Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 1 of 47
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`HUNTON ANDREWS KURTH LLP
`Ann Marie Mortimer (State Bar No. 169077)
`amortimer@HuntonAK.com
`Jason J. Kim (State Bar No. 221476)
`kimj@HuntonAK.com
`Jeff R. R. Nelson (State Bar No. 301546)
`jnelson@HuntonAK.com
`550 South Hope Street, Suite 2000
`Los Angeles, California 90071-2627
`Telephone: (213) 532-2000
`Facsimile: (213) 532-2020
`
`Attorneys for Plaintiffs
`FACEBOOK, INC. and INSTAGRAM, LLC
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`
`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`FACEBOOK, INC., a Delaware
`corporation; INSTAGRAM, LLC, a
`Delaware limited liability company,
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`
`
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` CASE NO.: 3:20-cv-02429
`
`COMPLAINT; DEMAND FOR
`JURY TRIAL
`
`Plaintiffs,
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`
`
`v.
`
`
`BASANT GAJJAR, d/b/a
`“LeadCloak”
`
`
`Defendant.
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`Hunton Andrews Kurth LLP
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`COMPLAINT; DEMAND FOR JURY TRIAL
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`3:20-cv-02429
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 2 of 47
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`Plaintiffs Facebook, Inc. (“Facebook”) and Instagram, LLC (“Instagram”) allege
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`the following:
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`INTRODUCTION
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`1.
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`Since May 2016, Defendant has enabled and assisted fraudulent
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`advertisers in circumventing Facebook’s and Instagram’s advertisement review
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`process using a practice known as “cloaking.” Cloaking is a “bait-and-switch”
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`technique used to hide the true nature of the website linked to an ad from Plaintiffs,
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`meanwhile presenting different content to users who clicked on the ad. Specifically,
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`Defendant developed, marketed, and sold software and services designed to cloak ads
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`that violated Plaintiffs’ Terms and Policies. As a result, Defendant prevented
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`Plaintiffs from detecting and rejecting improper ads.
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`2.
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`Defendant’s cloaking services were used to promote, among other things,
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`deceptive diet pills and pharmaceuticals, cryptocurrency investment scams, and even
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`misinformation about the economic impact of the COVID-19 pandemic.
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`3.
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`In addition to using technical enforcement measures against Defendant,
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`Plaintiffs bring this action for monetary and injunctive relief to stop Defendant’s
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`abuse and misuse of their platforms and products and violations of their Terms and
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`Advertising Policies.
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`PARTIES
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`4.
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`Plaintiff Facebook is a Delaware corporation with its principal place of
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`business in Menlo Park, San Mateo County, California. Plaintiff Instagram is a
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`subsidiary and product of Facebook.
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`5.
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`Defendant Basant Gajjar is the founder and system architect of an
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`unregistered California business called “LeadCloak,” which offered cloaking software
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`as a service on LeadCloak.com. Exs. 1, 2, and 3. According to the LeadCloak.com
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`website, LeadCloak is a “powerful cloaker that you can use to easily cloak various ad
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`networks to get targeted traffic to your website and offer pages.” Exs. 3 and 4.
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`LeadCloak claims that it enables advertisers to circumvent ad review systems used by
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`1
`COMPLAINT; DEMAND FOR JURY TRIAL
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`3:20-cv-02429
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
`Hunton Andrews Kurth LLP
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 3 of 47
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`Facebook, Instagram, Google, Oath, WordPress, Shopify, and others. Exs. 3 and 4.
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`Defendant Gajjar has operated LeadCloak since at least May 2016. Exs. 1 and 2.
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`6.
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`Defendant Gajjar is a citizen of India, currently residing in Bangkok,
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`Thailand. According to information from public records, between 2004 and 2019,
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`Defendant has also used various personal and business mailing addresses in the
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`United States, including addresses in Sacramento and San Jose, California. According
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`to Gajjar’s LinkedIn profile, one of his businesses operates in San Francisco. Ex. 1.
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`JURISDICTION AND VENUE
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`7.
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`The Court has jurisdiction under 28 U.S.C. § 1332 over all causes of
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`action alleged in this complaint because complete diversity exists and the amount in
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`controversy exceeds $75,000.
