UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ...

Case 0:10-cv-61942-MGC Document 5-4 Entered on FLSD Docket 10/14/2010 Page 6 of 10
number in China. However, I placed numerous phone calls throughout the day, but each time the
phone was off, and I was not able to leave a message.
11. I analyzed the physical address provided by Defendant Lin on the contact section
of the WHOIS record for the domain name tiffanycofrance.com, “Topeka, KS 66607, hangkong,
HK, 10012, CN,” and determined this address is invalid. Specifically, Topeka is not a part of
Hong Kong. Further, “10012” is not a valid postal code in Hong Kong. I also attempted to
contact Defendant Lin via telephone at +86.02474232921, the contact telephone number
Defendant Lin listed on the WHOIS registration for the website operating under the domain
name tiffanycofrance.com and determined the telephone number to be invalid. 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.
12. I analyzed the physical address provided by Defendant Lin on the contact section
of the WHOIS records for the domain names tiffanycoonlineshop.com and
tiffanyschmuckonline.com, “12 Pedder Street, hangkong, HK, 10011, CN,” and determined this
address is invalid. Although there is a building called Pedder Building located on No. 12 Pedder
Street, Hong Kong, a valid address in the Pedder Building must include a floor number and room
number. Additionally, 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 “Hendy Hally,” the alias
Defendant Lin used in the WHOIS registration records for the domain names
tiffanycoonlineshop.com and tiffanyschmuckonline.com, residing or operating in the building. I
also attempted to contact Defendant Lin via telephone at +86.02711979211, the contact
telephone number Defendant Lin listed on the WHOIS registrations for the websites operating
under the domain names tiffanycoonlineshop.com and tiffanyschmuckonline.com and
6