13. In 2012, a blogger with the ID of "wuseban" published my address at "2777 Alvarado Steet [sic] Suite C San Leandro California 94577" and other personal information at http://blog.sinovision.net/home/space/do/blog/uid/179595/id/162224.html . 

On August 30, 2014, Defendant Han posted a blog article at http://www.towngain.com/home.php?mod=space&uid=2144&do=blog&id=19412 . In the article, Han included a photo of the California data center where ZZB servers were hosted. Han stated that he discovered the blog of "wuseban" which published my personal information. Han wrote in mixed Chinese and English: "记得，后来岳东晓被五色版查到他的老底，包括公司名/地址等等个人信息，这是人们不愿意被披露的。那么是否可以保护这些个人信息呢？原来各公司都有privacy protection plan。比如，GoDaddy是$7.99/年。看来岳东晓为了一年省8块钱，隐私没有保护，所以让人兜了老底。" (English Translation: "I (Han) remember, later Yue Dongxiao's background was found out by Wuseban, including personal information such as company name/address etc. etc, this is what people are unwilling to disclose. Then can these personal information be protected? Usually most companies have privacy protection plans. For example, GoDaddy's cost is $7.99 per year. It appears that Yue Dongxiao, in order to per year save 8 dollars of money, failed to protect his privacy, and his background was dug out." )  Han's blog article included a link to http://blog.sinovision.net/home/space/do/blog/uid/179595/id/161735.html, which was a blog article written by "wuseban" in July 2012, where wuseban showed that the ZZB's servers were hosted by Hurricane Electric (he.net), at "48233 Warm Springs Blvd, Fremont, CA 94539."  Attached Exhibit 2 contains true copies of Han's above blog article, and wuseban's blog articles Han linked to or referenced, with the relevant portions circled.

14. According to Han's blog article at http://www.towngain.com/home.php?mod=space&uid=2144&do=blog&id=19467, he publicly launched a website at the domain name hanshan.co ("HANSHAN") on September 10, 2014. On the same day, Han also posted the announcement of the opening of HANSHAN on several other websites, including Backhina.com, yeyeclub.com and hanshan.co . Attached Exhibit 3 is a true copy of Han's announcement for the HANSHAN website.

 1. HAN'S DECLARATIONS ARE SUBSTANTIALLY FALSE

 Defendant Han has made three inconsistent declarations. The last one was largely blatant false accusations or conclusions. Plaintiff will refer to the one in Docket 42-1 (Han Decl.).

 Han claims that Hanshan.Co "shut down thoroughly on October 19, 2014." (Han Decl. ¶3.) Yet, Plaintiff accessed and saved pages from Hanshan.Co on July 31, 2015. (Yue Decl. ¶20; Ex. 5.) 

 Han swears that " Both hanshan.co and hanshan.info have NOT been RELY ON email as means of communication to users." (Han Decl. ¶6.) This is obviously false. When registering on HANSHAN, Plaintiff received an email from [email protected] specifically asked him to contact HANSHAN by email for any questions (Yue Decl. ¶24; Ex. 7.). Without email, a person cannot complete the registration process on HANSHAN.  Exhibit B to Han's declaration shows him reading emails sent to [email protected] and [email protected]. (Han Decl. ¶5; Ex. B) Han admits that he received Plaintiff's infringement notice from Goddady.com. (Han Decl. ¶11.), but conceals the fact that he received the notice by email.

 Han swears that he "knew nothing about Plaintiff’s personal information until after this law suit was filed." (Han Decl. ¶10.) This is knowingly false. On August 30, 2014, Han wrote a lengthy blog article which included a picture of the data center of ZZB (in Fremont, CA) and discussed Plaintiff's personal information (Yue Decl. ¶ 13; Ex. 2.); Plaintiff's infringement notice to HANSHAN included Plaintiff's address and phone number (Yue Decl. ¶18; Ex. 4.), Han received the notice in October 2014 (Han Decl. ¶11.); Han admits that he received the subpoena issued by Superior Court of California in June 2015 (Han Decl. ¶¶4-5), that subpoena had Plaintiff's name, address and telephone number on it. (Yue Decl. ¶25; Ex.8.); Exhibit A to Han's declaration shows a June 2015 message to Han, which included Plaintiff's Yahoo email address and fax number with 510 area code. This lawsuit was filed in July 2015.