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Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 1 of 23 Page ID #:256

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RYAN M. NISHIMOTO (State Bar No. 235208)


ryan.nishimoto@aporter.com
AMANDA SEMAAN (State Bar No. 293896)
amanda.semaan@aporter.com
ARNOLD & PORTER LLP
777 South Figueroa Street, Forty-Fourth Floor
Los Angeles, California 90017-5844
Telephone: 213.243.4000
Facsimile: 213.243.4199
Attorneys for Defendants
STEFAN DELGARDO ARGOTE, MATTHIAS
OLTMANN, TYRONE TOM PAUER, and
CHACHANI MISTI Y PICHU PICHU S.R.L.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION

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RIOT GAMES, INC., a Delaware


corporation,

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Plaintiff,
v.
STEFAN DELGADO ARGOTE a/k/a ,
Ohm and Burberry; MATTHIAS
OLTMANN a/k/a Joduskame,
Rolle3k, and Sheppard; TYRONE
TOM PAUER a/k/a Beaving;
CHACHANI MISTI Y PICHU PICHU
S.R.L., a company organized under the
laws of Peru; and DOES 1-10,
inclusive,
Defendants.

Case No. 2:16-CV-5871-RSWL-AS


The Honorable Alka Sagar
DECLARATION OF RYAN
NISHIMOTO IN SUPPORT OF
DEFENDANTS OPPOSITION TO
PLAINTIFFS EX PARTE
APPLICATION FOR LEAVE TO
TAKE LIMITED IMMEDIATE
DISCOVERY

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36562644

DECLARATION OF RYAN NISHIMOTO IN SUPPORT OF DEFENDANTS OPPOSITION TO PLAINTIFFS


EX PARTE APPLICATION FOR LEAVE TO TAKE LIMITED IMMEDIATE DISCOVERY

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 2 of 23 Page ID #:257

DECLARATION OF RYAN M. NISHIMOTO

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I, Ryan M. Nishimoto, declare and state:

1.

I am an attorney licensed to practice law in the State of California and a

partner with Arnold & Porter LLP (Arnold & Porter). I submit this declaration in

support of Defendants Opposition to Plaintiffs Ex Parte Application for Leave to

Take Limited Immediate Discovery. I have personal knowledge of the facts set forth

herein.

2.

On August 22, 2016 at about 1:40 p.m., I left a voicemail for and sent an

email to Marc Mayer, counsel for plaintiff Riot Games, Inc. (Riot), letting him

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know that Arnold & Porter had been retained to represent Chachani Misti y Pichu

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Pichu S.L.R., Stefan Delgado Argote, Matthias Oltmann, and Tyrone Tom Pauer

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(together, Defendants). I asked him to give me a call.

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3.

At about 2:30 p.m. the same day, Mr. Mayer called to discuss the case,

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but he didnt inform me that Riot was filing an ex parte application (the

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Application) later that day. It wasnt until approximately 6:00 that evening that he

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sent me a copy of the Application. I emailed Mr. Mayer at 8:52 p.m. noting that the

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Application obviously didnt comply with Local Rule 7-19 and asking him to

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withdraw it.

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4.

On August 23, 2016 at about 11:30 a.m., I spoke with Mr. Mayer over

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the telephone. During this call, I told Mr. Mayer that I was surprised that he hadnt

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told me about the Application the last time we talked, and I let him know that the

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Court clerk told us to file any opposition by 5 p.m. Mr. Mayer said he would ask

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Riot whether it would agree to withdraw the Application, and later confirmed that the

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Application would be withdrawn. He also asked whether Defendants would oppose

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the Application, whether Arnold & Porter would accept service on behalf of

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Defendants, whether we would agree to disclose any information in [Defendants]

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possession concerning the identity of those responsible for the LeagueSharp service,

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-1DECLARATION OF RYAN NISHIMOTO IN SUPPORT OF DEFENDANTS OPPOSITION TO PLAINTIFFS
EX PARTE APPLICATION FOR LEAVE TO TAKE LIMITED IMMEDIATE DISCOVERY

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 3 of 23 Page ID #:258

and whether we would represent that [Defendants] are the ones responsible for the

service.

5.

On August 24, 2016 at about 4:30 p.m., I emailed Mr. Mayer letting him

know that Defendants oppose the Application, that we werent authorized to accept

service, and that we werent able to give him the additional information he wanted at

that time. Mr. Mayer responded about an hour later, wanting to know the basis for

Defendants opposition. A copy of the entire August 22-24 email chain is attached as

Exhibit A to this declaration.


