Page 1
E-FILED
5/30/2019 8:52 AM
Clerk of Court
Superior Court of CA,
County of Santa Clara
19CVReviewed By: Y. Chavez
Ann Marie Mortimer (State Bar No. 169077)
amortimer@HuntonAK.com
Jason J. Kim (State Bar No. 221476)
kimj@HuntonAK.com
HUNTON ANDREWS KURTH LLP
550 South Hope Street, Suite Los Angeles, California 90071-Telephone: (213) 532-Facsimile: (213) 532-Attorneys for Plaintiff
FACEBOOK, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA CLARA
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
FACEBOOK, INC., a Delaware corporation,
Plaintiff,
CASE NO.:
19CV
COMPLAINT; DEMAND FOR JURY TRIAL
v.
TOLOCAL, INC., TOMONGOAD, INC., and
MIN GE a/k/a “Keater Ge,”
Defendants.
COMPLAINT; DEMAND FOR JURY TRIALPage 2
Plaintiff Facebook, Inc. (“Facebook”) alleges the following:
INTRODUCTION
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
1.
Between March 2018 and April 2019, Defendants ToLocal, Inc., ToMongoAd, Inc.,
Min Ge also known as “Keater Ge” (“Min Ge”), and others, operated a deceptive and misleading
advertising (“ads”) scheme on Facebook and Twitter. On Facebook, Defendants used deceptive and
misleading ads to lure Facebook users from the Facebook platform to websites designed to harvest
their email addresses and other contact information for email spam1 and automated telemarketing
campaigns (“robocalls”). Defendants’ ads falsely represented to Facebook users that they could check
their eligibility for tax credits and rebates related to solar energy initiatives by clicking on links in the
ads. Defendants’ ads redirected Facebook users to websites controlled by Defendants that prompted
Facebook users, with false and misleading promises of tax credits, solar panel installations, and other
purported state-sponsored solar energy initiatives, to input their contact information, including their
name, physical address, email address, and phone number. Defendants then collected and sold the
users’ contact information to online marketers and advertisers.
Facebook’s Terms of Service (“TOS”), Advertising and Page Policies, and California law. Facebook
brings this action for damages and to stop Defendants’ use of its platform in violation of its TOS and
Policies.
PARTIES
Defendants’ actions violate
2.
Plaintiff Facebook, Inc., is a Delaware corporation with its principal place of business
in Menlo Park, San Mateo County, California.
3.
ToLocal, Inc. (“ToLocal”) promotes itself as an advertising, digital marketing, and
public relations firm that operates the website tolocal.com. Ex. 1. ToLocal was incorporated in the
State of California on August 20, 2014. See Ex. 2. According to incorporation records, ToLocal’s
corporate address is 2100 Geng Rd. Suite 100, Palo Alto, California. Ex. 3. According to ToLocal’s
website, ToLocal’s address is 2483 Old Middlefield Way, Suite 202, Mountain View, California. See
Ex. 1.
In this complaint, “spam” refers to unsolicited email advertisements.
COMPLAINT; DEMAND FOR JURY TRIALPage 3
August 11, 2015. See Ex. 4. ToMongoAd was originally incorporated under the name “Global
XCapital Express Inc.” and changed its corporate name to ToMongoAd on March 23, 2016. Ex. 5.
The website tomongoad.com redirects users to the website tolocal.com.
tomongoad.com was registered by ToLocal. See Ex. 6.
5.
The domain name
Defendant Min Ge uses the alias “Keater Ge” and has been the sole Director, Chief
Executive Officer, Secretary of ToLocal since 2017. See Ex. 3. Min Ge has previously held the title
of President of ToLocal. Ex. 7. According to corporate records, Defendant Min Ge has been the
President and Secretary of ToMongoAd since March 2016. Ex. 8. Min Ge resides in Mountain View,
Hunton Andrews Kurth LLP
ToMongoAd, Inc. (“ToMongoAd”) was incorporated in the State of California on
550 South Hope Street, Suite Los Angeles, California 90071-
4.
California.
6.
At all times material to this action, each Defendant was the agent, employee, partner,
alter ego, subsidiary, or coconspirator of and with the other Defendants, and the acts of each Defendant
were in the scope of that relationship. In doing the acts and failing to act as alleged in this Complaint,
each Defendant acted with the knowledge, permission, and the consent of each of the other
Defendants; and, each Defendant aided and abetted the other Defendants in the acts or omissions
alleged in this Complaint.
JURISDICTION AND VENUE
7.
This Court has subject matter jurisdiction pursuant to California Code of Civil
Procedure § 410.10. The amount in controversy exceeds the jurisdictional minimum of this Court,
and the total amount of damages sought exceeds $25,000, exclusive of interest and costs. The
contractual interest at stake in this litigation has significant value to Facebook. Further, Defendants’
unlawful conduct and breaches have interfered with Facebook’s business and operation of its service.
8.
The Court has personal jurisdiction over ToLocal and ToMongoAd because they are
incorporated in the State of California and are located in Palo Alto and Mountain View, California.
9.
The Court has personal jurisdiction over Defendants Min Ge because he is a resident
of Mountain View, California.
10.
Venue is proper in this Court because a substantial part of the events giving rise to the
claims raised in this lawsuit occurred in Santa Clara County.
COMPLAINT; DEMAND FOR JURY TRIALPage 4
A.
Background on Facebook
11.
Facebook is a social networking website and mobile application that enables its users
to create their own personal profiles and connect with each other on their personal computers and
mobile devices. As of March 2019, Facebook daily active users averaged 1.56 billion and monthly
active users averaged 2.38 billion.
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
FACTUAL ALLEGATIONS
12.
Unlike personal Facebook user profiles, a Facebook Page is a public page on Facebook
designed for businesses, organizations, and public figures. A person can only create or manage a
Facebook Page if they are a Facebook user and have a personal Facebook account. Facebook Pages
can be managed by different users as administrators or moderators. The Facebook user that creates
the Page will be designated as the Page’s administrator by default.
13.
Page administrators and moderators can create and run ads and promotions on behalf
of their Facebook Pages.
B.
Facebook’s TOS, Pages and Advertising Policies
14.
Everyone who uses Facebook must agree to Facebook’s TOS (available at
https://www.facebook.com/terms.php) and other rules that govern access to, and use of, Facebook.
Facebook’s TOS prohibit violations of Facebook’s Advertising Policies (available at
https://www.facebook.com/policies/ads/) and Pages, Groups, and Events Policies (“Pages Policies”)
(available at https://www.facebook.com/policies/pages_groups_events/).
15.
Facebook’s TOS, Section 3.2.1, prohibits using Facebook “to do or share anything”
that (a) violates Facebook’s TOS or other terms and policies, which includes the Advertising and Pages
Policies; (b) “is unlawful, misleading, discriminatory, or fraudulent;” and (c) “infringes or violates the
someone else’s rights.”
16.
Facebook’s Pages Policies apply to the creators of Pages on Facebook. Pages Policy
2.1 states that “Pages . . . must not be misleading, fraudulent, or deceptive.”
17.
Facebook’s Advertising Policies apply to ads on Facebook. Advertising Policy 4.
states that “ads, landing pages, and business practices must not contain deceptive, false, or misleading
content, including deceptive claims, offers, or methods.” Advertising Policy 12.1 states that “any ad
COMPLAINT; DEMAND FOR JURY TRIALPage 5
data collected, received, or derived from your Facebook or Instagram ad . . . is only shared with
someone acting on your behalf, such as your service provider.” Advertising Policy 12.4 stated “Don’t
transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad
network, ad exchange, data broker and other advertising or monetization related service.”
C.
Defendants’ Deceptive Advertising Scheme
18.
Between March 2018 and April 2019, Defendants operated a deceptive and misleading
advertising scheme using Facebook and Twitter. On Facebook, Defendants’ scheme was designed to
deceive Facebook users into clicking on their ads and visiting Defendants’ websites in order to harvest
the users’ contact information for spam and robocall marketing campaigns. Defendants’ scheme
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
generally proceeded in three steps:
a. Defendants created Facebook Pages designed to promote false, misleading, and
deceptive information about purported state-sponsored solar energy initiatives, such as
free solar panel installations for Facebook users’ homes and millions of dollars in
government rebates and incentives for homeowners.
b. Defendants used their Facebook Pages to purchase ads containing false, misleading,
and deceptive advertising that solicited Facebook users to determine their eligibility for
state-sponsored “solar rebates” and “solar incentives” that did not exist. Defendants’
ads depicted images of United States elected officials, such as President Donald J.
Trump and state governors, in order to bolster the credibility of the ads and mislead
Facebook users.
c. When the Facebook users clicked on the ads, they were directed to websites controlled
by Defendants and prompted to enter their contact information, including name,
physical address, email address, and phone number. Defendants’ then collected and
sold this information for spam, robocalls, and other marketing campaigns.
19.
Defendants’ ads were directed at Facebook users located in various states, including
California, Massachusetts, New York, Illinois, Florida, Nevada, Texas, Delaware, New Mexico, New
Jersey, Connecticut, Colorado, Idaho, and Arizona.
COMPLAINT; DEMAND FOR JURY TRIALPage 6
1. Defendants Created and Administered Deceptive and Misleading Facebook
Pages as Part of Their Scheme.
