoisguard now fail to disclose the responsive information to the noticing party.
`63.
`On information and belief, when Whoisguard is served with a subpoena
`seeking Whoisguard’s Licensees’ information, Namecheap, instead of Whoisguard,
`responds to and provides the responsive information concerning Whoisguard’s
`Licensees.
`64. When administrative domain name complaints are filed against
`Whoisguard’s Licensees using the WhoisGuard service, Namecheap, instead of
`Whoisguard, discloses the name of Whoisguard’s Licensees to the dispute provider’s
`administrator.
`for whoisguard.com
`information
`to historic WHOIS
`65.
`According
`(Whoisguard’s domain name), Namecheap owned the domain name in the past, and
`Namecheap was also listed as the technical contact. Today the WHOIS information for
`whoisguard.com is hidden by the WhoisGuard proxy service.
`66.
`On information and belief, Namecheap still operates the whoisguard.com
`domain name and controls the content available on the website available at
`whoisguard.com.
`67.
`Namecheap and Whoisguard are instrumentalities and alter egos of each
`other. In view of the facts above, observing the separate corporate form of Whoisguard
`from Namecheap would sanction a fraud and promote injustice.
`68.
`In addition, Namecheap is liable for the actions of Whoisguard, as alleged
`in this Complaint, under the theory of direct participant liability.
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`Case 2:20-cv-00470-GMS Document 1 Filed 03/04/20 Page 12 of 29
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`D.
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`Defendants Registered, Trafficked In, and/or Used the Infringing
`Domain Names
`69. Whoisguard registered, trafficked in, or used at least forty-five domain
`names that are identical or confusingly similar to the Facebook Trademarks, FB
`Trademarks, Instagram Trademarks, and WhatsApp Trademarks (the “Infringing
`Domain Names”). For example:
`70. Whoisguard registered, trafficked in, or used at least the following
`Infringing Domain Names that are identical or confusingly similar to the Facebook
`Trademarks:
`xn--faceboo-jhb.net (faceboo(cid:440).net)
`facebo0k-login.com
`facebok-securty.com
`facebokloginpage.site
`facebooksupport.email
`howtohackfacebook-account.com
`facebookvideodownload.online
`facebookvideodownloaderonline.com
`faceboookmail.online
`facebokloginpage.space
`facebokproblemsolution.com
`facebokprofile.com
`71. Whoisguard registered, trafficked in, or used at least the following
`Infringing Domain Names that are identical or confusingly similar to the FB
`Trademarks:
`fbpokerforte.com
`fbhelp.me
`72. Whoisguard registered, trafficked in, or used at least the following
`Infringing Domain Names that are identical or confusingly similar to the Instagram
`
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`Case 2:20-cv-00470-GMS Document 1 Filed 03/04/20 Page 13 of 29
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`
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`Trademarks:
`xn--nstaram-yya574a.com (ìnsta(cid:1843)ram.com)
`lnstagrambusinesshelp.com
`weblogin-instagram.com
`instagramlogin.org
`instagramlogin.site
`instagramverify.services
`securedlogin-lnstagram.com
`security-instagram.email
`verified-lnstagram.com
`inst4gram.com
`instagram-download.pictures
`instagram-spy.online
`instagramspy.info
`hackanyinstagram.com
`hackinganinstagram.com
`cdninstagram.download
`cryptoinstagram.com
`73. Whoisguard registered, trafficked in, or used at least the following
`Infringing Domain Names that are identical or confusingly similar to the WhatsApp
`Trademarks:
`whatapp.services
`joinwhatsappgroup.online
`backupmywhatsapp.online
`download-whatsapp.online
`whatsappdownload.site
`whatsappsex.club
`whatsapptricks.club
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`Case 2:20-cv-00470-GMS Document 1 Filed 03/04/20 Page 14 of 29
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`whatzapphacks.xyz
`freewhatsappspy.com
`freewhatsapptracker.com
`ggirlsnumberwhatsapp.online
`whatsapp-sohbet.xyz
`whatsapponline.bid
`whatsapp-sohbet.club
`74. Whoisguard is or was the registrant for each of the Infringing Domain
`Names. A copy of the WHOIS entries for each of the Infringing Domain Names is
`attached to this Complaint as Exhibit 11.
`75. Whoisguard registered each of the Infringing Domain Names for one or
`more of Whoisguard’s Licensees.
`76. Whoisguard trafficked in the Infringing Domain Names by licensing the
`Infringing Domain Names to its Licensees.
`77.
`Plaintiffs’ Facebook Trademarks and Instagram Trademarks were
`distinctive and famous when Whoisguard registered, trafficked in, or used the Infringing
`Domain Names.
`78.
`Plaintiffs’ FB Trademarks and WhatsApp Trademarks were distinctive
`when Whoisguard registered, trafficked in, or used the Infringing Domain Names.
`79.
`The Licensees used the Infringing Domain Names.