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`8.
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`Defendant had multiple Facebook and Instagram accounts and thereby
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`agreed to Instagram’s Terms of Use, and Facebook’s Terms of Service and agreed to
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`submit to the personal jurisdiction of this Court for litigating this matter. Defendant
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`also had multiple ad accounts and agreed to Facebook’s Commercial Terms under
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`which he agreed to submit to the personal jurisdiction of this Court.
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`9.
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`In addition, the Court has personal jurisdiction because Defendant
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`knowingly directed and targeted his conduct at California and at Plaintiffs, which have
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`their principal place of business in California. Defendant transacted business and
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`engaged in commerce in California. Plaintiffs’ claims arise directly from all of these
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`California contacts.
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`10. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b) as
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`the threatened and actual harm to the Plaintiffs occurred in this district.
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`11. Pursuant to Civil L.R. 3-2(c), this case may be assigned to either the San
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`Francisco or Oakland division because Facebook is located in San Mateo County.
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 4 of 47
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`FACTUAL ALLEGATIONS
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`A. Background
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`1.
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`Advertising on Facebook and Instagram
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`12. Facebook is a social networking website and mobile application that
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`enables its users to create their own personal profiles and connect with each other on
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`their personal computers and mobile devices. As of December 2019, Facebook daily
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`active users averaged 1.66 billion and monthly active users averaged 2.5 billion.
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`13.
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`Instagram is a photo and video sharing service, mobile application, and
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`social network. Instagram users can post photos and videos to their profile. They can
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`also view and comment on posts shared by others on Instagram.
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`14. Anyone with a Facebook or Instagram account can create and place ads
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`on Facebook and Instagram. Every week, users create millions of ads through
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`Plaintiffs’ ad platforms, which provide advertisers with many options for reaching
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`their target audiences, so long as the ads comply with Facebook’s and Instagram’s
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`terms and policies.
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`15. To create and publish an ad on Facebook and Instagram, an advertiser
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`must agree to Facebook’s Terms of Service, Self-Serve Ad Terms, Commercial
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`Terms, and Advertising Policies. Advertisers are also subject to Facebook’s
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`Community Standards and Instagram’s Community Guidelines.
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`16. Ads are subject to Facebook’s ad review system, which relies primarily
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`on automated tools that review ads for compliance with Facebook’s Advertising
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`Policies. This automated review happens before an ad can run. Ads may also be
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`subject to additional review after they are published, depending on user feedback and
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`other indicators.
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`17.
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`If the ad review process identifies a policy violation, the ad is rejected,
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`and the advertiser will receive a rejection message. Some ads are flagged by the
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`automated ad review system for manual human review. If the ad review system does
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`COMPLAINT; DEMAND FOR JURY TRIAL
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`3:20-cv-02429
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
`Hunton Andrews Kurth LLP
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 5 of 47
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`not detect a policy violation, the advertiser will receive a notification confirming that
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`the ad will begin running.
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`18. Facebook can also take a range of enforcement actions against an
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`advertiser who violates the Advertising Policies, including banning an ad account
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`from running ads.
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`2.
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`Cloaking
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`19. One of the components reviewed by the ad review system is the website
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`landing page (“landing page”) a person will see if he or she clicks on an ad. If the
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`landing page violates Facebook’s Advertising Policies, the ad will be rejected.
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`20.
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`“Cloaking” is a malicious technique used to circumvent the ad review
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`process in order to deliver content on a landing page that violates Facebook’s
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`Advertising Policies.
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`21. Cloaking is used to misrepresent the landing page linked in an ad as
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`compliant to Facebook and its ad review system, while simultaneously promoting
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`non-compliant goods or services to Facebook users visiting the same landing page.
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`Essentially, the web server hosting the landing page is programmed to display a
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`landing page to Facebook’s review system that falls within the bounds of the
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`Advertising Policy, when in fact, the true landing pages displayed to users frequently
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`promote deceptive products and services and display disallowed images. The true
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`landing pages will frequently include ads for deceptive diet pills and pharmaceuticals,
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`cryptocurrency investment scams, or images of sexual content. Figure 1 is a visual
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`illustration of how cloaking generally works.