20.
on Facebook, Defendants and others working on behalf of ToLocal created multiple Facebook Pages.
At least three of these Pages were in the names of businesses, such as “Solar Energy Today,” “Home
Saving Net,” and “Solar Rebate.” Defendants’ Pages were used to promote false, misleading, and
deceptive content related to state-sponsored “solar rebates,” “solar incentives,” and tax credits.
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
Between March 2018 and April 2019, to support their deceptive advertising campaign
21.
On March 7, 2016, Defendant Min Ge created a Facebook Page using the business
name “Social Energy Today” (the “Social Energy Page”). On September 17, 2016, Defendant Min
Ge created a Facebook Page using the business name “Solar Rebate” (the “Solar Rebate Page”). On
June 14, 2017, a ToLocal employee created a Facebook Page using the business name “Home Saving
Net” (the “Home Saving Page”). Defendant Min Ge and several ToLocal employees administered
and moderated the Social Energy Page, the Solar Rebate Page, and the Home Saving Page.
22.
For example, as shown in Figure 1, on or about February 25, 2019, the Solar Energy
Page created by Defendant Min Ge posted misleading content in order to entice Facebook users to
click on a link on the Page. In fact, Facebook users who clicked on the link were redirected to landing
pages controlled by Defendants, which were designed to harvest their contact information.
///
///
///
///
///
///
///
///
///
///
///
COMPLAINT; DEMAND FOR JURY TRIALPage 7 Figure 1: Solar Energy Page Post
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
2. Defendants Purchased Deceptive Ads Using Their Facebook Pages.
23.
In order to reach more Facebook users, Defendants and others working on behalf of
ToLocal and ToMongoAd, created, purchased, and ran thousands of ads using their Facebook Pages.
24.
For example, between May 2018 and April 21, 2019, the Solar Energy Page purchased
and ran approximately 4,790 ads on Facebook, for the purpose of generating leads information for
spammers and robocallers. These ads were paid for by ToLocal and ToMongoAd. Defendants’ ads
frequently used images of state and federal elected officials to promote the legitimacy of the ads.
25.
The Social Energy Page ads contained false, deceptive, and misleading statements
related to “solar incentives” and “solar rebates.” As set forth in Figure 2, on October 8, 2018, one of
these ads targeted residents of New York and falsely claimed that “Gov. Cuomo will release $
million in solar incentives for NY home solar expansion,” and that New York homeowners could
COMPLAINT; DEMAND FOR JURY TRIALPage 8
“enter their zip code and answer 3 simple questions” to determine if they qualified for “new 2018 Gov.
sponsored incentives.” Ex. 9. In fact, Defendants collected and sold the information entered by users
in response to their questions for spam, robocalls, and other marketing campaigns.
Figure 2: Solar Energy Page Advertisement - New York
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
26.
Between October 2018 and November 2018, Defendants also claimed that the
governors of New Jersey, Texas, Florida, and California were also releasing “$10 million solar
incentives (sic)” in similar ads direct at residents of each of those states. Ex. 10 – 13.
27.
As set forth in Figure 3, one of the Solar Energy Page ads targeted residents of
California, falsely claiming that “Governor Jerry Brown will release $100 million solar incentives for
California solar expansion” and these were available to individuals “lucky enough to live in an active
zip code,” and limited to “150 applicants per day.” Ex. 14. These ads included a misleading image of
California Governor Jerry Brown.
COMPLAINT; DEMAND FOR JURY TRIALPage 9 Figure 3: Solar Energy Page Advertisement - California
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
28.
Between October 26, 2018 and November 12, 2018, Defendants also claimed that the
governors of Delaware, New Mexico, New York, New Jersey, and Arizona were also going to “release
$100 million solar incentives” in similar ads directed at residents of each of those states and containing
images of various governors. Ex. 15 - 19.
29.
The Home Saving Page ads also contained false, deceptive, and misleading statements
related to “solar incentives” and also used the same or similar images as the Solar Energy Page ads.
As set forth in Figure 4, one of the Home Saving Page ads was directed at residents of Nevada,
contained an image of the Nevada Governor, and falsely stated: “ATTENTION NEVADA HOME
OWNERS: There is a new policy just signed . . . Gov. Steve Sisolak will release $15 million in solar
incentives . . . . Check it out and see if you qualify!”
COMPLAINT; DEMAND FOR JURY TRIALPage 10 Figure 4: Home Saving Page Ad
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
30.
Between February 8, 2019 and February 15, 2019, Defendants also claimed that the
governors of California, Connecticut, Illinois, Massachusetts, Colorado, and Idaho were also going to
“release $15 million solar inceptives” in similar ads and used images of those governors. Ex. 20 - 25.
31.
The Solar Rebate Page ads also contained false, deceptive, and misleading statements
related to state-sponsored giveaways of solar panels. As set forth in Figure 5, some of the Solar Rebate
Page ads directed at Texas residents, contained an image of the Texas Governor Greg Abbot and
President Donald J. Trump, and falsely claimed that the State of Texas was “set to give solar panels
to homeowners at no cost down.”
///
///
///
COMPLAINT; DEMAND FOR JURY TRIALPage 11 Figure 5: Solar Rebate Page Advertisement
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
3. Defendants’ Ads Directed Facebook Users to Websites Designed to Harvest
Their Contact Information.
32.
Facebook users who clicked on Defendants’ ads on Facebook were redirected to
websites (which included various landing pages) controlled by Defendants. One of Defendants’
websites was hosted on the domain solar-energy-today.com, registered to Defendant Min Ge as the
domain name registrant, the registrant organization was ToLocal, and the registrant contact email
address was “payment@tolocal.com.” See Ex. 26. Defendants used a domain privacy service to
conceal their control of other websites, like solar-rebate.com.
33.
The Defendants’ landing pages asked the Facebook users and other visitors
(collectively “the visitors”) a series of questions under the false premise that the information was
necessary to determine their eligibility state-sponsored rebates and incentives. Typically, the visitors
were directed through a series of landing pages within Defendants’ websites that asked for different
types of information.
COMPLAINT; DEMAND FOR JURY TRIALPage 12
34.
The initial landing page hosted at solar-rebate.com first prompted the visitors to enter
their ZIP code and home ownership status. Ex. 27. The visitors were then directed to a secondary
landing page that prompted them to identify their electric utility provider, average monthly bill, and
other information about the home. Ex. 28. The visitors were then directed to a third landing page (Ex.
29) that prompted the visitors for their name, physical address, email address, and phone number, as
set forth in Figure 6.
Figure 6: Solar-Rebate.com Landing Page
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
35.
Defendants’ also hosted a website on the domain national-solar-rebate.com. This
website also prompted its visitors, through a series of sequential landing pages, to enter their contact
information. Ex. 30. The landing pages falsely quoted to its visitors that they could save “up to $3,or more” through solar rebates. Ex. 30.
COMPLAINT; DEMAND FOR JURY TRIALPage 13
36.
As shown in Figure 7, the website hosted at the domain solar-engery-today.com also
prompted its visitors, through a series of sequential landing pages, to enter their contact information.
Ex. 31. The landing pages prompted visitors to click through the site, by claiming, “this is the 1 simple
truth your power company doesn’t want you to know.” Ex. 31.
Figure 7: Solar-Energy-Today Landing Page
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
37.
On information and belief, Defendants intentionally directed their websites’ visitors
through multiple landing pages in order to conceal their true purpose (leads generation) until after the
visitors had already been prompted to enter information about themselves. Defendants collected, sold
or otherwise monetized Facebook users’ contact information by selling it for spam and robocall
marketing campaigns unrelated to state-sponsored solar initiatives or rebates.
D.
Defendants Unjustly Enriched Themselves and Their Unlawful Acts Have
Injured and Damaged Facebook
38.
Defendants’ breaches of Facebook’s TOS and Policies and other misconduct described
above have harmed Facebook, including by negatively impacting and interfering with Facebook’s
service. Defendants have negatively impacted the Facebook experience for users exposed to
Defendants’ false, misleading, and deceptive ads, thus harmed Facebook directly.
COMPLAINT; DEMAND FOR JURY TRIALPage 14
Hunton Andrews Kurth LLP
Facebook has suffered damages attributable to the efforts and resources it has used to
address the wrongdoings alleged in this Complaint, to investigate and mitigate Defendants’ conduct,
and to identify, analyze, and stop their injurious activities.
40.
Defendants’ scheme injured Facebook’s reputation, public trust, and goodwill.
41.
Defendants have been unjustly enriched by their activities at the expense of Facebook.
42.
Defendants received adequate consideration for their agreement with and contractual
550 South Hope Street, Suite Los Angeles, California 90071-
39.
obligations to Facebook. Facebook’s TOS and Policies as to Defendants are just and reasonable.
FIRST CAUSE OF ACTION
(Breach of Contract)
43.
Facebook incorporates all other paragraphs as if fully set forth herein.
44.
Defendant Min Ge created multiple personal Facebook accounts and was an
administrator or moderator for the Social Energy Page, the Solar Rebate Page, and the Home Saving
Page. Additionally, Defendant Min Ge held the role of administrator of the Solar Energy Page from
March 2016 until May 2019. Defendants agreed to Facebook’s TOS and Policies when they created
their Facebook accounts and the Solar Energy Page.