`Defendants’ Failure to Disclose Contact Information
`E.
`80.
`Under the RAA, which governs Namecheap’s permission under ICANN
`to act as a registrar, and by incorporation Namecheap’s Domain Name Registration
`Agreement, Namecheap and Whoisguard agreed that Whoisguard, as the Registered
`Name Holder, “shall accept liability for harm caused by wrongful use of the Registered
`Name, unless it discloses the current contact information provided by the licensee and
`the identity of the licensee within seven (7) days to a party providing [Whoisguard]
`reasonable evidence of actionable harm.” Exhibit 1 and Exhibit 7.
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`Case 2:20-cv-00470-GMS Document 1 Filed 03/04/20 Page 15 of 29
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`Namecheap’s Domain Name Registration Agreement and Whoisguard’s
`81.
`Proxy Agreement anticipate that they will be sued for misuse of domain names,
`including for trademark infringement and cybersquatting, and they require parties to
`their respective agreements to indemnify them against such claims. See Exhibits 1-2.
`82.
`Namecheap’s Domain Name Registration Agreement states that it will
`cancel its proxy service if a domain name is alleged to infringe on a third party’s
`trademark or if it receives valid evidence of trademark infringement. See Exhibit 1.
`83.
`Between October 2, 2018 and February 7, 2020, Plaintiffs’ authorized
`representatives sent at least the following notices to Whoisguard with evidence that each
`of the Infringing Domain Names caused Plaintiffs actionable harm and with a request
`that Whoisguard disclose the identities of the registrant(s) (“Plaintiffs’ Notices”):
`a.
`On October 2, 2018, Plaintiffs’ authorized representatives sent
`notice regarding fbhelp.me.
`b.
`On November 1, 2018, Plaintiffs’ authorized representatives sent
`notice regarding whatsapp-sohbet.xyz; whatsapponline.bid; and whatsapp-
`sohbet.club
`On January 23, 2019, Plaintiffs’ authorized representatives sent
`c.
`notice regarding: xn--faceboo-jhb.net (faceboo(cid:440).net).
`d.
`On May 5, 2019, Plaintiffs’ authorized representatives sent notice
`regarding: facebo0k-login.com.
`e.
`On May 30, 2019, Plaintiffs’ authorized representatives sent notice
`regarding instagram-download.pictures and facebokprofile.com.
`f.
`On June 7, 2019, Plaintiffs’ authorized representatives sent notice
`regarding whatapp.services; whatsappsex.club; whatsapptricks.club;
`and
`cryptoinstagram.com.
`g.
`On June 13, 2019, Plaintiffs’ authorized representatives sent notice
`regarding inst4gram.com.
`h.
`On June 14, 2019, Plaintiffs’ authorized representatives sent notice
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`Case 2:20-cv-00470-GMS Document 1 Filed 03/04/20 Page 16 of 29
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`regarding facebok-securty.com.
`i.
`On June 29, 2019, Plaintiffs’ authorized representatives sent notice
`regarding facebooksupport.email.
`j.
`On July 15, 2019, Plaintiffs’ authorized representatives sent notice
`regarding facebokproblemsolution.com; facebookvideodownloaderonline.com;
`freewhatsappspy.com.
`k.
`On July 15, 2019, Plaintiffs’ authorized representatives sent notice
`regarding
`freewhatsapptracker.com;
`hackanyinstagram.com;
`and
`hackinganinstagram.com.
`l.
`On July 18, 2019, Plaintiffs’ authorized representatives sent notice
`regarding
`howtohackfacebook-account.com;
`securedlogin-lnstagram.com;
`verified-lnstagram.com; and weblogin-instagram.com.
`m.
`On July 22, 2019, Plaintiffs’ authorized representatives sent notice
`regarding cdninstagram.download; security-instagram.email; instagramspy.info;
`backupmywhatsapp.online; and download-whatsapp.online.
`n.
`On July 25, 2019, Plaintiffs’ authorized representatives sent notice
`regarding
`facebookvideodownload.online;
`faceboookmail.online;
`ggirlsnumberwhatsapp.online;
`instagram-spy.online;
`and
`joinwhatsappgroup.online.
`o.
`On July 29, 2019, Plaintiffs’ authorized representatives sent notice
`including instagramlogin.org; instagramverify.services; facebokloginpage.site;
`instagramlogin.site; whatsappdownload.site;
`facebokloginpage.space;
`and
`whatzapphacks.xyz.
`p.
`On September 14, 2019, Plaintiffs’ authorized representatives sent
`notice regarding xn--nstaram-yya574a.com (ìnsta(cid:1843)ram.com).
`q.
`On February 7, 2020, Plaintiffs’ authorized representatives sent
`notice regarding fbpokerforte.com and lnstagrambusinesshelp.com.
`84.
`After receipt of Plaintiffs’ Notices, which presented Whoisguard with
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