IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
e360 INSIGHT, LLC, an Illinois Limited
Liability Company, and DAVID LINHARDT,
an individual,
Plaintiffs,
v.
THE SPAMHAUS PROJECT, a company
limited by guarantee and organized under the
laws of England, a/k/a THE SPAMHAUS
PROJECT, LTD.,
Defendant.
DECLARATION OF STEVE LINFORD1
I, Steve Linford, declare and state as follows:
1. I am the sole Director of The Spamhaus Project, LTD. I either have personal knowledge as to the facts and matters set forth in this affidavit or I have determined that such facts and matters are true and correct on the basis of information obtained from various sources, including my own personal experience, in the regular course of business, as Officer/Director of The Spamhaus Project, LTD.
2. I make this Affidavit to certify the responses provided in the Response to Citation to Discover Assets, and to assert and preserve any objections to this Court’s personal jurisdiction over The Spamhaus Project, LTD, while at the same time, attempting in good faith to comply
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1 Defendant expressly objects to this Court’s jurisdiction over The Spamhaus Project because Defendant is based solely in the United Kingdom and does not conduct or transact business in Illinois. Moreover, Defendant reserves its arguments based on Plaintiff’s failure to properly effect service of process. These objections are made notwithstanding Defendant’s good faith effort to comply with this Court’s order that it respond to the Citation to Discover Assets.
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with this Court’s Order that The Spamhaus Project, LTD respond to the Citation to Discover Assets filed by the Plaintiff.
3. I have read the Citation to Discover Assets and assert that the answers provided in the Response are true and correct to the best of my knowledge and belief.
4. The Spamhaus Project, LTD is a non-profit company organized under the laws of the United Kingdom, with its principle place of business in London, United Kingdom. The Spamhaus Project, LTD is not a citizen of Illinois.
5. The Spamhaus Project, LTD conducts no business with consumers directly.
6. The Spamhaus Project, LTD has no subsidiaries, successors, parent companies, or other such related entities.
7. The only location in which The Spamhaus Project, LTD does business is the United Kingdom. The Spamhaus Project, LTD does not have any employees in Illinois or anywhere else and does not pay any salaries or taxes in Illinois.
8. The Spamhaus Project, LTD has no physical or other presence in Illinois. It does not own, lease or have any interest in any real property and has no offices, warehouses, plants, suppliers, distributors, agents, employees, mailboxes, telephone listings, bank accounts, or business operations in Illinois. The Spamhaus Project, LTD is not registered or qualified to do business in Illinois, does not provide goods or services to persons in Illinois, and does not derive or expect to derive any direct revenue from goods consumed or services rendered in Illinois.
9. The Spamhaus Project, LTD is not required to and does not maintain a registered agent for service of process in Illinois.
10. The Spamhaus Project, LTD does not develop advertisement campaigns specifically for Illinois.
11. The Spamhaus Project, LTD is not a party to any contract with any person or entity located in the State of Illinois or calling for performance in the State of Illinois.
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
Executed this 10th day of November 2006.
______________________
Steve Linford