UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ...

Case 0:10-cv-61942-MGC Document 5-5 Entered on FLSD Docket 10/14/2010 Page 13 of
257
tiffanysonlineshop.com. (Composite Exhibit “2,” pp. 27, 43, 44, 49, 53, 54, 55,
59, 60, attached hereto.)
The phone number “+86.1070123453” is provided as the contact phone number in
the WHOIS data registration records for the Internet websites operating under the
domain names francetiffanybijoux.com, tiffanyandcofr.com, tiffanybijouxfr.com,
and tiffanyfrancebijoux.com. (Composite Exhibit “2,” pp. 14, 33, 42, 48, attached
hereto.)
The phone number “+86.5242652238” is provided as the contact phone number in
the WHOIS data registration records for the Internet websites operating under the
domain names bijoux-tiffany.com, tiffanysde.com, and tiffanysuk.com.
(Composite Exhibit “2,” pp. 4, 58, 62, attached hereto.)
Self-Identification 3
The Internet websites operating under the domain names bijouxtiffanyco.com and
tiffanysfrance.com self-identify as “bijouxtiffanyco”. (Composite Exhibit “1,”
pp. 12, 154, attached hereto.)
The Internet websites operating under the domain names tiffany-deutschland.com
and tiffany-deutschland.net self-identify as “tiffany-deutschland.com”.
(Composite Exhibit “1,” pp. 40, 45, attached hereto.)
The Internet websites operating under the domain names tiffanyandcofr.com and
tiffanyandcoparis.net self-identify as “tiffanyandcofr.com”. (Composite Exhibit
3 Self-identifications, how websites themselves identify the merchant’s e-business on the sites, are a very useful
indicator of common control and connections between websites. Sometimes, the common branding of multiple
domain names by the owner/operator of the domain names may be intentional, as the merchant desires to create a
connection in the minds of customers between the websites and to encourage customers to visit multiple sites.
Another explanation is the rushed reuse of a previously operated site, which was not carefully edited to remove all
references to its previous incarnation.
13