Blank Declaration in Support

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

JAMES S. GORDON, Jr., a married
individual, d/b/a ‘GORDONWORKS.COM';
OMNI INNOVATIONS, LLC., a
Washington limited liability company,
Plaintiffs,

v.

VIRTUMUNDO, INC, a Delaware
corporation d/b/a
ADNOWLEDGEMAIL.COM;
ADKNOWLEDGE, INC., a Delaware
corporation, d/b/a
ADKNOWLEDGEMAIL.COM; SCOTT
LYNN, an individual; and JOHN DOES,
1-X,
Defendants.

DECLARATION OF ERIC P. BLANK IN SUPPORT OF DEFENDANTS’ MOTION FOR ATTORNEYS’ FEES AND COSTS

I, Eric P. Blank, declare and testify as follows:

1. I am over eighteen years of age, competent to testify to the matters stated in this declaration, and make this declaration based upon personal knowledge.

2. Since 1996, I have been an attorney licensed to practice in Washington State. I am admitted to practice in the Western District of Washington and regularly have cases in this district.

3. I am the principal at Blank Law & Technology P.S. My practice focuses on technology, intellectual property and Internet-related litigation, and I
-2-
routinely represent clients in federal district court on technology matters similar to those at issue in the above-captioned action.

4. I have reviewed the rate sheet from Newman & Newman, LLP attached hereto as Exhibit A and find it to be reasonable and consistent with the prevailing rates for attorneys in this legal community for matters of similar complexity, novelty and legal exposure.

5. The rates charged by Newman & Newman, LLP are consistent with or less than the hourly rates at my law firm, to my understanding, and other comparable attorneys who practice in the same area of law.

6. I am familiar with the skill, expertise, and reputation of the attorneys at Newman & Newman, LLP and believe that they are particularly well qualified to represent parties in complex Internet-related litigation.

7. Furthermore, I recognize that Newman & Newman is well-known in the local legal community for its expertise and skill in representing clients in complex CAN-SPAM, RCW 19.190 et seq. and email-related litigation, and based on that expertise and reputation, it is reasonable that they charge hourly rates of greater than $350 for senior attorneys and $200 per hour for junior attorneys.

I certify and declare under the penalty of perjury under the laws of the State of Washington and the United States that to my knowledge the foregoing is true and correct.

Executed on this 19th day of June, 2007, at Seattle, Washington.

Eric P. Blank

Attachment	Date	Size
MotFeesCostsBlankDec.pdf	06/28/09 1:04 pm	109.24 KB
MotFeesCostsBlankDecExhA.pdf	06/28/09 1:04 pm	5.61 KB