Exhibits From First Amended Complaint - LegalForce v. LegalZoom, January 2, 2018

Case 5:17-cv-07194-NC Document 10-1 Filed 01/02/18 Page 1 of 192
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Case 5:17-cv-07194-NC Document 8
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EXHIBIT D
PO Box 745 Indooroopilly QLD 4068 AUSTRALIA

Ph 1300 662 173 or +61 7 3378 2668
Email enquiries@pacifictranscription.com.au
Web www.pacifictranscription.com.au
FILE DETAILS
Audio Length: 13 minutes
Audio Quality: High Average Low
Number of Facilitators: One
Number of Interviewees: One
Difficult Interviewee Accents: Yes No
Other Comments:
START OF TRANSCRIPT
Operator: Thank you for calling LegalZoom. Please remain on the line to be
connected to the next available representative. Need legal advice?
No problem. Although the LegalZoom customer care specialists can’t
provide legal advice, our network of independent attorneys can. Ask
us how. Calls may be recorded for quality assurance and training
purposes.
[Music plays]
Operator: Thank you for holding.
[Music plays]
Operator: Thank you for holding.
[Music plays]
Facilitator: Thank you for calling LegalZoom. This is Will. How can I help you?
[Unclear] words are denoted in square brackets and time stamps may be used to indicate their location within the audio.
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Recorded Page 2 of 8
Interviewee: Yeah, hi, Will. I have a trademark that I’ve requested filing through
LegalZoom and they said that there’s a problem with it, so I’m trying to
just record and understand what I need to do so I can get this properly
filed and moving forward.
Facilitator: Right. I understand this is the trademark review team, so we just

always discuss these types of matters, but let me go ahead and ask
you a few verification questions so I can secure your document. Can I
verify your first and last name?
Interviewee: Sure. My name is Raj, R-A-J, and my last name is Abhyanker,

A-B-H-Y-A-N-K-E-R.
Facilitator: What’s the…
Interviewee: What’s your name again? Your name is - what’s…
Facilitator: My name is Will.
Interviewee: Will, okay.
Facilitator: Yeah. Second verification question. Can you verify the email address
you use at LegalZoom?
Interviewee: R-A-J @ L-E-G-A-L-F-O-R-C-E-L-A-W dot com.
Facilitator: All right. Lastly, what is the name of the trademark that you’re
applying for?
Interviewee: [Drawmarkia].
Facilitator: Okay. Yeah, so we had some clarification required with the goods
and services description.
Interviewee: Uh-huh.
Facilitator: Your artist and drawing services website for animation and videos for
businesses. So basically the website’s just there - so I don’t know if
you’re trying to trademark the name for a software, like a software as
a service, or if you just provide artist and drawing services directly,
and you just use the website to promote those services so that you
can provide animations of videos for businesses.
PO Box 745 Indooroopilly QLD 4068 AUSTRALIA Ph 1300 662 173 or +61 7 3378 2668
Email enquiries@pacifictranscription.com.au Web www.pacifictranscription.com.au

Interviewee: Yeah, so what I do is I want to allow customers that have small

businesses and they want to make an animation video for their small
business to explain what that business does, I want to make a stop
motion sketch on a whiteboard and then have them create an
animation for the video they can put on YouTube and on their website.
Facilitator: Are you allowing users to create these videos, or you’re doing it
direct? Are you providing the tools so that users can create their own,
or are you doing it for them?
Interviewee: We do it for them and we basically get a questionnaire, what they

want, then we write the storyboard, and then we do the artist’s work
and they can approve it. So we do all the artist stuff.
Facilitator: All right. So this is - when you write artist and drawing services, this is
more like graphic illustration and drawing services. Right?
Interviewee: Right.
Facilitator: The reason I’m asking these questions is because we’re trying to - the
Trademark Office has a classification system and so if you were to,
say, do illustration services like the old-fashioned pen and paper
format, that’s class 41. But anything digital, digitally created services
are going to fall into class 42. So let me - because computer-related
sources falls under that class. So let me take a look and see what
pre-approved descriptions they have in their database. Then I’m
going to run it by you and see if you want to use that description.
Okay?
Interviewee: Okay.
Facilitator: I’m just wondering, because I’m using one of the template descriptions
in their database, graphic illustration and drawing services mainly, and
then I was going to put - and then in brackets it’s - you make - you
write what you want to write to make it indigenous to the applicant. So
graphic illustration and drawing services, namely creating custom
design of graphics and animation for the purpose of creating
animation videos for businesses. But I’m just wondering if this should

just end up being creating animation videos for businesses, just as

simple as that.
Interviewee: What do you think is better?
Facilitator: Well, so they come to you - I think the artist and drawing services are
implied within the confines of - so if I want to come to you, I come to
you because I want you to create a video for me, for my business, an
animation video.
Interviewee: Right. Yeah. So I make…
Facilitator: Okay. So whatever you do to create those animation videos is on

you, but as a consumer what I want you to give me is an animation
video. So I think that we don’t even have to indicate the illustration
and drawing unless you do those as stand-alone services outside of
creating the animation videos. But it’s all about what Drawmarkia is
going to brand identify. So if I think of LegalZoom, I think of them as a
document processing company. Right?
Interviewee: Yes.
Facilitator: If I think of Drawmarkia, I’m going to think of, oh, I need to contact
Drawmarkia so that they can create an animation video for me.
Interviewee: Right. Yes.
Facilitator: Would you agree with that? Does that make sense?
Interviewee: Yeah, I think I’ll go with what you recommend.
Facilitator: Okay. So I put - I’m just checking out one other thing to see if I can
incorporate this into the description. So they have a description in the
database that just reads animation design for others. So I was going
to kind of modify that so that it reads animation design for others,
namely creating animation videos for businesses.
Interviewee: Okay. So is that the best description you think? Is that the best?
Okay, yeah, whatever you think.
Facilitator: Yeah, I mean, as long - so these descriptions are not used for
advertisement purposes. Right? So they’re just there to steer your

trademark in its right designation or right classification, so that it’s

clear to the Trademark Office that you’re looking to seek it - so in your
case you’re going to be either under class 42 or 35.
Interviewee: Okay.
Facilitator: Class 42, because animation design’s in class - is a computer-related

service and - but a simple description of animation design for others
falls under that class. Class 35 would be because any type of service
that you - one does that’s used for the promotion or marketing of
businesses, not that you’re providing it themselves, but you’re using
that, sometimes falls under class 35. So it’s not important to put the
class code. It’s more important to search those classes, so when we
conduct the search, which is the next step, we’re going to go ahead
and see if anyone’s using that name in either class 42 or 35, which
would be the obstacles for you to get the trademark.
Interviewee: Okay. Cool. So, all right. Great.
Facilitator: Great. So I’ll make the update to the document. I’ll send you an email
as a confirmation of the revision to your application.
Interviewee: So what do you recommend? So which one do you recommend? Do

you recommend 32 or 45? Which one do you think is better?
Facilitator: Well, I recommend just not putting a class code, which you don’t have
to do. So you can designate a class code if you want, but if the
Trademark Office feels that it should be the other class they’re just
going to send a correspondence that you have to reply back to. If you
overlook it - it’s not a problem, but if you overlook it, then it can be a
problem, because they give you a deadline to respond. So it’s best to
just leave it blank so that they can just inform you which classification
they’re going to designate your trademark in.
Interviewee: Which one do you think fits better?
Facilitator: I don’t know. I mean, animation design for others is 42, but it might be
class 35 just because they do have - when you think of logos, you
create logos as a digital. It’s a graphic design work. But they have

marketing services, namely creating corporate logos for others.

Typically people want to use logos to brand identify something,
promote something. If I [take] up logos in class 42…
Interviewee: But we’re not making logos. We’re making little two-minute
animations.
Facilitator: I know.
Interviewee: It’s like drawing.
Facilitator: I absolutely understand that. I’m just using it as a correlative example.

So they don’t have anything animation in class 35, at least not that I
know of. Okay, so here, they have one in class 35. It says, providing
advertising services using 3D and animation designs. So who knows?
It’s not imperative to provide a classification upon submission of the
application. They have forms that allow you to not indicate class code
so they can simply do that for you.
Interviewee: Okay.
Facilitator: Even if you felt there was one class over the other, if they feel
differently, they’re just going to inform you of this and you have to
agree to it, or state a reason why you don’t want it to be that class.
But, like I said, if you don’t respond within a certain time, it will become
abandoned and you have to pay a petition to revive fee within a
certain amount of time. So let’s just push this through without a
classification code, unless you suggest otherwise, and I’ll send you a
confirmation email. Then we’ll go ahead and have a search
conducted.
Interviewee: I’ll just do what you recommend, so whatever you recommend is good.
Let’s move it forward.
Facilitator: Okay. We’ll go ahead and move it forward to the next step.
Interviewee: Okay. Thank you.
Facilitator: Do you have any other questions?

Interviewee: Can I start using my trademark now? Can I - what can I do with it?
Can I use it for my website to advertise the…
Facilitator: Well, yeah, you can. You filed it under intent to use, meaning that
you’re not - you don’t have the service available to others, at least not
using this name to do that. But it won’t hurt you to start using it and
conversely, if you rather us just change the filing basis to use in
commerce, and so we can take the screen shots of the website and
we’ll submit the materials to support your using commerce filing basis,
we can do that. But if your interest is to try to get some form of
trademark pending protection as soon as possible, then leaving it
under the intent to use would be the best bet.
Interviewee: Okay. Then if I give you my website, what do I need to show? Is

there - does the website - any website will work? Do I show my name
on it or…
Facilitator: It doesn’t matter. Yeah, it doesn’t matter what the domain name is, so
even if it’s not drawmarkia.com. They’re going to want to see that
there’s a prominent display of the name Drawmarkia on there and
then there’s an explanation of the services you provide and that it’s
clear that one could be able to obtain those services from you now.
Interviewee: Okay. So animation services and stuff for this. That would be
enough.
Facilitator: Yeah.
Interviewee: Okay. Cool. Thank you so much. Yeah, let’s move it forward. When
will it be filed?
Facilitator: I don’t know. So the search is going to take one to two business days.
The sooner you reply back to that, the sooner we’ll send you an email
requesting your electronic signature.
Interviewee: Okay. Thank you so much. I’m ready to move forward…
Facilitator: Okay. Right.
Interviewee: …and thanks.

[Over speaking]
Facilitator: Sounds good, Raj. We’ll take care of you. Take care.
Interviewee: Bye.
END OF TRANSCRIPT

EXHIBIT E

Ph 1300 662 173 or +61 7 3378 2668
FILE DETAILS
Other Comments:
START OF TRANSCRIPT
Interviewee: LegalZoom. This is Alex. How can I help you?
Facilitator: Yes. I ordered a trademark on LegalZoom and it says that I have

action required as my status, so I'm calling in to see what that is.
Interviewee: I can definitely help you out with that but, first, for verification
purposes, can I have you provide me with your first and last name
please?
Facilitator: Yes, it's Ryan Bethell. Last name is spelled B-E-T-H-E-L-L.
Interviewee: Okay, and then also your login email address for your LegalZoom
account.
Facilitator: It's ryanb@legalforcelaw.com.
Interviewee: And also the name of your trademark.
Facilitator: Piggiebank.
LegalZoom-PiggiebankMark-Recording2 Page 2 of 10
Interviewee: Okay. Let's see here. I do see that we do have some questions
regarding your goods and services description. I also see that you
paid for two classes. What it looks like is that your description does
indicate that you may fall under class 42 potentially. We were a little
unclear. So let's see here. To give you some background information,
the Trademark Office does separate different goods and services into
different classifications. Each of those classes does require a filing
fee, as you did pay for two. [Let me see here]. It does look like your
description indicates that you may be something along the lines of
software as a service. Is that appropriate?
Facilitator: Not - yeah. I think we're a software and we're a service [laughs]. What
would you recommend? I can give you the website that we have. It's
just piggiebank.com.
Interviewee: Okay.
Facilitator: I want a little help selecting that. I wasn’t sure which class to pick.
Interviewee: Okay, I see. When it comes to software the Trademark Office does
separate those into two different classes. The downloadable software
that you can actually download to either a computer, a mobile phone,
anything along those lines, that’s going to fall under class nine. If it's
something where you have to pay for access to your service - oh, I'm
sorry, to your software - that is hosted online and they don’t have to
directly download something, that’s considered software as a service,
and that will fall under class 42.
Facilitator: Okay. We do have a subscription model. It's like a CRM. Does that
mean that I should file Piggiebank as a software as a service then?
Interviewee: Let me see here. That’s going to be up to you, essentially, and on

what you determine your services fall under. All I can really tell you is
your options on what we're seeing it may fall under, and then it would
be up to you, ultimately, to decide what you do want to file it as. Given
that we are not attorneys, I cannot give you any direct legal advice.

Facilitator: Okay. What - so then we've got - we do two things. We have a

browser extension which you can download. Then we have the
subscription service which - does that mean that I should do both?
Interviewee: Let me see what the extension may fall under. That is downloadable,
correct, that browser extension you [were saying].
Facilitator: Yeah. It's just like a Google Chrome plugin. You download it and it
gives you access to our software. I guess it makes it easier to
navigate the non-downloadable portion, but I guess the core is non-
downloadable.
Interviewee: Right, okay, I see. That could be - if that software is actually

downloadable, then that would be under that class nine, and that
would be the - see what I can find in regards to that. I do have a
description that simply states computer - [I don’t like that one]. All
right. It simply states computer software for, and then you would
specify the function of the program, so you could include that
information regarding the fact that is a downloadable plugin.
Facilitator: Okay. That would be - so those would be separate though, those

would be two classes, the downloadable part and the non-
downloadable part.
Interviewee: Correct, yes.
Facilitator: Okay. Where's - I'm looking on the website. I can't find the description
that I wrote. Can you point me in that direction?
Interviewee: When it comes to on the actual LegalZoom website for access to that I
don’t entirely know where that is on your end
Facilitator: Okay.
Interviewee: What I can tell you is I do have that description in front of me. What I
have is…
Facilitator: Sure. Let's go through the description.
Interviewee: Okay. It's Piggiebank CRM helps small businesses stay organised.
Piggiebank is a salesforce alternative. It's quick and easy to get set up

and easy to use, designed specifically for businesses using Enterprise

Gmail.
Facilitator: Okay. Yeah, the Enterprise Gmail portion, is that - that’s the Google
Chrome plugin.
Interviewee: Okay, all right.
Facilitator: Does that description look okay?
Interviewee: As a description, all that is is describing what your service does. It

doesn’t really describe what it is, and that’s what the Trademark Office
is looking for, is for that actual description. What I have is, with this
class nine, there's one that states computer software for, and then we
can specify the function of that program. Then under class 42 I have
software as a service, services featuring software for, and then we can
use that language to specify the function of the program as well, if that
sounds appropriate.
Facilitator: Okay. Then I should, essentially, modify this to fit into one of those
templates.
Interviewee: I can do that right now, if you would like me to help you out doing that.
Facilitator: Sure.
Interviewee: I have that description for computer software for, and then specify the
function of that program. How would you like that worded?
Facilitator: So…
[Over speaking]
Interviewee: [That’s going to be] the downloadable portion.
Facilitator: The downloadable - what do you recommend?
Interviewee: For - when it comes to the description, typically, they're just looking for
a basic description of the function. The examples they use is for use in
database management, for use as a spreadsheet, for use - for word
processing; just simple descriptions like that. If it is, for instance, a
downloadable plugin for an internet browser, you could state that.

Facilitator: Okay. That sounds good…
[Over speaking]
Interviewee: …describe.
Facilitator: That sounds good.
Interviewee: Okay. So far I have that it is computer software for use as an internet
browser plugin. Then they're going to want you to also provide
information regarding what it does.
Facilitator: Okay. I guess the browser plugin, essentially, connects it to our CRM
and integrates with Gmail.
Interviewee: Okay.
Facilitator: I don’t know. I guess I'm - what are you - based on what you see, let
me, I guess, describe the service and then [laughs] you can tell me, I
guess, what makes sense on this form. I can't see it. The - essentially,
it's like an email aggregator and a customer relations management
software. The extension - all it does - it's a downloadable - it's for UI
that is ease of access and - it's a UI extension, so it syncs with your
Gmail account and then causes everything that you email to get sent
to - essentially, copied and pasted into the CRM. Maybe read back the
- does that help?
Interviewee: It does. I'm just trying to figure out the best way to see here. Okay, so
- can I have you describe that to me one more time so that I can use
some of that language?
Facilitator: Sure. It's the - which piece? Just the Google Chrome extension, what
it does?
Interviewee: Yeah, yeah.
Facilitator: Or the whole business? Okay.
Interviewee: You could give me all of it right now though. I'll…
[Over speaking]
Facilitator: Perfect. I guess because we're going to draft up two of these.

Interviewee: Yes, [exactly].
Facilitator: The - it's a customer relations management software. The Google

Chrome extension is a downloadable software that gives - essentially,
it's a UI interface that integrates with Google Chrome and syncs the
Gmail accounts with the CRM software.
Interviewee: Okay. Using very basic language, what I have right now…
Facilitator: Yeah, better to keep it simple, right.
Interviewee: Yeah. Under class nine I have computer software for use as an
internet browser plugin in connection with customer relations
management software. Then, under class 42, I have software as a
service, services featuring software for customer relations
management.
Facilitator: Okay.
Interviewee: Does that sound…
Facilitator: Yeah. Do you think that sounds good?
Interviewee: It does at my end, but my only concern is I don’t have details

regarding - you did describe it - your services to me. I just want to
make sure that it sounds good on your end.
Facilitator: Okay. I'll go with what you recommend.
Interviewee: Okay. Then when it comes to your - I have updated that. You are
listed as filing what’s called intent to use, so that does mean that the
Trademark Office is going to ask you for your specimens in the future.
That’s going to be four to five months after your initial filing date.
When they do ask you for those specimens it is going to be per class.
They're going to look for you to provide them the information regarding
that actual downloadable software. That could just be screenshots of
your download page for that software itself. Then they're going to ask
for information regarding that software as a service, which will also
just be - honestly, what I'm seeing on your website may be sufficient
when it comes to that software as a service.

Facilitator: A quick question. Right now the software portion that’s, I guess, the
non-downloadable part is ready now. Should I file one of them as in
use and one of them as intent to use? Or is there a disadvantage to
just filing both intent to use?
Interviewee: No. Actually, we can go ahead and do one and one. The way that it
works is that when you file for intent to use - as I say, the Trademark
Office will ask for that four to five months after that initial filing date.
They also require a $100 fee at the point of providing them that proof.
If you have the proof for that class 42 for software as a service, that
I'm seeing your website, that we could move forward with that one,
providing that to them, which would mean that they’ll just ask you for
the class nine proof, and it'll just be the $100 for the single class when
they ask you for it.
Facilitator: Can you see the website?
Interviewee: Yes. I do have it…
[Over speaking]
Facilitator: Does that look like it would - that would work for proof of use?
Interviewee: Let me go ahead and take a double check here. Yeah. I'm seeing -
yeah, absolutely, this would be…
Facilitator: Okay, that’s perfect. Then let's do the - we'll do one that we're using
now with the proof of use looks good, and then we'll do the other one,
I guess, intent.
Interviewee: Okay, absolutely. When we're doing that - when you do file for use in
commerce the Trademark Office asks for two dates from you. They're
going to ask for your date of first use anywhere and your date of first
use in commerce. That date of first use anywhere does need to come
before the date of first use in commerce, and they both have to be
current dates. They cannot be future dates. How would you like that
listed?
Facilitator: What does use in commerce mean?

Interviewee: That pretty much means the first time you were putting something out
in order to have it purchased.
Facilitator: Okay.
Interviewee: It could be a matter of - since it is out there and you are allowing
people to get started, you are already providing it as a service.
Facilitator: Okay. We - a quick question. We were at, actually, TechCrunch a few

months ago - is, I guess, where we did our soft launch, but we actually
didn’t have our first sale until later. Which would recommend that we
use as a date of first use?
Interviewee: They're looking for information in relation to this actual name. They
want you - just in case you have to provide proof - that you are, in fact,
using this name before somebody else. They want a date for you to
state that I was using it by this point. That’s what is best to think
about.
Facilitator: Okay. They would never like - they're not going to ask for an invoice or
something to show for use in commerce. If we advertised it, that’s
good.
Interviewee: When it comes to the application process they won't ask for that. If it's
anything to do with making sure you're protecting your name in
relation to somebody else trying to use it I don’t have direct
information for that, so I don’t know what they'd ask you for in terms of
that. Before the actual application itself they're not going to ask you for
that.
Facilitator: Okay. Well, thanks. Let's do the software as a service one then. Just
to confirm, it's - we'll do that as in use, and then the other one is intent.
Interviewee: Oh yes.
Facilitator: All right. Thanks.
Interviewee: Then when it comes to those dates I do need to put those in for you
before we can move forward.
Facilitator: Okay.

Interviewee: How would you like those listed?
Facilitator: [Sighs]. Can you - are you in front of the computer? I'm not. I'm sorry
[laughs]. Could you Google when TechCrunch was? Actually, hold on.
I can get it.
Interviewee: Okay.
Facilitator: Because that was our launch date. TechCrunch disrupt. It was 2017.
We were 18 September of this year.
Interviewee: Okay. Is that your date of first use anywhere, or your date of first use
in commerce, or both?
Facilitator: That’s first in commerce. I think we started development internally in -

let's call it 1 January of 2017.
Interviewee: Of '17, okay. All right. What I'm going to do is I'm going to be sending
you an email that will contain both these goods and services
descriptions that you're moving forward with. I am - I have updated
your application so that we're moving forward with the website you
provided as your proof for that class 42 description. Then we're doing
intent to use for your class three description. That is everything that I
need from you right now.
I will go ahead and make sure all of that is updated. Then I'm going to
go out and move your order on through to our search team. They're
going to take the next three to five business days to get you your
search results. Those will be posted to your account. You'll get an
email regarding that. Once you do receive that just give it a look over.
If there's anything about your order you want to update or change,
give us a call. We can help you out with that. If not, just let them know,
as a reply, that you do want to move forward, and then we'll go ahead
and prepare your application at that point.
Facilitator: All right. Thanks very much. Appreciate all the advice.
Interviewee: Thank you very much. Have a great day.
Facilitator: Bye.

Saying I'll go with what you recommend doesn’t mean anything

because asking the question what do you recommend…
END OF TRANSCRIPT


Ph 1300 662 173 or +61 7 3378 2668
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Other Comments:
START OF TRANSCRIPT
Facilitator: My name is Robert, how can I help you today?
Interviewee: Hey Robert, I have a note saying there was action required on my
Trademark.
Facilitator: Okay, I’ll just try to [get right at that], sir. Okay, said it was for your
Trademark?
Interviewee: Correct.
Facilitator: Okay, if I can ask who am I speaking with today?
Interviewee: My name is Ryan Bethell.
Facilitator: [Unclear] Mr Bethel. I have two show that you put the order number of
50921513 in the system?
Interviewee: That’s correct.
Piggiebank-PostSearch Page 2 of 7
Facilitator: Mr Bethell, can I also ask you what email address you use for your
order?
Interviewee: RyanB@Legalforcelaw.com
Facilitator: Alright, thank you, sir. Alright, let me take some quick notes and then I
can get access [unclear] and see if I can help you with this. [Pause]
Okay, Trademark, get that open. [Pause] Alright, it looks like we did
the [comprehensive] search for you and mailed that to you…
Interviewee: I see the - you mailed or emailed? I saw the email. Then I’m actually
looking at search results right now.
Facilitator: Oh yeah, let me check on that. Let me check on that and make sure. It
says it was mailed, so…
Interviewee: Okay, well I’m looking at an email version, that’s fine.
Facilitator: Okay, so they meant - [they may have meant] email note to say
[unclear]. So you did receive that then, okay. So have you had a
chance to…
Interviewee: Yeah, I’ve gone through them briefly…
Facilitator: …look over that…
Interviewee: I was looking for a little bit of direction. Looks like there’s - there are
nine different searches that are done and so what - how [were they
significant]? Could you explain just a little bit to me about what they
are and why they’re [important]?
Facilitator: Well, these search - I mean it’s just a more comprehensive search
[unclear]. [I can’t] It’s - well, the main search is more - [I said it] - it
search as much as the [comprehensive one] - it’s more
comprehensive so it just gives you more information.
Interviewee: Okay.
Facilitator: So basically it’s meant to give you as much information that you - it
can for the comprehensive, so it gives you more idea if there’s any -
could be any clash with your Trademark or if there could be any
possibly clash or conflict.

Interviewee: I guess my problem is, you definitely gave me a lot of information,

perhaps too much because I’m looking at this…
Facilitator: Oh, I see.
Interviewee: …and I just see there’s a hundred and something pages of document
and there’s no direction [laughs] as to - it’s [unclear]. It’s just a blank
page with - here’s - there’s a [blank] page with hundreds of different
search results.
Facilitator: Let me see - yeah and that’s why it’s comprehensive search. It’s really
comprehensive - there’s just a lot of information and…
Interviewee: So - I mean, I see, I went through them all sort of briefly - what - my
goal here is I want to register a Trademark. So what should [really
matter]?
Facilitator: [Pause] Well, look I mean they all matter, like the government ones
are the - I mean that’s [prescribed] to, it’s for government so that’s
[probably] the most part of this - there is some things that are done at
state level aren’t a real Trademark issue, but it’s depending on what
you want to do. You might come into conflict later on, so it’s - I mean
the government one’s definitely an important one. That’s depending
on what you want to do…
Interviewee: So when you say the government one - what are you - I don’t - I see…
Facilitator: Okay, well the federal [unclear] - federal search - the comprehensive
includes the federal and also state search. So state search will bring
up things that are state related that directly affect the Trademark on a
national level.
Interviewee: Okay.
Facilitator: Some states might have a - because it might be a name that’s in a

state that’s just like a business name or something that the state - it’s
already filed in state, so that might be…
Interviewee: [Okay]…

Facilitator: …if somebody was trying to do something nationwide, it might be

going to different to states though that - it’s just a real - I mean,
depending on what you want to do and how…
Interviewee: So…
Facilitator: …[unclear] you’re doing, so…
Interviewee: So if I - if there’s something that’s in a - shows up on the state search,

would that prevent me from going through - would that be a conflict
just for the Trademark registration?
Facilitator: Well, it might be a conflict if you’re going to do something in that state.

If it’s - like there was - we had one [example] there was a - let me think
- I can’t - there was a company - national company and there was a
company that started in another state; I think it was Minnesota, so that
when they went into that Minnesota they had to change their name.
They couldn’t use the name that that company in Minnesota already
had. I can’t remember if it was [Papa John’s] or maybe it was…
Interviewee: Oh, okay, so…
Facilitator: …something like that, but then - so something like that that might
happen.
Interviewee: But that was [kind of a one-off].
Facilitator: But that’s an example.
Interviewee: So but I could still - because there’s - if there was one that looked like
it’s pretty spot-on like in the state of Alabama, I don’t think we have
any plan to go and target Alabama specifically…
Facilitator: Yeah, so that gives you some information…
Interviewee: …but if there’s not - if that doesn’t pop up in the federal search, then
I’m okay? Just for the purpose of…
Facilitator: Yeah, that should be okay…
Interviewee: …[unclear].