6.

I called Mr. Mayer after I got his email to discuss the Application. I told

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him that we didnt see the grounds for Riots belief that Chachani was a shell entity,

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and didnt understand why Riot couldnt complete service on Chachani. I told him

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that the U.K. complaint attached as Exhibit 2 to the Mayer Declaration appeared to

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disclose Jaime Rosalino Prado Lira as Chachanis director. I also told him that the

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name CHAMISPI appears to be an acronym for Chachani Misti y Pichu Pichu

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S.L.R. I also informed him that a Google search on CHAMISPI and Jaime

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Rosalino Prado Lira returns a website showing that CHAMISPI and Chachani share

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the same address in Peru and that Mr. Lira is CHAMISPIs Gerente General. I

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asked Mr. Mayer if they had attempted to locate and serve Mr. Lira, but Mr. Mayer

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didnt give me a clear answer one way or the other. A copy of the webpage to which

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I referred Mr. Mayer is attached as Exhibit B to this declaration.


7.

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During my call with Mr. Mayer, I made the observation that, generally

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speaking, removal of forum postings from public view wasnt all that surprising if,

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e.g., postings violate forum policies. In any event, I told Mr. Mayer that each of the

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Defendants are aware of their document preservation obligations under the Federal

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Rules.

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8.

A copy of the webpage available at

https://www.cloudflare.com/customers/ is attached as Exhibit C to this declaration.

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-2DECLARATION OF RYAN NISHIMOTO IN SUPPORT OF DEFENDANTS OPPOSITION TO PLAINTIFFS
EX PARTE APPLICATION FOR LEAVE TO TAKE LIMITED IMMEDIATE DISCOVERY

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 4 of 23 Page ID #:259

9.

A copy of the webpage available at http://domain.me/me-as-montenegro/

is attached as Exhibit D to this declaration. A copy of the webpage available at

http://domain.me/contact-me/ is attached as Exhibit E to this declaration.

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I declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.
Executed this 29th day of August, 2016 at Los Angeles, California.

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/s/ Ryan M. Nishimoto


RYAN M. NISHIMOTO

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-3DECLARATION OF RYAN NISHIMOTO IN SUPPORT OF DEFENDANTS OPPOSITION TO PLAINTIFFS
EX PARTE APPLICATION FOR LEAVE TO TAKE LIMITED IMMEDIATE DISCOVERY

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 5 of 23 Page ID #:260

EXHIBIT A

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 6 of 23 Page ID #:261


Nishimoto, Ryan M.
From:
Sent:
To:
Cc:
Subject:

Mayer, Marc <MEM@msk.com>


Wednesday, August 24, 2016 5:47 PM
Nishimoto, Ryan M.
Kohler, Daniel
RE: Riot/Chachani 16-cv-5871

Ryan:
Thanks for your email.
Can you please let us know the basis for your opposition? As you know, the subpoenas we are requesting to serve are
quite limited. Perhaps there is a way to address in advance any concerns you may have.

msk

Marc Mayer | Partner, through his professional corporation


T: 310.312.3154 | mem@msk.com
Mitchell Silberberg & Knupp LLP | www.msk.com
11377 W. Olympic Blvd., Los Angeles, CA 90064
THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS
MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN
INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY
PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR
SYSTEM. THANK YOU.

From: Nishimoto, Ryan M. [mailto:Ryan.Nishimoto@aporter.com]


Sent: Wednesday, August 24, 2016 4:31 PM
To: Mayer, Marc
Cc: Kohler, Daniel
Subject: RE: Riot/Chachani 16-cv-5871

Marc -This will confirm that Defendants will oppose Riots Ex Parte Application. As to your other questions, we are not
authorized to accept service, nor are we able to provide you with the additional information you requested at this time.
We havent made appearances yet, so please email me a copy of any Ex Parte Application as soon as it is filed.
Ryan
Ryan M. Nishimoto
Arnold & Porter LLP
Office: +1 213.243.4158
Mobile: +1 323.336.5165
ryan.nishimoto@aporter.com

From: Nishimoto, Ryan M.