45.
Since March 2018, Defendants’ have used the Solar Energy Page, Home Saving Page,
and Solar Rebate Page and purchased and ran ads using those Pages to enrich themselves. Because
Defendants used and targeted Facebook and Facebook users, Defendants are subject to Facebook’s
TOS and Policies.
46.
Defendant breached Facebook’s TOS and Policies by taking the actions described
above, including using deceptive, false, or misleading content in Facebook ads and landing pages in
violation of TOS 3.2.1, Pages Policy 2.1, and Advertising Policy 4.13, 12.1 and 12.4.
47.
accordance with its agreement with Defendants.
Facebook has performed all conditions, covenants, and promises required of it in
48.
Defendants’ breaches have caused Facebook damages in an amount in to be determined
at trial.
COMPLAINT; DEMAND FOR JURY TRIALPage 15
SECOND CAUSE OF ACTION
(Unlawful, Unfair, or Fraudulent Business Practices)
49.
Facebook incorporates all other paragraphs as if fully set forth herein.
50.
Defendants’ actions described above, constitute unlawful, unfair, or fraudulent acts or
practices in the conduct of a business, in violation of California’s Business and Professions Code
Section 17200 et seq., including actions that are forbidden by other state law.
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
51.
Defendants’ practices are unfair because they offend established public policy and are
substantially injurious to Facebook and its users.
52.
Defendants’ practices are fraudulent because they are likely to deceive Facebook and
its users into believing Defendants’ ads were genuine, when, as alleged above, they were not.
53.
As a result of Defendants’ acts and omissions, Facebook was injured in fact and lost
money and property in the form of, among other things, costs to investigate, remediate, and prevent
Defendants’ wrongdoings.
THIRD CAUSE OF ACTION
(Breach of Implied Covenant of Good Faith and Fair Dealing)
54.
Facebook incorporates all other paragraphs as if fully set forth herein.
55.
To the extent the Defendants did not breach Facebook’s express TOS and Policies,
Defendants deprived Facebook of the full benefits of its contracts, including Facebook’s contractual
rights under its TOS, Pages Policy, and Advertising Policies.
56.
Facebook suffered damages as a result of these violations.
REQUEST FOR RELIEF
WHEREFORE, Plaintiff Facebook requests judgment against Defendants as follows:
1.
That the Court enter judgment against Defendants that Defendants have:
a. Breached their contracts with Facebook in violation of California law;
b. Breached the implied covenant of good faith and fair dealing in violation of
California law; and
c. Engaged in unlawful, unfair, or fraudulent business practices in violation of
California law.
COMPLAINT; DEMAND FOR JURY TRIALPage 16
2.
That the Court enter an injunction enjoining and restraining Defendants and their
agents, employees, successors, and assigns, and all other persons acting in concert with or conspiring
or affiliated with Defendants from:
a. Accessing or attempting to access Facebook’s platform and computer systems;
b. Engaging in any activity that disrupts, diminishes the quality of, interferes with the
performance of, or impairs the functionality of Facebook’s platform and computer
system;
c. Engaging in any activity, or facilitating others to do the same, that violates
Facebook’s TOS and Policies;
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
3.
proven at trial.
4.
That Defendants account for, hold in constructive trust, pay over to Facebook and
otherwise disgorge profits derived from Defendants’ unjust enrichment.
That Facebook be awarded damages as permitted by law and in such amounts to be
5.
That Facebook be awarded a recovery in restitution equal to any unjust enrichment
enjoyed by Defendant.
6.
That Facebook be awarded its reasonable costs, including reasonable attorneys’ fees.
7.
That Facebook be awarded pre- and post-judgment interest as allowed by law.
///
///
///
///
///
///
///
///
///
///
///
COMPLAINT; DEMAND FOR JURY TRIALPage 17
8.
That the Court grant all such other and further relief as the Court may deem just and
proper.
Dated: May 30,
HUNTON ANDREWS KURTH LLP
By:
Platform Enforcement and Litigation
Facebook, Inc.
Jessica Romero
Michael Chmelar
Stacy Chen
Hunton Andrews Kurth LLP
550 South Hope Street, Suite Los Angeles, California 90071-
/s/ Ann Marie Mortimer
Ann Marie Mortimer
Jason J. Kim
Attorneys for Plaintiff
FACEBOOK, INC.
JURY TRIAL DEMAND
Plaintiff hereby demands a trial by jury on all issues triable to a jury.
Dated: May 30,
HUNTON ANDREWS KURTH LLP
By:
/s/ Ann Marie Mortimer
Ann Marie Mortimer
Jason J. Kim
Attorneys for Plaintiff
FACEBOOK, INC.
Platform Enforcement and Litigation
Facebook, Inc.
Jessica Romero
Michael Chmelar
Stacy Chen
099900.12852 EMF_US 74233715v
COMPLAINT; DEMAND FOR JURY TRIALPage 18 EXHIBIT
17Page 19 05/21/2019 - tolocal.com homepage
• • •
Tt
C
Tolocal
I https i www.tolocal.com
TL
TOLOCAL
TO LOCALTO GLOBAL
Home
About
Services
ADVERTISING. DIGITAL
MARKETING. PUBLIC RELATIONS.
Tolocal provides cutting edge strategy, technology, and cross-channel marketing execution built to drive high-value
customers to your business and into your sales funnel.
Get Started!
Learn more
ContactPage 20 05/21/2019 - tolocal.com homepage
•
•
•
11 Tolocal
C
I
Q *
https www.tolocal.com
TL
TOLOCAL
10 LOCAL.I 0 GLOBAL
Home
About Tolocal
About
Services
Contact
•
Tolocal started 2014 as a dream to help businesses grow. We saw
companies reeling to adjust to a rapidly changing digital world and the
marketing landscape was full of traditional agencies, one-dimensional
specialists, and countless vendors peddling their particular product or
•
•
service. But there was nobody to help companies pull everything
together. So We Started Tolocal.
Our goal was to build an agency that focused on transparency,
sound business strategy, and in-depth multi-channel marketing
expertise. Today, Tolocal is a growing company with a wonderful team
and a strong stable of clients. We work hard, play hard, and we love what
•
we do.
•
What We Offer
(P"\ STRATEGY
BRANDING
.1:t ADVERTISING
Define the goals that mean success
Create an identity that matches the
Use the advanced targeting made
for your business and create the
experience your company delivers.
possible by digital channels to
•Page 21 05/21/2019 - tolocal.com homepage
TL
+
x
Tolocal
fl https:;’fwww.toiocal.com
TL
TOLOCAL
LOCAL
U GLOBAL
IO
Horne
About
Contact
l
Define the
goals; the
_
Em your buginess and
pian t
make
DIGITAL
it
mean Euccegs
Cream an
create
Experience yeur
the-
identity that
matches the
company
delivers.
happen.
WEB DEVELOPMENT
Launch. the online lead generatior‘:
Wansfos'm your webgize from
campaigns
digitai billboard to a
will
help you get
found and get grswing.
Happy
clients
possible by digital channeis
reac h
MARKETING
that
Use the advanced targeting made
3.50:1 r
I
ideal cusiomers.
PUBLIC RELATIONS
Reach the media outiets your
a
Quitomers read and build
business
engine your customers Ewe.
tine
reputatiom you deserve.
‘2’
I
15K
Awards won
Cups of Coffee
Projects completed
Get
In
Touch
20Page 22 05/21/2019 - tolocal.com homepage
TL
X
Tolocal
+
fl https://www.toiocal.com
TL
TOLOCAL
LOCAL
GLOBAL
[O
About
Horne
IO
I
Phone
w
Emall
3x 3.5a}
Address
03c:
TL
TOLOCAL
TO LOCALTO GLOBAL
11L,
ServicesPage 23 EXHIBIT
22Page 24 05/22/19 - TOLOCAL, INC. https://businesssearch.sos.ca.gov Articles of Incorporation
FILED
SECRETARY OF STATE
STATE OF CAI IPORNIA
ARTICLES OF INCORPORATION
ACC
AUG 20
OF
TOLOCAL, INC.
ARTICLE I
NAME
The name of this corporation is: ToLocal, Inc.
ARTICLE H
PURPOSE
The purpose of the corporation is to engage in any lawful act or activity for which a
corporation may be organized under the General Corporation Law of California other than
the banking business, the trust company business or the practice of a profession permitted
to be incorporated by the California Corporations Code.
ARTICLE III
INITIAL AGENT FOR SERVICE OF PROCESS
The name and address in the State of California of the corporation's initial agent for
service of process is:
NAN SHEN
2570 North First Street, 2 nd Floor
San Jose, CA
ARTICLE IV
CORPORATE ADDRESS
The initial street address of the corporation is:
Xot/Page 25 2370 North First Street, 2nd Floor
San Jose, CA
ARTICLE V
AUTHORIZED CAPITAL
5.General. The corporation is authorized to issue 10,000,000 shares of stock,
all of which shall be common stock, no par value.
5.Common Stock. Each holder of common stock shall be entitled to one vote
for each share of common stock held of record on all matters on which stockholders
generally are entitled to vote, subject to the provisions of law.
ARTICLE VI
INDEMNIFICATION
The Corporation shall indemnify its directors, officers, employees, and agents to the
fullest extent permitted by law.