Facilitator: … yeah, it’s up to you and what you’re going to do with your
Trademark in the future.
[Over speaking]
Interviewee: The one in Alabama, if it’s not in the federal search, that wouldn’t
affect the ability for me to register, is that what I’m understanding? But
it could ultimately affect my rights to use the mark down the road in
that state?
Facilitator: Yeah, in that certain state or something, yes.
Interviewee: Okay, and I did - as I went through the federal thing - the federal one
is the one I went through most closely and it - I was just wondering
what weight is given to the - because I see a couple of things that are
[unclear] - our Trademark is for Piggiebank and it’s - but it’s treated -
it’s like a software service - it’s going to have a novel spelling. It’s G-
G-I-E instead of G-G-Y and I see some things that are like Piggiebank
Management which is for - it’s like a - books.
So is that going to be a problem? Would something like that pose a

big risk to filing for a Piggiebank Trademark and software service?
Facilitator: Well, I mean we - I mean that’s - I guess that’s - it’s more for you to
decide. It’s hard to speak for you. We try to base [an application] on
what you have done and - but they could change and it’s very - it’s
hard to say what they are going to do for sure, but…
Interviewee: I’m not asking for sure, I mean I imagine you guys have tens of
thousands of Trademarks. So I’m asking in your experience, is
something like - so the mark [unclear] [looking] at is Piggiebank
Management. If you went to the federal search report [number 14] and
I see this registration - the pending mark - it looks like it hasn’t been
registered - and I wonder would we be able to get a similar Trademark
there because the names are similar, but we’re a totally different
service.
Facilitator: Okay, yeah, if it’s a different class that would make a difference.
Interviewee: Okay.

Facilitator: But if it’s a different class they wouldn’t compare it at all, so that’s…
Interviewee: Oh, oh so then I just need to…
Facilitator: …[unclear].
Interviewee: That’s actually - that’s very helpful. So as I go through this then we’re
going to be in I think - I can’t remember the number, but it was like
non-downloadable software and - what’s that 41, maybe 42 - it was in
the 40s. But we wouldn’t then - so when I go through the - the only
ones I need to worry about then, are the ones in that class? That
actually makes…
Facilitator: Yeah, that’s correct.
Interviewee: Oh, perfect. That’s…
[Over speaking]
Interviewee: …[unclear] easier to go through. Alright, now all of a sudden I can just
Control F and find the same class number. That actually makes it very
helpful.
Facilitator: Yeah.
Interviewee: Okay, so again, I think that what I’ll need to do is - do I just approve it
online? So I’m going to go through them and now I’m going to - based
on that, I’m just going to go through and look at all the class 42s and
then we can decide if we’re going to move forward from there.
Facilitator: Yeah, yeah then you call us and let's help you out to see if you
[unclear] search or not, or if you want to update your application or
[unclear], so.
Interviewee: Alright, well thanks. Thanks very much. I appreciate the advice.
Facilitator: Oh you’re welcome Mr Bethell and is there anything else I can help
you with? Do you have any questions?
Interviewee: No, I think that will be it for today. Thanks very much, appreciate it.
Facilitator: You’re welcome Mr Bethell, thank you. Have a wonderful day and
thanks for choosing LegalZoom.