Sent: Tuesday, August 23, 2016 2:15 PM
1

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 7 of 23 Page ID #:262


To: 'Mayer, Marc'
Cc: Kohler, Daniel
Subject: RE: Riot/Chachani 16-cv-5871

Marc -Thank you for your response. I would add to your second paragraph that you did not raise the application with me
during our call at 2:30 p.m., and that the first time we were made aware of the application or the relief sought therein
was at 6 p.m. when you emailed it to me. Regardless, we appreciate your cooperation. This will confirm as follows:
(a) Riot will withdraw its Ex Parte Application without prejudice to its refiling.
(b) We will let you know by 5 p.m. Pacific tomorrow (August 24, 2016) whether Defendants intend to oppose Riots
Application.
(c) We will respond to your questions as to (1) whether Arnold & Porter will accept service for the named
Defendants, and (2) whether Arnold & Porter will provide you with any information in Defendants possession
concerning the identity of those responsible for the LeagueSharp service or, alternatively, whether Arnold &
Porter will represent that Defendants are the ones responsible for the service.
Please confirm with us once the Ex Parte Application has been withdrawn.
Ryan

Ryan M. Nishimoto
Arnold & Porter LLP
Office: +1 213.243.4158
Mobile: +1 323.336.5165
ryan.nishimoto@aporter.com

From: Mayer, Marc [mailto:MEM@msk.com]


Sent: Tuesday, August 23, 2016 1:35 PM
To: Nishimoto, Ryan M.
Cc: Kohler, Daniel
Subject: RE: Riot/Chachani 16-cv-5871

Ryan:
We have discussed with Riot your request that Riot withdraw its Ex Parte Application in order to allow you additional
time to discuss the Application with your client and to let us know whether your client intends to oppose.
As you know, you contacted us for the very first time at approximately 1:30 yesterday afternoon, after our motion
papers were finalized and were in the process of being filed. As you also must know, on August 5 immediately after
we filed the complaint I contacted Paul Abbot of your UK office inquiring as to whether your firm represents Chachani,
and if so, whether it would accept service. I did not receive a response from Mr. Abbot. I also received no response
from your clients German counsel, even though just days before he threatened to file a declaratory relief action against
Riot.
Nonetheless, purely as a courtesy and to give you an opportunity to discuss this matter with your clients, we will
withdraw our Ex Parte Application without prejudice to its refiling. In the meantime, please let us know by the close of
2

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 8 of 23 Page ID #:263


business tomorrow (August 24, 2016) whether your client intends to oppose Riots Application. If we do not hear from
you by that time, we will refile our Application.
Additionally, please let us know whether (1) you will accept service for the named defendants, (2) you will provide us
with any information in your clients possession concerning the identity of those responsible for the LeagueSharp service
or, alternatively, whether you will represent that your clients are the ones responsible for the service. If you will not
provide us with this information, then it will be necessary for us to proceed with early discovery to identify those
responsible for the service.
We look forward to speaking with you soon.

msk

Marc Mayer | Partner, through his professional corporation


T: 310.312.3154 | mem@msk.com
Mitchell Silberberg & Knupp LLP | www.msk.com
11377 W. Olympic Blvd., Los Angeles, CA 90064
THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS
MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN
INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY
PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR
SYSTEM. THANK YOU.

From: Nishimoto, Ryan M. [mailto:Ryan.Nishimoto@aporter.com]


Sent: Tuesday, August 23, 2016 12:32 PM
To: Mayer, Marc
Cc: Kohler, Daniel
Subject: RE: Riot/Chachani 16-cv-5871

Thanks, Marc. Please let us know as soon as you can. As I mentioned on our call, the court has instructed us to file our
opposition by 5 p.m. today.
Ryan M. Nishimoto
Arnold & Porter LLP
Office: +1 213.243.4158
Mobile: +1 323.336.5165
ryan.nishimoto@aporter.com

From: Mayer, Marc [mailto:MEM@msk.com]


Sent: Tuesday, August 23, 2016 12:28 PM
To: Nishimoto, Ryan M.
Cc: Kohler, Daniel
Subject: RE: Riot/Chachani 16-cv-5871

Ryan I am discussing with our client whether, as a courtesy, we would be willing to withdraw the application without
prejudice to its refiling so that you can have a chance to discuss with your clients whether you intend to oppose and
whether you will accept service. I will get back to you shortly.

msk
3

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 9 of 23 Page ID #:264


Marc Mayer | Partner, through his professional corporation
T: 310.312.3154 | mem@msk.com
Mitchell Silberberg & Knupp LLP | www.msk.com
11377 W. Olympic Blvd., Los Angeles, CA 90064
THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS
MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN
INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY
PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR
SYSTEM. THANK YOU.