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 6 of 47
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`Figure 1: FB Ad Review and Cloaking
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`WITHOUT CLOAKING
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`WITH CLOAKING
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`Ad with link to website
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`Ad with link to website
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`Facebook Ad Review
`System
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`Facebook
`Users
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`Facebook Ad
`Review System
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`Facebook detects
`non-compliant landing page
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`Non-compliant
`landing page
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`Compliant
`landing page
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`3.
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`Facebook Terms of Service, Instagram’s Terms of Use, the
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`Advertising Policies, and Commercial Terms
`22. All Facebook users must agree to Facebook’s Terms of Service1 and
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`other rules that govern access to, and use of, Facebook. Those Terms include
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`Facebook’s Advertising Policy, Self-Service Ad Terms, and Commercial Terms.
`23. Everyone who uses Instagram agrees to Instagram’s Terms of Use2 and
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`other rules that govern access to and use of Instagram, including Instagram’s
`Community Guidelines.3 The Instagram Terms of Use state that because Instagram is
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`a Facebook product, the Instagram Terms of Use constitute an agreement between
`Instagram users and Facebook.4
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`1 Facebook’s Terms of Service can be found at https://www.facebook.com/terms.php.
`2 Instagram Terms of Use can be found at
`https://help.instagram.com/581066165581870.
`3 Instagram Community Guidelines can be found at
`https://help.instagram.com/477434105621119.
`4 https://help.instagram.com/581066165581870.
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 7 of 47
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`24.
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`Instagram’s Terms of Use and section 3.2.1 of the Facebook Terms of
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`Service prohibit users from “do[ing] . . . anything unlawful, misleading, [ ] or
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`fraudulent” or facilitate or support others in doing so.
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`25. Section 3.2.2 of the Facebook Terms of Service prohibits “upload[ing]
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`viruses or malicious code or doing anything that could disable, overburden, or impair
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`the proper working or appearance of [Facebook] Products.”
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`26. Facebook’s Advertising Policies specify what types of ad content are
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`allowed by people or entities that advertise across the Facebook Products.
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`27. Facebook’s Self-Serve Ad Terms apply when a user uses self-serve
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`advertising interfaces to create, submit, or deliver advertising or other commercial or
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`sponsored activity or content. The Self-Service Ad Terms include the Advertising
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`Policies.
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`28. Advertising Policy 4.13 (available at https://www.facebook.com/policies/
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`ads/) prohibits “ads, landing pages, and business practices” from “contain[ing]
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`deceptive, false, or misleading content, including deceptive claims, offers, or
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`methods.”
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`29. Advertising Policy 4.28 prohibits “tactics intended to circumvent our ad
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`review process or other enforcement systems,” including “techniques that attempt to
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`disguise the ad’s content or destination page,” as well as “[r]estrict[ing] Facebook’s
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`access to an ad’s destination page.”
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`30. Advertising Policy 4.32 prohibits ads that “promote products, services,
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`schemes or offers using deceptive or misleading practices.”
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`31. Facebook Commercial Terms apply to access and use of Facebook and
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`Facebook Products for any business or commercial purpose. Business and
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`commercial purposes include, but are not limited to, advertising and products on
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`Facebook and Instagram.
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 8 of 47
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`B. Defendant Agreed to Facebook and Instagram’s Terms and Policies
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`32. Defendant Gajjar has created and maintained at least four Facebook
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`accounts since September 13, 2006, and therefore, agreed to Facebook’s Terms of
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`Service and Policies. Between June 15, 2011 and November 16, 2019, Gajjar was an
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`administrator of eight Facebook Pages that promoted marketing, computing, and
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`financial services. Gajjar has used five ad accounts between January 4, 2008 and
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`December 30, 2019.
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`33. Defendant Gajjar created and maintained two Instagram user accounts,
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`since July 28, 2015 and November 7, 2019, and agreed to Instagram’s Terms of Use.
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`C. Defendant’s Cloaking on Facebook
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`34. Since March 2016, and continuing to the present, Defendant offered
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`cloaking services on the LeadCloak website targeting Facebook, Google and other
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`advertising platforms. Exs. 1 - 5.