Date: August 15,
NAN SHEN, Incorporator
24Page 26 EXHIBIT
25Page 27 05/22/19 - ToLocal, Inc - https://businesssearch.sos.ca.gov/ Statement of Information
State of California
,,.
Secretary of State
•-t4., -1.10: -,
Statement of Information
(Domestic Stock and Agricultural Cooperative Corporations)
FEES (Filing and Disclosure): $25.00.
If this is an amendment, see instructions.
IMPORTANT — READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
1 CORPORATE NAME
TOLOCAL, INC.
FM
FILED
In the office of the Secretary of State
of the State of California
APR-14
2. CALIFORNIA CORPORATE NUMBER
This Space for Filing Use Only
CNo Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.)
3 If there have been any changes to the information contained in the last Statement of Information filed with the California Secretary
of State, or no statement of information has been previously filed, this form must be completed in its entirety.
If there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed to Item 17.
Complete Addresses for the Following (Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
4.
STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
2100 GENG RD. SUITE 100., PALO ALTO, CA 5.
STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE IN CALIFORNIA, IF ANY
2100 GENG RD. SUITE 100., PALO ALTO. CA 6.
MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM
Names and Complete Addresses of the Following Officers
(The corporation must list these three officers. A comparable title for the specific
officer may be added; however, the preprinted titles on this form must not be altered.)
7.
CHIEF EXECUTIVE OFFICER/
MIN GE
8.
SECRETARY
MIN GE
9.
CITY
STATE
ZIP CODE
ADDRESS
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
2100 GENG RD. SUITE 100., PALO ALTO, CA
CHIEF FINANCIAL OFFICER/
YU GE
ADDRESS
2100 GENG RD. SUITE 100., PALO ALTO, CA
ADDRESS
2100 GENG RD. SUITE 100., PALO ALTO, CA
Names and Complete Addresses of All Directors, Including Directors Who are Also Officers
(The corporation must have at least one
director. Attach additional pages, if necessary.)
10. NAME
MIN GE
ADDRESS
CITY
STATE
ZIP CODE
2100 GENG RD. SUITE 100., PALO ALTO, CA
11. NAME
ADDRESS
CITY
STATE
ZIP CODE
12. NAME
ADDRESS
CITY
STATE
ZIP CODE
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY:
Agent for Service of Process If the agent is an individual, the agent must reside in California and Item 15 must be completed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State a
certificate pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS
MIN GE
15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA. IF AN INDIVIDUAL CITY
STATE
ZIP CODE
2100 GENG RD. SUITE 100., PALO ALTO, CA Type of Business
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
INTERNET SERVICE
17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
04/14/DATE
SI-200 (REV 0112013)
JIA ZHANG
EXECUTIVE ASSISTANT
TYPE/PRINT NAME OF PERSON COMPLETING FORM
TITLE
Page 1 of
SIGNATURE
APPROVED BY SECRETARY OF STATEPage 28 EXHIBIT
27Page 29 05/22/19 - ToMongoAd https://businesssearch.sos.ca.gov/ Articles of Incorporation
FILED
ARTICLES OF INCORPORATION
SECRETARY OF STATE
STATE OF CAI IPORNIA
OF
Global Capital Express Inc.
1St AUG I I
1. The name of the corporation is Global Capital Express Inc.
2. The purpose of the corporation is to engage in any lawful act or activity for which a
corporation may be organized under the General Corporation Law of California other than the
banking business, the trust company business or the practice of a profession permitted to be
incorporated by the California Corporations Code.
3. The name and street address in the State of California of this corporation's initial agent
for service of process is:
Min Ge, 2225 East Bayshore Rd. Suite 100, Palo Alto, California 4. The initial street address of this corporation is 2225 East Bayshore Rd. Suite 100, Palo
Alto, California 94303.
5. a) The corporation is authorized to issue two classes of shares, each with $0.001 as par
value, designated "Common Stock" and "Preferred Stock", respectively. The number of shares
of Common Stock authorized to be issued is 10,000 and the number of shares of Preferred Stock
authorized to be issued is 10000.
b) The Preferred Stock may be issued from time to lime in such number of series as the
Board of Directors may determine. The Board of Directors is authorized to determine or alter
the rights, preferences, privileges and restrictions granted to or imposed upon any wholly
unissued series of Preferred Stock, and to fix the number of shares of any series of Preferred
Stock and the designation of any such series of Preferred Stock. Subject to compliance with
applicable protective voting rights which may be granted to the Preferred Stock or any series of
Preferred Stock in Certificates of Determination or the corporation's Articles of Incorporation,
the Board of Directors is also authorized, within the limits and restrictions stated in any
resolution or resolutions of the Board of Directors originally fixing the number of shares
constituting any series, to increase or decrease (but not below the number of shares of such
series then outstanding) the number of shares of any series subsequent to the issue of the shares
of that series. In case the number of shares of any series shall be so decreased, the shares
constituting such decrease shall resume the status which they had prior to the adoption of the
resolution originally fixing the number of shares of such series.
6. The liability of the directors of the corporation for monetary damages shall be
eliminated to the fullest extent permissible under California law.
Cil
" lPage 30 7. This corporation is authorized to provide indemnification of agents (as defined in
Section 317 of the California Corporations Code) through bylaw provisions, agreements with
agents, vote of shareholders or disinterested directors or otherwise, in excess of the
indemnification otherwise permitted by Section 317 of the California Corporations Code,
subject only to the applicable limits set forth in Section 204 of the California Corporations Code
with respect to actions for breach of duty to the corporation and its shareholders.
8. Any repeal or modification of the foregoing provisions of Sections 6 and 7 by the
shareholders of this corporation shall not adversely affect any right or protection of an agent of
this corporation existing at the time of such repeal or modification.
I, the undersigned, as the sole incorporator of the corporation, declare that I am the person
who executed these Articles of Incorporation, which execution is my act and deed.
Executed on 8/10/2015.
LegalZoom.com, Inc., Incorporator
By: Cheyenne Moseley, Assistant Secretary
29Page 31 EXHIBIT
30Page 32 •
I
Ong°
••
PS:
.sos.ca.gov
Articles of Incorporation
•usmesssearc
C Added For Imagind
I • 20 ti
e I ica e o • menemen o
po 8 2 61
t#11.
3s CCertificate of Amendment of Articles of Incorporation
let/
The undersigned certify that
FILED
Secretary of State
State of C2lifomia
MAR 2 8
I. They are the paid prepare: of Global Capital Express Inc., a California corporation, Entity
Number C3815723.
2. Article 1 of the Articles of Incorporation of this corporation is amended to read as follows*
1. The name of the corporation is TomongoAd Inc.
3. The foregoing amendment of Articles of Incorporation has been duly approved by the board of
directors.
4. The foregoing amendment of Articles of Incorporation has been duly approved by the required
vote of shareholders in accordance with Section 902, California Corporations Code. The total
number of outstanding shares of the corporation is 10,000. The number of shares voting in favor
of the amendment equaled or exceeded the vote required The percentage vote required was more
than 50%.
We further declare under penalty of perjury under the laws of the State of California that the
matters set forth in this certificate are true and correct of our own knowledge.
DATE: /VW 2 3,
?Of (
Min Ge, President
to Ge, Secretary
31Page 33 EXHIBIT
32Page 34 Exhibit 6 - 05/22/19 - Whois screenshot from centralops.com for tomongoad.com
Queried whois.godaddy.com with "tomongoad.com"...
Domain Name: tomongoad.com
Registry Domain ID: 2263395382DOMAINCOM-VRSN
Registrar WHOIS Server: whois.godaddy.com
Registrar URL: http://www.godaddy.com
Updated Date: 2019-05-15T15:27:42Z
Creation Date: 2018-05-14T18:41:35Z
Registrar Registration Expiration Date: 2020-05-14T18:41:35Z
Registrar: GoDaddy.com, LLC
Registrar IANA ID: Registrar Abuse Contact Email: abuse@godaddy.com
Registrar Abuse Contact Phone: +1.Domain Status: clientTransferProhibited http://www.icann.org/epp#clientTransferProhibited
Domain Status: clientUpdateProhibited http://www.icann.org/epp#clientUpdateProhibited
Domain Status: clientRenewProhibited http://www.icann.org/epp#clientRenewProhibited
Domain Status: clientDeleteProhibited http://www.icann.org/epp#clientDeleteProhibited
Registrant Organization: ToLocal Inc
Registrant State/Province: California
Registrant Country: US
Registrant Email: Select Contact Domain Holder link at https://www.godaddy.com/whois/results.aspx?domain=tomongoad.com
Admin Email: Select Contact Domain Holder link at https://www.godaddy.com/whois/results.aspx?domain=tomongoad.com
Tech Email: Select Contact Domain Holder link at https://www.godaddy.com/whois/results.aspx?domain=tomongoad.com
Name Server: DEMI.NS.CLOUDFLARE.COM
Name Server: JASON.NS.CLOUDFLARE.COM
DNSSEC: unsigned
URL of the ICANN WHOIS Data Problem Reporting System: http://wdprs.internic.net/
>>> Last update of WHOIS database: 2019-05-23T17:00:00Z «<
33Page 35 EXHIBIT
34Page 36 INC. articles of incor • oration
A07797 FILED
37045/CERTIFICATE OF AMENDMENT OF
ARTICLES OF INCORPORATION
Secretary of State
State of California
Tc. JAN 1 4 2016 C
OF
TOLOCAL, INC.