END OF TRANSCRIPT

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EXHIBIT H
UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE DIRECTOR OF THE
In the Matter of )
)
Matthew H. Swyers, ) Proceeding No. D2016-20
)
Respondent )
~~~~~~~~~~~-l
FINAL ORDER
Pursuant to 37 C.F.R. § 11.27(b), the Director of the United States Patent and
Trademark Office ("USPTO" or "Office") received for review and approval from the
Director of the Office of Emollment and Discipline ("OED Director") an Affidavit For
Consent Exclusion pursuant to 37 C.F.R. § 11.27, executed by Matthew H. Swyers
("Respondent") on December 20, 2016. Respondent submitted the twelve-page Affidavit
For Consent Exclusion to the USPTO for the purpose of being excluded on consent
pursuant to 37 C.F.R. § 11.27.
For the reasons set forth herein, Respondent's Affidavit For Consent Exclusion
shall be approved, and Respondent shall be excluded on consent from practice before the
Office in trademark and non-patent matters commencing on the date of this Final Order.
Jurisdiction
Respondent, of Vienna, Virginia, is an attorney licensed to practice law in the
Commonwealth of Virginia and the District of Columbia and has practiced before the
USPTO in trademark matters. As such, he is subject to the USPTO Code of Professional

Responsibility, which is set forth at 37 C.F.R. § 10.20 et seq., and the USPTO Rules of
Professional Conduct, which are set forth at 37 C.F.R. §§ 11.101through11.901.1
Pursuant to 35 U.S.C. §§ 2(b)(2)(D) and 32 and 37 C.F.R. § 11.27, the USPTO
Director has the authority to approve Respondent's Affidavit for Consent Exclusion and
to exclude Respondent on consent from the practice of trademark and non-patent matters
before the Office.
Allegations of the Disciplinary Complaint
A disciplinary complaint is pending against Respondent (Proceeding No. 2016-20)
which alleges that:
a. Respondent, an experienced trademark lawyer and former USPTO

Trademark Examining Attorney, established The Trademark
Company, PLLC, and through that business systematically
permitted non-attorneys to practice trademark law for him with little
or no supervision.
b. Respondent, the sole attorney at the company, did not personally

review or sign thousands of trademark applications and related
documents (including statements of use, § 2(f) declarations, and
responses to Office actions) prepared by his non-lawyer employees
and filed with the USPTO, in violation of USPTO signature and
certification rules and despite assurances on the company website
that trademark applicants would be represented by a specialized
attorney.
c. As a result of Respondent's failure to supervise his employees,

multiple fraudulent or digitally manipulated specimens of use were
filed with the Office, which potentially jeopardized the trademark
applications of his clients.
1 The USPTO Code of Professional Responsibility applies to conduct prior to May 3, 2013, and
the USPTO Rules of Professional Conduct apply to conduct on or after May 3, 2013.
2
d. Respondent failed to deposit client funds paid in advance into a

client trust account and improperly split legal fees with his non-
practitioner employees.
e. Respondent failed to respond to lawful requests for information or

cooperate with the investigation conducted by the Office of
Enrollment and Discipline.
Respondent's Affidavit For Consent Exclusion
Respondent acknowledges in his December 20, 2016 Affidavit For Consent
Exclusion that:
1. His consent is freely and voluntarily rendered, and he is not being subjected
to coercion or duress.
2. He is aware that the disciplinary complaint filed against him (Proceeding
No. D2016-20) alleges that he violated the following Disciplinary Rules of the USPTO
Code of Professional Responsibility and/ or the USPTO Rules of Professional Conduct:
a. 37 C.F.R. § 10.23(a) (engaging in disreputable or gross

misconduct by, inter alia: directing or allowing his employees
to prepare, sign, and file trademark applications, responses to
Office Actions, and other trademark documents; directing or
allowing his employees to provide legal advice and guidance
to trademark applicants; and/ or directing or allowing his
employees to communicate with his clients about trademark
search reports and opinions, without his involvement or
supervision; engaging in disreputable or gross misconduct
by, inter alia: failing to comply with the USPTO's electronic
signature rules by not personally electronically signing
trademark applications and trademark documents filed with
the USPTO and, instead, directing or allowing his employees
to sign or forge his electronic signature to the documents,
which resulted in the validity of registered trademarks being
jeopardized; engaging in disreputable or gross misconduct
by, inter alia: directing or allowing his employees to sign or
forge his name to § 2(£) declarations and file the § 2(f)
declarations with the Office, when (i) he knew that the
3
Trademark Examining Attorneys would rely on the

declarations when examining trademark applications and
issuing registrations and when he knew or reasonably should
have known that the validity of an applicants' applications
and registrations were jeopardized by the false and/ or forged
declarations; and/ or (ii) he knew or should have known his
employees did not have adequate knowledge to aver, "The
mark has become distinctive of the goods/ services through
the applicant's substantially exclusive and continuous use in
commerce that the U.S. Congress may lawfully regulate for at
least the five years immediately before the date of this
statement;" engaging in disreputable or gross misconduct by,
inter alia: (i) failing to adequately supervise his employees or
adequately review their work, thus permitting them to create
false or fraudulent specimens and/ or digitally altered images
of marks that did not depict the actual mark as used in
commerce and file these specimens with the Office, and as a
result, in some cases, the USPTO issued trademark
registrations based on the false or fraudulent specimens or
digitally altered marks, putting the validity of the resulting
trademarks in jeopardy, (ii) failing to inform his clients that
their trademark registrations or applications were potentially
invalid and/ or take timely and effective remedial action on
their behalf and/ or offer or provide restitution to them,
and/ or (iii) failing to inform the USPTO of the potentially
invalid applications and/ or registrations that resulted from
the filing of false or fraudulent specimens or digitally altered
marks; engaging in disreputable or gross misconduct by, inter
alia: (i) not informing clients who purchased trademark legal
services from The Trademark Company that their
applications and other trademark documents were not
prepared or reviewed by an attorney prior to being filed with
the Office; and/ or (ii) collecting fees from clients for
trademark legal services that were supposed to be performed
by an attorney when their applications and other trademark
documents were not prepared or reviewed by an attorney
prior to being filed with the Office);
b. 37 C.F.R. § 10.23(b)(4) (engaging in conduct involving

dishonesty, fraud, deceit, or misrepresentation by, inter alia:
not informing clients who purchased trademark legal services
from The Trademark Company that their applications and
other trademark documents were not prepared or reviewed
4
by an attorney prior to being filed with the Office; engaging

in conduct involving dishonesty, fraud, deceit, or
misrepresentation by, inter alia: (i) not personally
electronically signing trademark applications and trademark
documents filed with the USPTO and, instead, directing or
allowing his employees to sign or forge his electronic
signature to the documents, thereby misleading the USPTO,
his clients, and the public into believing that Respondent had
actually signed the trademark application or trademark
document; and/ or (ii) not affirmatively informing the
Trademark Examining Attorney that the actual signatory, the
employee, was not identified on the document; engaging in
conduct involving dishonesty, fraud, deceit, or
misrepresentation by, inter alia: directing or allowing his
employees to sign or forge his name to § 2(f) declarations and
file the § 2(f) declarations with the Office, when (i) he knew
that the Trademark Examining Attorneys would rely on the
issuing registrations, and/ or (ii) he knew or should have
known his employees did not have adequate knowledge to
aver, "The mark has become distinctive of the goods/ services
through the applicant's substantially exclusive and
continuous use in commerce that the U.S. Congress may
lawfully regulate for at least the five years immediately before
the date of this statement;" engaging in conduct involving
(i) failing to adequately supervise his employees or
marks; engaging in conduct involving dishonesty, fraud,
deceit, or misrepresentation by, inter alia: (i) not informing
5
clients who purchased trademark legal services from The

Trademark Company that their applications and other
trademark documents were not prepared or reviewed by an
attorney prior to being filed with the Office; and/ or (ii)
collecting fees from clients for trademark legal services that
were supposed to be performed by an attorney when their
the Office);
c. 37 C.F.R. § 10.23(b)(5) (engaging in conduct prejudicial to the

administration of justice by, inter alia: (i) directing or allowing
his employees to prepare, sign, and file trademark
applications, responses to Office Actions, and other
trademark documents; directing or allowing his employees to
provide legal advice and guidance to trademark applicants;
and/ or directing or allowing his employees to communicate
with his clients about trademark search reports and opinions,
without his involvement or supervision; and/ or (ii) not
reviewing trademark applications and other trademark
documents (e.g., responses to Office Actions) prepared and
filed by his employees before they were filed with the Office;
engaging in conduct prejudicial to the administration of
justice by, inter alia: (i) failing to comply with the USPTO's
electronic signature rules by not personally electronically
signing trademark applications and trademark documents
filed with the USPTO and, instead, directing or allowing his
employees to sign or forge his electronic signature to the
documents, which resulted in the validity of registered
trademarks being jeopardized and/ or (ii) directing or
signature to trademark applications and other trademark
documents knowing that the actual signatory, the employee,
was not identified on the documents contrary to
Respondent's certifications under § 11.18; engaging in
conduct prejudicial to the administration of justice by, inter
alia: directing or allowing his employees to sign or forge his
name to§ 2(f) declarations and file the § 2(f) declarations with
the Office, when (i) he knew that the Trademark Examining
Attorneys would rely on the declarations when examining
trademark applications and issuing registrations; and/ or (ii)
he knew or should have known his employees did not have
adequate knowledge to aver, "The mark has become
6
distinctive of the goods/ services through the applicant's

substantially exclusive and continuous use in commerce that
the U.S. Congress may lawfully regulate for at least the five
years immediately before the date of this statement;" and/ or
(iii) he knew that (a) the actual signatory, the employee, was
not identified on the document and (b) the actual signatory,
the employee, did not have the knowledge to support the
factual contentions found in the declaration; engaging in
alia: (i) failing to adequately supervise his employees or
trademarks in jeopardy, and/ or (ii) failing to inform the
USPTO of the potentially invalid applications and/ or
registrations that resulted from the filing of false or
fraudulent specimens or digitally altered mark);
d. 37 C.F.R. § 10.23(b)(6) (engaging in any other conduct that

adverse! y reflects on the practitioner's fitness to practice
before the Office, by engaging in the conduct referenced in
Count I of the Complaint to the extent that his conduct does
not otherwise violate a provision of the USPTO Code of
Professional Responsibility; engaging in any other conduct
that adversely reflects on the practitioner's fitness to practice
Count II of the Complaint to the extent that his conduct does
that adversely reflects on the practitioner's fitness to practice
Count III of the Complaint to the extent that his conduct does
Professional Responsibility; any other conduct that adversely
reflects on the practitioner's fitness to practice before the
Office, by engaging in the conduct referenced in Count IV of
the Complaint to the extent that his conduct does not
otherwise violate a provision of the USPTO Code of
Professional Responsibility);
7
e. 37 C.F.R. §§ 10.23(a) and (b) via 10.23(c)(2)(ii) (knowingly

giving false or misleading information or knowingly
participating in a material way in giving false or misleading
information to the USPTO or any employee of the USPTO by,
inter alia: directing or allowing his employees to sign or forge
his name to § 2(£) declarations and file the § 2(f) declarations
with the Office, when (i) he knew that the Trademark
Examining Attorneys would rely on the declarations when
examining trademark applications and issuing registrations,
and/ or (ii) he knew or should have known his employees did
not have adequate knowledge to aver, "The mark has become
distinctive of the goods/services through the applicant's
factual contentions found in the declaration);
f. 37 C.F.R. §§ 10.23(a) and (b) via 10.23(c)(15) (violating the

certifications made to the USPTO under 37 C.F.R. § 11.18 by,
his electronic signature to trademark applications and other
trademark documents knowing that the actual signatory, the
employee, was not identified on the documents; violating the
certifications made to the USPTO under 37 C.F.R. § 11.18 by,
his name to § 2(f) declarations and file the § 2(f) declarations
with the Office, knowing that (i) the actual signatory, the
' employee, was not identified on the document and (ii) the
actual signatory, the employee, did not have the knowledge
to support the factual contentions found in the declaration;
violating the certifications made to the USPTO under 37
C.F.R. § 11.18 by, inter alia, failing to adequately supervise his
employees or adequately review their work, thus permitting
them to create false or fraudulent specimens and/ or digitally
altered images of marks that did not depict the actual mark as
used in commerce and file these specimens with the Office);
g. 37 C.F.R. § 10.31(a) (deceiving or misleading prospective

applicants or other persons having immediate or prospective
8
business before the Office by word, circular, letter, or

advertising with respect to prospective business before the
Office by, inter alia: advertising on The Trademark Company's
website that trademark applications would be prepared by an
attorney when Respondent knew that trademark applications
were not prepared or reviewed by an attorney prior to being
filed with the USPTO; engaging in any other conduct that
adversely reflects on the practitioner's fitness to practice
Count V of the Complaint to the extent that his conduct does
Professional Responsibility);
h. 37 C.F.R. § 10.47(a) and (c) (aiding a non-practitioner in the

unauthorized practice of law before the Office by, inter alia: (i)
directing or allowing his employees to prepare, sign, and file
trademark applications, responses to Office Actions, and
other trademark documents; directing or allowing his
employees to provide legal advice and guidance to trademark
applicants; and/ or directing or allowing his employees to
communicate with his clients about trademark search reports
and opinions, without his involvement or supervision;
and/ or (ii) not reviewing trademark applications and other
trademark documents (e.g., responses to Office Actions)
prepared and filed by his employees before they were filed
with the Office);
i. 37 C.F.R. § 10.48 (sharing legal fees with a non-practitioner by

paying employees non-discretionary monthly bonuses tied to
the proceeds generated by the trademark legal services
provided to applicants with whom they interacted);
j. 37 C.F.R. § 10.77(b) (handling a legal matter without

preparation adequate under the circumstances by, inter alia:
failing to comply with the USPTO' s electronic signature rules
by not personally electronically signing trademark
applications and trademark documents filed with the USPTO
and, instead, directing or allowing his employees to sign or
forge his electronic signature to the documents, which
resulted in the validity of registered trademarks being
jeopardized);
9
k. 37 C.F.R. § 10.77(c) (neglecting client matters by, inter alia: not

reviewing trademark applications, responses to Office
Actions, and other trademark documents prepared and filed
by his employees before they were filed with· the Office;
neglecting client matters by, inter alia: (i) failing to adequately
supervise his employees or adequately review their work,
thus permitting them to create false or fraudulent specimens
and/ or digitally altered images of marks that did not depict
the actual mark as used in commerce and file these specimens
with the Office, and as a result, in some cases, the USPTO
issued trademark registrations based on the false or
fraudulent specimens or digitally altered marks, putting the
validity of the resulting trademarks in jeopardy, and/ or (ii)
failing to inform his clients that their trademark registrations
or applications were potentially invalid and/ or take timely
and effective remedial action on their behalf and/ or offer or
provide restitution to them);
1. 37 C.F.R. § 10.84(a)(l) (intentionally failing to seek the lawful

objectives of a client through reasonably available means
permitted by law by, inter alia: intentionally failing to inform
his clients that their trademark registrations or applications
were potentially invalid and/ or take timely and effective
remedial action on their behalf and/ or offer or provide
restitution to them);
m. 37 C.F.R. § 10.84(a)(3) (intentionally prejudicing or damaging

the client during the course of a professional relationship by,
inter alia: intentionally failing to inform his clients that their
trademark registrations or applications were potentially
their behalf and/ or offer or provide restitution to them);
n. 37 C.F.R. § 10.89(c)(6) (intentionally or habitually violating

any provision of the USPTO Code of Professional
Responsibility while appearing in a professional capacity
before a tribunal by, inter alia: (i) directing or allowing his
employees to prepare, sign, and file trademark applications,
responses to Office Actions, and other trademark documents;
directing or allowing his employees to provide legal advice
and guidance to trademark applicants; and/ or directing or
allowing his employees to communicate with his clients about
trademark search reports and opinions, without his
10
involvement or superv1s10n; and/ or (ii) not reviewing

trademark applications, responses to Office Actions, and
other trademark documents prepared and filed by his
employees before they were filed with the Office;
intentionally or habitually violating any provision of the
USPTO Code of Professional Responsibility while appearing
in a professional capacity before a tribunal by, inter alia: failing
to comply with the USPTO's electronic signature rules by not
personally electronically signing trademark applications and
trademark documents filed with the USPTO and, instead,
directing or allowing his employees to sign or forge his
electronic signature to the documents, which resulted in the
validity of registered trademarks being jeopardized;
in a professional capacity before a tribunal by, inter alia:
directing or allowing his employees to sign or forge his name
to § 2(f) declarations and file the § 2(f) declarations with the
Office, when (i) he knew that the Trademark Examining
Attorneys would rely on the declarations when examining
trademark applications and issuing registrations, and/ or (ii)
he knew or should have known his employees did not have
adequate knowledge to aver, "The mark has become
years immediately before the date of this statement;";
in a professional capacity before a tribunal by, inter alia: (i)
failing to adequately supervise his employees or adequately
review their work, thus permitting them to create false or
fraudulent specimens and/ or digitally altered images of
marks that did not depict the actual mark as used in
fraudulent specimens or digitally altered marks);
11
o. 37 C.F.R. § 10.112(a) (failing to deposit legal fees paid in

advance into a separate client trust account by depositing
them instead into The Trademark Company's operating
account);
p. 37 C.F.R. § 11.101 (failing to provide competent

representation by, inter alia: not reviewing trademark
trademark documents prepared and filed by his employees
before they were filed with the Office; failing to provide
competent representation by, inter alia: failing to comply with
the USPTO's electronic signature rules by not personally
signature to the documents, which resulted in the validity of
registered trademarks being jeopardized; failing to provide
competent representation by, inter alia: directing or allowing
his employees to sign or forge his name to § 2(f) declarations
and file the § 2(£) declarations with the Office, when (i) he
knew that the Trademark Examining Attorneys would rely on
the declarations when examining trademark applications and
issuing registrations and when he knew or reasonably should
have known that the validity of the applicants' applications
and registrations were jeopardized by the false declarations;
failing to provide competent representation by, inter alia: (i)
failing to adequately supervise his employees or adequately
review their work, thus permitting them to create false or
fraudulent specimens and/ or digitally altered images of
marks that did not depict the actual mark as used in
trademarks in jeopardy, and/ or (ii) failing to inform his
clients that their trademark registrations or applications were
potentially invalid and/ or take timely and effective remedial
action on their behalf and/ or offer or provide restitution to
them);
q. 37 C.F.R. § 11.104(a) (failing to keep his client reasonably

informed by, inter alia: (i) not informing Ms. Teague of the
Office Action received on her behalf in U.S. Trademark
12
Application No. 86/287,301 and by not informing her that he

had filed substitute specimens without confirming with her
whether the substitute specimens depicted her mark as used
in commerce, and/ or (ii) failing to inform his clients that their
trademark registrations or applications were potentially
their behalf and/ or offer or provide restitution to them);
r. 37 C.F.R. § 11.115(a) (failing to hold property of a client or

third person that is in the lawyer's possession in connection
with a representation separate from the lawyer's own
property, by depositing fees paid in advance by clients for
trademark legal services and costs into his operating account);
s. 37 C.F.R. § ll.115(c) (failing to deposit into a client trust

account legal fees and expenses that have been paid in
advance, to be withdrawn by the practitioner only as fees are
earned or expenses incurred, by depositing fees paid in
advance by clients for trademark legal services and costs into
his operating account);
t. 37 C.F.R. § ll.303(a)(l) (knowingly making a false statement

of fact to a tribunal or failing to correct a false statement of
material fact previously made to the tribunal by the
practitioner by, inter alia: failing to inform the USPTO of the
potentially invalid applications and/ or registrations that
resulted from the filing of false or fraudulent specimens or
digitally altered marks);
u. 37 C.F.R. § ll.303(d) (failing, in an ex parte proceeding, to

inform the tribunal of all material facts known to the
practitioner that will enable the tribunal to make an informed
decision, even if the facts are adverse by, inter alia: directing
or allowing his employees to sign or forge his name to § 2(f)
declarations and file the § 2(f) declarations with the Office,
when (i) he knew that the Trademark Examining Attorneys
would rely on the declarations when examining trademark
applications and issuing registrations and/ or (ii) he knew or
should have known his employees did not have adequate
knowledge to aver, "The mark has become distinctive of the
goods/services through the applicant's substantially
exclusive and continuous use in commerce that the U.S.
Congress may lawfully regulate for at least the five years
13
immediately before the date of this statement;"; failing, in an

ex parte proceeding, to inform the tribunal of all material facts
known to the practitioner that will enable the tribunal to make
an informed decision, even if the facts are adverse, by, inter
alia, failing to inform the USPTO of the potentially invalid
applications and/ or registrations that resulted from the filing
of false or fraudulent specimens or digitally altered marks);
v. 37 C.F.R. § 11.503(a) (failing to make reasonable efforts to

ensure that The Trademark Company had in effect measures
giving reasonable assurance that its employees' conduct was
compatible with Respondent's professional obligations, as is
required by him as a partner or a person of comparable
managerial authority of The Trademark Company by, inter
alia: failing to adequately supervise his employees or
trademarks in jeopardy);
w. 37 C.F.R. § 11.503(b) (failing to make reasonable efforts to

ensure that the conduct of The Trademark Company
employees over whom he had direct supervisory authority
was compatible with Respondent's professional obligations
by, inter alia: failing to adequately supervise his employees or
trademarks in jeopardy);
x. 37 C.F.R. § 11.503(c) (ordering or ratifying the conduct of the

employees of The Trademark Company which would have
been a violation of the USPTO Rules of Professional Conduct
had it been committed by a practitioner, and/ or failing to take
remedial measures once he learned of the conduct by, inter
14
alia: (i) failing to adequately supervise his employees or

marks);
y. 37 C.F.R. § 11.504(a) (sharing legal fees with a non-

practitioner by paying employees non-discretionary monthly
bonuses tied to the proceeds generated by the trademark legal
services provided to applicants with whom they interacted);
z. 37C.F.R.§11.505 (assisting other persons in the unauthorized

practice of law before the USPTO by, inter alia: (i) directing or
allowing his employees to prepare, sign, and file trademark
filed by his employees before they were filed with the Office);
aa. 37 C.F.R. § 11.701 (making false or misleading

communications about the practitioner or the practitioner's
services by, inter alia: advertising on The Trademark
Company's website that trademark applications would be
prepared by an attorney when Respondent knew that
trademark applications were not prepared or reviewed by an
attorney prior to being filed with the USPTO);
15
bb. 37 C.F.R. §11.SOl(b) (failing to respond to lawful requests for

information and failing to cooperate with OED by inter alia: (i)
telling a witness not to talk to OED; (ii) falsely telling potential
witnesses that talking to OED could affect their trademark
rights; (iii) withholding the names of former employees for
months; and/ or (iv) not providing OED with the documents
it sought (invoices, employment agreements, correspondence
about§ 2(£) declarations, and/ or a privilege log));
cc. 37 C.F.R. § ll.804(c) (engaging in conduct involving

not informing clients who purchased trademark legal services
from The Trademark Company that their applications and
other trademark documents were not prepared or reviewed
by an attorney prior to being filed with the Office; engaging
in conduct involving dishonesty, fraud, deceit, or
misrepresentation by, inter alia: (i) not personally
signature to the documents, thereby misleading the USPTO,
his clients, and the public into believing that Respondent had
actually signed the trademark application or trademark
document; and/ or (ii) not affirmatively informing the
Trademark Examining Attorney that the actual signatory, the
employee, was not identified on the document; engaging in
conduct involving dishonesty, fraud, deceit, or
misrepresentation by, inter alia: directing or allowing his
employees to sign or forge his name to § 2(£) declarations and
file the § 2(f) declarations with the Office, when (i) he knew
that the Trademark Examining Attorneys would rely on the
issuing registrations, and/ or (ii) he knew or should have
known his employees did not have adequate knowledge to
aver, "The mark has become distinctive of the goods/ services
through the applicant's substantially exclusive and
continuous use in commerce that the U.S. Congress may
lawfully regulate for at least the five years immediately before
the date of this statement;" engaging in conduct involving
dishonesty, fraud, deceit, or misrepresentation, by, inter alia:
(i) failing to adequately supervise his employees or
16

marks; engaging in conduct involving dishonesty, fraud,
deceit, or misrepresentation by, inter alia: (i) not informing
clients who purchased trademark legal services from The
Trademark Company that their applications and other
trademark documents were not prepared or reviewed by an
attorney prior to being filed with the Office; and/ or (ii)
collecting fees from clients for trademark legal services that
were supposed to be performed by an attorney when their
the Office; engaging in conduct involving dishonesty, fraud,
deceit, or misrepresentation by, inter alia, falsely telling
potential witnesses that talking to OED could affect their
trademark rights);
dd. 37 C.F.R. § 11.804(d) (engaging in conduct prejudicial to the

administration of justice by, inter alia: (i) directing or allowing
his employees to prepare, sign, and file trademark
filed by his employees before they were filed with the Office;
engaging in conduct prejudicial to the administration of
justice by, inter alia: (i) failing to comply with the USPTO's
electronic signature rules by not personally electronically
signing trademark applications and trademark documents
17
filed with the USPTO and, instead, directing or allowing his

employees to sign or forge his electronic signature to the
documents, which resulted in the validity of registered
trademarks being jeopardized and/ or (ii) directing or
signature to trademark applications and other trademark
documents knowing that the actual signatory, the employee,
was not identified on the documents contrary to
Respondent's certifications under § 11.18; engaging in
conduct that is prejudicial to the administration of justice by,
his name to § 2(f) declarations and file the § 2(f) declarations
with the Office, when (i) he knew that the Trademark
Examining Attorneys would rely on the declarations when
examining trademark applications and issuing registrations,
and/ or (ii) he knew or should have known his employees did
not have adequate knowledge to aver, "The mark has become
factual contentions found in the declaration; engaging in
conduct that is prejudicial to the administration of justice by,
inter alia: (i) failing to adequately supervise his employees or
fraudulent specimens or digitally altered marks; engaging in
aliri: (i) telling a witness not to talk to OED; (ii) falsely telling
potential witnesses that talking to OED could affect their
trademark rights; (iii) withholding the names of former
employees for months; and/ or (iv) not providing OED with
18
the documents it sought (invoices, employment agreements,

correspondence about § 2(f) declarations, and/ or a privilege
log));
ee. 37 C.F.R. § 11.804(i) (engaging in any other conduct that

adversely re£1ects on the practitioner's fitness to practice
Count I of the Complaint, to the extent that the conduct does
not otherwise violate another provision of the USPTO Rules
of Professional Conduct; engaging in any other conduct that
adversely refiects on the practitioner's fitness to practice
Count II of the Complaint, to the extent that the conduct does
of Professional Conduct; engaging in any other conduct that
adversely refiects on the practitioner's fitness to practice
Count III of the Complaint to the extent that his conduct does
not otherwise violate a provision of the USPTO Rules of
Professional Conduct; engaging in any other conduct that
adverse] y refiects on the practitioner's fitness to practice
Count IV of the Complaint to the extent that his conduct does
that adversely refiects on the practitioner's fitness to practice
Count V of the Complaint, to the extent that the conduct does
of Professional Conduct; other conduct that adversely refiects
on the practitioner's fitness to practice before the Office, by
engaging in the acts and omissions described in Count VIII
above).
3. Without admitting that he violated any of the Disciplinary Rules of the USPTO
Code of Professional Responsibility and/ or the Rules of Professional Conduct which are
the subject of the disciplinary complaint in Proceeding No. D2016-20, he acknowledges
that, if and when he applies for reinstatement to practice before the USPTO in trademark
or other non-patent matters under 37 C.F.R. § 11.60, the OED Director will conclusively
19
presume, for the limited purpose of determining the application for reinstatement, that
(a) the allegations regarding him in the complaint filed in Proceeding No. D2016-20 are
true and (b) he could not have successfully defended himself against such allegations.
4. He has fully read and understands 37 C.F.R. §§ 11.5(b), 11.27, 11.58, 11.59, and
11.60, and is fully aware of the legal and factual consequences of consenting to exclusion
from practice before the USPTO in trademark and non-patent matters.
5. He consents to being excluded from practice before the USPTO in trademark
and non-patent matters.
Exclusion on Consent
Based on the foregoing, the USPTO Director has determined that Respondent's
Affidavit For Consent Exclusion complies with the requirements of 37 C.F.R. § 11.27(a).
Accordingly, it is hereby ORDERED that:
1. Respondent's Affidavit For Consent Exclusion shall be, and hereby is,
approved;
2. Respondent shall be, and hereby is, excluded on consent from practice
before the Office in trademark and non-patent matters commencing on the date of this
Final Order;
3. The OED Director shall electronically publish the Final Order at the Office
of Enrollment and Discipline's electronic FOIA Reading Room, which is publicly
accessible at http://e-foia.uspto.gov/Foia/ OEDReadingRoom.jsp;
4. The OED Director shall publish a notice in the Official Gazette that is
materially consistent with the following:
20
Notice of Exclusion on Consent
This notice concerns Matthew H. Swyers of Vienna, Virginia, an

attorney licensed to practice law in the Commonwealth of Virginia
and the District of Columbia and practicing before the United States
Patent and Trademark Office ("USPTO" or "Office) in trademark
matters. The Director of the USPTO has accepted Mr. Swyers'
affidavit for consent exclusion and ordered his exclusion on consent
from practice before the Office in trademark and non-patent matters.
Mr. Swyers voluntarily submitted his affidavit at a time when a

disciplinary complaint was pending against him. The complaint
alleged that Mr. Swyers, an experienced trademark lawyer and
former USPTO Trademark Examining Attorney, established The
Trademark Company, PLLC, and through that business
systematically permitted non-attorneys to practice trademark law
for him with little or no supervision. The complaint alleged that Mr.
Swyers, the sole attorney at the company, did not personally review
or sign thousands of trademark applications and related documents
(including statements of use, § 2(f) declarations, and responses to
Office actions) prepared by his non-lawyer employees and filed with
the USPTO, in violation of USPTO signature and certification rules
and despite assurances on the company website that trademark
applicants would be represented by a specialized attorney. Further,
the complaint alleged that, as a result of Mr. Swyers' failure to
supervise his employees, multiple fraudulent or digitally
manipulated specimens of use were filed with the Office, which
potentially jeopardized the trademark applications of his clients. The
complaint also asserted that Mr. Swyers failed to deposit client funds
paid in advance into a client trust account and improperly split legal
fees with his non-practitioner employees. Finally, the complaint
alleged that Mr. Swyers failed to respond to lawful requests for
information or cooperate with the investigation conducted by the
Office of Enrollment and Discipline.
Mr. Swyers' affidavit acknowledged that the disciplinary complaint

filed against him alleged that his conduct violated the following
provisions of the USPTO Code of Professional Responsibility, for
conduct prior to May 3, 2013: 37 C.F.R. §§ 10.23(a) (engaging in
disreputable or gross misconduct); 10.23(b)(4) (engaging in conduct
involving dishonesty, fraud, deceit, or misrepresentation);
21
10.23(b)(5) (engaging in conduct prejudicial to the administration of

justice); 10.23(a) and (b) via 10.23(c)(2)(ii) (knowingly giving false or
misleading information or knowingly participating in a material
way in giving false or misleading information to the USPTO or any
employee of the USPTO); 10.23(a) and (b) via 10.23(c)(15) (violating
the certifications made to the USPTO under 37 C.F.R. § 11.18);
10.31(a) (deceiving or misleading prospective applicants or other
persons having immediate or prospective business before the Office
by advertising with respect to prospective business before the
Office); 10.47(a) and (c) (aiding a non-practitioner in the
unauthorized practice of law before the Office); 10.48 (sharing legal