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`35. Since January 2018, Defendant’s cloaking service was used to cloak the
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`landing pages for hundreds of ads on Facebook directed at Facebook users in the
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`United States and elsewhere. Some of the cloaked landing pages promoted
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`cryptocurrency schemes and diet scams in violation of Facebook’s Advertising
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`Policies and used the images of celebrities.
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`36. For example, on or about September 16, 2019, Defendant’s cloaking
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`service delivered an ad with an innocuous landing page to Facebook’s ad review
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`system, which depicted an Amazon page for sweaters (Figure 2(a)). Ex. 6. In fact,
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`Facebook users that clicked on the same ad were directed to a fake Fox News page
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`marketing a dietary supplement and using images of celebrities (Figure 2(b)). Ex. 7.
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`The ad was directed at users in the United States, including California. Between
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`September 16, 2019 and September 17, 2019, approximately 425 Facebook users
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`clicked on the ad and were directed to a cloaked landing page as a result of
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`Defendant’s service.
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`COMPLAINT; DEMAND FOR JURY TRIAL
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`3:20-cv-02429
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
`Hunton Andrews Kurth LLP
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 9 of 47
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`Figure 2(a): Landing Page
`Displayed to FB Review System
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`Figure 2(b): Landing Page
`Displayed to FB Users
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`37. Similarly, between March 21, 2020 and March 30, 2020, Defendant’s
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`cloaking service was used to conceal the true landing page of ads directed at Facebook
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`users in Denmark in order to promote a crytocurrency investment scheme.
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`Specifically, at various times between March 21, 2020, and March 30, 2020,
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`Defendant’s cloaking delivered an ad with an innocuous landing page to Facebook’s
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`ad review system, which promoted stainless steel spoons (Figure 3(a)). Ex. 8. In fact,
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`Facebook users that clicked on the same ad were directed to a fake news article that
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`promoted bitcoin investments to counter the economic impact of the COVID-19
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`pandemic and used the image of a local celebrity. (Figure 3(b)). Ex. 9.
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`Appoximatley 4,202 Facebook users clicked on the ad.
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`Figure 2(a): Landing Page
`Displayed to FB Review System
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`Figure 3(b): Landing Page
`Displayed to FB Users
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 10 of 47
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`D. Defendant’s Cloaking Service
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`38. Defendant promoted his cloaking service online and advertised that it
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`was designed to circumvent various advertising review systems, including those
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`operated by Facebook, Instagram, Google, Oath, WordPress, Shopify, and others.
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`Exs. 3, 4, and 10. On his website, Defendant promoted various types of cloaking
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`techniques to advertisers. Ex. 4. For example, Defendant’s website advised
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`advertisers to block IP addresses belonging to Facebook or Google in order to prevent
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`Facebook and Google from reviewing the non-complaint landing page used for the ad
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`when advertising on Facebook and Google. Ex. 11.
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`39. Defendant’s customers used LeadCloak.com to setup and run cloaked
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`advertising campaigns on Facebook and Google. Exs. 3, 4, and 10 – 14. Advertisers
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`using the LeadCloak website were able to select the advertising network for the
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`campaign; the landing page to be shown to the ad review system; the geographic
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`locations to target with the campaign; and set other advertising criteria. Exs. 10 – 13.
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`40. Once an advertiser set up a campaign, LeadCloak generated and
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`delivered computer code (“LeadCloak cloaking code”) to the advertiser that enabled
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`the advertiser to cloak ads on advertising networks, including Facebook if that was the
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`selected network. Ex. 13. The LeadCloak cloaking code provided the logic used to
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`determine which landing page would be shown to the user (or ad review system) that
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`clicked on an advertisement. Advertisers integrated the LeadCloak cloaking code into
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`their pre-existing code base on their web server to enable cloaking.
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`41.
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`In exchange for a fixed fee, Defendant provided advertisers with access
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`to his cloaking software and technical support. Ex. 14. Defendant offered his
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`cloaking service under a monthly plan or a “pay-as-you-go” plan. Id.
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`42. Defendant charged monthly users of his cloaking services a fixed fee
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`based on the number of advertising campaigns the customer ran. Id. As shown in
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`Figure 4 below, the Defendant charged his monthly customers between $399 and
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`$1,999 a month for use of his cloaking service.