The undersigned certify that:
1. They are the President and the Secretary, respectively, of TOLOCAL, INC., a
California corporation.
2. Article V (5.1) of the Articles of Incorporation of this corporation is amended to read
as follows:
The total number of shares of all classes of stock that the corporation is authorized
to issue is One Hundred Million (100,000,000), no par value.
3. The foregoing amendment of Articles of Incorporation has been duly approved by
the board of directors.
4. The foregoing amendment of Articles of Incorporation has been duly approved by
the required vote of shareholders in accordance with Section 902, California
Corporations Code. The total number of outstanding shares of the corporation is
2,000,000. The number of shares voting in favor of the amendment equaled or
exceeded the vote required. The percentage vote required was more than 50%.
We further declare under penalty of perjury under the laws of the State of California that
the matters set forth in this certificate are true and correct of our own knowledge.
DATED:
ppc
"Vic
Mi6 GE, President
Yu GE, Secretary
35Page 37 EXHIBIT
36Page 38 Information
_
,,...,
.
State of California
.
S
Secretary of State
Statement of Information
. ....
(Domestic Stock and Agricultural Cooperative Corporations)
FEES (Filing and Disclosure): $25.00.
If this is an amendment, see instructions.
IMPORTANT — READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
I_
CORPORATE NAME
FD
FILED
In the office of the Secretary of State
of the State of California
TOMONGOAD INC.
JUN-02 2. CALIFORNIA CORPORATE NUMBER
This Space for Filing Use Only
C
No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.)
If there have been any changes to the Information contained In the last Statement of Information flied with the California Secretary
of State, or no statement of Information has been previously filed, this form must bo completed In Its entirety.
7 If there has been no change in any of the information contained in the last Statement of Information fled with the California Secretary
--1 of State. check the box and proceed to Item 17.
Complete Addresses for the Following
4.
(Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE
CITY
STATE
ZIP CODE
5. STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE IN CALIFORNIA. IF ANY
2100 GENG ROAD. SUITE #100. PALO ALTO. CA
CITY
STATE
ZIP CODE
6.
CITY
STATE
ZIP CODE
2100 GENG ROAD, SUITE #100, PALO ALTO, CA
MAILING ADDRESS OF CORPORATION. IF DIFFERENT THAN ITEM
Names and Complete Addresses of the Following Officers (The corporation must list these three Officers. A comparable title for
the spook
officer may be added: however. the preprinted titles on this form must not be altered.)
7.
CHIEF EXECUTIVE OFFICER/
MIN GE
8.
SECRETARY
MIN GE
9.
CITY
STATE
ZIP CODE
ADDRESS
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
2100 GENG ROAD, SUITE #100, PALO ALTO, CA
CHIEF FINANCIAL OFFICER/
MIN GE
ADDRESS
2100 GENG ROAD, SUITE #100. PALO ALTO, CA
ADDRESS
2100 GENG ROAD. SUITE #100. PALO ALTO, CA
Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one
director. Attach additional pages, If necessary.)
10. NAME
MIN GE
ADDRESS
CITY
STATE
ZIP CODE
2100 GENG ROAD, SUITE #100, PALO ALTO. CA
it. NAME
ADDRESS
CITY
STATE
ZIP CODE
12. NAME
ADDRESS
CITY
STATE
ZIP CODE
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS. IF ANY:
Agent for SeTVICI) of Process
If the agent is an individual, the agent must reside in California and Item 15 Mat be competed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of Stale a
certiecato pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS
MIN GE
15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA. IF AN INDIVIDUAL CITY
STATE
ZIP CODE
2100 GENG ROAD, SUITE #100, PALO ALTO. CA Type of Business
16 DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
ONLINE INTERNET SERVICE
Ir. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE. THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS. IS TRUE AND CORRECT.
06/02/DATE
SI-200 (REV 01/2013)
CHEYENNE MOSELEY
AUTH. REP.
TYPE/PRINT NAME OF PERSON COMPLETING FORM
TITLE
Page 1of
SIGNATURE
APPROVED BY SECRETARY OF STATEPage 39 EXHIBIT
38Page 40 Solar Energy Today
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION NEW YORK HOMEOWNERS: There is a new Gov. sponsored initiatives that offers you the best solar deal
NOW, Gov, Cuomo will release $10 million solar incentives for
NY home solar expansion.
Enter your zip code and answer 3 simple questions. If you are
lucky enough to live in an active zip code, you can get paid ...
•
-4 V-
_
Aifi
•••••;....•
•
•••
Last Week! New York State Sponsored Solar Incentive
Application Ends in 5 Days, Receive FREE Quotes & Get...
Solar programs are so popular that people throughout the
United States are signing up at a record pace. If you act now,...
BIGSAVINGUSA.COM
Get OfferPage 41 EXHIBIT
40Page 42 p
Solar Energy Today
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION CALIFORNIA HOMEOWNERS: There is a new
2018 program that offers you the best solar deal NOW. Gov.
Brown will release $10 million solar incentives for CA home
solar expansion.
Enter your zip code and answer 3 simple questions. If you are
lucky enough to live in an active zip code, you can get paid ...
a
•„
a
4)
Last Week! California Statewide Sponsored Solar
Application Ends in 5 Days, Get FREE Quotes Now..
Solar programs are so popular that people throughout the
United States are signing up at a record pace. If you act now,...
BIGSAVINGUSA.COM
Get OfferPage 43 EXHIBIT
42Page 44 Solar Energy Today
/
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION FLORIDA HOMEOWNERS: There is a new 20'Gov. sponsored initiatives that offers you the best solar deal
NOW. Gov. Rick Scott will release $10 million solar incentives
for FL home solar expansion.
Enter your zip code and answer 3 simple questions. If you are
lucky enough to live in an active zip code, you can get paid ...
ow.
•
11:
Last Week! Florida State Sponsored Solar Incentive
Application Ends in 5 Days, Receive FREE Quotes & Get...
Solar programs are so popular that people throughout the
United States are signing up at a record pace. If you act now,...
BIGSAVINGUSA.COM
Get OfferPage 45 EXHIBIT
44Page 46 Solar Energy Today
r
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION TEXAS HOMEOWNERS: There is a new program that offers you the best solar deal NOW. Gov. Brown
will release $10 million solar incentives for TX home solar
expansion.
Enter your zip code and answer 3 simple questions. If you are
lucky enough to live in an active zip code, you can get paid ...
/
-
se
a .
.
.
ne',,,
iii: e
- 4;11.„
44r
Last Week! Texas Sponsored Solar Application Ends in Days, Get FREE Quotes Now..
Solar programs are so popular that people throughout the
United States are signing up at a record pace. If you act now,...
BIGSAVINGUSA.COM
Get OfferPage 47 EXHIBIT
46Page 48 Solar Energy Today
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION NEW JERSEY HOMEOWNERS: There is a new
2018 Gov. sponsored initiatives that offers you the best solar
deal NOW. Gov. Murphy will release $10 million solar
incentives for NJ home solar expansion.
Enter your zip code and answer 3 simple questions. If you are
lucky enough to live in an active zip code, you can get paid ...
!!!!!r3r
•
••
411Ik
e a fr
f
No.
Last Week! NEW JERSEY Endorsed Solar Incentive
Application Ends in 5 Days, Receive FREE Quotes & Get...
Solar programs are so popular that people throughout the
United States are signing up at a record pace. If you act now,...
BIGSAVINGUSA.COM
Get Offer
4Page 49 EXHIBIT
48Page 50 *
Solar Energy Today
sponsored • Palo for by SOLAR ENERGY TODAY
ATTENTION CALIFORNIA HOMEOWNERS: There is a new policy that your power provider doesn't want you to know
about. Governor Jerry Brown will release $100 million solar
incentives for California solar expansionlf you are lucky
enough to live in an active zip code, you can get paid to go
solar. Check it out and see if you qualify!
It'Ad
California Government Set To Give sou. Panels To
Homeowners At No Cost Down, Policy Effective Already
Limited to 150 applicants per day. Only some rig codes are
eltteble in each state. Those Tat..
NATIONALSOtAll-PCIIATECOM
Apply NowPage 51 EXHIBIT
50Page 52 'pp
Solar Energy Today
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION DELAWARE HOMEOWNERS: There is a new
policy that your power provider doesn't want you to know
about. The Gov. John Carney will release $100 million solar
incentives for DE home solar expansion. If you are lucky
enough to live in an active zip code, you can get paid to go
solar. Check it out and see if you qualify!
I
Delaware Government Set To Give Solar Panels To Homeowners At No
Cost Down
Click HERE to see how much solar energy incentives you are eligible for
before the program expires. DE homeowners only
URBIGSAVINGS.COM
51Page 53 EXHIBIT
52Page 54 ,A
Solar Energy Today
17 Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION NEW MEXICO HOMEOWNERS: There is a new
2018 policy that your power provider doesn't want you to
know about. The Gov. Susana Martinez will release $million solar incentives for NM home solar expansion. If you
are lucky enough to live in an active zip code, you can get
paid to go solar. Check it out and see if you qualify!
