JOHN DOE'S COUNTER NOTIFICATION

TO POWERMARK HOMES 2ND DMCA COPYRIGHT INFRINGEMENT CLAIM

From: "Greg Beck" <gbeck@citizen.org>
Date: Mon, October 08, 2007 4:05 pm
To: <abuse@godaddy.com>

I am an attorney for the anonymous owner of the website powermarkhomessuckscom ("John Doe"). Pursuant to your Copyright Dispute Policy, I am submitting this email as a Counter Notification to the claim of copyright infringement submitted by Bruce W. McClain earlier today. Mr. McClain claimed that a photograph at http://powermarkhomessucks.com/PHI_exhibitA.htm violated the copyright of Powermark Homes, Inc.

I declare under penalty of perjury that I have a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled. Doe consents to jurisdiction in the Federal District Court for the judicial district of Arizona and will accept service of process from the complaining party or an agent of such party.

*Because there is pending litigation to discover the identity of John Doe, it is important that no identifying information regarding Doe be sent to Mr. McClain attached to this Counter Notice.*

/s/Gregory A. Beck
Gregory A. Beck
Attorney for John Doe
1600 20th St. NW
Washington, DC 20009
Ph: 202-588-7713
Fax: 202-588-7795
gbeck@citizen.org
_______________________
Gregory A. Beck
Public Citizen Litigation Group
1600 20th Street, NW
Washington, DC 20009
202.588.7713 (phone)
202.588.7795 (fax)
http://www.citizen.org/litigation/