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`COMPLAINT; DEMAND FOR JURY TRIAL
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`3:20-cv-02429
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
`Hunton Andrews Kurth LLP
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 11 of 47
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`Figure 4: Monthly Cost for Defendant’s Cloaking Service
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`43. Defendant charged “pay-as-you-go” advertisers a fixed fee based on the
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`number of clicks an advertiser’s advertisement received. Id. The prices for
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`Defendant’s “pay-as-you-go” plan is shown below in Figure 5.
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`Figure 5: Pay-as-you-go Cost for Defendant’s Cloaking Service
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
`Hunton Andrews Kurth LLP
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 12 of 47
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`E.
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`Facebook’s Enforcement Actions
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`44. Facebook took various technical enforcement measures against
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`Defendant and his customers, including disabling user and ad accounts on Facebook
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`and Instagram.
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`F. Defendant’s Acts Have Caused Damage and a Loss to Facebook
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`45. Defendant interfered with Plaintiffs’ service and has negatively impacted
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`the Facebook and Instagram experience for users who viewed and clicked on ads
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`containing landing pages cloaked using his software and service.
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`46. Defendant’s breaches of Plaintiffs’ Terms and Advertising Policies have
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`caused Facebook substantial harm.
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`47. Defendant’s actions injured Plaintiffs’ reputation, public trust, and
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`goodwill.
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`48. Facebook has suffered damages attributable to the efforts and resources it
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`has used to address this Complaint, investigate and mitigate Defendant’s conduct, and
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`attempt to identify, analyze, and stop his injurious activities.
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`CAUSE OF ACTION
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`(Breach of Contract)
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`49. Plaintiffs reallege and incorporate all preceding paragraphs.
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`50. Since September 13, 2006, Defendant Gajjar created and maintained at
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`least four Facebook user accounts and therefore he agreed to Facebook’s Terms and
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`Policies, including the Commercial Terms and Advertising Policies.
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`51. Since July 28, 2015, Defendant Gajjar created and maintained two
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`Instagram user accounts and therefore he agreed to Instagram’s Terms of Use.
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`52. Between June 15, 2011 and November 16, 2019, Defendant was an
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`administrator of eight Facebook Pages that promoted marketing, computing, and
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`financial services. Gajjar also used five ad accounts between January 4, 2008 and
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`December 30, 2019.
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`COMPLAINT; DEMAND FOR JURY TRIAL
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`3:20-cv-02429
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
`Hunton Andrews Kurth LLP
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 13 of 47
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`53. From 2016 to the present, Defendant breached the Instagram Terms of
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`Use, Facebook’s Terms of Service, and Advertising Policies 4.13, 4.28, and 4.32 by
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`taking the actions described in this Complaint, including by cloaking the landing
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`pages of ads appearing on Facebook and Instagram. More specifically, Defendant
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`developed, marketed, and sold cloaking software as a service on his website
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`LeadCloak.com. Defendant enabled and supported Facebook advertisers in
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`circumventing Facebook’s automated ad review process and other enforcement
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`systems. Through his actions, Defendant misrepresented certain ads’ true landing
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`page to Plaintiffs, and as a result, Defendant facilitated and supported evading
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`Plaintiffs’ ad review system.
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`54. Defendant’s actions violated Facebook’s Term of Service 3.2.1 and
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`Instagram’s Terms of Use because they constitute unlawful, misleading, or fraudulent
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`conduct and Defendant facilitated and supported others to do the same.
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`55. Defendant’s actions violated Facebook’s Term of Service 3.2.2 because
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`his cloaking code disabled and impaired and could disable and impair Facebook’s ad
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`review system and Facebook’s ability to access an ad’s landing page.
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`56. Defendant violated Self-Service Ad Terms and Advertising Policies 4.13
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`and 4.32 because he cloaked ads that used landing pages that contained deceptive,
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`false, or misleading content, including deceptive and misleading claims, offers, and
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`methods to promote products, services and schemes like the cryptocurrency scam
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`shown in figure 3(b) above. Additionally, Defendant’s conduct violated Advertising
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`Policy 4.28, which explicitly prohibits the use of tactics to circumvent Facebook’s ad
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`review process, including restricting Facebook’s ability to access an ad’s landing
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`page.