•
New Mexico Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. NM homeowners...
URBIGSAVINGS.COM
Learn MorePage 55 EXHIBIT
54Page 56 Solar Energy Today
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION NEW JERSEY HOMEOWNERS: There is a new
2018 policy that your power provider doesn't want you to
know about. Your New Governor, Phil Murphy, will release
$100 million solar incentives for New Jersey solar expansion.
If you are lucky enough to live in an active zip code, you can
get paid to go solar. Check it out and see if you qualify!
•
e•;
.•
•
0.•
•
•-
•
..
^CZ
.
•
‘,.1.• •
fr ri
•••
4
S
$
I"
•
—
O
New Jersey Government Set To Give Solar Panels To
Homeowners At No Cost Down, Policy Effective Already
Limited to 150 applicants per day. Only some zip codes are
eligible in each state. Those that...
SOLAR-ENERGY-TODAY.COM
Apply NowPage 57 EXHIBIT
56Page 58 Solar Energy Today
'
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION ARIZONA HOMEOWNERS: There is a new policy that your power provider doesn't want you to know
about. The Gov. Doug Ducey will release $100 million solar
incentives for AZ home solar expansion. If you are lucky
enough to live in an active zip code, you can get paid to go
solar. Check it out and see if you qualify!
W
T
IPL
14/
I
g•
Arizona Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. AZ homeowners only
URBIGSAVINGS.COM
Learn MorePage 59 EXHIBIT
58Page 60 Solar Energy Today
ot
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION NEW YORK HOMEOWNERS: There is a new policy that your power provider doesn't want you to know
about. Governor Andrew Cuomo will release $100 million
solar incentives for New York solar expansion. If you are lucky
enough to live in an active zip code, you can get paid to go
solar. Check it out and see if you qualify!
t
--wathei-4.,
New York State Government Set To Give Solar Panels To
Homeowners At No Cost Down, Policy Effective Already
Limited to 150 applicants per day. Only some zip codes are
eligible in each state. Those that...
SOLAR-ENERGY-TODAY.COM
Apply NowPage 61 EXHIBIT
60Page 62 Home Saving Net
Sponsored • Paid for by National Solar Rebate
ATTENTION CALIFORNIA HOMEOWNERS: There is a new
policy just be signed. The new Gov. Gavin Newsom will release
$15 million solar incentives for keeping supporting CA home
solar expansion. If you are lucky enough to live in an active zip
code, you can get paid to go solar. Check it out and see if you
qualify!
LIVE
Ic
C
Fore
CAUFORMR GOVERNOR
44N
56N
lOW
Mit ASSIMILT OST. le
•
48-
td BAKER
California Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. CA homeowners only
URBIGSAVINGS.COM
Learn MorePage 63 EXHIBIT
62Page 64 Home Saving Net
Sponsored • Paid for by National Solar Rebate
ATTENTION CONNECTICUT HOMEOWNERS: There is a new
policy just be signed. The new Gov. Ned Lamont will release
$15 million solar incentives for keeping supporting CT home
solar expansion. If you are lucky enough to live in an active zip
code, you can get paid to go solar. Check it out and see if you
qualify!
;It
*
*
4.
*
•
M`
Connecticut Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. CT homeowners only
URBIGSAVINGS.COM
Learn MorePage 65 EXHIBIT
64Page 66 Home Saving Net
SWIPE
Sponsored • Paid for by National Solar Rebate
ATTENTION ILLINOIS HOMEOWNERS: There is a new policy
just be signed. The new Gov. J. B. Pritzker will release $million solar incentives for keeping supporting IL home solar
expansion. If you are lucky enough to live in an active zip
code, you can get paid to go solar. Check it out and see if you
qualify!
r" -•amJB
FOr -1114 ;#.
& Juliana
FOR ILLINOIS
Illinois Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. IL homeowners only
URBIGSAVINGS.COM
Learn MorePage 67 EXHIBIT
66Page 68 Home Saving Net
.
Sponsored • Paid for by National Solar Rebate
ATTENTION MASSACHUSETTS HOMEOWNERS: There is a
new policy just be signed. The re-elected Gov. Charles Baker
will release $15 million solar incentives for keeping supporting
MA home solar expansion. If you are lucky enough to live in an
active zip code, you can get paid to go solar. Check it out and
see if you qualify!
•
•
I
•
•
•
•
■
t
II
Massachusetts Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. MA homeowners only
URBIGSAVNGS.COM
Learn MorePage 69 EXHIBIT
68Page 70
Home Saving Net
Sponsored • Paid for by National Solar Rebate
ATTENTION COLORADO HOMEOWNERS: There is a new
policy just be signed. The new Gov. Jared Polis will release
$15 million solar incentives for keeping supporting CO home
solar expansion. If you are lucky enough to live in an active zip
code, you can get paid to go solar. Check it out and see if you
qualify!
I
ti
a
rm.
Colorado Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. CO homeowners only
URBIGSAVINGS,COM
Learn MorePage 71 EXHIBIT
70Page 72 Home Saving Net
••••
Sponsored • Paid for by National Solar Rebate
ATTENTION IDAHO HOMEOWNERS: There is a new policy just
be signed. The new Gov. Brad Little will release $15 million
solar incentives for keeping supporting ID home solar
expansion. If you are lucky enough to live in an active zip
code, you can get paid to go solar. Check it out and see if you
qualify!
•
sl
%
its
I
•
S
Idaho Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. ID homeowners only
URBIGSAVINGS.COM
Learn MorePage 73 EXHIBIT
72Page 74 5 / 22 /2019 solar-energy-today.com WHOIS 09 / 08 / 2017 domaintools - Min Ge
solar-energy-today.corn
Advanced
Filters: solar-energy-today.com
III■
Pivot Engine
pDNS
Visualization
Stats
IP Tools
Whois History
Hosting History
Screenshot History
solar-energy-today.com
Historical Records
39 records found
2018-06-
changes
2018-06-
changes
> 2017-09-
changes
2017-02-
changes
2016-10-
changes
2016-07-
changes
2016-03-
changes
2015-05-
changes
2015-05-
changes
2015-03-
changes
2014-12-
changes
2014-10-
changes
2014-07-
changes
Domain Name: solar-energy-today.com
Registry Domain ID: 2011197288_DOMAIN_COM-VRSN
Registrar WHOIS Server: whois.godaddy.com
Registrar URL: http://www.godaddy.com
Updated Date: 2017-02-23T01:08:43Z
Creation Date: 2016-03-10T20:31:46Z
Registrar Registration Expiration Date: 2018-03-10T20:31:46Z
Registrar: GoDaddy.com, LLC
Registrar IANA ID: Registrar Abuse Contact Email: abuse@godaddy.com
Registrar Abuse Contact Phone: +1.Domain Status: clientTransferProhibited http://www.icann.org/epp#clientTransferProhibited
Domain Status: clientUpdateProhibited http://www.icann.org/epp#clientUpdateProhibited
Domain Status: clientRenewProhibited http://www.icann.org/epp#clientRenewProhibited
Domain Status: clientDeleteProhibited http://www.icann.org/epp#clientDeleteProhibited
Registry Registrant ID: Not Available From Registry
Registrant Name: Min Ge
Registrant Organization: ToLocal Inc
Registrant Street: 2225 East Bayshore Rd. Suite Registrant City: Palo Alto
Registrant State/Province: California
Registrant Postal Code: Registrant Country: US
Registrant Phone: +1.Registrant Phone Ext:
Registrant Fax:
Registrant Fax Ext:
Registrant Email: payment@tolocal.com
Registry Admin ID: Not Available From Registry
Admin Name: Min Ge
Admin Organization: ToLocal Inc
Admin Street: 2225 East Bayshore Rd. Suite Admin City: Palo Alto
73Page 75 EXHIBIT
74Page 76 3/21/19 Screenshot of http://solar-rebate.com/ as on 06/29/2018 via http://archive.org
gl Solar Discounts from Solar Re
+
https web.archive.org/web/20180629044340/http://solar-rebate.com/
http://solar-rebate.com/
MAY JUN AUG
Go
Iri
111000011110111110 65 captures
2017 2018
ILL
to
21 Mar 2004 - 7 Nov
About this capture
You may be eligible for a new US solar program.
Solar
Rebate
FIND OUT IF YOU QUALIFY NOW!
STEP ONE
Find Out if You Qualify Below. Only takes 30 seconds!
Do you own your home?
•
No, I rent my home.
•
\
•
•
What is your zip code?
Privacy Policy
Terms of UsePage 77 EXHIBIT
76Page 78 3/21/19 Screenshot of http://solar-rebate.com/ as on 06/29/2018 via http://archive.org
• • •_
gl Solar Discounts from Solar Re
itsikT
+
https web.archive.org/web/20180629044340/http://solar-rebate.com/
C
II•irl
X
A11(1111;
http://solar-rebate.com/
MAY JUN AUG
Go
Iri
Privacy Policy
Terms of UsePage 79 EXHIBIT
78Page 80 3/21/19 Screenshot of http://solar-rebate.com/ as on 06/29/2018 via http://archive.org
C
U https,rweb.archaorg/wecc20170617022141Thttp //solar -rotate conV
*Si
co
him tisolar-rebate.somi
64 .aptuiec
law
s es
el • JAI
JUN JUL
17 00'
2016 2017 201$
You may be eligible for a new US solar program.