fees with a non-practitioner); 10.77(b) (handling a legal matter
without preparation adequate under the circumstances); 10.77(c)
(neglecting client matters); 10.84(a)(1) (intentionally failing to seek
the lawful objectives of a client); 10.84(a)(3) (intentionally
prejudicing or damaging the client during the course of a
professional relationship); 10.89(c)(6) (intentionally or habitually
violating any provision of the USPTO Code of Professional
Responsibility while appearing in a professional capacity before a
tribunal); 10.112(a) (failing to deposit legal fees paid in advance into
a separate client trust account); and 10.23(b)(6) (engaging in other
conduct that adversely reflects on the practitioner's fitness to
practice before the Office).
Mr. Swyers's affidavit also acknowledged that the disciplinary

complaint alleged that his conduct violated the following provisions
of the USPTO Rules of Professional Conduct, for conduct on or after
May 3, 2013: 37 C.F.R. §§ 11.101 (failure to provide competent
representation); 11.104(a)(3) (failing to keep the clients reasonably
informed about the status of a matter); 11.115(a) (failing to hold
property of a client or third person that is in the lawyer's possession
in connection with a representation separate from the lawyer's own
property); 11.115(c) (failing to deposit into a client trust account legal
fees and expenses that have been paid in advance, to be withdrawn
by the practitioner only as fees are earned or expenses incurred);
11.303(a)(1)(knowingly making a false statement of fact to a tribunal
or failing to correct a false statement of material fact previously made
to the tribunal); 11.303( d) (failing, in an ex parte proceeding, to inform
the tribunal of all material facts known to the practitioner that will
enable the tribunal to make an informed decision, even if the facts
are adverse); 11.503(a) (failing to make reasonable efforts to ensure
that The Trademark Company had in effect measures giving
reasonable assurance that its employees' conduct was compatible
22
with Respondent's professional obligations); 11.503(b) (failing to

make reasonable efforts to ensure that the conduct of The Trademark
Company employees over whom he had direct supervisory
authority was compatible with Respondent's professional
obligations); 11.503(c) (ordering or ratifying the conduct of the
employees of The Trademark Company which would have been a
violation of the USPTO Rules of Professional Conduct had it been
committed by a practitioner, and/ or failing to take remedial
measures once he learned of the conduct); 11.504(a) (sharing legal
fees with a non-practitioner); 11.505 (aiding in the unauthorized
practice of law before the USPTO); 11.701 (making false or
misleading communications about the practitioner or the
practitioner's services); 11.801 (b) (failing to cooperate with the Office
of Emollment and Discipline in an investigation); 11.804(c)
(engaging in conduct involving dishonesty, fraud, deceit or
misrepresentation); 11.804(d) (engaging in conduct that is prejudicial
to the administration of justice); and 11.804(i) (engaging in the acts
and omissions that adversely reflect on Respondent's fitness to
practice before the Office).
While Mr. Swyers did not admit to violating any of the Disciplinary
Rules of the USPTO Code of Professional Responsibility or the
USPTO Rules of Professional Conduct as alleged in the pending
disciplinary complaint, he acknowledged that, if and when he
applies for reinstatement, the OED Director will conclusively
presume, for the limited purpose of determining the application for
reinstatement, that (i) the allegations set forth in the OED
investigation against him are true, and (ii) he could not have
successfully defended himself against such allegations.
This action is taken pursuant to the provisions of 35 U.S.C.

§§ 2(b)(2)(D) and 32, and 37 C.F.R. §§ 11.27 and 11.59. Disciplinary
decisions involving practitioners are posted for public reading at the
Office of Enrollment and Discipline Reading Room, available at:
http://go.usa.gov/x9rhg.
5. Respondent shall comply fully with 37 C.F.R. § 11.58; and
23
6. Respondent shall comply fully with 37 C.F.R. § 11.60 upon any request for
reinstatement.
~
David Shewchuk
Deputy General Counsel for General Law
'2~ 1~11
Date
20\ l
United States Patent and Trademark Office
on behalf of
Michelle K. Lee
Under Secretary of Commerce for Intellectual Property and
Director of the United States Patent and Trademark Office
cc:
Director of the Office of Emollment and Discipline

U.S. Patent and Trademark Office
Danny M. Howell
Robert Jackson Martin IV
Anne M. Sterba
Law Office of Danny M. Howell, PLLC
2010 Corporate Ridge, Suite 700
Mclean, VA 22102
Counsel for Matthew H. Swyers
24
EXHIBIT I

BEFORE THE DIRECTOR
OF THE UNITED STATES PATENT AND TRADEMARK OFFICE
In the Matter of )
)
Tracy W. Druce, )
) Proceeding No. D2014-13
Respondent )
)
FINAL ORDER
The Director of the Office of Enrollment and Discipline ("OED Director") for the United
States Patent and Trademark Office ("USPTO" or "Office") and Tracy W. Druce ("Respondent")
have submitted a Proposed Settlement Agreement ("Agreement") to the Under Secretary of
Commerce for Intellectual Property and Director of the United States Patent and Trademark
Office ("USPTO Director") for approval.
The Agreement, which resolves all disciplinary action by the USPTO arising from the
stipulated facts set forth below, is hereby approved. This Final Order sets forth the parties'
stipulated facts, legal conclusion, and agreed upon sanction.
Jurisdiction
1. At all times relevant hereto, Respondent of Houston, Texas, was a registered

patent attorney (Registration No. 35,493) and was subject to the USPTO Code of Professional
Responsibility, which is setforth at 37 C.F.R. § 10.20 et seq]
2. The USPTO Director has jurisdiction over this matter pursuant to 35 U.S.C.
§§ 2(b)(2)(D) and 32 and37 C.F.R. §§ 11.19 and 11.26.
Stipulated Facts
3. The USPTO registered Respondent as a patent attorney on March 24, 1992.
4. Respondent's registration number is 35,493.
5. In 2004, Respondent established a law firm, Novak Druce LLP.
6. In 2005, Noval, Druce LLP became Novak, Druce & Quigg LLP.
1 The USPTO Code of Professional Responsibility applies to Respondent's alleged misconduct

that OCCUlTed prior to May 3, 2013. The USPTO Rules of Professional Conduct, 37 C.F.R.
§ 11.101 et seq., apply to it practitioner's misconduct occufl'ing after May 2,2013.
7, At all times relevant to this Agreement, anon-lawyer assistant,

worked for Respondent at Novak Druce LLP and Novak, Druce & Quigg LLP from 2004
through late 2006, hereinafter referred to as "the non-lawyer assistant,")
8, At all relevant times, Respondent was responsible for the supervision of the
non-lawyer assistant.
9, From at least 2004 through 2006, the non-lawyer assistant submitted, with intent
to deceive, knowingly false statements to the Office in many patent applications that Respondent
was responsible for prosecuting on behalf of clients,
10, The non-lawyer assistant submitted the following types offalse statements to the
Office in patent applications that Respondent was responsible for prosecuting:
a, fabricating email COnfilnlation messages and submitting the fabricated emails

to the Office as evidence that papers had been sent to the Office via facsimile
transmission when, in fact, the papers were never sent to the Office;
b, affixing USPTO receipt stamps to postcards and submitting the doctored

postcard receipts to the Office as evidence that the Office had received papers
when, in fact, the papers were never sent to the Office;
c, fabricating a United States Postal Service Express Mail label that falsely
represented a patent application had been mailed to the Office on a certain
date when, in fact, the application had never been sent to the Office; and
d, backdating certificates of mailing that falsely represented that papers had been
mailed to the Office weeks and/or months earlier than they actually had been
sent.
11. Additionally, the non-lawyer assistant signed Respondent's signature to papers

filed with the Office in many patent applications that Respondent was responsible for
prosecuting on behalf of clients, .
12, Additionally, the non-lawyer assistant electronically "cut and pasted" a digital
version of Respondent's signature and affixed it to papers filed with the Office in many patent
applications that Respondent was responsible for prosecuting on behalf of clients,
13, Additionally, the non-lawyer assistant prepared petitions; signed Respondent's

name to the petitions and/or affixed a digital version of Respondent's signature to the petitions;
and filed the petitions in the Office,
2
14. Respondent knew that the non-lawyer assistant had signed Respondent's name to
application papers submitted to the Office in many patent applications that Respondent was
responsible for prosecuting on behalf of clients.
15. The non-lawyer assistant represented in a declaration that he engaged in the'

misconduct described in paragraphs 9-12, above, without Respondent's lmowledge.
16. Respondent represents that he did not know of the non-lawyer assistant's
misconduct described in paragraphs 9-12, above, and the non-lawyer assistant represents that he
acted alone and kept his misconduct secret from Respondent.
17. Respondent acJmowledges he did not adequately supervise the non-lawyer

assistant's activities.
18. Previously, Respondent completed and returned to the OED Director the USPTO
Mandatory Survey (Form PTO 107S) issued under 37 C.F.R. § 11.1 1(a)(2). Respondent
indicated on the survey that he did not wish to remain on the register of registered practitioners
(37 C.F.R. § 11.5), and the OED Director removed Respondent from the register. Accordingly,
ptlrsuant to 37 C.F.R. § 11.10(a), Respondent is not permitted to prosecute patent applications of
others before the Office or represent others in any proceedings before the Office unless and until
he is reinstated to the register.
Joint Legal Conclusion
19. Respondent aclmowledgeS' that, based on the above stipulated facts, he violated
37 C.F.R. § 1O.77(c) (a practitioner shall not neglect a legal matter entrusted to the practitioner)
by not adequately supervising his non-lawyer assistant.
Agreed Upon Sanction
20. Respondent agrees, and it is hereby ORDERED that:
a. If Respondent seeks reinstatement to the Office's register of practitioners under

37 C.F.R. § 11.7, Respondent shall be suspended from practice before the Office
in patent, trademark, and other non-patent matters for twenty-four (24) months
commencing on the date that a request for Respondent's reinstatement to the
re gister is granted;
b. The 24-month suspension, which is contingent upon Respondent seeking and

being granted reinstatement, shall be stayed;
c. Respondent shall serve a twenty-four (24) month period of probation commencing

on the date that a request for Respondent's reinstatement to the register is granted;
3
d. Respondent shall be permitted to practice before the USPTO in patent, trademark,

and other non-patent matters during his probationary period unless his probation
is revoked and he is suspended by order of the USPTO Director or otherwise no
longer has the authority to practice;
e. When and if Respondent seeks reinstatement pursuant to 37 C.F.R. § 11.7, the

present disciplinary proceeding will not be a basis for barring his reinstatement
provided that Respondent complies with the terms of the Final Order;
f. Respondent shall provide certain information to certain present and former

client(s) as set forth in subparagraphs i. through aa., below;
g. Respondent shall use his best efforts to identifY each patent application that
Respondent prosecuted before the Office at any time between January 1,2004,
and December 31, 2006, that meet all of the following three conditions:
(1) The Office received between January 1,2004, and December31,

2006, any of the following: (i) a petition to revive an abandoned application, (ii) a
petition to withdraw the holding of abandomnent; and/or (iii) a petition for
extension of time where the petition for extension of time was transmitted to the
Office by the non-lawyer assistant and where the petition for extension of time's
transmittal date preceded the Office's receipt date by more than thirty (30) days;
(2) The non-lawyer assistant transmitted any paper in the application

to the Office at any time between January 1,2004, and December 31, 2006; and
(3) The Office issued a patent on the application at any time;
h. For each patent application identified by Respondent pursuant to the preceding

subparagraph, Respondent shall identify the present client(s) and former client(s)
for whom patent legal services on the application were performed;
i. For each present and former client(s) identified by Respondent pursuant to the
preceding subparagraph, Respondent shall provide each such present and former
client(s) with the following documents:
(1) A copy of the Apri110, 2014 declaration executed by the

non-lawyer assistant with the patent application serial numbers redacted; and
(2) A copy of the redacted Final Order;
j. Respondent shall also provide unambiguous written notification to the present and
former client(s) that Respondent represented in connection with U.S. Patent
4
Application No _ _ of the specific false statements described in

~ 14 of the April 10, 2014 declaration;2
k. Respondent shall also provide unambiguous written notification to the present and
former client(s) that Respondent repres'ented in connection with
U.S. Patent Application No. _ o f the specific potentially false
statements described in ~ 15 of the April 10, 2014 declaration;
Application N 0._
1. Respondent shall also provide unambiguous written notification to the present and
of the specific potentially false statements described
in ~ 15 of the April! 0,2014 declaration;
m. Respondent shall also provide unambiguous written notification to the present and
Application No._ofthe specific potentially false statements described
in ~ 15 of the April 10, 2014 declaration;
n. Respondent shall also provide unambiguous written notification to the present and
former client(s) ~dent represented in connection with U.S. Patent
Application N o . _ of the specific potentially false statements described
o. Respondent shall also provide unambiguous written notification to the present and
Application No. _ o f the specific potentially false statements described
p. Respondent shall also provide unambiguous written notification to the present and
Application No._ofthe specific potentially false statements described
in ~ 16 of the April 10, 2014 declaration and the potential backdating of
certificates of mailing described in ~ 17 of the Apri110, 2014 declaration;
q. Respondent shall also provide unambiguous written notification to the present and
Application No. _ o f the potential backdating of certificates of mailing
described in ~ 17 of the April 10, 2014 declaration; ,
r. Respondent shall also provide unambiguous written notification to the present and
2~application serial number identified in ~ 14~ 10,2014 declaration as

" _ " is incorrect. The correct serial number i s _
5
Application No, _ o f the potential backdating of certificates of mailing

described in 'If 17 of the April 10, 2014 declaration;
s, Respondent shall also provide unambiguous written notification to the present and
former client(s) that Respondent represented in connection with U,S, Patent
Application N o , _ o f t h e potential backdating of certificates of mailing
t, Respondent shall also provide unambiguous written notification to the present and
former client(s) that Respondent represented in counection with U, S, Patent
described in 'If 17 of the Apri110, 2014 declaration;
u, Respondent shall also provide unambiguous written notification to the present and
fornier client(s) ~dent represented in connection with ofU,S, Patent
described in 'If 17 ofthe April 10, 2014 declaration;
v, Respondent shall also provide unambiguous written notification to the present and
former client(s) that Respondent represented in connection with U,S, Patent
w, Respondent shall also provide unambiguous written notification to the present and
former client(s) ~dent represented in counection with U,S, Patent
Application N o , _ of the potential backdating of certificates of mailing
described in 'If 17 ofthe April 10, 2014 declaration;
x, Respondent shall also provide unambiguous written notification to the present and
former client(s) that Respondent represented in connection with ofU,S, Patent
described in 'If 17 of the April 10, 2014 declaration; ,
y. Respondent shall also provide unambiguous written notification to the present and
Application No. _ o f the potential backdating of certificates of mailing
described in 'If 17 of the Apri110, 2014 declaration;
z. Respondent shall also provide unambiguous written notification to the present and
Application N o . _ o f t h e potential backdating of certificates of mailing
described in 'If 17 of the Apri110, 2014 declaration;3 ,
3 The patent application serial number identified in ~ 14 of the Apri110, 2014 declaration as
' _ ' is incorrect. The correct serial number i s _
6
aa. Respondent shall also provide unambiguous written notification to the present and
former client(s) ~dent represented in connection with U.S. Patent
Application N o . _ o f t h e potential backdating of certificates of mailing
described in ~ 17 of the April 10, 2014 declaration;
bb. Within 120 days of the day that the Final Order is signed, Respondent shall
submit the following to the OED Director: (1) an affidavit or declaration attesting
to his compliance with the terms of this Agreement and the Final Order for
notifying present and former client(s) as set forth in subparagraphs i. through aa.,
above, and (2) a copy of the correspondence to clients, including the written
notifications transmitted to the current and former client(s), evidencing his
compliance with the terms of this Agreement and the Final Order for notifying
present and former client(s); the client correspondence provided to the OED in
accordance with this subparagraph shall be marked "CONFIDENTIAL" by the
Respondent, and the OED shall keep the correspondence confidential;
cc. (1) lfthe OED Director is of the good faith opinion that Respondent, during
Respondent's probationary period, failed to comply with any provision of the
Agreement, this Final Order, or any provision of the USPTO Rules of
Professional Conduct, the OED Director shall:
.(A) Issue to Respondent an Order to Show Cause why the USPTO

Director should not enter an order immediately suspending Respondent for up
to twenty-four (24) months for the violation set forth in paragraph 19, above;
(B) Send the Order to Show Cause to Respondent at the last

address of record Respondent furnished to the OED Director pursuant to
. 37 C.F.R. § 11.11; and
(C) Grant Respondent thirty (30) days to respond to the Order to

Show Cause; and
(2) In the event that after the 3 O-day period for response and consideration of the
response, if any, received from Respondent, the OED Director continues to be of
the opinion·that Respondent, during Respondent's probationary period, failed to
comply with any provision of the Agreement, this Final Order, or any provision of
the USPTO Rilles of Professional Conduct, the OED Director shall:
(A) Deliver to the USPTO Director: (i) the Order to Show Cause;
(ii) Respondent's response to the Order to Show Cause, if any; and
(iii) argument and evidence causing the OED Director to be of the opinion that
Respondent, during Respondent's probationary period, failed to comply with
any provision of the Agreement, Final Order, or any provision of the USPTO
Rules of Professional Conduct; and
7
(B) Request that the USPTO Director enter an order immediately

suspending Respondent for up to twenty-four (24) months for the violation set .
forth in paragraph 19, above;
dd. Nothing herein shall prevent the OED Director from seeking discipline for the
misconduct leading to Respondent's suspension pursuant to the preceding
subparagraph;
ee. In the event the USPTO Director suspends Respondent pursuant to subparagraph
cc., above, and Respondent seeks a review of the suspension, any such review of
the suspension shall not operate to postpone or otherwise hold in abeyance the
suspension;
ff. The OED Director shall comply with 37 C.F.R. § 11.59 exceptthat.
and all patent application serial numbers shall be redacted
from the Final Order.
gg. The OED Director shall electronically publish the Final Order at the Office of
Enrollment and Discipline's electronic ForA Reading Room, which is publicly
accessible at http://e-foia.uspto. govlFoialOEDReadingRoom.jsp;
hh. The OED Director shall publish a notice in the Official Gazette that is materially
consistent with the following:
Notice of Discipline
This notice concerns Tracy W. Druce of Houston, Texas (Registration No.

35,493), who previously left the United States Patent and Trademark Office
("USPTO" or "Office") register of practitioners. The USPTO Director has
ordered that, if Mr. Druce is reinstated to the register of practitioners, then he
shall be suspended from practice before the Office in patent, trademark, and
other non-patent matters for twenty-four (24) months, with the entirety of the
suspension stayed, for violating 37 C.F.R. § 10.77(c) (a practitioner shall not
neglect a legal matter entrusted to the practitioner), Mr . .Druce wi11 also be
required to serve a twenty-four (24) month period of probation upon being
reinstated to the register ..
Mr. Druce was responsible for the supervision of a non-lawyer

assistant who, from at least 2004 through 2006, submitted, with intent
to deceive, knowingly false statements to the Office in many patent
applications that Mr, Druce was responsible for prosecuting on behalf
of clients. The non-lawyer assistant did the following: (1) fabricated
email confirmation messages and submitted the fabricated emails to
the Office as evidence that papers had been sent to the Office via
facsimile transmission when, in fact, the papers were never sent to the
8
Office; (2) affixed USPTO receipt stamps to postcards and submitted

the doctored postcard receipts to the Office as evidence that the Office
had received papers when, in fact, the papers were never sent to the
Office; (3) fabricated a United States Postal Service Express Mail label
that falsely represented that a patent application had been mailed to the
Office on a certain date when, in fact, the application had never been
sent to the Office; and (4) backdated certificates of mailing that falsely
represented that papers had beep mailed to the Office weeks and/or
months earlier than they actually had been sent.
The violation of37 C.F.R. § 10.77(c) is predicated upon Mr. Druce

not adequately supervising a non-lawyer assistant.
Mr. Druce represents that he did not have actual knowledge of the
non-lawyer assistant's false submissions to the Office, and the non-
lawyer assistant represents that he acted alone and kept his misconduct
secret from Mr. Druce.
In reaching a settlement with Mr. Druce, OED Director took into

consideration the following: (a) the non-lawyer assistarit's misconduct
occurred many years ago in 2004, 2005, and 2006; (b) Mr. Druce
cooperated with the investigation of the facts and circumstances
involved in this disciplinary proceeding; and (c) Mr. Druce will take
prompt action to notify present and former clients about the
misconduct committed in patent applications where patents were
granted.
This action is the result of a settlement agreement between Respondent

and the OED Director pursuant to the provisions of 35 U.S.C.
§§ 2(b)(2)(D) and 32 and 37 C.F.R. §§ 11.26 and 11.59. Disciplinary
decisions involving practitioners are posted for public reading at the
Office of Enrollment and Discipline Reading Room, available at:
http://e-foia.uspto.gov/Foia/OEDReadingRoom.jsp.
ii. Nothing in this Agreement or the Final Order approving this Agreement shall
prevent the Office from considering the record of this disciplinary proceeding (1)
when addressing any further complaint or evidence of the same or similar
misconduct concerning Respondent brought to the attention of the Office; andlor
(2) in any future disciplinary proceeding against Respondent (a) as an aggravating
factor to be taken into consideration in determining any discipline to be imposed
andlor (b) to rebut any statement or representation by or on Respondent's behalf;
jj. The OED Director shall file a motion with the administrative law judge requesting
the dismissal of the pending disciplinary proceeding within fourteen (14) days of
the date ofthe Final Order; and
9
Ide The OED Director and Respondent shall each bear their own costs incurred to date
and in carrying out the terms of this Agreement and the Final Order.
The foregoing is understood and agreed to by:
SEP - 5 20H
Wi JAMES O. PAYNE Date
Deputy General Counsel for General Law
on behalf of
Michelle K.. Lee

Deputy Under Secretary of Commerce for Intellectual Property
and Deputy Director of the United States Patent and Trademark Office
cc: Director ofthe Office of Enrollment and Discipline

Abbe David Lowell

Chadbourne & Parke LLP
30 Rockefeller Plaza, New York, NY 10112
Respondent's Counsel
Christopher Man
Chadbourne & Parke LLP
1200 New Hampshire Ave N.W., Washington, DC 20036
Respondent's Counsel
10
EXHIBIT J

BEFORE THE DIRECTOR OF THE
In the Matter of: )

)
Leonard Tachner, ) Proceeding No. D20l4-22
)
Respondent )
)
FINAL ORDER
Pursuant to 37 C.F.R. § l1.27(b), the Director of the United States Patent and Trademark
Office ("USPTO" or "Office") received for review and approval from the Director of the
Office of Emollment and Discipline ("OED Director") an Affidavit of Resignation Pursuant to
37 C.F.R. § 11.27 executed by Leonard Tachner ("Respondent") on June 2, 2014. Respondent
submitted the affidavit to the USPTO for the purpose of being excluded on consent pursuant to
37 C.F.R. § 11.27.
For the reasons set forth herein, Respondent's Affidavit of Resignation shall be approved
and Respondent shall be excluded on consent from practice before the Office in patent,
trademark, and other non-patent matters commencing on the date of this Final Order.
Jurisdiction
Respondent of San Jose, California, is a registered patent attorney (Reg. No. 26,344) and
is subject to the USPTO Rules of Professional Conduct, 37 C.F.R. § 11.101, et seq.
See 37 C.F.R. § 11.19(a).!
Pursuant to 35 U.S.C. §§ 2(b)(2)(D) and 32 and 37 C.F.R. § 11.27, the USPTO Director
has the authority to approve Respondent's Affidavit of Resignation and to exclude Respondent
1 The USPTO Code of Professional Responsibility applies to practitioner misconduct

that occurred prior to May 3, 2013, while the USPTO Rules of Professional Conduct,
37 C.F.R. § 11.101 et seq., apply to a practitioner misconduct that occurred after May 2, 2013.
on consent from practice before the Office in patent, trademark, and other non-patent matters
before the Office.
Respondent's Affidavit of Resignation
Respondent acknowledges in his June 2, 2014 Affidavit of Resignation that:
I. His consent is freely and voluntarily rendered, and he is not being subjected to
coercion or duress.
2. He is aware that the OED Director opened an investigation of allegations that
that he violated the USPTO Rules of Professional Conduct, namely: OED File No. G2239. The
investigation concerned allegations, inter alia, that:
a. By Final Order dated April 12, 2013, Respondent was suspended for five years
from the practice of patent, trademark and other non-patent matters before the
USPTO for neglecting patent matters by allowing patents to expire for not timely
paying maintenance fees, fora failing to inform clients of important USPTO
correspondence and giving misleading information to clients about the status of
their patents. He also failed to conduct an inquiry reasonable under the
circumstances prior to signing and filing certain submissions with the USPTO;
b. By Final Order dated April 12,2013, Respondent was granted limited recognition
to practice before the USPTO commencing on the date the Final Order and
expiring thirty (30) days after the date the Final Order is signed, with such limited
recognition being granted for the sole purpose of facilitating Respondent's
compliance with the provisions of37 C.F.R. § 11.58(b).
c. Respondent engaged in the unauthorized practice oflaw in the prosecution of U.S.

Trademark application nos. 85/906,074 and 85/906,085 by representing clients
before the USPTO while he was not authorized to do so; and
d. Respondent did not inform his clients or the trademark examiner in U.S.
Trademark application nos. 85/906,074 and 85/906,085 that he was not authorized
to represent the clients before the USPTO.
3. He is aware that the disciplinary complaint pending against him alleges that he
violated the following provisions of the USPTO Rules of Professional Conduct:
a. 37 C.F.R. § l1.804(a) (proscribing engaging in conduct that is a violation ofthe

USPTO Rules of Professional Conduct);
2
b. 37 C.F.R. § 11.804(c) (proscribing engaging in conduct involving dishonesty,

fraud, deceit, or misrepresentation);
c. 37 C.F.R. § 11.804(d) (proscribing engaging in conduct that is prejudicial to the

administration of justice); and
d. 37 C.F.R. § 11.505 (proscribing the unauthorized practice oflaw).
4. Without admitting to any of the allegations at issue in the pending
disciplinary investigation or to violating any of the USPTO Rules of Professional Conduct,
Respondent acknowledges that, if and when he applies for reinstatement under 37 C.F.R. §
11.60, the OED Director will conclusively presume, for the purpose of determining the
application for reinstatement, that (a) the allegations set forth in OED File No. G2239 and
USPTO disciplinary proceeding D2014-22 are true and (b) he could not have successfully
defended himself against such allegations.
5. Respondent has fully read and understands 37 C.F.R. §§ I 1.5 (b), 11.27,
11.58, 11.59, and 11.60, and is fully aware of the legal and factual consequences of
consenting to exclusion from practice before the USPTO in patent, trademark, and other
non-patent matters.
6. He consents to being excluded from practice before the USPTO in
patent, trademark, and other non-patent matters.
Exclusion on Consent
Based on the foregoing, the USPTO Director has determined that Respondent's
Affidavit of Resignation complies with the requirements of37 C.F.R. § 11.27(a). Hence, it
is ORDERED that:
a. Respondent's Affidavit of Resignation shall be, and hereby is, approved;
b. Respondent shall be, and hereby is, excluded on consent from practice before
3
the Office in patent, trademark, and other non-patent matters commencing on the date of this
Final Order;
c. The OED Director shall electronically publish this Final Order at the Office
of Emollment and Discipline's electronic ForA Reading Room, which is publicly accessible
at http://e-foia.uspto.govlFoialOEDReadingRoom.jsp;
d. The OED Director shall publish the following notice in the Official
Gazette:
Notice of Exclusion on Consent
This notice concerns Leonard Tachner of San Jose California, a registered

patent attorney (Reg. No. 26,344). The Director of the United States Patent
and Trademark Office ("USPTO" or "Office") has accepted Mr. Tachner's
affidavit of resignation and ordered his exclusion on consent from practice
before the Office in patent, trademark, and other non-patent matters.
Mr. Tachner voluntarily submitted his affidavit at a time when a disciplinary

investigation was pending against him. The investigation concerned
allegations, inter alia, that;
a) By Final Order dated April 12,2013, Respondent was suspended for five
years from the practice of patent, trademark and other non-patent matters
before the USPTO for neglecting patent matters by allowing patents to expire
for not timely paying maintenance fees, for failing to inform clients of
important USPTO correspondence and giving misleading information to
clients about the status of their patents. He also failed to conduct an inquiry
reasonable under the circumstances prior to signing and filing certain
submissions with the USPTO;
b) By Final Order dated April 12, 2013, Respondent was granted limited
recognition to practice before the USPTO commencing on the date the Final
Order and expiring thirty (30) days after the date the Final Order is signed,
with such limited recognition being granted for the sole purpose offacilitating
Respondent's compliance with the provisions of37 C.F.R. § 11.58(b).
c) Respondent engaged in the unauthorized practice of law in the prosecution
of U.S. Trademark application nos. 85/906,074 and 85/906,085 by
representing clients before the USPTO while he was not authorized to do so;
and
d) Respondent did not inform his clients or the trademark examiner in U.S.
Trademark application nos. 85/906,074 and 85/906,085 that he was not
authorized to represent the clients before the USPTO.
4
The disciplinary investigation concerned allegations that Respondent violated

the following provisions of the USPTO Rules of Professional Conduct:
a. 37 C.F.R. § 11.804(a) (proscribing engaging in conduct that is a violation of
the USPTO Rules of Professional Conduct);
b. 37 C.F.R. § 11.804(c) (proscribing engaging in conduct involving
dishonesty, fraud, deceit, or misrepresentation);
c. 37 C.F.R. § 1l.804(d) (proscribing engaging in conduct that is prejudicial
to the administration of justice); and
d. 37 C.F.R. § 11.505 (proscribing the unauthorized practice oflaw).
While Mr. Tachner did not admit to any ofthe allegations at issue in the
pending disciplinary investigation or to violating any of the Disciplinary Rules
of the USPTO Code of Professional Conduct, he acknowledged that, if and
when he applies for reinstatement, the OED Director will conclusively
presume, for the purpose of determining the application for reinstatement, that
(i) the allegations set forth in OED File No. G2239 and USPTO disciplinary
proceeding D2014-22 are true, and (ii) he could not have successfully
defended himself against such allegations.
This action is taken pursuant to the provisions of35 U.S.C. §§ 2(b)(2)(D)

and 32, and 37 C.F.R. §§ 11.27 and 11.59. Disciplinary decisions involving
practitioners are posted for public reading at the Office of Enrollment and
Discipline Reading Room, available at:
http://e-foia. uspto.gov/FoialOEDReadingRoom. j sp.
e. Respondent shall comply with 37 C.F.R. § 11.58;
f. The OED Director shall comply with 37 C.F.R. § 11.59;
g. Respondent shall comply with 37 C.F.R. § 11.60 upon any request for
reinstatement;
h. The OED Director and Respondent shall bear their own costs incurred to date;
and
in carrying out the terms of this agreement
i. USPTO Disciplinary Proceeding No. D2014-22 is hereby dismissed.
(only signature page follows)
5
JUN 3 0 2014
Date SO. PAYNE
epu y General Counsel for General Law
it States Patent and Trademark Office
'oJ
on behalf of
Michelle K. Lee
Deputy Under Secretary of Commerce for Intellectual
Property and Deputy Director of the United States Patent and
Trademark Office
cc:
Director of the Office of Enrollment and Discipline

U.S. Patent and Trademark Office
Cameron Weiffenbach
Miles & Stockbridge, P.C.
1751 Pinnacle Drive, Suite 500
McLean, Virginia 22102
Respondent's counsel
6
EXHIBIT K
12/12/2017 Avvo, LegalZoom,
Case 5:17-cv-07194-NC Document Rocket10-1
Lawyer Declared Off-Limits | Law.com
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Avvo, LegalZoom, Rocket Lawyer Declared

O -Limits
By David Gialanella | June 22, 2017 at 04:49 PM | Originally published on New Jersey Law Journal (/njlawjournal/)
 (http://www.almreprints.com)
(http://images.law.com/contrib/content/uploads/sites/292/2017/06/Josh-King-Article-
201706211757.jpg) Josh King is a Vice President, Business Development and General Counsel at
Avvo, Inc. HANDOUT.
A joint opinion by three New Jersey Supreme Court committees has blacklisted three Trending Stories
web-based services that match litigants with attorneys because of concerns over 1 Here Are The Ten Highest Paid
illicit fee-sharing and referral fees. Female GCs In The U.S.
(/corpcounsel/sites/corpcounsel/2017/12/05/here-
Avvo facilitates improper fee-splitting, while LegalZoom and Rocket Lawyer operate are-the-ten-highest-paid-
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2 Mostly White and Male:
Diversity Still Lags Among
The opinion decrees that “New Jersey lawyers may not participate in the Avvo legal SCOTUS Law Clerks
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service programs because the programs improperly require the lawyer to share a white-and-male-diversity-still-
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NATIONAL LAW JOURNAL
7.3(d).” (/NATIONALLAWJOURNAL/)
It adds: “The Committees further nd that LegalZoom and Rocket Lawyer appear to 3 Boutiques Aim to 'Blow the
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All three companies have defended their services. THE AMERICAN LAWYER
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The New Jersey State Bar Association sent an inquiry to the ACPE, asking whether
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(/dailyreportonline/sites/dailyreportonline/2017/12/11/g
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fees to Avvo for legal services provided by a liated lawyers, after which Avvo pays
the lawyer but keeps a marketing fee. 5
https://www.law.com/sites/almstaff/2017/06/22/avvo-legalzoom-rocket-lawyer-declared-off-limits/ 1/4
Filed 01/02/18 Page 94 of 192
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“Business Advantage Pro” and “Legal Advantage Plus,” through which customers get (/americanlawyer/sites/americanlawyer/2017/12/08/en
30-minute phone consultations with lawyers of their choosing, or the “ rst available” bankruptcies-leave-some-law-
rms-looking-forlorn/)
lawyer. Lawyers do not pay to participate in LegalZoom, and LegalZoom keeps its