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`57. Defendant’s actions interfered and caused others to interfere with
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`Instagram and Facebook’s service in violation of Facebook’s Commercial Terms.
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`58. Facebook has performed all conditions, covenants, and promises required
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`of it in accordance with its agreement with Defendant.
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`COMPLAINT; DEMAND FOR JURY TRIAL
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`3:20-cv-02429
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
`Hunton Andrews Kurth LLP
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 14 of 47
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`59. Defendant’s breaches of Plaintiffs’ Terms and Policies have caused
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`damages to Plaintiffs in an amount to be determined at trial.
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`REQUEST FOR RELIEF
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`WHEREFORE, Plaintiffs request judgment against Defendant as follows:
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`1.
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`That the Court enter judgment against Defendant that Defendant has
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`breached his contract with Plaintiffs in violation of California law; and
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`2.
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`That the Court enter a permanent injunction enjoining and restraining
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`Defendant and his agents, servants, employees, successors, and assigns, and all other
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`persons acting in concert with or conspiracy with him or affiliated with Defendant
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`from:
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`a.
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`Accessing or attempting to access Facebook’s and Instagram’s
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`platform and computer systems;
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`b.
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`Developing, offering, and marketing software or computer code
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`intended to circumvent Facebook’s ad review process and other
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`enforcement measures;
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`c.
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`Engaging in any activity that disrupts, diminishes the quality of,
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`interferes with the performance of, or impairs the functionality of
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`Facebook’s and Instagram’s platform and computer systems;
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`d.
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`Engaging in any activity, or facilitating others to do the same, that
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`violates Facebook’s Terms of Service, Self-Service Ad Terms, and
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`Advertising Policies, and Instagram’s Terms of Use.
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`3.
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`4.
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`That Plaintiffs be awarded damages in such amounts to be proven at trial.
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`That Plaintiffs be awarded pre- and post-judgment interest as allowed by
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`law.
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`/ / /
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`/ / /
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`/ / /
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`/ / /
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`13
`COMPLAINT; DEMAND FOR JURY TRIAL
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`3:20-cv-02429
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 15 of 47
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`5.
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`That the Court grant all such other and further relief as the Court may
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`deem just and proper.
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`
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`Dated: April 9, 2020
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`HUNTON ANDREWS KURTH LLP
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`By: /s/ Ann Marie Mortimer
`Ann Marie Mortimer
`Jason J. Kim
`Jeff R. R. Nelson
`Attorneys for Plaintiffs
`FACEBOOK, INC. and
`INSTAGRAM, LLC
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`Facebook Platform Enforcement
`and Litigation
`Jessica Romero
`Michael Chmelar
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`14
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`Los Angeles, California 90071-2627
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 16 of 47
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`DEMAND FOR JURY TRIAL
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`Plaintiffs hereby demand a trial by jury on all issues triable to a jury.
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`
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`Dated: April 9, 2020
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`HUNTON ANDREWS KURTH LLP
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`By: /s/ Ann Marie Mortimer
`Ann Marie Mortimer
`Jason J. Kim
`Jeff R. R. Nelson
`Attorneys for Plaintiffs
`FACEBOOK, INC. and
`INSTAGRAM, LLC
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`073923.0000048 EMF_US 79884725v1
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`3:20-cv-02429
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 17 of 47
`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 17 of 47
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`EXHIBIT 1