From: Nishimoto, Ryan M. [mailto:Ryan.Nishimoto@aporter.com]


Sent: Monday, August 22, 2016 8:52 PM
To: Mayer, Marc
Cc: Kohler, Daniel
Subject: RE: Riot/Chachani 16-cv-5871

Marc -- it was good speaking with you as well, and we look forward to your clients response.
With regard to the ex parte application, I have not had an opportunity to review it nor discuss it with my clients, but a
quick review shows that it does not appear to include the information required by LR 7-19, including 17-19.1, which
requires:
L.R. 7-19.1 Notice of Application. It shall be the duty of the attorney so applying (a) to make reasonable, good
faith efforts orally to advise counsel for all other parties, if known, of the date and substance of the proposed ex
parte application and (b) to advise the Court in writing and under oath of efforts to contact other counsel and
whether any other counsel, after such advice, opposes the application.
In light of this, we ask that you withdraw the application.
Please do not hesitate to contact me if you would like to discuss further in the meantime. My cell is 323-336-5165 and I
will be in the office 213-243-4158 all day tomorrow.
Ryan
Ryan M. Nishimoto
Arnold & Porter LLP
Office: +1 213.243.4158
Mobile: +1 323.336.5165
ryan.nishimoto@aporter.com

From: Mayer, Marc [mailto:MEM@msk.com]


Sent: Monday, August 22, 2016 6:07 PM
To: Nishimoto, Ryan M.
Cc: Kohler, Daniel
Subject: RE: Riot/Chachani 16-cv-5871

Ryan:
It was good speaking with you this afternoon.
I have passed along the substance of our conversation to our client, and we will get back to you shortly.

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 10 of 23 Page ID


#:265

In the meantime, as a courtesy and for your information, I am attaching a copy of a request for limited discovery that we
filed earlier today.

msk

Marc Mayer | Partner, through his professional corporation


T: 310.312.3154 | mem@msk.com
Mitchell Silberberg & Knupp LLP | www.msk.com
11377 W. Olympic Blvd., Los Angeles, CA 90064
THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS
MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN
INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY
PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR
SYSTEM. THANK YOU.

From: Nishimoto, Ryan M. [mailto:Ryan.Nishimoto@aporter.com]


Sent: Monday, August 22, 2016 1:40 PM
To: Mayer, Marc
Subject: Riot/Chachani 16-cv-5871

Hi Marc -Following up my v/m to you just now, we represent Chachani and the individual defendants in the action brought by
Riot. Please give me a ring when you have a minute.
Ryan
Ryan M. Nishimoto
Partner
Arnold & Porter LLP
44th Floor
777 South Figueroa Street
Los Angeles, CA 90017-5844
Office: +1 213.243.4158
Mobile: +1 323.336.5165
ryan.nishimoto@aporter.com
www.arnoldporter.com

This communication may contain information that is legally privileged, confidential or exempt from disclosure. If you are not the intended recipient, please note that
any dissemination, distribution, or copying of this communication is strictly prohibited. Anyone who receives this message in error should notify the sender
immediately by telephone or by return e-mail and delete it from his or her computer.
_____________________________
For more information about Arnold & Porter LLP, click here:
http://www.arnoldporter.com

This communication may contain information that is legally privileged, confidential or exempt from disclosure. If you are not the intended recipient, please note that
any dissemination, distribution, or copying of this communication is strictly prohibited. Anyone who receives this message in error should notify the sender
immediately by telephone or by return e-mail and delete it from his or her computer.
_____________________________
For more information about Arnold & Porter LLP, click here:
http://www.arnoldporter.com

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 11 of 23 Page ID


#:266
This communication may contain information that is legally privileged, confidential or exempt from disclosure. If you are not the intended recipient, please note that
any dissemination, distribution, or copying of this communication is strictly prohibited. Anyone who receives this message in error should notify the sender
immediately by telephone or by return e-mail and delete it from his or her computer.
_____________________________
For more information about Arnold & Porter LLP, click here:
http://www.arnoldporter.com

This communication may contain information that is legally privileged, confidential or exempt from disclosure. If you are not the intended recipient, please note that
any dissemination, distribution, or copying of this communication is strictly prohibited. Anyone who receives this message in error should notify the sender
immediately by telephone or by return e-mail and delete it from his or her computer.
_____________________________
For more information about Arnold & Porter LLP, click here:
http://www.arnoldporter.com

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 12 of 23 Page ID


#:267

EXHIBIT B

Chamispi S.R.L.
Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 13 of 23 Page ID
#:268

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Actividad Comercial: Telecomunicaciones
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Distrito / Ciudad: Arequipa

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Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 15 of 23 Page ID
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Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 16 of 23 Page ID


#:271

EXHIBIT C

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 17 of 23 Page ID


#:272
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Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 18 of 23 Page ID


#:273

EXHIBIT D

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 19 of 23 Page ID


#:274
I.,

your domain name 1.ME


CID

REGISTER .ME

.ME as Montenegro

.ME as a company

Corporate-social responsibility

.ME team

Press clippings

Register a .ME
.ME Premium Domains
Premium Domain Program

.ME as Montenegro

.ME Partners
.ME on Social Media
CO MPANY
About .ME
.ME as a Company
Policies
Contact .ME
FAQ
NEWS AND BOG

.ME Blog
Success stories
Build your brand
Tricks of trade

.Me is a rcTLD of Montenegro.