THE AMERICAN LAWYER
subscription fees, the committees said. (/AMERICANLAWYER/)
Rocket Lawyer, which o ers “limited legal advice on document-related matters” and
a free 30-minute phone consultation, does not take payments from lawyers to join—
though the lawyers “agree to o er a discounted fee for additional services”—and
does not share its subscription fees with the lawyers, according to the opinion.
LegalZoom and Rocket Lawyer’s services “appear to be legal service plans,” which are
permissible under RPC 7.3(e)(4), but “as of the date of this Joint Opinion … neither
organization has registered a legal service plan with the Administrative O ce of the
Courts,” the committees said.
The Avvo plans have a di erent problem, according to the opinion: They are “pay-for-
service plans,” and the company’s business model violates RPC 5.4(a), which
prohibits fee-sharing.
“The participating lawyer receives the set price for the legal service provided, then
pays a portion of that amount to Avvo,” the committee said. “The label Avvo assigns
to this payment (“marketing fee”) does not determine the purpose of the fee. … Here,
lawyers pay a portion of the legal fee earned to a nonlawyer; this is impermissible
fee sharing.”
The committees found that the LegalZoom and Rocket Lawyer models do not violate
the fee-sharing stricture.
The opinion also holds that marketing fees lawyers pay to Avvo are not for
advertising but amount to an “impermissible referral fee” by the de nition contained
in RPCs 7.2(c) and 7.3(d).
“When the lawyers pay a fee to the company based on the retention of the lawyer by
the client or the establishment of an attorney-client relationship, the answer to the
inquiry is simple: the company operates an impermissible referral service,” the
committees said.
On the bright side for Avvo, the committees did nd that its model does not “unduly
interfere with a lawyer’s professional judgment in violation of Rule of Professional
Conduct 5.4(c)” by limiting the scope of representation.
“Avvo does not insert itself into the legal consultation in a manner that would
interfere with the lawyer’s professional judgment,” they said. “As for LegalZoom and
Rocket Lawyer, Inquirer suggested that lawyers may be constricted in the service
they provide for clients in the limited phone consultations. Again, however, this is the
nature of legal service plans.”
The committees also found that Avvo’s practice of holding the lawyer’s fee until the
service is provided violates an attorney’s requirement to maintain a registered trust
account per Rule 1:28(a)-2.
Avvo submitted a response contending that it wasn’t giving referrals and its
marketing fee is a separate transaction—meaning that it doesn’t amount to fee-
sharing. The company also “claimed to be serving a public purpose of improving
access to legal services,” according to the opinion.
“The Committees acknowledge that improving access to legal services is

commendable, but participating lawyers must still adhere to ethical standards,” they
said.
The opinion also dispensed with the notion that Avvo is engaged in commercial
speech that’s protected by the First Amendment.
The committees noted that Avvo’s business model has been found to violate ethics
standards in Pennsylvania, South Carolina and Ohio.
LegalZoom submitted a response emphasizing that its employees don’t o er legal

services, and has a contract with a New Jersey rm to which it pays a monthly fee
based on the number of participants in the service plan. The opinion does not
identify the name of the rm. Judiciary spokeswoman Winnie Comfort said any
documents identifying the rm are con dential.
Rocket Lawyer, too, submitted a response, stating that the actual legal services are
provided by independent lawyers, who are “paid an undisclosed sum by Rocket
Lawyer for participation in the ‘Q&A Service,’” according to the opinion.
Filed 01/02/18 Page 95 of 192
Avvo Chief Legal O cer Josh King said in a statement that the company is “happy the
Committees concluded that Avvo Legal Services doesn’t interfere with the
independent professional judgment of lawyers, but disappointed that the
Committees focused solely on mechanistic application of the rules rather than what
the law requires: consumer protection and respect for the First Amendment.”
He added: “Avvo is attempting to address the pressing need for greater consumer
access to justice, and we will continue to do so despite this advisory opinion.”
Rocket Lawyer, through a spokeswoman, declined to comment on the opinion.
A representative of LegalZoom, reached by email, did not provide comment by press

time.
NJSBA President Robert Hille issued a statement saying the association “has in recent
years frequently expressed concern about the growing number of organizations that
have sought to open the door to fee sharing, which could interfere with a lawyer’s
independent professional judgement.”
The NJSBA sent the inquiry “since many of our colleagues have taken advantage of
the services some companies o er, without a thorough vetting of how they comport
with the ethics rules,” added Hille, of McElroy, Deutsch, Mulvaney & Carpenter in
Morristown. “The association will continue to monitor developments as these issues
evolve and will provide guidance to its members.”
The opinion was accompanied by a notice to the bar, which included an appendix
listing 46 legal service plans that are registered in the state, including plans o ered
through labor unions, government entities and corporations.
Contact David Gialanella at dgialanella@alm.com.On Twitter: @dgialanellanjlj.
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From time to time, LegalZoom may perform certain attorney access services and introduce our visitors to attorneys through various methods, including
but not limited to (i) legal plans, (ii) third party attorney directory listings, and (iii) third party limited scope agreements. At no time is an attorney-client
relationship fostered or created with LegalZoom through the performance of any such services.
This Site and Applications are not intended to create any attorney-client relationship, and your use of LegalZoom does not and will not create an
attorney-client relationship between you and LegalZoom. Instead, you are and will be representing yourself in any legal matter you undertake through
LegalZoom's legal document service.
1. Privacy Policy. LegalZoom respects your privacy and permits you to control the treatment of your personal information. A complete statement of
LegalZoom's current Privacy Policy can be found by clicking here. LegalZoom's Privacy Policy is expressly incorporated into this Agreement by
reference.
When you open an account to use or access certain portions of the Site, Applications, or the Services, you must provide complete and accurate
information as requested on the registration form. You will also be asked to provide a user name and password. You are entirely responsible for
maintaining the confidentiality of your password. You may not use a third party's account, user name or password at any time. You agree to notify
LegalZoom immediately of any unauthorized use of your account, user name or password. LegalZoom shall not be liable for any losses you incur as a
result of someone else's use of your account or password, either with or without your knowledge. You may be held liable for any losses incurred by
LegalZoom, our affiliates, officers, directors, employees, consultants, agents and representatives due to someone else's use of your account or
password.
In connection with the use of certain LegalZoom products or services, you may be asked to provide personal information in a questionnaire,
application, form or similar document or service. This information will be protected pursuant to our Privacy Policy. In addition, you grant LegalZoom a
worldwide, royalty-free, nonexclusive, and fully sublicensable license to use, distribute, reproduce, modify, publish and translate this personal
information solely for the purpose of enabling your use of the applicable service. You may revoke this license and terminate rights held by LegalZoom
at any time by removing your personal information from the applicable service.
2. Ownership. This Site and Applications are owned and operated by LegalZoom.com, Inc. All right, title and interest in and to the materials provided
on this Site and Applications, including but not limited to information, documents, logos, graphics, sounds and images (the "Materials") are owned
either by LegalZoom or by our respective third party authors, developers or vendors ("Third Party Providers"). Except as otherwise expressly provided
by LegalZoom, none of the Materials may be copied, reproduced, republished, downloaded, uploaded, posted, displayed, transmitted or distributed in
any way and nothing on this Site or on any Applications shall be construed to confer any license under any of LegalZoom's intellectual property rights,
whether by estoppel, implication or otherwise. See the "Legal Contact Information" below if you have any questions about obtaining such licenses.
LegalZoom does not sell, license, lease or otherwise provide any of the Materials other than those specifically identified as being provided by
LegalZoom. Any rights not expressly granted herein are reserved by LegalZoom.
3. Limited Permission to Download. LegalZoom hereby grants you permission to download, view, copy and print the Materials on any single, stand-
alone computer (or, for Microsoft Agave users, one copy of the Application on up to five devices affiliated with your Marketplace Windows Live ID
account) solely for your personal, informational, non-commercial use provided that (i) where provided, the copyright and trademark notices appearing
on any Materials not be altered or removed, (ii) the Materials are not used on any other website or in a networked computer environment and (iii) the
Materials are not modified in any way, except for authorized editing of downloadable forms for personal use. This permission terminates automatically
without notice if you breach any of the terms or conditions of these Terms of Use. On any such termination, you agree to immediately destroy any
downloaded or printed Materials. Any unauthorized use of any Materials contained on this Site or Applications may violate copyright laws, trademark
laws, laws of privacy and publicity and communications regulations and statutes.
4. Links to Third Party Sites. This Site and Applications may contain links to websites controlled by parties other than LegalZoom (each a "Third
Party Site"). LegalZoom works with a number of partners and affiliates whose sites are linked with LegalZoom. LegalZoom may also provide links to
other citations or resources with whom it is not affiliated. LegalZoom is not responsible for and does not endorse or accept any responsibility for the
availability, contents, products, services or use of any Third Party Site, any website accessed from a Third Party Site or any changes or updates to
such sites. LegalZoom makes no guarantees about the content or quality of the products or services provided by such sites. LegalZoom is not
responsible for webcasting or any other form of transmission received from any Third Party Site. LegalZoom is providing these links to you only as a
convenience, and the inclusion of any link does not imply endorsement by LegalZoom of the Third Party Site, nor does it imply that LegalZoom
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sponsors, is affiliated or associated with, guarantees, or is legally authorized to use any trade name, registered trademark, logo, legal or official seal,
or copyrighted symbol that may be reflected in the links. You acknowledge that you bear all risks associated with access to and use of content
provided on a Third Party Site and agree that LegalZoom is not responsible for any loss or damage of any sort you may incur from dealing with a third
party. You should contact the site administrator for the applicable Third Party Site if you have any concerns regarding such links or the content located
on any such Third Party Site.
5. Use of LegalZoom Legal Forms. On our Site, through our Applications, and through certain partners, we offer self-help "fill in the blank" forms. If
you buy a form from one of our partners, you will be directed to that partner's website and their terms of use will control. If you buy or download a form
on our Site or Application, the terms and conditions of these Terms of Use control. You understand that your purchase, download, and/or- use of a
form document is neither legal advice nor the practice of law, and that each form and any applicable instructions or guidance is not customized to your
particular needs.
License to Use.
LegalZoom grants you a limited, personal, non-exclusive, non-transferable license to use our forms (the "Forms") for your own personal, internal
business use, or if you are an attorney or professional, for your client. Except as otherwise provided, you acknowledge and agree that you have no
right to modify, edit, copy, reproduce, create derivative works of, reverse engineer, alter, enhance or in any way exploit any of the Forms in any
manner, except for modifications in filling out the Forms for your authorized use. You shall not remove any copyright notice from any Form.
Resale of Forms Prohibited.
By ordering or downloading Forms, you agree that the Forms you purchase or download may only be used by you for your personal or business use
or used by you in connection with your client and may not be sold or redistributed without the express written consent of LegalZoom.com.
6. DISPUTE RESOLUTION BY BINDING ARBITRATION
Please read this carefully. It affects your rights.
Summary:
Most customer concerns can be resolved quickly and to the customer's satisfaction by calling our Customer Care Center at (800) 773-0888. In the
unlikely event that the LegalZoom Customer Care Center is unable to resolve your complaint to your satisfaction (or if LegalZoom has not
been able to resolve a dispute it has with you after attempting to do so informally), we each agree to resolve those disputes through
binding arbitration or in small claims court rather than in a court of general jurisdiction. Arbitration is less formal than a lawsuit in court.
Arbitration uses a neutral arbitrator instead of a judge or jury, allows for more limited discovery than a court does, and is subject to very limited review
by courts. Any arbitration under these Terms will take place on an individual basis; class arbitrations and class actions are not
permitted. While in some instances, upfront costs to file an arbitration claim may exceed similar costs to bring a case in court, for any non-frivolous
claim that does not exceed $75,000, LegalZoom will pay all costs of the arbitration. Moreover, in arbitration you may recover attorney's fees from
LegalZoom to the same extent or more as you would in court. The arbitrator shall apply the same limitations period that would apply in court.
Under certain circumstances (as explained below), LegalZoom will pay you more than the amount of the arbitrator's award and will pay your attorney
(if any) his or her reasonable attorney's fees if the arbitrator awards you an amount greater than what LegalZoom offered you to settle the dispute.
You may speak with independent counsel before using this Site or completing any purchase.
Arbitration Agreement:
(a) LegalZoom and you agree to arbitrate all disputes and claims between us before a single arbitrator. The types of disputes and claims we agree to
arbitrate are intended to be broadly interpreted. It applies, without limitation, to:
claims arising out of or relating to any aspect of the relationship between us, whether based in contract, tort, statute, fraud, misrepresentation, or any other legal
theory;
claims that arose before these or any prior Terms (including, but not limited to, claims relating to advertising);
claims that are currently the subject of purported class action litigation in which you are not a member of a certified class; and
claims that may arise after the termination of these Terms.
For the purposes of this Arbitration Agreement, references to "LegalZoom," "you," and "us" include our respective subsidiaries, affiliates, agents,
employees, business partners, predecessors in interest, successors, and assigns, as well as all authorized or unauthorized users or beneficiaries of
services or products under these Terms or any prior agreements between us. Beneficiaries include, but are not limited to, those named in an estate
planning document.
Notwithstanding the foregoing, either party may bring an individual action in small claims court. This arbitration agreement does not preclude your
bringing issues to the attention of federal, state, or local agencies. Such agencies can, if the law allows, seek relief against us on your behalf. You
agree that, by entering into these Terms, you and LegalZoom are each waiving the right to a trial by jury or to participate in a class
action. These Terms evidence a transaction or website use in interstate commerce, and thus the Federal Arbitration Act (“FAA”) governs the
interpretation and enforcement of this provision. This arbitration provision will survive termination of these Terms.
(b) A party who intends to seek arbitration must first send, by U.S. certified mail, a written Notice of Dispute ("Notice") to the other party. A Notice to
LegalZoom should be addressed to: Notice of Dispute, General Counsel, LegalZoom.com, Inc., 101 North Brand Blvd., 11th Floor, Glendale, CA
91203 (the "Notice Address"). The Notice must (a) describe the nature and basis of the claim or dispute and (b) set forth the specific relief sought
("Demand"). If LegalZoom and you do not reach an agreement to resolve the claim within 30 days after the Notice is received, you or LegalZoom may
commence an arbitration proceeding. During the arbitration, the amount of any settlement offer made by LegalZoom or you shall not be disclosed to
the arbitrator until after the arbitrator determines the amount, if any, to which you or LegalZoom is entitled.
You may download or copy a form Notice from http://www.legalzoom.com/arbitration-forms.pdf.
You may download or copy a form to initiate arbitration from the AAA website at https://www.adr.org.
(c) After LegalZoom receives notice at the Notice Address that you have commenced arbitration, it will promptly reimburse you for your payment of the
filing fee, unless your claim is for more than $75,000. (Currently, the filing fee for consumer-initiated arbitrations is $200, but this is subject to change
by the arbitration provider. If you are unable to pay this fee, LegalZoom will pay it directly after receiving a written request at the Notice Address.) The
arbitration will be governed by the Consumer Arbitration Rules (the "AAA Rules") of the American Arbitration Association (the "AAA"), as modified by
these Terms, and will be administered by the AAA. The AAA Rules are available online at www.adr.org or by calling the AAA at 1-800-778-7879. (You
may obtain information about the arbitration process directed to non-lawyers, including information about providing notice to LegalZoom, at
http://www.legalzoom.com/arbitration-information.pdf.) The arbitrator is bound by these Terms. All issues are for the arbitrator to decide, except that
issues relating to the scope, enforceability, and interpretation of the arbitration provision and the scope, enforceability, and interpretation of paragraph
(f) are for the court to decide. Unless LegalZoom and you agree otherwise, any arbitration hearings will take place in the county (or parish) of your
contact address. If your claim is for $10,000 or less, you may choose whether the arbitration will be conducted solely on the basis of documents
submitted to the arbitrator, by a telephonic hearing, or by an in-person hearing as established by the AAA Rules. If you choose to proceed either in
person or by telephone, we may choose to respond only by telephone or submission. If your claim exceeds $10,000, the AAA Rules will determine
whether you have a right to a hearing. The parties agree that in any arbitration of a dispute or claim, neither party will rely for preclusive effect on any
award or finding of fact or conclusion of law made in any other arbitration of any dispute or claim to which LegalZoom was a party. Except as otherwise
provided for herein, LegalZoom will pay all AAA filing, administration, and arbitrator fees for any arbitration initiated in accordance with the notice
requirements above. If, however, the arbitrator finds that either the substance of your claim or the relief sought in the Demand is frivolous or brought
for an improper purpose (as measured by the standards set forth in Federal Rule of Civil Procedure 11(b)), then the payment of all such fees will be
governed by the AAA Rules. In such case, you agree to reimburse LegalZoom for all monies previously disbursed by it that are otherwise your
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obligation to pay under the AAA Rules. In addition, if you initiate an arbitration in which you seek relief valued at more than $75,000 (excluding
attorney’s fees and expenses), the payment of these fees will be governed by the AAA rules.
(d) If, after finding in your favor in any respect on the merits of your claim, the arbitrator issues you an award that is greater than the value of
LegalZoom's last written settlement offer made before an arbitrator was selected, then LegalZoom will:
pay you either the amount of the award or $2,000 ("the alternative payment"), whichever is greater; and
pay your attorney, if any, the amount of attorney's fees, and reimburse any expenses (including expert witness fees and costs), that your attorney reasonably accrues
for investigating, preparing, and pursuing your claim in arbitration (the "attorney's payment").
If LegalZoom did not make a written offer to settle the dispute before an arbitrator was selected, you and your attorney will be entitled to receive the
alternative payment and the attorney's fees, respectively, if the arbitrator awards you any relief on the merits. The arbitrator may make rulings and
resolve disputes as to the payment and reimbursement of fees, expenses, and the alternative payment and the attorney's fees at any time during the
proceeding and upon request from either party made within 14 days of the arbitrator's ruling on the merits. In assessing whether an award that
includes attorney’s fees or expenses is greater than the value of LegalZoom’s last written settlement offer, the arbitrator shall include in his or her
calculations only the value of any attorney’s fees or expenses you reasonably incurred in connection with the arbitration proceeding before
LegalZoom’s settlement offer.
(e) The right to attorney's fees and expenses discussed in paragraph (d) supplements any right to attorney's fees and expenses you may have under
applicable law. Thus, if you would be entitled to a larger amount under applicable law, this provision does not preclude the arbitrator from awarding you
that amount. However, you may not recover duplicative awards of attorney's fees or costs. Although under some laws LegalZoom may have a right to
an award of attorney's fees and expenses if it prevails in an arbitration proceeding, LegalZoom will not seek such an award.
(f) The arbitrator may award injunctive relief only in favor of the individual party seeking relief and only to the extent necessary to provide relief
warranted by that party's individual claim. YOU AND LEGALZOOM AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN
YOUR OR ITS INDIVIDUAL CAPACITIES AND NOT AS PLAINTIFFS OR CLASS MEMBERS IN ANY PURPORTED CLASS OR REPRESENTATIVE
PROCEEDING OR IN THE CAPACITY OF A PRIVATE ATTORNEY GENERAL. Further, unless both you and LegalZoom agree otherwise, the
arbitrator may not consolidate more than one person's claims, and may not otherwise preside over any form of a representative or class proceeding.
The arbitrator may award any relief that a court could award that is individualized to the claimant and would not affect other customers. Neither you
nor we may seek non-individualized relief that would affect other customers. If a court decides that applicable law precludes enforcement of any of
this paragraph's limitations as to a particular claim for relief, then that claim (and only that claim) must be severed from the arbitration and may be
brought in court.
(g) If the amount in dispute exceeds $75,000 or either party seeks any form of injunctive relief, either party may appeal the award to a three-arbitrator
panel administered by AAA by a written notice of appeal within thirty (30) days from the date of entry of the written arbitration award. An award of
injunctive relief shall be stayed during any such appeal. The members of the three-arbitrator panel will be selected according to AAA rules. The three-
arbitrator panel will issue its decision within one hundred and twenty (120) days of the date of the appealing party's notice of appeal. The decision of
the three-arbitrator panel shall be final and binding, subject to any right of judicial review that exists under the FAA.
(h) Notwithstanding any provision in the applicable Terms to the contrary, we agree that if we make any future change to this arbitration provision
(other than a change to any notice address, website link or telephone number provided herein), that change will not apply to any dispute of which we
had written notice on the effective date of the change. Moreover, if we seek to terminate this arbitration provision, any such termination will not be
effective until at least thirty (30) days after written notice of such termination is provided to you, and shall not be effective as to disputes which arose
prior to the date of termination.
7. Additional Terms. Some LegalZoom Services may be subject to additional posted guidelines, rules or terms of service ("Additional Terms") and
your use of such Services will be conditioned on your agreement to the Additional Terms. If there is any conflict between these Terms of Use and the
Additional Terms, the Additional Terms will control for that Service, unless the Additional Terms expressly state that these Terms of Use will control.
8. Reviews, Comments, Communications, and Other Content. At various locations on the Site or through Applications, LegalZoom may permit
visitors to post ratings, reviews, comments, questions, answers, and other content (the "User Content"). Contributions to, access to and use of the
User Content is subject to this paragraph and the other terms and conditions of these Terms of Use.
Rights and Responsibilities of LegalZoom.
LegalZoom is not the publisher or author of the User Content. LegalZoom takes no responsibility and assumes no liability for any content posted by
you or any third party.
Although we cannot make an absolute guarantee of system security, LegalZoom takes reasonable steps to maintain security. If you have reason to
believe system security has been breached, contact us by email for help.
If LegalZoom's technical staff finds that files or processes belonging to a member pose a threat to the proper technical operation of the system or to
the security of other members, LegalZoom reserves the right to delete those files or to stop those processes. If the LegalZoom technical staff suspects
a user name is being used by someone who is not authorized by the proper user, LegalZoom may temporarily disable that user's access in order to
preserve system security. In all such cases, LegalZoom will contact the member as soon as feasible.
LegalZoom has the right (but not the obligation), in our sole and absolute discretion, to edit, redact, remove, re-categorize to a more appropriate
location or otherwise change any User Content.
Rights and Responsibilities of LegalZoom Users or Other Posters of User Content.
You are legally and ethically responsible for any User Content - writings, files, pictures or any other work - that you post or transmit using any
LegalZoom service that allows interaction or dissemination of information. In posting User Content, you agree that you will not submit any content:
that is known by you to be false, inaccurate or misleading;
that infringes anyone’s copyright, patent, trademark, trade secret or other proprietary rights or rights of publicity or privacy. Please see Compliance with Intellectual
Property Laws below;
that violates any law, statute, ordinance, or regulation (including, but not limited to, those governing export control, consumer protection, unfair competition,
antidiscrimination, or false advertising). Please see Compliance with Export Restrictions below;
that is, or may reasonably be considered to be, defamatory, libelous, hateful, racially or religiously biased or offensive, unlawfully threatening or unlawfully harassing,
or advocates or encourages illegal conduct harmful to any individual, partnership or corporation. Please see Inappropriate Content below;
that includes advertisements, spam, or content for which you were compensated or granted any consideration by any third party;
that includes information that references other websites, addresses, email addresses, phone numbers, or other contact information;
that contains any computer virus, worms, or other potentially damaging computer programs or files;
that otherwise violates these Terms of Use.
Attorneys that submit User Content and provide advice do so at their own risk.
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Under United States federal law, you retain copyright on all works you create and post as User Content, unless you choose specifically to renounce it.
In posting a work as User Content, you authorize other members who have access to that service to make personal and customary use of the work,
including creating links or reposting, but not otherwise to reproduce or disseminate it unless you give permission for such dissemination.
You grant LegalZoom a perpetual, irrevocable, royalty-free, transferable right and license to use, copy, modify, delete in its entirety, adapt, publish,
translate, create derivative works from, sell, distribute, and/or incorporate such content into any form, medium, or technology throughout the world
without compensation to you. You have the right to remove any of your works from User Content at any time.
You are not required to provide your real name when signing up as a user of LegalZoom. LegalZoom permits anonymous or pseudonymous accounts.
Any user may request that such member's email address be hidden to provide for additional privacy.
Ratings and reviews will generally be posted in two to four business days.
By submitting your email address in connection with your rating and review, you agree that LegalZoom may use your email address to contact you
about the status of your review and other administrative purposes.
9. NO WARRANTY. THE SITE, APPLICATIONS, AND ALL MATERIALS, DOCUMENTS OR FORMS PROVIDED ON OR THROUGH YOUR USE OF
THE SITE OR APPLICATIONS ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. TO THE FULLEST EXTENT PERMITTED BY LAW,
LEGALZOOM EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED
TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT.
LEGALZOOM MAKES NO WARRANTY THAT: (A) THE SITE, APPLICATIONS, OR THE MATERIALS WILL MEET YOUR REQUIREMENTS; (B) THE
SITE, APPLICATIONS, OR THE MATERIALS WILL BE AVAILABLE ON AN UNINTERRUPTED, TIMELY, SECURE OR ERROR-FREE BASIS; (C)
THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SITE, APPLICATIONS, OR ANY MATERIALS OFFERED THROUGH THE SITE
OR APPLICATIONS, WILL BE ACCURATE OR RELIABLE; OR (D) THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION OR OTHER
MATERIAL PURCHASED OR OBTAINED BY YOU THROUGH THE SITE, APPLICATIONS, OR IN RELIANCE ON THE MATERIALS WILL MEET
YOUR EXPECTATIONS.
OBTAINING ANY MATERIALS THROUGH THE USE OF THE SITE OR APPLICATIONS IS DONE AT YOUR OWN DISCRETION AND AT YOUR
OWN RISK. LEGALZOOM SHALL HAVE NO RESPONSIBILITY FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT
RESULTS FROM THE DOWNLOAD OF ANY CONTENT, MATERIALS, INFORMATION OR SOFTWARE.
NOTWITHSTANDING THE ABOVE, LEGALZOOM OFFERS A 60 DAY SATISFACTION GUARANTEE, THE TERMS OF WHICH ARE AVAILABLE
HERE. THIS DISCLAIMER OF WARRANTY DOES NOT APPLY TO THE PURCHASE OF PRODUCTS OR SERVICES BY NORTH CAROLINA
CONSUMERS.
10. LIMITATION OF LIABILITY AND INDEMNIFICATION. EXCEPT AS PROHIBITED BY LAW, YOU WILL HOLD LEGALZOOM AND ITS
OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS HARMLESS FOR ANY INDIRECT, PUNITIVE, SPECIAL, INCIDENTAL, OR
CONSEQUENTIAL DAMAGE, HOWEVER IT ARISES (INCLUDING ATTORNEYS' FEES AND ALL RELATED COSTS AND EXPENSES OF
LITIGATION AND ARBITRATION, OR AT TRIAL OR ON APPEAL, IF ANY, WHETHER OR NOT LITIGATION OR ARBITRATION IS INSTITUTED),
WHETHER IN AN ACTION OF CONTRACT, NEGLIGENCE, OR OTHER TORTIOUS ACTION, OR ARISING OUT OF OR IN CONNECTION WITH
THIS AGREEMENT, INCLUDING WITHOUT LIMITATION ANY CLAIM FOR PERSONAL INJURY OR PROPERTY DAMAGE, ARISING FROM THIS
AGREEMENT AND ANY VIOLATION BY YOU OF ANY FEDERAL, STATE, OR LOCAL LAWS, STATUTES, RULES, OR REGULATIONS, EVEN IF
LEGALZOOM HAS BEEN PREVIOUSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. EXCEPT AS PROHIBITED BY LAW, IF THERE IS
LIABILITY FOUND ON THE PART OF LEGALZOOM, IT WILL BE LIMITED TO THE AMOUNT PAID FOR THE PRODUCTS AND/OR SERVICES,
AND UNDER NO CIRCUMSTANCES WILL THERE BE CONSEQUENTIAL OR PUNITIVE DAMAGES. SOME STATES DO NOT ALLOW THE
EXCLUSION OR LIMITATION OF PUNITIVE, INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE PRIOR LIMITATION OR EXCLUSION MAY
NOT APPLY TO YOU. THIS PARAGRAPH DOES NOT APPLY TO NORTH CAROLINA CONSUMERS.
11. Unsolicited Submissions. Except as may be required in connection with your use of LegalZoom Services, LegalZoom does not want you to
submit confidential or proprietary information to us through this Site or any Applications. All comments, feedback, information or material submitted to
LegalZoom through or in association with this Site shall be considered non-confidential and LegalZoom's property. By providing such submissions to
LegalZoom you hereby assign to LegalZoom, at no charge, all worldwide right, title and interest in and to the submissions and any intellectual property
rights associated therewith. LegalZoom shall be free to use and/or disseminate such submissions on an unrestricted basis for any purpose. You
acknowledge that you are responsible for the submissions that you provide, including their legality, reliability, appropriateness, originality and content.
12. Compliance with Intellectual Property Laws. When accessing LegalZoom or using the LegalZoom legal document preparation Service, you
agree to obey the law and you agree to respect the intellectual property rights of others. Your use of the Service and the Site is at all times governed
by and subject to laws regarding copyright, trademark and other intellectual property ownership. You agree not to upload, download, display, perform,
transmit or otherwise distribute any information or content in violation of any third party's copyrights, trademarks or other intellectual property or
proprietary rights. You agree to abide by laws regarding copyright ownership and use of intellectual property, and you shall be solely responsible for
any violations of any relevant laws and for any infringements of third party rights caused by any content you provide or transmit or that is provided or
transmitted using your LegalZoom user account.
LegalZoom has adopted a policy that provides for the immediate removal of any content, article or materials that have infringed on the rights of
LegalZoom or of a third party or that violate intellectual property rights generally. LegalZoom's policy is to remove such infringing content or materials
and investigate such allegations immediately.
Copyright Infringement:
1. Notice. LegalZoom has in place certain legally mandated procedures regarding allegations of copyright infringement occurring on the Site or with the Service. The
Company has adopted a policy that provides for the immediate suspension and/or termination of any Site or Service user who is found to have infringed the rights of
the Company or of a third party, or otherwise violated any intellectual laws or regulations. The Company's policy is to act expeditiously upon receipt of proper
notification of claimed copyright infringement to remove or disable access to the allegedly infringing content. If you have evidence, know, or have a good faith belief
that your rights or the rights of a third party have been violated and you want the Company to delete, edit, or disable the material in question, you must provide the
Company with the following information in writing (see 17 U.S.C 512(c)(3) for further detail): (1) A physical or electronic signature of a person authorized to act on
behalf of the owner of an exclusive right that is allegedly infringed; (2) Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted
works at a single online site are covered by a single notification, a representative list of such works at that site; (3) Identification of the material that is claimed to be
infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled and information reasonably sufficient to permit the
service provider to locate the material; (4) Information reasonably sufficient to permit the Company to contact you, such as an address, telephone number, and, if
available, email address; (5) A statement that you have a good faith belief that use of the material in the manner complained of is not authorized by the copyright
owner, its agent, or the law; and (6) A statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on
behalf of the owner of an exclusive right that is allegedly infringed.
The above written information must be sent to our registered Copyright Agent:
General Counsel
c/o LegalZoom.com, Inc.
