UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ...

Case 0:10-cv-61942-MGC Document 5-4 Entered on FLSD Docket 10/14/2010 Page 3 of 10
used in the WHOIS registration records for the domain names bijouxtiffanyco.com and
tiffanyandcopascher.com, residing or operating in the building. Moreover, “10012” is not a valid
postal code in Hong Kong. I also attempted to contact Defendant Lin via telephone at
+86.02321979211, the contact telephone number Defendant Lin listed on the WHOIS
registrations for the websites operating under the domain names bijouxtiffanyco.com and
tiffanyandcopascher.com, and determined this telephone number is not valid. I determined this
number is invalid because it is not a registered telephone number in China. Specifically, this
telephone number is an unregistered number and has not been issued for anyone’s use. When I
called this number, a voice informed me that it was not registered and was invalid.
6. I analyzed the physical address provided by Defendant Lin on the contact section
of the WHOIS records for the domain names bijouxtiffanyfrance.com, bracelettiffany.com,
francetiffany.com, tiffanyandcofrance.net 1 , and tiffanyzuerich.com, “Centre 11-13 Shing Yip
Street, hangkong, HK, 10011, CN,” and determined this address is invalid. Although there is an
office building called Wah Shing Centre located on 11-13, Shi Yip Street, Hong Kong, a valid
address in Wah Shing Centre must include a floor number and room number. The address
provides neither a floor number nor room number. Moreover, a representative from the
management office of the building confirmed to me that there is no record of any individual or
business using the name “Kong Yuen,” the alias Defendant Lin used in the WHOIS registration
records for the domain names bijouxtiffanyfrance.com, bracelettiffany.com, francetiffany.com,
tiffanyandcofrance.net, and tiffanyzuerich.com, residing or operating in the building. Also,
“10011” is not a valid postal code in Hong Kong. I also attempted to contact Defendant Lin via
telephone at +86.02111979211, the contact telephone number Defendant Lin listed on the
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Additionally, I analyzed the physical address provided on the shipping label on the outer packaging of the purchase
received by Jason Holmes from Defendant Lin via the website tiffanyandcofrance.net, “9F-2 (Brother Plaza), 77,
Sec. 4, Nanking East Road Hong Kong,” and determined the address is false. Specifically, there is no Brother Plaza
or Nanking East Road in Hong Kong.
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