Solar
FIND OUT IF YOU QUALIFY NOWT
Rebate
STEP THREE
Find Out if You Qualify Below. Only takes 30 seconds!
First Name
Last Name
`4•IlUe"ti re•efiei!.!JS
City
TX
Email
Phone
•
•
SUBMIT —#
Tr"
i
■ SAVE 70% On your monthly electric bills
Save Money with Solar!
Get Your FREE Solar Quote...
0 Copyright 2017 Sohn Rebate All Aphis Reserved
II Up to 30-50% off with government rebates & incentives.
III Lease a system for as little as SO down
Homo
Privacy Policy
Terms of UsePage 81 EXHIBIT
80Page 82 5 / 26 / 2019 national-solar-rebate.com 11 / 5 / 18 archive.org I stage VIRGINIA Residents: Make sure to ask about special limited-time incentives.
NATIONAL SOLAR
Norton
REBATE
111.1.1.
Get Your FREE Solar Quote...
For billing and service inovres
Call 245rs a day 7 days a week
For bilimp and seNrce inquires
Call 24nr5 a day 7 days a week
Old BO Dale BO Prepared June
New BO Dale Bill Prepared July
Your account summary
AsnOue101your an tramp cede
Pmfimamt rammed on May 01. Thad,0,
MM.= MheMNew chmmea
Iron, prenous cyme
Tell Annuli Due by JuM
5126
Your account summary
.1126
Ameunl 01 you, Lam Wong cycle
Payment mowed on July 51-ThankYou
50 OS
Mona Unpaid
New charges
Trial Amoral( Due by Nome
horn premous cycle
S4135 $0.57
CS7.
Old Bill : 5135.
Total Savings: $128.• kcruk.. 'MUMS wk. v.+ DCF.1)44400+ "MIT. vOu Pun...
L.M. Mug 30u. rrneu
So, how does this program work? You no longer have to buy solar panels, the policy let's
you lease solar panels for as little as $0 upfront. Until now, solar panels cost $10's of
thousands of dollars to purchase and install and unless you were building a new home or
had that much extra cash sitting around, the cost was more than the benefit. The solar
panels had to be purchased. It was impossible for companies to offer rent or lease
agreements because they would lose money.
NOTE: You are not locked into your power company policy If you've
already paid your current policy, you can very easily switch to solar power.
With average savings of 50% when you own, these online services are gaining massive
popularity. One of the most trusted, secure and effective free online service that provides
home owners the best local rates is this website Over 500,000 consumers have already
trusted this website to get significant discounts. If you too would like to receive the
benefits of using this free service you can click here or the button below. Then just enter
your state information and click continue to determine if your eligible.
HOW DO I SEE IF I QUALIFY
Step 1: Click your state on the map to instantly check your zip code for free
Step 2: Once you go through a few questions, you will have the opportunity to compare the
best quotes in your area.
88
PDF Page 1
PlainSite Cover Page
PDF Page 2
1
2
3
4
5
6
7
E-FILED
5/30/2019 8:52 AM
Clerk of Court
Superior Court of CA,
County of Santa Clara
19CV348954
Reviewed By: Y. Chavez
Ann Marie Mortimer (State Bar No. 169077)
amortimer@HuntonAK.com
Jason J. Kim (State Bar No. 221476)
kimj@HuntonAK.com
HUNTON ANDREWS KURTH LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
Telephone: (213) 532-2000
Facsimile: (213) 532-2020
Attorneys for Plaintiff
FACEBOOK, INC.
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
FOR THE COUNTY OF SANTA CLARA
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
11
FACEBOOK, INC., a Delaware corporation,
Plaintiff,
12
13
14
15
16
CASE NO.:
19CV348954
COMPLAINT; DEMAND FOR JURY TRIAL
v.
TOLOCAL, INC., TOMONGOAD, INC., and
MIN GE a/k/a “Keater Ge,”
Defendants.
17
18
19
20
21
22
23
24
25
26
27
28
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 3
1
Plaintiff Facebook, Inc. (“Facebook”) alleges the following:
2
INTRODUCTION
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
3
1.
Between March 2018 and April 2019, Defendants ToLocal, Inc., ToMongoAd, Inc.,
4
Min Ge also known as “Keater Ge” (“Min Ge”), and others, operated a deceptive and misleading
5
advertising (“ads”) scheme on Facebook and Twitter. On Facebook, Defendants used deceptive and
6
misleading ads to lure Facebook users from the Facebook platform to websites designed to harvest
7
their email addresses and other contact information for email spam1 and automated telemarketing
8
campaigns (“robocalls”). Defendants’ ads falsely represented to Facebook users that they could check
9
their eligibility for tax credits and rebates related to solar energy initiatives by clicking on links in the
10
ads. Defendants’ ads redirected Facebook users to websites controlled by Defendants that prompted
11
Facebook users, with false and misleading promises of tax credits, solar panel installations, and other
12
purported state-sponsored solar energy initiatives, to input their contact information, including their
13
name, physical address, email address, and phone number. Defendants then collected and sold the
14
users’ contact information to online marketers and advertisers.
15
Facebook’s Terms of Service (“TOS”), Advertising and Page Policies, and California law. Facebook
16
brings this action for damages and to stop Defendants’ use of its platform in violation of its TOS and
17
Policies.
18
PARTIES
19
20
Defendants’ actions violate
2.
Plaintiff Facebook, Inc., is a Delaware corporation with its principal place of business
in Menlo Park, San Mateo County, California.
21
3.
ToLocal, Inc. (“ToLocal”) promotes itself as an advertising, digital marketing, and
22
public relations firm that operates the website tolocal.com. Ex. 1. ToLocal was incorporated in the
23
State of California on August 20, 2014. See Ex. 2. According to incorporation records, ToLocal’s
24
corporate address is 2100 Geng Rd. Suite 100, Palo Alto, California. Ex. 3. According to ToLocal’s
25
website, ToLocal’s address is 2483 Old Middlefield Way, Suite 202, Mountain View, California. See
26
Ex. 1.
27
28
1
In this complaint, “spam” refers to unsolicited email advertisements.
1
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 4
1
August 11, 2015. See Ex. 4. ToMongoAd was originally incorporated under the name “Global
3
XCapital Express Inc.” and changed its corporate name to ToMongoAd on March 23, 2016. Ex. 5.
4
The website tomongoad.com redirects users to the website tolocal.com.
5
tomongoad.com was registered by ToLocal. See Ex. 6.
5.
The domain name
Defendant Min Ge uses the alias “Keater Ge” and has been the sole Director, Chief
7
Executive Officer, Secretary of ToLocal since 2017. See Ex. 3. Min Ge has previously held the title
8
of President of ToLocal. Ex. 7. According to corporate records, Defendant Min Ge has been the
9
President and Secretary of ToMongoAd since March 2016. Ex. 8. Min Ge resides in Mountain View,
10
Hunton Andrews Kurth LLP
ToMongoAd, Inc. (“ToMongoAd”) was incorporated in the State of California on
2
6
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
4.
11
California.
6.
At all times material to this action, each Defendant was the agent, employee, partner,
12
alter ego, subsidiary, or coconspirator of and with the other Defendants, and the acts of each Defendant
13
were in the scope of that relationship. In doing the acts and failing to act as alleged in this Complaint,
14
each Defendant acted with the knowledge, permission, and the consent of each of the other
15
Defendants; and, each Defendant aided and abetted the other Defendants in the acts or omissions
16
alleged in this Complaint.
17
18
JURISDICTION AND VENUE
7.
This Court has subject matter jurisdiction pursuant to California Code of Civil
19
Procedure § 410.10. The amount in controversy exceeds the jurisdictional minimum of this Court,
20
and the total amount of damages sought exceeds $25,000, exclusive of interest and costs. The
21
contractual interest at stake in this litigation has significant value to Facebook. Further, Defendants’
22
unlawful conduct and breaches have interfered with Facebook’s business and operation of its service.
23
24
25
26
27
28
8.
The Court has personal jurisdiction over ToLocal and ToMongoAd because they are
incorporated in the State of California and are located in Palo Alto and Mountain View, California.
9.
The Court has personal jurisdiction over Defendants Min Ge because he is a resident
of Mountain View, California.
10.
Venue is proper in this Court because a substantial part of the events giving rise to the
claims raised in this lawsuit occurred in Santa Clara County.
2
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 5
1
2
A.
Background on Facebook
3
11.
Facebook is a social networking website and mobile application that enables its users
4
to create their own personal profiles and connect with each other on their personal computers and
5
mobile devices. As of March 2019, Facebook daily active users averaged 1.56 billion and monthly
6
active users averaged 2.38 billion.
Hunton Andrews Kurth LLP
7
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
FACTUAL ALLEGATIONS
12.
Unlike personal Facebook user profiles, a Facebook Page is a public page on Facebook
8
designed for businesses, organizations, and public figures. A person can only create or manage a
9
Facebook Page if they are a Facebook user and have a personal Facebook account. Facebook Pages
10
can be managed by different users as administrators or moderators. The Facebook user that creates
11
the Page will be designated as the Page’s administrator by default.