101 North Brand Blvd., 11th Floor
Glendale, CA 91203
mailto:copyrightagent@legalzoom.com
2. Counter-Notice. If you believe that your Content that was removed (or to which access was disabled) is not infringing, or that you have the authorization from the
copyright owner, the copyright owner's agent, or pursuant to the law, to post and use the material in your Content, you may send a written counter-notice containing
the following information to the Copyright Agent: (1) Your physical or electronic signature; (2) Identification of the Content that has been removed or to which access
has been disabled and the location at which the Content appeared before it was removed or disabled; (3) A statement that you have a good faith belief that the
Content was removed or disabled as a result of mistake or a misidentification of the Content; and (4) Your name, address, telephone number, and email address, a
statement that you consent to the jurisdiction of the federal court in Austin, Texas, and a statement that you will accept service of process from the person who
provided notification of the alleged infringement. If a counter-notice is received by the Copyright Agent, the Company may send a copy of the counter-notice to the
original complaining party informing that person that it may replace the removed Content or cease disabling it in 10 business days. Unless the copyright owner files
an action seeking a court order against the Content provider, member or user, the removed Content may be replaced, or access to it restored, in 10 to 14 business
days or more after receipt of the counter-notice, at the Company's sole discretion.
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13. Inappropriate Content. When accessing the Site, any Applications, or using LegalZoom's Services, you agree not to upload, download, display,
perform, transmit or otherwise distribute any content that: (i) is libelous, defamatory, obscene, pornographic, abusive or threatening; (b) advocates or
encourages conduct that could constitute a criminal offense, give rise to civil liability or otherwise violate any applicable local, state, national or foreign
law or regulation; or (c) advertises or otherwise solicits funds or is a solicitation for goods or services. LegalZoom reserves the right to terminate or
delete such material from its servers. LegalZoom will cooperate fully with any law enforcement officials or agencies in the investigation of any violation
of these Terms of Use or of any applicable laws.
14. Compliance with Export Restrictions. You may not access, download, use or export the Site, Applications, or the Materials in violation of United
States export laws or regulations or in violation of any other applicable laws or regulations. You agree to comply with all export laws and restrictions
and regulations of any United States or foreign agency or authority and to assume sole responsibility for obtaining licenses to export or re-export as
may be required. You acknowledge and agree that the Materials are subject to the United States Export Administration Laws and Regulations and
agree that none of the Materials or any direct product therefrom is being or will be acquired for, shipped, transferred or re-exported, directly or
indirectly, to proscribed or embargoed countries or their nationals or used for any prohibited purpose.
15. Personal Use. The site is made available for your personal use on your own behalf.
16. Children. Minors are not eligible to use the Site or Applications and we ask that they do not submit any personal information to us.
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12/14/2017 How LegalZoom
Case 5:17-cv-07194-NC Provides Businesses
Document 10-1 FiledWith Affordable
01/02/18 Legal Assistance
Page 116 of 192
 / Tech / #CuttingEdge
OCT 9, 2017 @ 12:30 PM 1,240 
How LegalZoom Provides Businesses With

Affordable Legal Assistance
Amit Chowdhry, CONTRIBUTOR

I cover noteworthy technology, startups and gadgets FULL BIO 
Opinions expressed by Forbes Contributors are their own.
When you are running a business, it can be a challenge to handle some of the nitty
gritty details such as filing trademarks and handling copyright protections.
LegalZoom simplifies those processes by providing legal help and services for only
$300 per year, depending on your legal plan.
By providing substantial value at a low cost, LegalZoom CEO John Suh told me that
nearly 4 million small businesses and families have trusted the company since it
launched in 1999. And LegalZoom is the largest former of small businesses, the
largest filer of trademarks at 250,000+ and the company’s network of independent
attorneys can provide advice in all 50 states. Plus LegalZoom owns a law firm in the
U.K. with over 200 employees.
https://www.forbes.com/sites/amitchowdhry/2017/10/09/how-legalzoom-provides-businesses-with-affordable-legal-assistance/#2a33959432de 1/4
Page 117 of 192
LegalZoom
Page 118 of 192
LegalZoom CEO John Suh
Suh said that LegalZoom was founded on the principle that access to quality legal
help is a basic fundamental right. Suh told me that the majority of Americans “have
a doctor they can turn to when life throws them a curve ball.” However, only the top
5% of small business owners or families have a law firm that they can reach out to at
a moment’s notice. “We believe in a world where everyone has a trusted lawyer,
someone who can not only handle the unexpected but proactively help to protect the
things people value the most,” said Suh in an interview.
LegalZoom started with only $1 million in angel funding. “I’m most proud of the
human potential we’ve been able to unlock within our team of Zoomers. We’ve
created a team focused on continuous learning, and we execute with a creative,
strategic mindset. Realizing that evolution is a collaborative effort and minimizing
fear of failure has allowed us to be nimble in an industry known for stagnancy,”
added Suh in the interview.
Suh described himself as a “supply chain geek,” who has been fascinated by how
technology would transform manufacturing and distribution across many
industries. Over the last 20 years, Suh has run Internet companies that had
interesting supply chain approaches to the fashion, consumer electronics, and legal
industries. Prior to heading up LegalZoom, Suh was the CEO of the Internet division
of Li and Fung called StudioDirect. And before that, he co-founded and worked as
CEO of Castling Group.
Recommended by Forbes

Three Things To Consider Before Using
Top 5 Digital Transformation Trends In Legal Legal Templat...
LegalZoom Customers
I asked Suh if he could share any interesting stories about LegalZoom customers. A
couple of customers that came to mind included GORUCK and Chi’Lantro.
GORUCK is a rugged backpack brand and Chi’Lantro Korean Mexican fusion mobile
truck company.
Page 119 of 192
GORUCK was started by a former 10th Special Forces staff sergeant named Jason
McCarthy. McCarthy was unemployed, nearly broke, recently divorced and was
having a hard time adapting to civilian life. McCarthy said that the only thing
keeping him going was Java, his chocolate Labrador dog. When McCarthy thought
about the heavy-duty survival packs that his fellow soldiers carried around in Iraq as
an exercise called “rucking,” a lightbulb in his head turned on. McCarthy founded
GORUCK and turned to LegalZoom for legal help. GORUCK pulled in total revenues
of $15 million in equipment sales and live events last year. And McCarthy now gives
back to the military community by hiring veterans at GORUCK and his nonprofit
Java Forever in memory of his first chocolate lab dog.
Chi’Lantro was founded by Jae Kim, who immigrated from Seoul to the U.S. at age
12. As of seven years ago, Jim had $30,000 in savings and a maxed out credit card.
With his savings, he decided to purchase a food truck and established a Korean
Mexican fusion mobile truck company called Chi'Lantro. As the son of a single
mother, Kim often spent time cooking while he mom was at work. To launch his
company, Kim turned to LegalZoom to help set up an LLC. Even though Chi'Lantro
had a slow start in Austin, Texas, he was able to raise $600,000 from Barbara
Corcoran on the TV show Shark Tank. Now Chi’Lantro has 4 locations in Austin,
Texas and there are plans to expand in Dallas, Houston and San Antonio.
“We literally have millions of conversations each year with small business owners.
Drive and passion are recurring themes. Business owners want to take care of legal
matters quickly and efficiently so they can get back to the all-consuming job of
running their business,” explained Suh.
What are your thoughts about LegalZoom? Have you utilized their services before?
Please leave a comment!
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EXHIBIT R
e 5:17-cv-07194-NC Document 10-1 Filed 01/02/18 Page 137 of
EXHIBIT S
12/1/2017 Attorney-Led
Case Trademark Registration
5:17-cv-07194-NC - Register a Trademark
Document and File01/02/18
10-1 Filed Your TrademarkPage
Application
139Online | LegalZoom
of 192
Customer Care: (855) 525-3087
Log Out My Account Help  
Starting Your Business  Running Your Business  Wills & Trusts  Personal & Family 
Home ▸ Business ▸ Intellectual Property
Attorney-Led Trademark Registration
For your mark. Get set

with an attorney. Go.
Enlist an experienced attorney so that you have the freedom to run your
business.
Start my trademark application
No hourly rates. Just one flat fee.

* **
$799 + government filing fee
See details
Here's why
It's about a proven record It's about a united effort It's about your rights
With an attorney's legal knowledge and about a We're in this together. Your trademark team will be You owe it to yourself. With a registered trademark,
quarter-million trademark applications under our belt, there for you during the trademark search, filing, and you'll have rights to use and protect it across the U.S.
you have experience on your side. monitoring phases.
Why do I need a comprehensive search? Why do I need an attorney to analyze my search

results?
If you're currently using or planning to use a trademark, it's always a good idea to see if
there are similar marks that could be confused with yours, or might affect your ability to
Your search results can be hundreds of pages long, and determining whether a conflict
register, use or protect your trademark. Similar marks don't have to be registered with exists requires a multi-factor analysis that isn't always straightforward. It can be vital to
the USPTO to affect your ability to use your trademark, making it important to conduct a have an experienced trademark attorney carefully analyze your search results and
comprehensive search that includes common law marks that are being used by advise you on the strength of your mark, to help guide your application and steer you
businesses across the country. Our dedicated Comprehensive Search team leverages
clear of infringement lawsuits.
their experience to uncover potential federal and common law conflicts and set you up
for success.
Here's how
Tell us about your goals Review your application Get the support you need
We'll contact you to learn more about your product or Once an attorney has reviewed your information and Your team will be there to answer your questions,
service and then begin a comprehensive trademark prepared your trademark application, he/she will send monitor the progress of your application, and take
search of other U.S. marks that might pose a conflict. it to you to approve. action when necessary.
Get started today

Save 30%
Attorney-Led
Trademark Registration
$
799*
+ government filing fee**
Regular price $1,145
Package Details:
Trademark consultation
Comprehensive Search - Federal and

common law
($299 value)
Analysis of your trademark search results

($299 value)
Preparation and filing of your application

($299 value)
Monitoring of your application status

($49 value)
Response to a basic Office action

($199 value)
https://www.legalzoom.com/business/intellectual-property/trademark-registration-overview-a.html?gclid=CIr1w9_u7s4CFVRwvAodJXsEHQ 1/2
10-1 Filed Your TrademarkPage
Application
140Online | LegalZoom
of 192
Have questions? We have answers.
Common questions A specialist is here to help
 What if I don't have a registered trademark? What can happen?

 Why choose a federal over a state trademark? (855) 525-3087
 What is an Office action and how does it affect an application?
We're available Mon-Fri 8am to 5pm PT
 What are trademark classes and why are they important? Our agents are based in the United States.
Register your trademark now

*
Price includes one class. Search fees for additional classes will apply. Your attorney can advise whether additional classes are recommended.
**
Consists of the government discounted TEAS RF electronic filing fee of $275. If the stricter "TEAS Plus" system can be used for your application, you will be refunded $50 to account for
the lower filing fee of $225. The USPTO may later charge a $125 fee should you choose not to communicate with them electronically or otherwise do not meet the requirements of the
discounted TEAS RF or TEAS Plus filing requirements.
ATTORNEY ADVERTISEMENT: This portion of the LegalZoom website is an advertisement for legal services. LegalZoom does not endorse or recommend any lawyer or law firm who
advertises on our site. The law firm responsible for this advertisement is LegalZoom Legal Services Ltd. LegalZoom Legal Services Ltd. is authorized and regulated by the Solicitors
Regulation Authority. SRA ID 617803. LegalZoom Legal Services Ltd. is a subsidiary of LegalZoom.com, Inc.

Blog
LegalZoom provides access to independent attorneys and self-help services at your specific direction. We are not a law firm or a substitute for an attorney or law
firm. We cannot provide any kind of advice, explanation, opinion, or recommendation about possible legal rights, remedies, defenses, options, selection of forms ABOUT SSL CERTIFICATES
or strategies. Your access to the website is subject to our Terms of Use.
View Site Directory
https://www.legalzoom.com/business/intellectual-property/trademark-registration-overview-a.html?gclid=CIr1w9_u7s4CFVRwvAodJXsEHQ 2/2
10-1 Filed Your Trademark Application
Page 141Online | LegalZoom
of 192
Home ▸ Business ▸ Intellectual Property
Attorney-Led Trademark Registration
For your mark. Get

set with an
attorney. Go.
Enlist an experienced attorney so that you have the freedom to
run your business.
No hourly rates. Just one flat fee.

* **
$599 + government filing fee
See details
Here's why
It's about a proven record It's about a united effort It's about your rights
With an attorney's legal knowledge and about We're in this together. Your trademark team will You owe it to yourself. With a registered
a quarter-million trademark applications under be there for you during the trademark search, trademark, you'll have rights to use and protect
our belt, you have experience on your side. filing, and monitoring phases. it across the U.S.
Why do I need a comprehensive search? Why do I need an attorney to analyze my

search results?
If you're currently using or planning to use a trademark, it's always a good
idea to see if there are similar marks that could be confused with yours, or
Your search results can be hundreds of pages long, and determining whether
might affect your ability to register, use or protect your trademark. Similar
a conflict exists requires a multi-factor analysis that isn't always
marks don't have to be registered with the USPTO to affect your ability to
straightforward. It can be vital to have an experienced trademark attorney
use your trademark, making it important to conduct a comprehensive search
carefully analyze your search results and advise you on the strength of your
that includes state databases and common law marks that are being used by
mark, to help guide you application and steer you clear of infringement
businesses across the country. Our dedicated Comprehensive Search team
lawsuits.
leverages their experience to uncover potential federal, state, and common
law conflicts and set you up for success.
Here's how
https://www.legalzoom.com/business/intellectual-property/trademark-registration-overview-c.html?utm_source=abandoner&utm_medium=email&utm_c… 1/4
of 192
Tell us about your goals Review your application Get the support you need
We'll contact you to learn more about your Once an attorney has reviewed your Your team will be there to answer your
product or service and then begin a information and prepared your trademark questions, monitor the progress of your
comprehensive trademark search of other U.S. application, he/she will send it to you to application, and take action when necessary.
marks that might pose a conflict. approve.
Get started today

Save 48%
Attorney-Led
$
599*
+ government filing fee**
Regular price $1,145
Package Details:
Trademark consultation
Comprehensive Search - Federal, state

and common law
($299 value)
Analysis of your trademark search results

($299 value)
Preparation and filing of your application

($299 value)
Monitoring of your application status

($49 value)
Response to a basic Office action

($199 value)
Common questions A specialist is here to help
 What if I don't have a registered trademark? What can happen?

 Why choose a federal over a state trademark? (855) 525-3087
 What is an Office action and how does it affect an application?
We're available Mon-Fri 8am to 5pm PT
of 192
 What are trademark classes and why are they important? Our agents are based in the United States.
Register your trademark now

*
Price includes one class. Search fees for additional classes will apply. Your attorney can advise whether additional classes are recommended.
**
Consists of the government discounted TEAS RF electronic filing fee of $275. If the stricter "TEAS Plus" system can be used for your application, you will be
refunded $50 to account for the lower filing fee of $225. The USPTO may later charge a $125 fee should you choose not to communicate with them electronically or
otherwise do not meet the requirements of the discounted TEAS RF or TEAS Plus filing requirements.
ATTORNEY ADVERTISEMENT: This portion of the LegalZoom website is an advertisement for legal services. LegalZoom does not endorse or recommend any
lawyer or law firm who advertises on our site. The law firm responsible for this advertisement is LegalZoom Legal Services Ltd. LegalZoom Legal Services Ltd. is
authorized and regulated by the Solicitors Regulation Authority. SRA ID 617803. LegalZoom Legal Services Ltd. is a subsidiary of LegalZoom.com, Inc.

Blog
An offer of membership in our legal plan is not an endorsement or advertisement for any individual attorney. The legal plan is available in
most states.
EXHIBIT T
12/1/2017 Do You
Case 5:17-cv-07194-NC Need a Lawyer
Document to File aFiled
10-1 Trademark? | LegalZoom
01/02/18 Page 145 of 192
Do You Need a Lawyer to File a Trademark?

by Jane Haskins, Esq.
Freelance writer
You can search for existing trademarks and prepare and file a trademark application using
online tools on the U.S. Patent and Trademark Office (USPTO) website or through another
online trademark service—without the assistance of a lawyer.
While the application process can be done on your own, there are certain procedures and
formatting requirements that you must follow, and you must choose the correct filing basis
and description for your products or services. If your application is not prepared properly, it
may be refused or delayed.
When You Need a Lawyer
In some instances, it is a good idea to consult with a lawyer, either before, during or after the
trademark registration process. Reasons to contact a lawyer include:
You have conducted a trademark search and are concerned that there might be a
likelihood of confusion between your mark and another mark that is already registered or
for which there is a pending registration application. A trademark lawyer can advise you
on the chances that your trademark application will be refused due to confusion with the
competing mark or can help you revise your application so it will be more likely to gain
approval.
You have questions about trademarks or trademark registration that are not answered by
the USPTO website or other online resources.
You anticipate filing foreign trademarks as well as a U.S. trademark and you want
assistance from someone with expertise in foreign trademark laws.
You need to respond to a refusal to register or an Office action.
You believe that someone else is using your trademark without your permission.
Trademark owners are responsible for enforcing their trademarks. Failure to protect your
trademark can lead to assumptions that the owner has abandoned the mark or consented,
even informally, to its misuse. A lawyer can explain your rights and advise you on how to
respond to a possible infringement and, if necessary, file a lawsuit on your behalf.
Want toaccused
You are protect your big
of trademark idea? We
infringement. can
Often, anshow you
accusation willbest practices.
come in the form of
a cease and desist letter asking you to stop using the mark and threatening legal action if
you do not. A lawyer can evaluate the letter and advise you on how to respond.
EMAIL ADDRESS
Finding a Trademark Lawyer
https://www.legalzoom.com/articles/do-you-need-a-lawyer-to-file-a-trademark 1/4
12/1/2017 Do You
01/02/18 Page 146 of 192
If you do decide to hire a lawyer, you should look for someone who has experience
conducting and evaluating trademark searches, filing applications with the USPTO, and
enforcing trademark rights. Finding an attorney who has worked on trademarks in your
particular industry may also be important, as there may be industry-specific knowledge that
will help your application get accepted more easily. You will also want to make sure that the
attorney will be the one handling your application, and that they won’t be passing it off to a
paralegal.
In searching for a trademark attorney, you may come across businesses that offer services
for trademark applications that are less expensive. However, it is highly advised that you hire
a licensed attorney, as she will be more knowledgeable regarding trademark laws.
The USPTO does not recommend attorneys or provide lists of attorneys. Your local bar
association may have a directory of attorneys or a lawyer referral service that can help you
find a lawyer with expertise in trademark matters.
Ready to register a trademark? LegalZoom can help. LegalZoom's attorney-led trademark

registration services allow you to register a trademark with the help of an attorney. With
attorney-led trademark services, an attorney will contact you to learn more about your
product or service and begin a comprehensive trademark search. Once an attorney has
reviewed your information and prepared your trademark application, he/she will send it to
you to approve. Your team of attorneys will be there to answer your questions, monitor the
progress of your application, and take action when necessary.
Make sure your work is protected
START MY REGISTRATION
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EXHIBIT U
12/1/2017 LegalZoom
Case 5:17-cv-07194-NC | Trademark Registration
Document 10-1 Filed & Trademark Search Services
01/02/18 Page 151 of 192
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We've done this a thousand times (about 220,000 times, actually), and have crafted a questionnaire to
help make the application process easier for you.
We look out for you

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12/1/2017 LegalZoom
01/02/18 Page 152 of 192
Before we submit your application, we do a basic trademark search and inform you of any direct
conflicts so your brand has a better chance of succeeding.
We know where to go
Once your application is done, we’ll get it into the right hands at the U.S. Patent & Trademark Office, so
all you have to do is wait for their response.
What is a trademark?
A trademark typically protects names, words, slogans and symbols that identify a business or brand and distinguishes it
from others. Trademarks include brand names such as "Coca-Cola" and symbols such as Nike's famous "swoosh."
Learn more
What are the benefits of registering a trademark?
Federal registration provides several advantages, including giving you a legal presumption of ownership and exclusive
rights to use the mark nationwide in connection with your goods or services. It also gives you the right to bring a federal suit
against anyone who may be infringing on your mark, and allows you to use the coveted ® symbol.
Learn more
What can you trademark?
A name, such as your company's name or a line of products.

A logo or other symbol or design used to create brand recognition.
A slogan or other phrase used in connection with your brand.
What can't you trademark?

A creative work such as a book, film, song, or theatrical performance is generally protected by a copyright.
An invention, mechanical device, business method, or process is generally protected by a utility patent.
An idea itself can't be protected, though it may be eligible for a copyright or patent once it's manifest in tangible form.
Copyright, trademark and patent: what's the difference?
12/1/2017 LegalZoom
01/02/18 Page 153 of 192
How it works
For a more detailed view of the trademark process, and details on government processing times, click here.
1. Complete our trademark registration questionnaire.
2. We search the federal trademark database for direct conflicts.
3. Once documents are signed, we file your application with the USPTO.
Get started today
Basic
$
199
Filing
We file your trademark application with the U.S. Patent and Trademark Office
(USPTO)
Basic trademark search
12/1/2017 LegalZoom
01/02/18 Page 154 of 192
We perform a basic federal direct-hit search of the federal trademark database for direct conflicts with
your trademark
Discount on comprehensive trademark search

If you need a more thorough search for similar, competing marks.
Peace of Mind Review™

Digitalization, color adjustment and compilation of your trademark specimens and designs
Email delivery of your trademark application
View More
Start my Trademark Registration
Best Value
Complete
$
219
Includes everything from the Basic package, plus:
Cease and Desist Letter Package
(a $14.95 value)
Trademark Assignment Agreement

Enables the trademark owner to transfer trademark rights or ownership to another individual or entity.
Electronic copy of your trademark application, available to download in your

account.
Business Advisory Plan – 30-day trial*
View More
Ask away. We have answers.
Common questions
12/1/2017 LegalZoom
01/02/18 Page 155 of 192
 What's the difference between a copyright and a trademark?
 What's included in a trademark search?
 How long does it take for a trademark to be registered?
A specialist is here to help
(866) 679-2319
We're available Mon-Fri 5am-7pm PT,
Weekends 7am-4pm PT
Our agents are based in the United States.
Speak with an attorney
Get legal advice from an independent

attorney at a price you can afford.
Find out more
Questions and answers
This public forum is not intended to provide legal advice and is not a substitute for professional legal
advice. Unless specifically indicated, the content is not drafted, supported, or vetted by LegalZoom.
It is simply a place for customers to help customers. If you need legal advice, LegalZoom can
connect you to a licensed and independent attorney. If you are providing answers, please do not
provide legal advice if you are not qualified or licensed to do so.
Protect your trademark now
Don’t leave your brand at risk.
12/1/2017 LegalZoom
01/02/18 Page 156 of 192
Apply for Trademark Registration with LegalZoom
A federally registered trademark can protect your brand nationwide. By trademarking a business name, logo,
company phrase or other slogan with the U.S. Patent and Trademark Office (USPTO), you establish a legal
presumption of ownership and an exclusive right to use the trademark nationwide. Federal trademark
registration lists your trademark in the USPTO’s online databases and allows you to use the ® symbol, which
essentially notifies the public that you own the trademark. Trademark registration also allows the trademark
owner to bring action against infringers in federal court. In just a few simple steps, LegalZoom can help you create
and file a trademark application with the USPTO. The process begins by answering a few questions and
providing a sample of your mark. We perform a trademark search, create your trademark application, and file
the application with the USPTO. The USPTO will review your application and make a decision whether to approve
it or not and you will be notified of their decision. Start protecting your brand by applying to register a trademark
through LegalZoom today.
*Telephone consultations with a participating firm, during normal business hours, of up to one half (1/2) hour each, limited to
one consultation for each new legal matter. After the 30-day trial period, benefits to the Business Legal Plan (also Business
Advantage Pro or Business Advisory Plan) continue automatically at the plan rate (currently $39.99 per month). Cancel by
calling (877) 818-8787. For full details, see the Legal Plan Contract and Subscription Terms.
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An offer of membership in our legal plan is not an endorsement or advertisement for any
individual attorney. The legal plan is available in most states.
Disclaimer: Communications between you and LegalZoom are protected by our Privacy
Policy but not by the attorney-client privilege or as work product. LegalZoom provides
access to independent attorneys and self-help services at your specific direction. We are
not a law firm or a substitute for an attorney or law firm. We cannot provide any kind of
advice, explanation, opinion, or recommendation about possible legal rights, remedies,
defenses, options, selection of forms or strategies. Your access to the website is subject
to our Terms of Use.
View Site Directory
ABOUT SSL CERTIFICATES
EXHIBIT V
11/30/2017 Trademark Pricing
Case 5:17-cv-07194-NC Packages - Trademark
Document 10-1 Application Fees and Costs
Filed 01/02/18 Page| LegalZoom
159 of 192
Home ▸ Business ▸ Intellectual Property ▸ Trademark
Trademark Registration pricing
Unlike simple do-it-yourself forms, LegalZoom provides a personal review of your work for completeness and
consistency after you create your document through the LegalZip® system.* Along
You get lifetime customer support and our 100% satisfaction guarantee. Bestwith a series of automated
Value
checks, our document scriveners personally review the answers you provide for the following**:
Compare our Complete information. We'll contact you by phone and email regarding any missing information.
Basic Complete Coverage
Our most economical
Spelling andpackage All-inclusive
checkers. package
Trademark Registration punctuation. We do not rely solely on software spell
packages and pricing

$
199
Correct capitalization and lowercasing where required.
$
219
1
+ Federal Filing
Proper Fee
pagination and blank space elimination. + Federal Filing Fee1
Complete words. We spell out abbreviations or symbols in English where appropriate.

Get Started Get Started
Correct residency information. Indicating the proper state is critical to ensure the document conforms to
your state's requirements.
Full names. We verify that full names are given (first and last) and that all names appear consistently
Filing of trademark application with the United throughout the document.
States Patent and Trademark Office (USPTO)
* Not available in Missouri
A basic federal direct-hit search of the federal ** Not all products are checked for all elements. Trademark art, for example, often includes different spelling,
trademark database for direct conflicts with capitalization, abbreviations, etc. that are intentional. So for this product, these elements would not be reviewed.
your trademark2 (a $75.00 value) or a discount
on our Comprehensive Trademark Search
Package
LegalZoom Peace of Mind Review™
Digitalization, color adjustment and

compilation of your trademark specimens and
designs
Email delivery of your trademark application
Electronic copy of your trademark application,

available to download in your account.
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12/1/2017 Trademark PricingDocument
10-1 Application Fees and Costs
Filed 01/02/18 | LegalZoom
Page 160 of 192
Home | Business | Intellectual Property | Trademark
Trademark Registration Pricing
No matter which option you choose, Trademark with Attorney Help Trademark
you'll always have our support: Flat fee Starts at
$599
+ federal filing fee1
$199
+ federal filing fee2
Before filing
Trademark Search
Your search will look for possible conflicts that affect your Comprehensive search Basic search
ability to register your trademark ($299 value) ($75 value)
Trademark Application & Filing

Based on the information you provide, your application and
supporting materials will be filed with the U.S. Patent &
Trademark Office (USPTO)
Trademark Paperwork
You’ll get a digital copy of your application for your records
Trademark Consultations
You'll speak with a trademark specialist and independent ($299 value)
trademark attorney who will discuss your trademark with you
before completing and filing your application with the USPTO
Trademark Search Analysis

Your trademark attorney will review and analyze your search ($299 value)
results to advise if any pre-existing trademark could cause
your application to be denied or lead to other legal issues.
Additional Trademark Search

If the trademark attorney discovers any direct conflicts,
another search on a new or different mark is included.
After filing
Trademark Application Tracking

A trademark attorney will track the progress of your
application with the USPTO
Basic Office Action Response ($199 value)

A trademark attorney will respond to a basic Office action if
the USPTO rejects your application and needs more
information
START WITH AN ATTORNEY START MY APPLICATION
How it works
1 2 3 4
APPLICATION PREPARATION TRADEMARK SEARCH FILING TRACKING & RESPONDING
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12/1/2017 Trademark PricingDocument
10-1 Application Fees and Costs
Filed 01/02/18 | LegalZoom
Page 161 of 192
We’ll perform a trademark search Need more help?
Searching for marks that may be similar to yours is important. When you select our trademark service with attorney help, you
Knowing how to interpret the results is even more so. We have get a comprehensive search and your trademark attorney will
basic and comprehensive search options so you can see if there analyze the results and advise on what to do next. If the attorney
are any pre-existing marks that could lead to the denial of your discovers any direct conflicts, another search on a new or
application or other legal issues. different mark is included.
Here are some commonly asked questions A specialist is here to help
 What can happen if I don't have a registered trademark?

 What are trademark classes and why are they important? (855) 525-3087
 How long does it take for a trademark to be registered?
We're available Mon-Fri 8am-5pm PT
 What is an Office action and how does it affect an application? Our agents are based in the United States.
1
Consists of the government discounted TEAS RF electronic filing fee of $275. If the stricter "TEAS Plus" system can be used for your application, you will be refunded $50 to account for the lower
filing fee of $225. The USPTO may later charge a $125 fee should you choose not to communicate with them electronically or otherwise do not meet the requirements of the discounted TEAS RF or
TEAS Plus filing requirements.
2
Consists of the government discounted TEAS RF electronic filing fee of $275. If the stricter "TEAS Plus" system can be used for your application, LegalZoom will use this system. The TEAS Plus system streamlines
the U.S. Patent and Trademark Office (USPTO) review process and has a lower filing fee of $225, but requires additional LegalZoom labor to process. If the TEAS Plus system can be used for your application,
LegalZoom will still charge $275, of which $225 will be allocated to the USPTO fee and $50 to a LegalZoom processing fee. The USPTO may later charge a $125 fee should you choose not to communicate with them
electronically or otherwise meet the requirements of the discounted TEAS RF or TEAS Plus filing fees.
ATTORNEY ADVERTISEMENT: This portion of the LegalZoom website is an advertisement for legal services. LegalZoom does not endorse or recommend any lawyer or law firm who advertises on our site. The law
firms responsible for this advertisement are LegalZoom Legal Services Ltd. and Dunlap Bennett & Ludwig PLLC. LegalZoom Legal Services Ltd. is authorized and regulated by the Solicitors Regulation Authority. SRA ID
617803. LegalZoom Legal Services Ltd. is a subsidiary of LegalZoom.com, Inc.

Blog
LegalZoom provides access to independent attorneys and self-help services at your specific direction. We are not a law firm or a substitute for an attorney or law
firm. We cannot provide any kind of advice, explanation, opinion, or recommendation about possible legal rights, remedies, defenses, options, selection of forms ABOUT SSL CERTIFICATES
or strategies. Your access to the website is subject to our Terms of Use.
View Site Directory
https://www.legalzoom.com/business/intellectual-property/trademark-registration-pricing-a.html 2/2
EXHIBIT W
12/12/2017 Case 5:17-cv-07194-NCTrademark/Service
Document 10-1 Mark Application, Principal Register
Filed 01/02/18 Page 163 of 192
Trademark Electronic Application System - TEAS Application
Under the Paperwork Reduction Act of 1995 no persons are required to respond to a collection of information unless it displays a valid OMB control number.
PTO Form 1478 (Rev 09/2006)
OMB No. 0651-0009 (Exp. 02/28/2018)
Trademark/Service Mark Application, Principal Register

Version 5.10 - Validation Page
