DEBEVOISE & PLIMPTON LLP

1 DEBEVOISE & PLIMPTON LLPJ onathan R. Tuttle801 Pennsylvania Avenue , Suite 500 Washington, 20004(202) & PLIMPTON LLPD avid H. Bernstein (pro hac vicepending)Christopher S. Ford (pro hac vicepending)919 Third AvenueNew York, New York 10022(212) STATES DISTRICT COURTEASTERN DISTRICT OF VIRGINIAALEXANDRIA DIVISION_____DEBEVOISE & PLIMPTON LLP,Plaintiff, , )))))))))))))Civil Action No. _____COMPLAINTP laintiff DEBEVOISE & PLIMPTON LLP ( DEBEVOISE ), for its Complaint in thisaction, complains and alleges as follows:Preliminary an internationally well-known law firm that owns theregistered trademarks DEBEVOISE and DEBEVOISE & PLIMPTON files thisinremaction pursuant to the Anti-cybersquatting Consumer Protection Act ( ACPA ), 1125(d), against theres, the above-captioned domain names, < > and < >.

2 The < > and < DEBEVOISE -Case 1:21-cv-01386-LO-IDD Document 1 Filed 12/13/21 Page 1 of 11 PageID# > domain names expropriate the entirety of the distinctive DEBEVOISE WHOIS Registration Record ( WHOIS Record ) for < > and < > has the registrant s name, organization, address,phone number and email address redacted by a privacy service based in addition to cybersquatting through use of the DEBEVOISE mark, the< > domain is being used in a fraudulent scheme to imitate theDebevoise law firm and its attorneys. On information and belief, the registrant and/ortheir affiliates have sent emails from < > purporting to be actualDebevoise attorneys, such as Christopher Anthony, and sent these phishing emails tothird parties in an attempt to obtain sensitive information or funds.

3 An example of thesemalicious emails using the < > domain is attached, along withChristopher Anthony s legitimate biography A and < > domain currently redirects the visitor toDebevoise s legitimate website, which is located at Oninformation and belief, this redirection is a means of tricking recipients of the fraudulentemails into thinking that the < > domain is a legitimate domain ownedand operated by DEBEVOISE , which it is < > domain currently displays paid-per-clickadvertisements for competitive legal services in an improper attempt to profit off of thegoodwill and reputation that DEBEVOISE has established in the legal market by advertisinghighly related services using a confusingly similar 1:21-cv-01386-LO-IDD Document 1 Filed 12/13/21 Page 2 of 11 PageID# bad faith registration and abuse of < > and< > is causing irreparable harm to DEBEVOISE and putting innocentindividuals at risk of serious financial loss.

4 DEBEVOISE is entitled to a mandatorypreliminary injunction requiring the immediate transfer of the domain names and otherappropriate & PLIMPTON LLP is a limited liability partnership registered inthe State of New York with a principal place of business at 919 Third Avenue, NewYork, NY < > and < > domains areregistered with Namecheap Inc. ( Namecheap ) and the registrant s contact informationis redacted from the WHOIS Record. DEBEVOISE is unable to determine the identity ofthe registrant from the WHOIS Record; however, the WHOIS record does disclose thatthe privacy service is located in Reykjavik, Iceland.

5 The WHOIS Records showing theredacted registration information for < > and < > isattached as Exhibit and Court has subject matter jurisdiction over this action pursuant to15 1121(a), 1125(d), 28 1331, 1332, 1338 and 28 1125(d)(2)(A) provides for anin remaction against a domainname if the owner of the trademark is unable to obtain personal jurisdiction over a personwho would have been a defendant under 1125(d)(1). The registrant of < DEBEVOISE -Case 1:21-cv-01386-LO-IDD Document 1 Filed 12/13/21 Page 3 of 11 PageID# > and < > would have been a defendant under Section1125(d)(1) because both of the domains are confusingly similar indeed, identical tothe federally registered DEBEVOISE trademark.

6 Further, the domain names are beingused in bad faith to profit from the goodwill of the distinctive DEBEVOISE trademarkand < > is attempting to trick unsuspecting visitors and recipients intogiving the registrant and/or their affiliates their sensitive information or information and belief, DEBEVOISE is unable to obtain personaljurisdiction over the registrant of the < > and < >domain names. Because the registrant is using an Iceland-based privacy service to masktheir identity, DEBEVOISE has been unable to contact the registrant directly, and attemptsto contact the registrant through the Icelandic privacy service have been in DEBEVOISE s attempt to identify and contact the registrant has uncovered anyfacts that would establish personal jurisdiction over the registrant.

7 Upon information andbelief, the registrant s only contact with the United States is its registration of< > and < > domain names with the and hosting service, Court has jurisdiction over theres, the < > and< > domain names, pursuant to 15 1125(d)(2)(C)(i), becauseVerisign Global Registry Services ( Verisign GRS ), the registry which is the exclusiveregistry for all TLD .com domain names, including < > and< >, has its principal place of business in Reston, CableNews Network, LP, LLLP v. , 56 F. App'x 599, 602 (4th Cir. 2003)Case 1:21-cv-01386-LO-IDD Document 1 Filed 12/13/21 Page 4 of 11 PageID# 45(affirming the district court s ruling that, because the registry, VeriSign GRS, is in theEastern District of Virginia, the court had jurisdiction under the ACPA).

8 Verisign GRSmaintains the shared reservation system for .com domain names that allows allregistrars, including Namecheap, to enter new domain names into the master directoryand to submit modifications, transfers, re-registrations and deletions of existing .com domain notice of this action to Namecheap, the current registrar of thedomain names, Namecheap is required, pursuant to 15 1125(d)(2)(D)(i)(I), todeposit the registrar certificate that will provide this Court with control over the< > and < > domain is proper in this district under 28 1391(b) because asubstantial part of the events giving rise to the claim occurred in this DEBEVOISE is a leading international law firm with offices across the worldthat handles a wide breadth of legal services ranging from, but not limited to,international dispute resolution to intellectual property litigation to corporate mergers andacquisitions.

9 DEBEVOISE is of international renown it is the only law firm to appear ontheAmerican LawyerA-list every year since that lists inception. Further, DEBEVOISE andits lawyers are regularly mentioned in public decisions by prominent courts and othertribunals. DEBEVOISE is also often featured in leading publications such asThe New YorkTimesandThe Wall Street 1:21-cv-01386-LO-IDD Document 1 Filed 12/13/21 Page 5 of 11 PageID# is the sole and exclusive owner of a number of registered,incontestable trademarks in the United States, including DEBEVOISE ( Reg. ,777,096) and DEBEVOISE & PLIMPTON ( Reg.)

10 No. 2,513,942). TheDEBEVOISE and DEBEVOISE & PLIMPTON trademarks are also registered inmany countries throughout the world, including, but not limited to, the United Kingdom,the European Union, China, Japan, India, South Korea, Turkey, and the has an active presence on the Internet and maintains onlineblogs and newscasts to further build and expand its online D. Theprincipal domain name registered by DEBEVOISE is < >. Debevoiseregistered this domain name in on June 13, 1996, and has used the domain name inconnection with its website and its corporate email. DEBEVOISE also owns other domainnames that incorporate the DEBEVOISE mark, including but not limited to,< > and < >.