.ME news
Montenegro is a very small country, with little more that 600 000 people. Still, it is famous for its natural
Events
Being responsible

beauty and long, rich, history. Now, Montenegro is getting recognized for one more thing - .ME domain
name.

It all started shortly after Montenegro gained independence in June of 2006, when the ISO 3165
Maintenance Agency assigned the emerging nation the country code ME. Proud of the country's
new-found sovereignty, the new government of Montenegro took important additional measures to
formalize the country's fledging independence. One such step was to submit an application to 'ANA for
delegation of .ME as the country's Top Level Domain (-LD). The delegation was finally approved and
took place in September 2007.

Understanding that "ME" has multiple meanings and has mass appeal as a word, in numerous
languages, the government of Montenegro embarked on generalizing the .ME name space so that
anyone and everyone could enjoy obtaining a .ME for themselves. As a result, in November of 2007, a
formal public RFP was issued to find a Registration Agent who could provide a world-class registry
platform, run operations for an international registry, and deliver marketing expertise to make .ME a
worldwide success. The contract was eventually awarded to doMEn, Ltd, a Montenegrin joint venture
(doing business as .Me Registry), whose partners include Afilias Limited, GoDaddy.com, Inc., and
ME-net Ltd.

Since 200B, when the first domain name was registered, .ME Registry has done its best to promote
Montenegro and to take part in its development by being an active member of its community. As one
of the leading companies in the IT sector of Montenegro, .ME Registry is concentrated on raising
awareness about the importance of ICE and equipping its community, especially young people, with
tools necessary to acquire ICT related knowledge.

Even though .ME has opened its doors to the world to everyone wanting to secure the most personal
domain name for themselves, there are third level domains opened only for Montenegrin people, such
as co.me, net.me, org.me, priv.me, and its.me.

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 20 of 23 Page ID


#:275
ME-net is a Montenegrin company with a long history in the ICT sector in Montenegro, which includes
successful privatization of the country's largest ISP.

GoDaddy.com is the world's largest domain name registrar and the largest paid Web host provider in
North America.

Afilias is a leading registry services provider that supports more than 13 million domains worldwide.

COMPANY

REGISTER .ME

About .ME

.ME premium domains

.ME team

Premium domain

Policies

program

Contact .ME

Register a .M E

FAQ

.ME partners
.ME on social media

Registrar login
Secure login

.ME newsletter
First name

Last name

O I want to know more about how to Nil Id my personal and/or


business brand.

O I want to know more about .ME startups and recent ICT trends
your a-mad

Subscribe

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 21 of 23 Page ID


#:276

EXHIBIT E

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 22 of 23 Page ID


#:277
.Me success stories

Premium domains

Partners

REGISTER .ME

Register a .ME
.ME Premium Domains

Contact .Me

Premium Domain Program


.ME Partners
.ME on Social Media
COMPANY

About .ME
.ME as a Company
Policies
Contact .ME
FAQ
NEWS AND BOG
.ME

Blog

doMEn d.o.o.

Success stones
Build your brand

Address:

Tricks of trade

City kvart

.ME news

Masa Djurovica
Events
Being responsible

Lamela 3/1

Podgorica, 81000

Montenegro

Phone:
+382 77 300 070

Fax:
+1 866 941 5341 +382 77 300 079

Send us an e-mail

Name

E-mail address

Subject

Message

your Inman name .ME

ED

Case 2:16-cv-05871-RSWL-AS Document 18-1 Filed 08/29/16 Page 23 of 23 Page ID


#:278

COMPANY

REGISTER .ME

About .ME

.ME premium domains

.M E team

Premium domain

Policies

program

Contact .ME

Register a .ME

FAQ

.ME partners
.ME on social media

Registrar login
Secure login

.ME newsletter
First name

Last name

El I wanito know more az.our howto build my personal and/or


business brand_

n I want to know more about .ME startups and recent ICTtrends


your e-mail

Subscribe

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