On Tue Dec 12 15:31:07 EST 2017 You completed all mandatory fields and successfully validated the form. It has NOT been filed to the USPTO at this
point. Please complete all steps below to submit the application.
NOTE:For an instructional video on the Validation Page, click here.

STEP 1: Review the application data in various formats, by clicking on the phrases under Application Data. Use the print function within your browser to print
these pages for your own records. If the Mark and Specimens appear huge, click here.
Note: It is important that you review this information for accuracy and completeness now. Corrections after submission may not be permissible, thereby possibly
affecting your legal rights.
Note: If you are using the e-signature approach or the handwritten pen-and-ink signature approach, you must click on the final link to access the specific "text form"
for that purpose.
Application Data
Input Mark XML File Text Form for E-Signature
STEP 2: If there are no errors and you are ready to file this application electronically, confirm the e-mail address for acknowledgment. Once you submit the form
electronically, we will send an electronic acknowledgment of receipt to the e-mail address entered below. If no e-mail address appears, you must enter one. If we
should send the acknowledgment to a different e-mail address, or to an additional address(es), please enter the proper address or additional address(es). For multiple
addresses/receipts, please separate e-mail addresses by either a semicolon or a comma.
NOTE: This e-mail address is only for the purpose of receiving the acknowledgment that the transmission reached the USPTO, and is not related to the e-mail that will be used for correspondence purposes
(although it could be the same address. The official e-mail address that the USPTO will use for any future communication is whatever appears in the specific correspondence section of the form.)
* E-mail for acknowledgment

To ensure we can deliver your e-mail confirmation successfully, please re-enter your e-mail address(es) here:
* E-mail for acknowledgment
STEP 3: Read and check the following:
Important Notice:
(1) Once you submit this application, we will not cancel the filing or refund your fee. The fee is a processing fee, which we do not refund even if we cannot
issue a registration after our substantive review. This is true regardless of how soon after submission you might attempt to request cancellation of the filing.
Therefore, please review ALL information carefully prior to transmission.
(2) All information you submit to the USPTO at any point in the application and/or registration process will become public record, including your name, phone
number, e-mail address, and street address. By filing this application, you acknowledge that YOU HAVE NO RIGHT TO CONFIDENTIALITY in the
information disclosed. The public will be able to view this information in the USPTO's on-line databases and through internet search engines and other on-line
databases. This information will remain public even if the application is later abandoned or any resulting registration is surrendered, cancelled, or expired. To
maintain confidentiality of banking or credit card information, only enter payment information in the secure portion of the site after validating your form. For any
information that may be subject to copyright protection, by submitting it to the USPTO, the filer is representing that he or she has the authority to grant, and is
granting, the USPTO permission to make the information available in its on-line database and in copies of the application or registration record.
(3) Be aware that private companies not associated with the USPTO often use trademark application and registration information from the USPTO's
databases to mail or e-mail trademark-related solicitations (samples of non-USPTO solicitations included).
If you have read and understand the above notice, please check the box before you click on the Pay/Submit button.
STEP 4: If you are ready to file electronically:

Click on the Pay/Submit button below, to access the site where you will select one of three possible payment methods. After successful entry of payment
information, you can complete the submission to the USPTO. A valid transaction will result in a screen that says SUCCESS! Also, we will send an e-mail
acknowledgment within 24 hours.
WARNING: Click on the Pay/Submit button ONLY if you are now entirely prepared to complete the Pay/Submit process. After clicking the button, you can NOT
return to the form, since you will have left the TEAS site entirely. Once in the separate payment site, you must complete the Pay/Submit process within 30 minutes.
WARNING: Fee payments by credit card may not be made from 2 a.m. to 6 a.m. Sunday, Eastern Standard Time. If you are attempting to file during that specific
period, you must use either the deposit account or electronic funds transfer payment method.
Pay/Submit
Burden/Privacy Statement | TEAS Form Burden Statement
Help Desk | Bug Report | Feedback | TEAS Home | Trademark Home | USPTO
https://teas.uspto.gov/forms/teas.service?form.action=SIGNRES&formId=bas&id=USPTO/BAS-24.5.91.150-20171209150659049380-New/Application-… 1/2
EXHIBIT X
12/12/2017 ApplicantsDocument
Case 5:17-cv-07194-NC and registrants10-1
represented by excluded
Filed 01/02/18parties |Page
USPTO 165 of 192
Applicants and registrants represented by excluded

parties
If the USPTO suspects that a party, whether an individual or a firm, is engaging in unauthorized practice of trademark law or otherwise improper activities
before the USPTO, the Commissioner for Trademarks may issue a show-cause order. A show-cause order requires the party to establish the legitimacy of
their activities and to explain why they should not be excluded from acting on behalf of others before the USPTO. Depending on the party’s response, a
show-cause order may be followed by an exclusion order, which formally excludes the party from serving as an attorney, correspondent, domestic
representative, and/or signatory in trademark matters before the USPTO.
Review copies of show-cause orders and exclusion orders issued by the Commissioner for Trademarks
Get information on unauthorized practice of trademark law and who may practice before the USPTO in trademark matters
Once a party has been excluded, the USPTO will change the correspondence address for each affected application or registration file record to that of the
applicant, registrant, or domestic representative, as appropriate, and will notify the affected applicant or registrant that:
The excluded party is not entitled to practice before the USPTO in trademark matters and, therefore, may not represent the applicant or
registrant.

Any power of attorney granted to the excluded party is void ab initio, meaning it was invalid from the start of any action taken by the excluded
party.

The excluded party may not sign responses to Office actions, authorize examiner’s amendments or priority actions, conduct interviews with
USPTO employees, or otherwise represent an applicant, registrant, or party to a proceeding before the Office.
All correspondence concerning the application or registration will be sent to the domestic representative if one has been appointed, or,
alternatively, and in most circumstances, to the applicant or registrant at its address of record.
What to do if the USPTO excluded the party representing you

(1) Review your application/registration record
Go to the Trademark Status & Document Retrieval (TSDR) system and enter your serial number or registration number to retrieve the record for
your application or registration.
(2) Review your contact information
Once you have retrieved your application/registration record in TSDR, select the “Status” tab and review the Attorney/Correspondence Information
to confirm that the correspondence information is correct.
If the correspondence information is incorrect, correct it by filing a Change of Correspondence Address form. If necessary, you may also change the
owner’s address information, using the Change of Owner’s Address form. Both forms are available at Correspondence and Attorney/Domestic
Representative Forms.
(3) Determine if you are required to file anything
Select the “Documents” tab in TSDR and view the outgoing correspondence from the USPTO in the record to determine if you are required to file
anything in connection with your application or registration, such as a response to an Office action, a statement of use, or a registration maintenance
document.
If your application is still pending and you fail to file a required document before the deadline, your application will be abandoned. If your mark is
already registered, and you fail to submit the required registration maintenance documents on time, your registration will expire or be cancelled. All
required documents may be filed electronically by using the appropriate electronic form in the Trademark Electronic Application System (TEAS).
After your initial review of your application or registration record, continue to monitor the status of your application or registration, using the
“Status” tab in TSDR.
For applications, you should check the status every six months between the filing date of the application and issuance of a registration.

If your mark is already registered and you have filed an affidavit of use or excusable nonuse under §8 or §71 of the Trademark Act, or a
renewal application under §9 of the Act, you should check the status of the registration every six months until you receive notice that the
affidavit or renewal application has been accepted.
https://www.uspto.gov/trademark/trademark-updates-and-announcements/applicants-and-registrants-represented-excluded 1/3
USPTO 166 of 192
Questions?
For pending applications, contact the assigned examining attorney, whose contact information is provided in Office actions sent in
connection with your application. In TSDR, Office actions are identified as “Offc Action Outgoing” in the “Documents” tab. For registrations,
contact the assigned Post Registration specialist, whose contact information will be provided in any Office action sent in connection with
registration maintenance filings, or the Office of Petitions at 571-272-8950.
For general questions about the trademark process, guidance on the type of information required in a particular electronic form, or
information about which USPTO offices or employees to contact for particular issues, contact the Trademark Assistance Center at
571-272-9250, or toll-free at 1-800-786-9199. You can also email TrademarkAssistanceCenter@uspto.gov.
(4) Review all documents previously submitted on your behalf
If your application is still pending, and a registration has not yet issued, you should review any documents submitted on your behalf to confirm that
it was signed by the appropriate party and that all the information in the document is correct. If you believe that any submitted document was
improperly signed or contains incorrect information, you should contact the assigned examining attorney, who can answer questions about the
process for resubmitting documents.
If your mark is already registered and registration maintenance documents have been submitted on your behalf, you should review the documents to
confirm that they contain accurate information and are properly signed. If you have any questions about a registration maintenance document
submitted on your behalf, you may contact the assigned Post Registration specialist whose contact information will be provided in any Office action
sent in connection with registration maintenance filings, or the Office of Petitions at 571-272-8950.
For additional information on who may sign documents submitted to the USPTO in connection with trademark applications and registrations, see
Proper Representation in Trademark Matters and TMEP §§611.03–611.04.
(5) Consider hiring a qualified attorney to represent you
Consider hiring a qualified attorney with expertise in trademark matters to represent you in the application process. While a USPTO trademark
examining attorney will try to help you through the examination process even if you do not hire an attorney, USPTO attorneys are not permitted to
give you legal advice.
A private trademark attorney who is licensed in the United States and is authorized to practice before the USPTO may:
Help you avoid future costly legal problems by conducting a comprehensive search of federal registrations, state registrations, and
"common law" unregistered trademarks before you file your application. Comprehensive searches are important because other trademark
owners may have protected legal rights in trademarks similar to yours that are not federally registered. Therefore, those trademarks will not
appear in our Trademark Electronic Search System database, but they could still ultimately prevent your use of your mark.

Help you during the application process with several things that could seriously impact your trademark rights, such as determining the best
way to describe your goods and services and preparing responses to refusals to register your mark that we may issue.

Assist you after your mark is registered by filing registration maintenance documents and by taking actions to help you police and enforce
your trademark rights. While the USPTO registers trademarks, you, as the trademark owner, are fully responsible for any enforcement of
your private trademark rights.
If you decide to hire an attorney, you should be aware that, under U.S. federal regulations, the only individuals who may represent an applicant or
registrant in trademark matters before the USPTO, other than certain previously authorized trademark agents, are (1) attorneys who are licensed to
practice in the United States and (2) Canadian agents or attorneys who are authorized by the USPTO to represent applicants located in Canada.
Employing a foreign attorney or other individual who is not authorized to practice before the USPTO to represent you in connection with your
trademark application may delay and prolong the trademark application examination process and could jeopardize the validity of any resulting
registration.
The USPTO has established a Law School Clinic program in which participating law schools provide free legal services to trademark applicants in
connection with trademark applications before the USPTO. Each school in the program has its own criteria for accepting clients. If you are interested,
you should contact a participating school to inquire about becoming a client. For a list of schools participating in this program and additional
information about the program, visit Law School Clinic Certification Program.
For more information on finding a qualified private attorney to assist you, visit Using Private Legal Services.
For more information on the unauthorized practice of trademark law and who may practice before the USPTO in trademark matters, visit Proper
Representation in Trademark Matters.

What to do when your application is abandoned

USPTO 167 of 192
When an application is abandoned, it means that the application is no longer pending and, thus, a registration will not be issued. The USPTO may deem
your application abandoned if you fail to submit a response to an Office action or fail to respond completely to an Office action; if you fail to respond to a
suspension inquiry; or if you fail to file a statement of use. In addition, an application may be “expressly abandoned,” meaning that the applicant has
requested that application be abandoned and that no further prosecution of the application will occur.
In some cases, you may file a petition to revive an abandoned application or request that an abandoned application be reinstated. More information about
abandonment and the process of reviving or reinstating an abandoned application may be found at Abandoned Applications.

What to do if your registration expires or is cancelled

Once your mark is registered, you, as the registration owner, must file specific documents and pay the required fees at regular intervals to keep the
registration "alive" or valid. Failure to file these documents or pay the required fees will result in the cancellation or expiration of your registration.
If you failed to timely respond to an Office action refusing to accept a §8 affidavit, §71 affidavit, or §9 renewal application due to an extraordinary
situation, you may file a formal petition under 37 C.F.R. §§2.146(a)(5) and 2.148 to accept a late response. You may file the petition electronically using the
Petition to the Director under Trademark Rule 2.146 form, available at Petition Forms. You must file the petition within two months of the issue date of the
cancellation notice. If you did not receive the cancellation notice, or no cancellation notice was issued, you must file the petition must within two months
of the date the Trademark database was updated to indicate that the registration expired or was cancelled.
If your registration expires or is cancelled, but you have proof that a USPTO error led to the cancellation or expiration, you may file a request to
reinstate a cancelled or expired registration. You may file the request electronically using the Petition to the Director under Trademark Rule 2.146 form,
available at Petition Forms. Although a petition fee is required in order to file the form, it will be refunded if USPTO error is found. For a list of examples of
situations where the USPTO may reinstate a cancelled or expired registration, please see TMEP §1712.02(a).
For additional information about maintaining your trademark registration, visit Keeping Your Registration Alive.
EXHIBIT Y
12/12/2017 ABA ethics opinion
Case 5:17-cv-07194-NC sparks renewed
Document debateFiled
10-1 over nonlawyer
01/02/18ownership
Pageof law169
firms of 192
Home / In-Depth Reporting / ABA ethics opinion sparks renewed debate…
ETHICS
ABA ethics opinion sparks renewed debate over nonlawyer ownership of law firms
BY JAMES PODGERS (HTTP://WWW.ABAJOURNAL.COM/AUTHORS/13/)
DECEMBER 2013 (/MAGAZINE/ISSUE/2013/12/)
Like 18 Share Tweet Share 14 submit
An opinion issued recently by the ABA Standing Committee on Ethics and Professional Responsibility
could ignite a debate over the concept of nonlawyer ownership of law firms only months after the
association’s House of Delegates sidestepped the issue while considering recommendations of the
Commission on Ethics 20/20.
The ABA Model Rules of Professional Conduct—which are the direct basis for professional conduct rules
in every state except California—do not permit nonlawyer ownership. And ABA Formal Opinion 464
(http://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/formal_opinion_464.pdf) (PDF), issued Aug. 19,
does not deal with the issue of nonlawyer ownership. Rather, the opinion addresses the narrow question
of whether the Model Rules permit a lawyer to divide a legal fee with a lawyer in a jurisdiction that would
allow the other lawyer to eventually distribute some portion of the fee to a nonlawyer.
Illustration by Tim Marrs
“Interfirm division of legal fees is clearly contemplated by the Model Rules,” specifically Rules 1.5 and 5.4,
the committee states in its opinion. “A division of a legal fee by a lawyer or law firm in a Model Rules jurisdiction with a lawyer or law firm
in another jurisdiction that permits the sharing of legal fees with nonlawyers does not violate Model Rule 5.4(a) simply because a
nonlawyer could ultimately receive some portion of the fee under the applicable laws of the other jurisdiction.”
The committee bases its analysis largely on the distinction made by the Model Rules on dividing fees with lawyers and sharing fees with
nonlawyers. Rule 1.5(e) authorizes “a division of a fee between lawyers who are not in the same firm” under certain limited circumstances.
Meanwhile Rule 5.4(a) states, “A lawyer or law firm shall not share legal fees with a nonlawyer,” except under another set of limited
circumstances.
Accordingly, a division of fees between lawyers under Model Rule 1.5 does not trigger the prohibitions in Model Rule 5.4 against fee
sharing with nonlawyers, states the opinion. “As explained in Comment [1] to Model Rule 5.4: ‘These limitations are to protect the lawyer’s
independence of professional judgment.’ The rule protects a lawyer’s independent professional judgment by limiting the influence of
nonlawyers on the client-lawyer relationship.”
SOUND THE ALARM
But despite its seemingly narrow scope, Opinion 464 has set off alarms among some segments of the legal profession. Their concern is
that any step in the direction of giving nonlawyers some form of ownership involvement in law firms threatens the professional
independence that is one of the core principles of lawyering.
“The whole idea of Model Rule 5.4 is that a law firm won’t be in-dependent if it’s splitting fees with a firm with nonlawyer owners,” says
Lawrence J. Fox, a past chair of the ethics committee and a member of the ABA Commission on the Evaluation of the Model Rules of
Professional Conduct, known as Ethics 2000. “In one simple, unsupported opinion, we’ve destroyed a principle we’ve fought so hard to
protect,” says Fox, a partner at Drinker Biddle & Reath in Philadelphia.
Another critic of Opinion 464 is John E. Thies, the immediate-past president of the Illinois State Bar Association and the National Caucus
of State Bar Associations. “It’s difficult to reconcile the opinion with ABA policy,” says Thies, a shareholder at Webber & Thies in Urbana.
In 2000, for instance, the House of Delegates rejected a proposal to allow multidisciplinary practice at law firms. That policy is known as
the MacCrate resolution for Robert MacCrate of New York City, senior counsel with Sullivan & Cromwell. He led the charge against a
proposal by the Commission on Multidisciplinary Practice, which had pushed for relaxation of professional conduct rules to allow lawyers
and professionals in other disciplines to join together in single businesses. “The sharing of legal fees with nonlawyers and the ownership
or control of the practice of law by nonlawyers are inconsistent with the core values of the legal profession,” states the resolution, which
passed by a wide majority in the House. “The law governing lawyers that prohibits lawyers from sharing legal fees with nonlawyers and
from directly or indirectly trans-ferring to nonlawyers ownership or control over entities practicing law should not be revised.”
Thies and Fox also suggest that the ethics committee may have overstepped its jurisdictional bounds in issuing Opinion 464. “The
committee is supposed to interpret the rules, not change them,” Fox says. “It was just an end run.”
On Oct. 18, the ISBA Board of Governors adopted a resolution objecting to ABA Ethics Opinion 464 on grounds that it “creates new policy
bypassing the ABA House of Delegates,” is “a violation of existing ABA policy” and is inconsistent with ISBA policy. This is not a new
gambit for the ISBA, whose board adopted a similar resolution in 2012 when it was concerned that the Ethics 20/20 Commission was
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considering the possibility of proposing that the ABA Model Rules be revised to permit some form of limited nonlawyer ownership of law
firms.
Despite criticisms, the ethics committee is comfortable with its opinion, says chair Paula J. Frederick. “We took this on to provide helpful
guidance to lawyers confronted with this issue,” says Frederick, who is general counsel to the State Bar of Georgia in Atlanta. “The
opinion does not make any statement, pro or con, about nonlawyer ownership of law firms. It simply answers the question of whether the
Model Rules allow a lawyer practicing in a Model Rules state to divide a legal fee with a lawyer who practices in a firm that shares fees
with nonlawyers. The opinion is limited to an interpretation of Rules 1.5 and 5.4, is squarely within the committee’s jurisdiction, and thus is
entirely appropriate.”
The core value at stake in Opinion 464 “is whether dividing a fee in this way is likely to compromise the lawyer’s independence of
professional judgment,” Frederick says. “If you presume that you are dealing with the typical lawyer—that is, one who tries to be ethical
and who is reasonably aware of her obligations under the rules of professional conduct—I see little likelihood that this type of fee sharing
by co-counsel would have any impact on the lawyer in the Model Rules state or her client.”
Despite the growing heat over Opinion 464, issues relating to nonlawyer ownership of law firms in the United States still are largely
prospective. So far, the District of Columbia is the only U.S. jurisdiction that permits a limited form of nonlawyer ownership. But nonlawyer
ownership is becoming more common in foreign jurisdictions, notably Australia, Canada, England and Wales. American law firms doing
business overseas are in a quandary over how to balance the more permissive rules on business structures in other countries and the
more restrictive regulations in U.S. jurisdictions.
HAVE WE BEEN HERE BEFORE?
Nonlawyer ownership turned out to be one of the toughest issues for the ABA Commission on Ethics 20/20 to deal with, even though it
never developed recommendations in that area. By the time the commis-sion completed its work early this year, it had drafted a wide
range of proposals to revise the Model Rules of Professional Conduct in response to the growing impact of technology and globalization
on the legal profession. The commission’s recommendations, submitted in two separate batches, breezed through the association’s
policymaking House of Delegates in August 2012 and again in February.
But in April 2012, at the close of one of the commission’s many drafting meetings, co-chairs Jamie S. Gorelick and Michael Traynor
announced that the commission had decided not to develop a proposal on whether nonlawyers should be allowed to have some form of
limited ownership interest in U.S. law firms. Gorelick is a partner at Wilmer Cutler Pickering Hale and Dorr in Washington, D.C. Traynor of
Berkeley, Calif., is a past president of the American Law Institute.
“Since its creation in 2009, the commission has undertaken a careful study of alternative law practice structures,” said Gorelick and
Traynor in their statement. “Based on the commission’s extensive outreach, research, consultation and the response of the profession,
there does not appear to be a sufficient basis for recommending a change to ABA policy on nonlawyer ownership of law firms.”
Nevertheless, the commission still had to contend with a resolution co-sponsored by the Illinois State Bar Association and the ABA Senior
Lawyers Division that called for the House of Delegates to reaffirm its MDP policy from 2000 and to affirm that the law governing lawyers
relating to nonlawyer ownership and fee sharing should not be changed.
After a heated debate, the House voted to postpone the resolution indefinitely, which cleared the way for the Ethics 20/20 Commission to
prepare its final recommendations for House consideration in February. But the commission declined to submit a resolution on the fee
division issue, instead referring it to the ethics committee. And now that the committee has issued Opinion 464, the merry-go-round of
debate over the issue is starting up all over again.
The question is how productive those efforts might be. “Whatever one thinks about the merits of nonlawyer ownership of law firms, the
discussion needs to continue in the U.S., especially as we learn more about experiences abroad,” says Andrew Perlman, a law professor
at Suffolk University in Boston who served as chief reporter for the Ethics 20/20 Commission. “But I don’t think we’ll see movement on the
ABA level. The ABA is reluctant to even discuss the issue at a policy level.”
This article originally appeared in the December 2013 issue of the ABA Journal with this headline: “Second Time Around: An ABA ethics
opinion sparks renewed debate over nonlawyer ownership of law firms.”
Copyright 2017 American Bar Association. All rights reserved.
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EXHIBIT Z
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Shingle
Bars Can’t Handle The Regulation of Non-Lawyer Providers,

So Let Us Solos/Smalls Compete
April 29, 2016 | 1 Comment
To the Commission on the Future of Legal Services,

These comments respond to the Commission’s
issues paper seeking feedback on whether state bar
associations ought to consider regulation of non-
legal service providers – ranging from online how-to
publications and websites to human-supported or
technology-enabled form-filling services. The short
answer – don’t. Because just as Tom Cruise’s
character couldn’t handle the truth, the state bars
can’t handle the regulation of non-lawyer service
providers. Moreover, there’s no need to, because
they are already subject to three higher and more
effective forces of regulation: the Federal Trade
Commission, market forces and e-shaming .
I’m not suggesting that non-legal service providers
are perfect, or that they expand access to justice the
way many claim. Some day they may – but they’re
not there yet, and in this regard, the arrogant proclamations that tech has solved the problem seem premature at best.
The reality is different. Like any emerging technology, non-legal service providers are enduring serious growing pains. A quick search on the web shows
hundreds of complaints about Legal Zoom (here), Rocket Lawyer (here, here and here) and Avvo (here). Most state bars can scarcely keep pace with the
several dozens of complaints lodged against lawyers. How could they ever effectively address consumer complaints about, and oversee compliance with
non-legal service providers?
The fact is that state bars aren’t well suited to address the problems that consumers have about these services. If you look through the complaints, many
common gripes emerge: abysmal customer support, deceptive billing practices and sluggish service and response times. Most consumers simply want the
money back – a remedy that state bars can’t provide anyway. And even if one state bar were to shut down a service, it would simply re-emerge elsewhere.
More effective mechanisms exist to address deception by non-lawyer providers. Consumers can file complaints at the Federal Trade Commission and
the Better Business Bureau or air their gripes online. There’s no need for the state bars to attempt to replicate existing regulation, when at best, they could
only serve as a pallid shadow of these systems.
Does that mean that there’s no role for state bars in dealing with non-legal service providers? Absolutely not. Foremost, state bars should start by fulfilling
their job of educating consumers about legal services. For example, state bars can educate consumers about how services like Legal Zoom and Rocket
Lawyer compare to hiring a lawyer (on the one hand) and relying on entirely free tools (like Court self-help programs or using resources at state secretary
offices to incorporate). But more importantly, they ought to stand out of the way and let solo and small firms compete with non-legal service providers
instead of imposing more and more regulation that deters members of the public from using lawyers to begin with.
Here’s a list of what needs to change. I’ve covered many of these topics at MyShingle, a blog that the Commission should be reading:
Abolish Trust Accounts – They don’t keep client money safe and have made it difficult for lawyers to accept credit card payments (like non-lawyer
providers) and deposit the money directly into operating funds to facilitate cash flow. Likewise, make it easier, not harder to accept flat fees.
Eliminate Unfair and Ridiculous Advertising Regulations – Lawyers are subject to a completely ludicrous maze of regulations governing advertising
–which don’t apply to non-lawyer providers . Compliance adds cost and puts attorneys at a substantial disadvantage at a time when many consumers
are turning to the internet to find lawyers. One rule ought to apply: is the communication deceptive, and leave it at that.
Create A Safe Harbor for Innovation – Many solos and smalls won’t dare innovate because the consequences can be draconian . Let’s give solos and
smalls a safe harbor to innovate – and if firms can demonstrate a good faith effort for undertaking an action, give them a pass if it infringes on ethics
and doesn’t substantially harm consumers.
The bars have enough work to do in helping to make lawyers relevant again. They shouldn’t waste their resources trying to stop a train that’s already left the
gate. Moreover, regulating non-legal service providers won’t make lawyers relevant – or bar associations either. Isn’t that what this proposal is all about
anyway?
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Case 5:17-cv-07194-NC Beat Them, Let’s
Document 10-1Compete
FiledWith Them! – My Shingle
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Inspiring, Celebrating & Empowering

(https://myshingle.com/)
Solo & Small Law Firms
If We Can’t Beat Them, Let’s Compete With Them!

February 22, 2005 | 29 Comments (https://myshingle.com/2005/02/articles/client-relations/if-we-cant-beat-them-lets-compete-with-them/#disqus_thread)
(http://www.facebook.com/sharer.php?u=https://myshingle.com/2005/02/articles/client-relations/if-we-cant-beat-them-lets-compete-with-them/)
(https://plus.google.com/share?url=https://myshingle.com/2005/02/articles/client-relations/if-we-cant-beat-them-lets-compete-with-them/)
(http://www.linkedin.com/shareArticle?mini=true&url=https://myshingle.com/2005/02/articles/client-relations/if-we-cant-beat-them-lets-compete-with-them/)
(https://twitter.com/share?url=https://myshingle.com/2005/02/articles/client-relations/if-we-cant-beat-them-lets-compete-with-
them/&text=If+We+Can%E2%80%99t+Beat+Them%2C+Let%E2%80%99s+Compete+With+Them%21+&hashtags=) (mailto:?Subject=If We Can%26#8217;t Beat
Them, Let%26#8217;s Compete With Them!&Body=%20https://myshingle.com/2005/02/articles/client-relations/if-we-cant-beat-them-lets-compete-with-them/)
I’m never more morti ed than when I see lawyers trying to shut down legal document preparation services like We the People which purportedly compete with
lawyers – as the Illinois Bar is doing. See Lawyers Protest Expanding Legal Document Preparers (http://www.suntimes.com/output/herman/cst- n-law21.html),
Chicago Sun times (2/21/05). I can’t understand why attorneys, who offer a valuable service, feel the need to put glori ed typing services like We the People out of
business.
First, to say that document prep services even compete with what lawyers provide gives those services credibility that they don’t deserve. Document prep services
don’t offer clients a lawyer’s expertise and legal knowlege. Instead, they simply take information from a form (completed by a client), generate a document – a living
trust, a bankruptcy petition or uncontested divorce – and le it. And for that, clients pay $199 (for bankruptcy) or $399 (for a living trust). Agreed, these services
generally charge less than attorneys – but not always. However, they certainly cost more than if clients did the work themselves.
So why are lawyers threatened? The bars (like ISBA) won’t admit that they’re trying to help lawyers preserve our own monopoly on legal service. So the bars claim
instead that document prep companies do a disservice to clients with shoddy work or improper advice. Granted, that’s a signi cant problem. But rather than try to
shut these companies down, it’s our job as attorneys to persuade clients that the value that attorneys can add to living wills and bankruptcy petitions and uncontested
divorces justify the added cost. Moreover, client welfare can be preserved through less onerous means such as education or consumer protection claims. Clients
who believe that their cases were mishandled have sued We the People and the FTC has ned the company for deceptive advertising practices. Those efforts should
be su cient to protect clients from the inadequacies of document prep services.
Moreover, in our haste to run non-legal professionals out of town, we lawyers forget that many of the clients who use these document service providers constitute
business that we are never going to capture anyway because of cost considerations. In the absence of these non-legal document services, many of these clients
would probably handle their matters pro se. Yet, according to this article (http://www.washingtonpost.com/wp-dyn/articles/A113-2004May29.html) in the
Washington Post, a company like We the People generates $50 million in fees from 200,000 customers a year. That’s a lot of lost business for lawyers. We ought to
try to capture it for ourselves by competing with companies like We the People.
And how might we do that? Lawyers can try to come up with ways to provide simple, routine services inexpensively. Perhaps there’s a way to automate the process
– or to quickly review a form already prepared by a client. Perhaps a lawyer could run a seminar on ling your own bankruptcy petition and charge $35.00 to a
roomful of people who would then ll out the forms on the spot and have the option of ling them on their own – or paying an additional fee for a private
consultation. With podcasting now the rage, maybe a lawyer could put together a little MP3 on how to ll in a bankruptcy form that clients could download and listen
to. Clearly, there’s a demand for cheaper service – $50 million worth – and it just bugs me to let it go to providers who’ve not gone to law school. But getting rid of
those people won’t direct that $50 million pot towards attorneys – it will just result in fewer available options for lawyers who can’t hire attorneys.
Finally, those of you who’ve visited my website (http://www.his.com/israel/loce) may wonder what gives me, an energy regulatory practitioner, the credibility to