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`EXHIBIT 1
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 18 of 47
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`2019-12-13 - Screenshot from https://www.linkedin.com/in/basant-gajjar-037b1a
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 19 of 47
`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 19 of 47
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`EXHIBIT 2
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`EXHIBIT 2
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`4/1/2020
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`Iris | DomainTools
`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 20 of 47
` Inspect: leadcloak.com
`
`Domain Profile
`
`Screenshot History
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`Whois History
`
`Hosting History
`
`SSL Profile
`
`2016-12-06 - (3 years ago)
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`Domain
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`leadcloak.com
`
`Record Date
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`2016-12-06
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`Registrar
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`Server
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`Created
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`Updated
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`Expires
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`GODADDY.COM, LLC
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`whois.godaddy.com
`
`2016-11-29 (3 years ago)
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`2016-11-29 (3 years ago)
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`2017-11-29 (2 years ago)
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`Unique Emails
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`abuse@godaddy.com
`leadcloak.com@domainsbyproxy.com
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`https://research.domaintools.com/iris/search/?q=leadcloak.com
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`4/1/2020
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`Iris | DomainTools
`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 21 of 47
`Domain Name: leadcloak.com
`Registry Domain ID: 2077722849_DOMAIN_COM-VRSN
`Registrar WHOIS Server: whois.godaddy.com
`Registrar URL: http://www.godaddy.com
`Update Date: 2016-11-29T07:13:32Z
`Creation Date: 2016-11-29T07:13:31Z
`Registrar Registration Expiration Date: 2017-11-29T07:13:31Z
`Registrar: GoDaddy.com, LLC
`Registrar IANA ID: 146
`Registrar Abuse Contact Email: abuse@godaddy.com
`Registrar Abuse Contact Phone: +1.4806242505
`Domain Status: clientTransferProhibited http://www.icann.org/epp#clientTransferProhibited
`Domain Status: clientUpdateProhibited http://www.icann.org/epp#clientUpdateProhibited
`Domain Status: clientRenewProhibited http://www.icann.org/epp#clientRenewProhibited
`Domain Status: clientDeleteProhibited http://www.icann.org/epp#clientDeleteProhibited
`Registry Registrant ID: Not Available From Registry
`Registrant Name: Registration Private
`Registrant Organization: Domains By Proxy, LLC
`Registrant Street: DomainsByProxy.com
`Registrant Street: 14747 N Northsight Blvd Suite 111, PMB 309
`Registrant City: Scottsdale
`Registrant State/Province: Arizona
`Registrant Postal Code: 85260
`Registrant Country: US
`Registrant Phone: +1.4806242599
`Registrant Phone Ext:
`Registrant Fax: +1.4806242598
`Registrant Fax Ext:
`Registrant Email: leadcloak.com@domainsbyproxy.com
`Registry Admin ID: Not Available From Registry
`Admin Name: Registration Private
`Admin Organization: Domains By Proxy, LLC
`Admin Street: DomainsByProxy.com
`Admin Street: 14747 N Northsight Blvd Suite 111, PMB 309
`Admin City: Scottsdale
`Admin State/Province: Arizona
`Admin Postal Code: 85260
`Admin Country: US
`Admin Phone: +1.4806242599
`Admin Phone Ext:
`Admin Fax: +1.4806242598
`Admin Fax Ext:
`Admin Email: leadcloak.com@domainsbyproxy.com
`Registry Tech ID: Not Available From Registry
`Tech Name: Registration Private
`Tech Organization: Domains By Proxy, LLC
`Tech Street: DomainsByProxy.com
`Tech Street: 14747 N Northsight Blvd Suite 111, PMB 309
`Tech City: Scottsdale
`Tech State/Province: Arizona
`Tech Postal Code: 85260
`Tech Country: US
`Tech Phone: +1.4806242599
`Tech Phone Ext:
`Tech Fax: +1.4806242598
`Tech Fax Ext:
`Tech Email: leadcloak.com@domainsbyproxy.com
`Name Server: NS47.DOMAINCONTROL.COM
`Name Server: NS48.DOMAINCONTROL.COM
`DNSSEC: unsigned
`URL of the ICANN WHOIS Data Problem Reporting System: http://wdprs.internic.net/
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`https://research.domaintools.com/iris/search/?q=leadcloak.com
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`4/1/2020
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`Iris | DomainTools
`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 22 of 47
`31 records found
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`https://research.domaintools.com/iris/search/?q=leadcloak.com
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`3/3
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 23 of 47
`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 23 of 47
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`EXHIBIT 3
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`EXHIBIT 3
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`22
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`22
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 24 of 47
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`2020-04-06 - Screenshot from leadcloak.com
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`23
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 25 of 47
`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 25 of 47
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`EXHIBIT 4
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`EXHIBIT 4
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`24
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`Case 3:20-cv-02429 Document 1 Filed 04/09/20 Page 26 of 47
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`2020-04-06 - Screenshot from leadcloak.com/compare
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`25
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`Case 3:20-cv-02429 Do