comment on competition with non-legal providers. Well, in my industry, the competition betweeen lawyers and non-legal providers is even more rampant. The
Federal Energy Regulatory Commission (www.ferc.gov), one of the major regulatory fora where I practice permits non-lawyers to represent clients in agency
proceedings. And many times, non-lawyer economists or consultants initially negotiate the terms of power supply contracts and tariffs and handle uncontested
project permitting without ever bringing a lawyer in the door. I’ve had to mold my practice in such a way that I can provide added value that my non-legal competitors
can’t. I did this partly by educating clients on the mess that can result by failing to use an attorney so as to adequately preserve one’s rights (e.g., to protest a
contract or seek rehearing) – and partly by offering services like appellate work or representation at hearings – that non-attorneys either can’t provide or are
uncomfortable providing. In short, if I’ve found ways to make my legal services vital in the energy regulatory eld, surely my colleagues can do the same in the
general practice area.
If you have any ideas on how to compete with non-legal document preparation providers or any success stories to share, we welcome your comments below – or
cross posts at your web log.
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12/14/2017 These venture
Case 5:17-cv-07194-NC capitalists10-1
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Home / In-Depth Reporting / These venture capitalists skip law firms…
FEATURES
These venture capitalists skip law firms for legal

services startups
BY SUSANNA RAY
MAY 2014 (/MAGAZINE/ISSUE/2014/05/)
Venture capitalist Jason Mendelson

(http://www.abajournal.com/legalrebels/article/jason_mendelson/), in
a speech he gave last year, was not venturing
much oral capital into the concept of investing in
legal services.
A corporate and securities-law attorney before he
co-founded the Foundry Group, his venture
capital firm, Mendelson told a conference he
found it difficult to invest in companies serving
law firms because, unlike regular enterprise
customers, they don’t always act rationally when
it comes to economics. He warned that most
legal startups would fail due to the industry’s
complications and barriers.
Jason Mendelson is the Next up to speak was Colin Rule, the founder
Foundry Group co-founder and chief operating officer at Modria, which bills
and one of four managing itself online as “the world’s leading online dispute
directors. He hails from resolution experts.” And things changed.
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Boulder, Colo., and his JD is Mendelson says he was so impressed by Rule

from the University of and by Modria’s emphasis in targeting an area of
Michigan. Photo by Matt the law that wasn’t regulated by the ABA Model
Nager. Rules of Professional Conduct or serviced by
traditional law firms that he immediately agreed
to a meeting and made an investment shortly afterward.
“We made a love connection at that conference,” Mendelson says.
Rule is just as starry-eyed.
“We’ve spent a lot of time talking to VCs, and a lot of the time they don’t
understand the law profession,” Rule says. “That’s a big challenge. Occasionally
around the table at a VC meeting there’s a lawyer, and when you talk about the
challenges the legal profession is facing, they get it. Jason got it.”
CASH FOR LAW, NOT FIRMS
It’s no secret that investment money is flowing into
law. In February, an article on the website of Tech Editor’s Note: Three
Cocktail, a media company covering startups, crowed years ago, the ABA
that “roughly $458 million was invested into legal Journal began a
startups in the last year by investors. This is a series of reports on
remarkable increase from the $66 million invested in the paradigm shift in
2012. And 2014 began with a strong January, seeing how law is being
almost $12 million done in four deals. Awareness and practiced. Noting the
confidence in the legal startup arena is growing.” changes brought on
by a maturing market,
But that money is not going to law firms. Venture
disruptive technology,
capitalists are skeptical of the upheaval underway in
economic recession
BigLaw, with uncertainty around changes in pricing
and the rise of legal
and ownership rules as well as concern about
services competing
efficiency and access to justice. So instead, VCs are
with law firms for parts
investing in the legal technology vendors that are
of the legal dollar, this
filling in some of those holes.
series has looked at
Lex Machina, Modria, Ravel, Rocket Lawyer, how the legal
LegalZoom, SIPX (the Stanford Intellectual Property business is
Exchange) and more—all have been the beneficiaries responding—and the
of this new outreach from venture capital as they seek legal profession often
to compete with or complement major law firms. not responding—to
pressures never
before placed on
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The fact that VCs are interested in this budding lawyers and law firms.
segment of the legal industry—and that they only
invest in enterprises they expect will make money for This article is the fifth
them—suggests a trend is taking shape that’s here to in our magazine
stay and likely to lead to good results. series. It is a look at
the venture capitalists
“These people don’t invest money to lose,” Mendelson
who are financing
says of his fellow venture capitalists. The flow of funds
legal services, but not
was slow to get started, however, in part because of
law firms, to both
an aversion to the law. “There are very few lawyers
increase access to
who become startup investors, and those who do
justice and make
typically shun legal startups,” says VC Clint Korver,
money—lots of it.
who founded Ulu Ventures in 2009 in Palo Alto, Calif.,
They are redefining
with his wife, Miriam Rivera, former vice president and
what lawyers do, and
deputy general counsel at Google.
helping shift the
That’s why Rule says he tries to keep the law out of paradigm of law
his pitches to investors. Since Modria is an online practice today. There
dispute resolution and mediation platform based in is also online-only
San Jose, Calif., Rule talks instead about the problem content for the series,
and about the value disputes that aren’t currently available here
addressed in the legal model. (http://www.abajournal.com/lawb
“Where there’s a huge unmet need, a company can ythenumbers/#tabs-1).
emerge with a solution and grow quickly,” Rule says. Paradigm Shift
“That’s what gets investors excited.” Feature Stories
But the separation between law and venture October 2013
capitalists is melting away. The current chair of the Who’s eating law
National Venture Capital Association is Josh Green, a firms’ lunch?
former Silicon Valley attorney. And Peter Thiel, co- (http://www.abajournal.com/mag
founder of PayPal, has a law degree from Stanford azine/article/whos_eating_law_fi
and has helped fund a few legal tech companies, rms_lunch/)
including the legal research startup Judicata.
July 2012
In fact, this new investment interest has been led The Pedigree
largely by venture capitalists with legal backgrounds. Problem: Are law
Another investor with a law degree is Ron Dolin, who school ties choking
worked at CERN, the European Council for Nuclear the profession?
Research in Geneva, before getting a PhD in (http://www.abajournal.com/mag
computer science and becoming one of the first 100
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employees at Google. He left after six years to pursue azine/article/the_pedigree_probl

a JD and now teaches legal technology and em_are_law_school_ties_choki
informatics at Stanford Law School. ng_the_profession/)
He’s also an angel investor with a focus on legal January 2012

technology startups and says he wants to start a The Law School
whole pipeline of them to whittle away at the Bubble: How long will
inefficiencies in the industry. it last if law grads can’t
ANGEL OR VC? pay bills?
(http://www.abajournal.com/mag
The difference between angel investors like Dolin and azine/article/the_law_school_bu
big-money venture capitalists like Mendelson isn’t bble_how_long_will_it_last_if_la
clear-cut anymore, Dolin says. “It’s now kind of a w_grads_cant_pay_bills/)
continuum,” he says. “Typically, angels put in $10,000
to $100,000. But VCs are putting in seed money July 2011
because they want to gain early entry into a company. Paradigm Shift: Law
And angels are putting in half a million now, so it’s job stagnation may
getting a little more mushy.” have started before
the recession—and it
The basic need, regardless of the stated motivation, is may be a sign of
to take tens of millions of dollars and turn that into lasting change
hundreds of millions. And venture capitalists are (http://www.abajournal.com/mag
hungry for more ideas that will get them there. azine/article/paradigm_shift/)
“When you’re working on something like legal aid, March 2011

that’s not likely to lead to for-profit startups,” Dolin What America’s
says. “But in consumer law, there’s plenty of room for Lawyers Earn
startups there. And when you start talking about (http://www.abajournal.com/mag
consumer law, now you’re looking at interest among azine/article/what_americas_law
VC people. You’re going from Saks Fifth Avenue to yers_earn/)
something like Wal-Mart or Sears.”
The
latent
market
for the
legal
needs
of the
middle
class is
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Pictured from left to right, Venture Capitalists Robert Siegel, Jeff tens of
Thermond, Miriam Rivera, Clint Korver, Ron Dolin, and Josh Becker. billions
Photo by Norbert von der Groeben. of
dollars
a year, Dolin says, as long as the right services
and the right pricing structure are developed.
“It’s like H&R Block—where’s the legal
equivalent of that?” Dolin says. “When you start
talking consumer law, you get that increase in
scale and ramp-up of a startup. If they hit the
market right, that’s what a VC is looking for,” he
says. “The ones that don’t fail have to pay for
the ones that do fail, so they’re looking for high- Ron Dolin is an Angel investor
end growth.” and Stanford Law School
research fellow from Stanford,
But returns aren’t all that drive VCs. Calif., with a JD from the
“Yes, there’s making money, but a lot of it is University of California’s
enabling dreams and pursuing causes,” says Hastings College of the Law.
Dolin. “I’m wanting to invest in legal tech Photo by Norbert von der
because I want legal technology to succeed. It’s Groeben.
incredibly important with consumer law. “The
latent market is a signal of inefficiency—of people not getting the help they need
because the infrastructure is broken. The fact that someone’s making money is
indicative of an inefficiency being fixed. “It’s not selling Pet Rocks,” he says. “I
don’t want to sell Pet Rocks. I want to have an impact in a field that is really
important for humanity. And the fact there are such inefficiencies also means
there’s a lot of money to be made.”
Dolin says he often co-invests with Ulu Ventures’ Rivera, whom he knows from
their time together at Google.
“Miriam will contact me when she has a legal tech company because she likes
having me onboard, and she feels it helps them be more successful because of
my engineering and law background,” Dolin says.
Rivera shares Dolin’s drive, he says.
“Miriam cares about women in law, minorities, access to legal justice, making
money. All these various interests align, and where you see such huge
inefficiencies as you do in the legal industry, you can simultaneously help people
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and make money—and that’s the best,” Dolin says. “You don’t have to decide
between making money and helping people.”
Korver, Rivera’s husband and now chief operating officer of NovoEd—an online,
college-level education provider—agrees with Dolin’s assessment: “We have
financial criteria for our investments, but we’re also looking to make the world a
better place,” he says.
HER STORY
Rivera, one of the most influential women in
Silicon Valley, got her start as a venture
capitalist “half by accident and half intentionally,”
given her background with the law and Google,
Korver says. Rivera says she’s “one of the crazy
people who actually loved practicing —a glutton
for punishment—the intellectual challenge of law
Miriam Rivera is Ulu tied to core values of justice and fairness.”
Ventures’ co-founder and
That’s what also makes the legal industry
managing partner in Palo
attractive to her as an investor, she says,
Alto, Calif., who received her
although she knows all too well that the
JD/MBA from Stanford
complexity and inefficiency can be barriers to
University. Photo by Norbert
entry for investors.
von der Groeben.
“Perhaps a knowledge of the law makes you
aware of how conservative a profession it is and how slow to adapt, so it makes
you more cautious,” Rivera says. “But at some level there are new and interesting
opportunities.”
Rivera’s business background enhanced her value as an attorney, she says,
helping her bring a more quantitative and data-driven approach to the practice
and operation of law. But as Google’s vice president and deputy general counsel,
she found herself looking at metrics and running law departments in a way that
was novel in the field of law, where most participants don’t have backgrounds in
business or operations.
Google was going through a high-growth phase, and she had a hard time figuring
out how to resolve matters in compliance with the law while still meeting metrics
such as closing advertising partnerships in three days. Going too slowly could
have stalled revenue growth and hurt the company’s future.
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So Rivera looked to find “ways people could do legal tasks with as little legal
intervention as possible.” That started the company on the hunt for technology
that could automate some of these legal solutions.
In addition, since Google was a very data-driven company, the founders and
then-CEO Eric Schmidt wanted to understand the tradeoffs between legal
protections and business needs in financial terms. It was difficult for Rivera to
provide the executives with data on risks of commercial litigation or contract work.
“It was so frustrating trying to be a data-driven legal department when the whole
profession doesn’t even support the use of data—because it’s fine to reinvent the
wheel if you get paid every time you re-create the wheel,” Rivera says.
And that’s why Lex Machina, a legal analytics company based in Menlo Park,
Calif., sparked her interest.
Lex Machina offers the tools to assess and compare law firms’ and lawyers’ work
and outcomes, assuaging the frustration Rivera still carried from when she was
building Google’s legal department from two to 150 attorneys, but had no way of
evaluating the counsel she paid, says Josh Becker, Lex Machina’s CEO.
For Korver, who has a PhD in management science and engineering from
Stanford, what resonated was the company’s focus on making better decisions
through legal analytics, Becker says.
Korver was the first to see that Lex Machina wasn’t competing against traditional
legal providers, but instead was providing a new capability—combining a lawyer’s
intuition with hard data to make the best decisions, Becker says.
“There is a cool factor,” Rivera says. “It’s a lot of fun to be a part of. When I look
at a company and imagine the future of law and how it will be different, I can see
the impact.”
Ulu Ventures has gone on to help fund such legal startups as Hire an Esquire
(flexible law-firm staffing); Ravel (legal research); SIPX (copyright management);
and EasyESI (document storage and review).
“Once you make an investment in an area, particularly in one that’s somewhat
tricky for general VCs to understand, you become someone people know to go
to,” Rivera says. “You understand what they are trying to do and that there really
is a market potential here. People not familiar with law often underestimate how
big an industry it really is.”
POSTER CHILD
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Lex Machina is one poster child for this new

investing development.
“When I started in 2011—we raised our first
round in the beginning of 2012—you had very
few venture capitalists that had ever invested in
the legal space,” says Becker, who was once a
venture capitalist himself. “It was very much an
area that wasn’t on the radar screen with VCs.
There was a lot of skepticism.” Lex Machina CEO, Josh
Becker, hails from Menlo
Becker says he used his relationships and Park, Calif., and has a
credibility with investors to get venture JD/MBA from Stanford
capitalists to take a look at the merits of Lex University. Photo by Norbert
Machina and not just dismiss it out of hand von der Groeben.
because it was law-related. “Once we did that,
we were able to attract investment,” Becker
says. “And we helped pave the way for a lot of companies because once one VC
goes into a space, others look at it.”
Indeed, the number of legal companies seeking funds through AngelList, a
website that helps connect startups with investors, has surged from only a few
three years ago to 461 as of press time. A venture-capitalist firm’s entry into one
company in an industry not only attracts others; it also can make that firm
comfortable enough for further forays in that field. One of Lex Machina’s
investors, XSeed Capital, went on to help fund SIPX.
XSeed, based in Portola Valley, Calif., was founded in 2006 to invest in
companies that have tech as a key differentiator, says Robert Siegel, a general
partner at the firm. The partnership makes its initial investments at the seed stage
and works with management when a startup is raw but has “the ability to become
humongous,” Siegel says.
“We are backed by institutional investors looking for high risk and high reward,”
he says. “We’re looking to fund the next Google.”
XSeed is small, managing just $110 million, making it part of a new wave of micro
venture capitalists who focus on the seed stage of a startup, Siegel says. That
often requires a close relationship with universities, which is where the core of
money for technology gets invested, he says.
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XSeed looks closely at risks in a startup’s

technology, execution and market, Siegel says.
The company likes technology risk because, if
technology is a differentiator, good engineers
can solve most problems. If there’s execution
risk, then XSeed considers whether it can help
the firm hire the right skill set, Siegel says,
similar to being the coach of a sports team.
Market risk—“Will the dogs eat the dog food?”—
Robert Siegel, from Portola
is the variable that’s hated by most VCs, who
Valley, Calif., is a general
don’t like the uncertainty of knowing whether
partner at XSeed Capital with
customers are going to buy a product or not, he
an MBA from Stanford
says.
University. Photo by Norbert
von der Groeben. “We look at the law profession as but one
potential vertical that has the ability to be
reinvented,” Siegel says. “I’d be lying if I said
that we looked at 20 verticals and law was the only one we chose. But when we
looked, there were attributes that made us believe there would be certain
opportunities here. It’s a large market with slow incumbents, old technology and
new technology being developed that can deliver better solutions that are
available today.”
Hence XSeed’s investment in Lex Machina, which came out of Siegel’s alma
mater, Stanford, where he’s now on the faculty. He had known Becker at Lex
Machina for the last 15 years, and when Becker was looking to raise money for
his startup, “people advised Josh to go talk to Rob, because the guys at XSeed
like funding companies with deep tech breakthroughs out of universities,” Siegel
says.
THE STANFORD INCUBATOR
Stanford Law has been an incubator for legal
startups, being situated in the heart of Silicon
Valley and hosting its swarm of entrepreneurial
activity.
In fact, Korver and Rivera, whose JD/MBA is
from Stanford and who recently served on its
board of trustees, say Ulu Ventures focuses on
tech coming out of the school. Korver teaches
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entrepreneurship there, too, and the pair co- Clint Korver is NovoEd’s COO
founded a group called Stanford Angels & and Ulu Ventures’ co-founder.
Entrepreneurs to connect alumni seeking startup His PhD is in management
assistance with those offering funds. science and engineering from
Stanford University, and he
The VC firm subleases space from a law firm on
now resides in Palo Alto,
Stanford land in a building whose red-tile roofs
Calif. Photo by Norbert von
match the university’s.
der Groeben.
“We’ll take a meeting with any company coming
through CodeX,” the Stanford Center for Legal
Informatics, Korver said in an interview before stepping back from Ulu Ventures
to join one of its companies.
Silicon Valley has the right ingredients for the new developments in the legal
industry, with the confluence of a law school, design school, startup mentality,
venture capitalists, banks and law firms. And most have made sure they’re close
enough to be within biking distance of Stanford, since so many entrepreneurs
don’t have cars, Rivera says.
“The machinery, the culture, the mindset is such that when it gets going, it’s going
to kick ass,” Dolin says of the valley. “So all of a sudden we realized, ‘Hey, we
could apply this innovative machinery to the legal system, so let’s do that.’ “
And the ecosystem does make a difference. Many of the entrepreneurs already
knew the investors they ended up working with through friends or their kids’
sports teams.
“It’s a small valley,” Becker says.
But Silicon Valley isn’t the only hotbed for legal startups.
“Relatively speaking, there’s been quite a lot that has come out of Stanford, but if
you go to these legal tech dinners, it’s not like the majority of them are from
Stanford,” Dolin says. “Legal tech is coming from all over the place.”
Still, Lex Machina’s Stanford connection was what got the company its first
meeting with XSeed, which is closely associated with the school. One of XSeed’s
investment theses is that technology is enabling the analysis of data better than
at any other time in history, says Jeff Thermond, a venture partner with the firm.
And Lex Machina fit with that. It just happened to be in the legal space.
“I don’t think we went out and said, ‘Let’s go light up the legal services space
because we think it’s the natural area for VC investing,’ ” Thermond says. “From
the outside, people think venture capitalists tend to invest in categories. In reality,
firms for01/02/18
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the investments are about companies, and they’re very specific.”

Thermond worked in information technology and computer networking for 30
years before joining XSeed as a venture partner. He doesn’t have legal training,
but when he was an executive at Broadcom, the company “got involved in a
bunch of lawsuits, and he got involved, so he had personal experience,” Becker
says. So when XSeed invested in Lex Machina, Thermond “just got it right away
and joined the board to be a mentor to me.”
Venture capitalists rarely have time to get out and search for something in a
certain space, Thermond says. Mostly they just evaluate the pitches coming in
and decide whether one fits their view of the world, whether they like the team,
whether the market is big enough to produce a venture-size return and whether
the technology is there.
“The law is a very appealing space to us because whereas retailers for 20 years
have been doing things with fancy databases to analyze consumers, the law has
been a laggard in adopting technology like this,” Thermond says. “We think
there’ll be a very high payoff.”
And the herd mentality is strong.
“If someone is really successful in a given area, everyone will jump on the
bandwagon,” says Rivera.
GROWING CLOSER
Venture capitalists’ partnership with legal
companies is maturing. Becker says that for his
first round of funding, he had to run around and
pitch to a lot of firms. But for a recent round, last
May, “they really sought us out and found us,”
he says. The company raised $4.8 million in a
Series A funding round led by Cue Ball Capital
in Boston. (Series A is the first major venture Colin Rule is the founder and
funding round after the seed capital.) COO at Modria based in San
Jose, Calif. Photo by Norbert
Cue Ball has a more traditional venture-capitalist von der Groeben.
approach and didn’t invest in Lex Machina out of
a love for law, Thermond says. Instead, the
company sees “a large market that’s missing something, a lot of technology out
here, a proven team—and it doesn’t look like a firm that will require a ton of
money put into it, so it should be a good return,” Thermond says.
firms for01/02/18
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That’s a big change from two or three years ago, when most VCs weren’t open to
even contemplating a company in the legal industry, Becker says.
“It still has to be a solid plan, but at least now VCs are open to looking at you,” he
says. “It’s pretty hot. There’s a lot going on. It’s really exciting.”
And all of the newly available financial backing is in turn inspiring new startups.
“There are a lot of very entrepreneurial lawyers. And once they see there’s capital
out there, if they’ve got ideas—that’s spurring interest,” Becker says.
To be sure, one foray into the field doesn’t necessarily lead to an entire
settlement. And the industry’s growth path is still bumpy, with only a handful of
companies—such as online document and legal advice suppliers LegalZoom and
Rocket Lawyer—getting broad attention.
“I know the disruption is happening” in law, Mendelson says, “but I’m frustrated
trying to find entities that can command VC-type returns. There have been some
nice, but no massive, wins in legal tech. But as for the billion-dollar exits, I haven’t
seen anything like that.”
In the meantime, there are more and more investors—law-minded or not—
jumping into legal technology startups to get a piece of the legal system’s
evolution.
“Venture capitalists are all looking for whatever new thing is going to get them
going, and they don’t mind if it’s consumer law,” Dolin says. “They’re just like,
‘Let’s make it happen.’ So we are.”
This article originally appeared in the May 2014 issue of the ABA Journal with this
headline: “They’re After Legal Gold: But these venture capitalists skip law firms
for legal services startups.”
Susanna Ray is a freelance writer based in Seattle.
Copyright 2017 American Bar Association. All rights reserved.
12/14/2017 Ethics opinions
Case 5:17-cv-07194-NC have to reflect
Document 10-1the present
Filed and future—not the
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Home / In-Depth Reporting / Ethics opinions have to reflect the present…
BUILDING THE 21ST-CENTURY LAW FIRM
Ethics opinions have to reflect the present and

future—not the past
BY CAROLYN ELEFANT
DECEMBER 2017 (/MAGAZINE/ISSUE/2017/12/)
http://www.abajournal.com/magazine/article/legal_ethics_opinion_relevance 1/5
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Shutterstock
One of the most enduring purposes behind the ABA Model Rules of Professional
Conduct and corresponding state ethics standards is to protect clients and the
public from “overreaching, overcharging, underrepresentation and
misrepresentation.” (See Ohralik v. Ohio State Bar, 1978.)
More than a century after the 1908 adoption of the association’s first set of
guidelines, the ABA Canons of Professional Ethics, the clients whom ethics
standards protect and the lawyers governed by them have changed drastically.
Yet in substance and form, ethics standards remain stagnant—and the same lofty
principles that once inspired the best in lawyers will soon render us irrelevant.
ARCHAIC RULES
In substance, today’s legal ethics standards are so utterly out of sync with the
lifestyle, social conventions and technology savvy of today’s consumers that they
actually breed mistrust.
Imagine an encounter with an alien that hails from a planet where placing one’s
hands around a new acquaintance’s throat is intended as a sign of respect. Yet
without this background, you’d understandably feel distrustful and threatened if
greeted by a stranger who has a firm vise around your neck. The same is true of
ethics standards in the modern world: They require lawyers to act in a manner
that is so alien in today’s society as to arouse suspicion. Consider the two
following scenarios.
Case 1: Penny Prospect, a mom seeking a divorce, arrives at your office for a
consult. You think the meeting went well, but you never hear back. It turns out
your instincts weren’t wrong—Penny was leaning toward retaining you—until she
viewed your profile on LinkedIn and saw a disclaimer that states: “This profile is
attorney advertising.”
In a decade of using LinkedIn (including as recently as that morning when she
updated her profile in anticipation of searching for a higher-paying job), she has
never seen a disclaimer like this. She knows LinkedIn’s user agreement
(https://www.linkedin.com/legal/user-agreement) prohibits advertising. Doesn’t this lawyer
understand terms of service?
Penny’s concerns aren’t allayed when she clicks a link to the lawyer’s blog and
once again sees “This blog is attorney advertising” underneath the blog caption.
Penny doesn’t bother to read the posts; she assumes that if they’re advertising,
they won’t be very valuable.
01/02/18 past 188 of 192
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Penny wonders what’s wrong with this dude. He’s so caught up in promoting
himself online that he won’t have time to handle her case. Ultimately, Penny
heads to LegalZoom, which doesn’t have the same advertising disclaimers, and
signs up for the do-it-yourself divorce package that includes attorney review.
Case 2: Noah Newbie is a recent business school graduate seeking to
incorporate an online business. After the meeting, you hand him a 15-page
retainer agreement and ask him to sign it and send it back with a check.
Noah leaves the office and tosses the retainer agreement into the trash can. He
doesn’t understand a word of it. Plus, he’s always paid bills by credit card. He’s
not sure that he still has a checkbook.
He decides to search his lawyer’s ratings online, but there’s not a client review or
testimonial to be found. Because Noah always checks ratings before making a
purchase, he’s disconcerted about why he can’t find any for his lawyer: Were they
so bad she paid to have them removed?
Then Noah discovers a site called Avvo Answers, where he can ask questions
about incorporating a business for $39. Noah searches for a New York lawyer.
When he can’t find one, he discovers that several bars, including New York, have
banned lawyers from doing business on Avvo. Apparently, it’s unethical for the
site to take a cut of the $39 fee you pay to talk to a lawyer.
Noah doesn’t get it. Isn’t it a common online business model for the platform
providing goods or services to take a cut of the sale? That’s how Etsy and Airbnb
work—heck, Uber is killing it. Noah can’t believe this rule is really intended to
protect clients. It’s probably a way to force clients to have to trek to a stuffy, old
lawyer’s office and fork over $1,000.
It looks like his mentor, who heads a successful startup, was right after all: Noah
is going to have to start his corporation at Rocket Lawyer by himself. Noah sighs,
thinking it was easier to find his fiancée online through a dating site than it is to
hire a lawyer.
REAL RULINGS, FALSE FEARS

These aren’t fantasy scenarios; they are based on actual ethics opinions. New
York County Lawyers Association Formal Opinion 748
(http://www.nycla.org/siteFiles/Publications/Publications1748_0.pdf) (2015) requires disclaimers in
LinkedIn profiles. State Bar of California Formal Opinion 2016-196
(http://www.calbar.ca.gov/Portals/0/documents/ethics/Opinions/CAL%202016-196%20[12-0006]%20Blogging.pdf)
treats a blog as advertising that’s subject to advertising rules if the attorney
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makes known their availability for service. And New York State Bar Association
Ethics Opinion 1132 (http://www.nysba.org/EthicsOpinion1132/) (2017) finds Avvo Answers
and similar sites to constitute unethical fee splitting, as did a 2016 advisory
opinion (https://www.scbar.org/lawyers/legal-resources-info/ethics-advisory-opinions/eao/ethics-advisory-opinion-
16-06/) from the South Carolina Bar.
As these examples bear out, the parade of horribles that regulators envision—fee
splitting with nonlawyers injecting their interest into the attorney-client
relationship, testimonials and reviews that might dupe clients into hiring an
unqualified lawyer, making objective and useful information online available
through a LinkedIn profile or a blog without prominently labeling it as advertising
(I’m stumped to figure out what kind of harm that could ever cause)—doesn’t
intimidate today’s clients at all.
Most of today’s clients have seamlessly, thoroughly integrated social media and
“sharing-economy” platforms, as well as online payments and content-based
marketing, as part of their daily lives. They’ve acclimated to the cultures of each
online universe they inhabit and grown adept at distinguishing between causal
informational websites and biographical profiles, and chatty personal exchanges
and paid advertising. So when lawyers can’t conform their conduct to these
mores, they’re first viewed with suspicion or annoyance and, ultimately, ignored.
Read more ... (http://www.abajournal.com/magazine/article/legal_ethics_opinion_relevance/P1)
1 2 Next Page
Carolyn Elefant is an energy and eminent domain attorney based in Washington,

D.C. She says blogging at MyShingle “has given me a bird’s-eye view of the
changes that have been roaring through the legal profession and an opportunity
to chronicle and speak on these trends.”
This article was published in the December 2017 issue of the ABA Journal with
the title "Change the Rules! Ethics opinions have to reflect the present and future
—not the past."
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Exhibits From First Amended Complaint - LegalForce v. LegalZoom, January 2, 2018

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Exhibits From First Amended Complaint - LegalForce v. LegalZoom, January 2, 2018

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Case 5:17-cv-07194-NC Document 10-1 Filed 01/02/18 Page 1 of 192

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PO Box 745 Indooroopilly QLD 4068 AUSTRALIA

Audio Length: 13 minutes

Audio Quality: High Average Low

Number of Facilitators: One

Number of Interviewees: One

Difficult Interviewee Accents: Yes No

Operator: Thank you for holding.

Operator: Thank you for holding.

Facilitator: Right. I understand this is the trademark review team, so we just

Interviewee: Sure. My name is Raj, R-A-J, and my last name is Abhyanker,

Facilitator: What’s the…

Interviewee: What’s your name again? Your name is - what’s…

Facilitator: My name is Will.

Interviewee: Will, okay.

Interviewee: R-A-J @ L-E-G-A-L-F-O-R-C-E-L-A-W dot com.

Email enquiries@pacifictranscription.com.au Web www.pacifictranscription.com.au

Interviewee: Yeah, so what I do is I want to allow customers that have small

Interviewee: We do it for them and we basically get a questionnaire, what they

Email enquiries@pacifictranscription.com.au Web www.pacifictranscription.com.au

just end up being creating animation videos for businesses, just as

Interviewee: What do you think is better?

Interviewee: Right. Yeah. So I make…

Facilitator: Okay. So whatever you do to create those animation videos is on

Interviewee: Right. Yes.

Interviewee: Yeah, I think I’ll go with what you recommend.

Email enquiries@pacifictranscription.com.au Web www.pacifictranscription.com.au

trademark in its right designation or right classification, so that it’s

Facilitator: Class 42, because animation design’s in class - is a computer-related

Interviewee: Okay. Cool. So, all right. Great.

Interviewee: So what do you recommend? So which one do you recommend? Do

Interviewee: Which one do you think fits better?

Email enquiries@pacifictranscription.com.au Web www.pacifictranscription.com.au

marketing services, namely creating corporate logos for others.

Interviewee: It’s like drawing.

Facilitator: I absolutely understand that. I’m just using it as a correlative example.

Interviewee: Okay. Thank you.

Facilitator: Do you have any other questions?

Email enquiries@pacifictranscription.com.au Web www.pacifictranscription.com.au

Interviewee: Okay. Then if I give you my website, what do I need to show? Is

Interviewee: Okay. Thank you so much. I’m ready to move forward…

Facilitator: Okay. Right.

Interviewee: …and thanks.

Email enquiries@pacifictranscription.com.au Web www.pacifictranscription.com.au

Email enquiries@pacifictranscription.com.au Web www.pacifictranscription.com.au

PO Box 745 Indooroopilly QLD 4068 AUSTRALIA

Audio Length: 19 minutes

Audio Quality: High Average Low

Number of Facilitators: One

Number of Interviewees: One

Difficult Interviewee Accents: Yes No

Interviewee: LegalZoom. This is Alex. How can I help you?

Facilitator: Yes. I ordered a trademark on LegalZoom and it says that I have

Facilitator: Yes, it's Ryan Bethell. Last name is spelled B-E-T-H-E-L-L.

Facilitator: It's ryanb@legalforcelaw.com.

Interviewee: And also the name of your trademark.

Interviewee: Let me see here. That’s going to be up to you, essentially, and on

Email enquiries@pacifictranscription.com.au Web www.pacifictranscription.com.au

Facilitator: Okay. What - so then we've got - we do two things. We have a

Interviewee: Right, okay, I see. That could be - if that software is actually

Facilitator: Okay. That would be - so those would be separate though, those

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