12
13
13.
Page administrators and moderators can create and run ads and promotions on behalf
of their Facebook Pages.
14
B.
Facebook’s TOS, Pages and Advertising Policies
15
14.
Everyone who uses Facebook must agree to Facebook’s TOS (available at
16
https://www.facebook.com/terms.php) and other rules that govern access to, and use of, Facebook.
17
Facebook’s TOS prohibit violations of Facebook’s Advertising Policies (available at
18
https://www.facebook.com/policies/ads/) and Pages, Groups, and Events Policies (“Pages Policies”)
19
(available at https://www.facebook.com/policies/pages_groups_events/).
20
15.
Facebook’s TOS, Section 3.2.1, prohibits using Facebook “to do or share anything”
21
that (a) violates Facebook’s TOS or other terms and policies, which includes the Advertising and Pages
22
Policies; (b) “is unlawful, misleading, discriminatory, or fraudulent;” and (c) “infringes or violates the
23
someone else’s rights.”
24
25
26
16.
Facebook’s Pages Policies apply to the creators of Pages on Facebook. Pages Policy
2.1 states that “Pages . . . must not be misleading, fraudulent, or deceptive.”
17.
Facebook’s Advertising Policies apply to ads on Facebook. Advertising Policy 4.13
27
states that “ads, landing pages, and business practices must not contain deceptive, false, or misleading
28
content, including deceptive claims, offers, or methods.” Advertising Policy 12.1 states that “any ad
3
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 6
1
data collected, received, or derived from your Facebook or Instagram ad . . . is only shared with
2
someone acting on your behalf, such as your service provider.” Advertising Policy 12.4 stated “Don’t
3
transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad
4
network, ad exchange, data broker and other advertising or monetization related service.”
5
C.
Defendants’ Deceptive Advertising Scheme
6
18.
Between March 2018 and April 2019, Defendants operated a deceptive and misleading
7
advertising scheme using Facebook and Twitter. On Facebook, Defendants’ scheme was designed to
8
deceive Facebook users into clicking on their ads and visiting Defendants’ websites in order to harvest
9
the users’ contact information for spam and robocall marketing campaigns. Defendants’ scheme
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
generally proceeded in three steps:
11
a. Defendants created Facebook Pages designed to promote false, misleading, and
12
deceptive information about purported state-sponsored solar energy initiatives, such as
13
free solar panel installations for Facebook users’ homes and millions of dollars in
14
government rebates and incentives for homeowners.
15
b. Defendants used their Facebook Pages to purchase ads containing false, misleading,
16
and deceptive advertising that solicited Facebook users to determine their eligibility for
17
state-sponsored “solar rebates” and “solar incentives” that did not exist. Defendants’
18
ads depicted images of United States elected officials, such as President Donald J.
19
Trump and state governors, in order to bolster the credibility of the ads and mislead
20
Facebook users.
21
c. When the Facebook users clicked on the ads, they were directed to websites controlled
22
by Defendants and prompted to enter their contact information, including name,
23
physical address, email address, and phone number. Defendants’ then collected and
24
sold this information for spam, robocalls, and other marketing campaigns.
25
19.
Defendants’ ads were directed at Facebook users located in various states, including
26
California, Massachusetts, New York, Illinois, Florida, Nevada, Texas, Delaware, New Mexico, New
27
Jersey, Connecticut, Colorado, Idaho, and Arizona.
28
4
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 7
1
1. Defendants Created and Administered Deceptive and Misleading Facebook
2
Pages as Part of Their Scheme.
3
20.
4
on Facebook, Defendants and others working on behalf of ToLocal created multiple Facebook Pages.
5
At least three of these Pages were in the names of businesses, such as “Solar Energy Today,” “Home
6
Saving Net,” and “Solar Rebate.” Defendants’ Pages were used to promote false, misleading, and
7
deceptive content related to state-sponsored “solar rebates,” “solar incentives,” and tax credits.
Hunton Andrews Kurth LLP
8
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
Between March 2018 and April 2019, to support their deceptive advertising campaign
21.
On March 7, 2016, Defendant Min Ge created a Facebook Page using the business
9
name “Social Energy Today” (the “Social Energy Page”). On September 17, 2016, Defendant Min
10
Ge created a Facebook Page using the business name “Solar Rebate” (the “Solar Rebate Page”). On
11
June 14, 2017, a ToLocal employee created a Facebook Page using the business name “Home Saving
12
Net” (the “Home Saving Page”). Defendant Min Ge and several ToLocal employees administered
13
and moderated the Social Energy Page, the Solar Rebate Page, and the Home Saving Page.
14
22.
For example, as shown in Figure 1, on or about February 25, 2019, the Solar Energy
15
Page created by Defendant Min Ge posted misleading content in order to entice Facebook users to
16
click on a link on the Page. In fact, Facebook users who clicked on the link were redirected to landing
17
pages controlled by Defendants, which were designed to harvest their contact information.
18
///
19
///
20
///
21
///
22
///
23
///
24
///
25
///
26
///
27
///
28
///
5
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 8
Figure 1: Solar Energy Page Post
1
2
3
4
5
6
7
8
9
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
11
12
13
14
15
16
17
18
19
20
21
2. Defendants Purchased Deceptive Ads Using Their Facebook Pages.
23.
In order to reach more Facebook users, Defendants and others working on behalf of
ToLocal and ToMongoAd, created, purchased, and ran thousands of ads using their Facebook Pages.
24.
For example, between May 2018 and April 21, 2019, the Solar Energy Page purchased
22
and ran approximately 4,790 ads on Facebook, for the purpose of generating leads information for
23
spammers and robocallers. These ads were paid for by ToLocal and ToMongoAd. Defendants’ ads
24
frequently used images of state and federal elected officials to promote the legitimacy of the ads.
25
25.
The Social Energy Page ads contained false, deceptive, and misleading statements
26
related to “solar incentives” and “solar rebates.” As set forth in Figure 2, on October 8, 2018, one of
27
these ads targeted residents of New York and falsely claimed that “Gov. Cuomo will release $10
28
million in solar incentives for NY home solar expansion,” and that New York homeowners could
6
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 9
1
“enter their zip code and answer 3 simple questions” to determine if they qualified for “new 2018 Gov.
2
sponsored incentives.” Ex. 9. In fact, Defendants collected and sold the information entered by users
3
in response to their questions for spam, robocalls, and other marketing campaigns.
Figure 2: Solar Energy Page Advertisement - New York
4
5
6
7
8
9
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
11
12
13
14
15
16
17
18
19
26.
Between October 2018 and November 2018, Defendants also claimed that the
20
governors of New Jersey, Texas, Florida, and California were also releasing “$10 million solar
21
incentives (sic)” in similar ads direct at residents of each of those states. Ex. 10 – 13.
22
27.
As set forth in Figure 3, one of the Solar Energy Page ads targeted residents of
23
California, falsely claiming that “Governor Jerry Brown will release $100 million solar incentives for
24
California solar expansion” and these were available to individuals “lucky enough to live in an active
25
zip code,” and limited to “150 applicants per day.” Ex. 14. These ads included a misleading image of
26
California Governor Jerry Brown.
27
28
7
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 10
Figure 3: Solar Energy Page Advertisement - California
1
2
3
4
5
6
7
8
9
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
11
12
13
14
15
16
17
28.
Between October 26, 2018 and November 12, 2018, Defendants also claimed that the
18
governors of Delaware, New Mexico, New York, New Jersey, and Arizona were also going to “release
19
$100 million solar incentives” in similar ads directed at residents of each of those states and containing
20
images of various governors. Ex. 15 - 19.
21
29.
The Home Saving Page ads also contained false, deceptive, and misleading statements
22
related to “solar incentives” and also used the same or similar images as the Solar Energy Page ads.
23
As set forth in Figure 4, one of the Home Saving Page ads was directed at residents of Nevada,
24
contained an image of the Nevada Governor, and falsely stated: “ATTENTION NEVADA HOME
25
OWNERS: There is a new policy just signed . . . Gov. Steve Sisolak will release $15 million in solar
26
incentives . . . . Check it out and see if you qualify!”
27
28
8
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 11
Figure 4: Home Saving Page Ad
1
2
3
4
5
6
7
8
9
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
11
12
13
14
15
16
17
30.
18
Between February 8, 2019 and February 15, 2019, Defendants also claimed that the
19
governors of California, Connecticut, Illinois, Massachusetts, Colorado, and Idaho were also going to
20
“release $15 million solar inceptives” in similar ads and used images of those governors. Ex. 20 - 25.
31.
21
The Solar Rebate Page ads also contained false, deceptive, and misleading statements
22
related to state-sponsored giveaways of solar panels. As set forth in Figure 5, some of the Solar Rebate
23
Page ads directed at Texas residents, contained an image of the Texas Governor Greg Abbot and
24
President Donald J. Trump, and falsely claimed that the State of Texas was “set to give solar panels
25
to homeowners at no cost down.”
26
///
27
///
28
///
9
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 12
Figure 5: Solar Rebate Page Advertisement
1
2
3
4
5
6
7
8
9
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
11
12
13
14
15
3. Defendants’ Ads Directed Facebook Users to Websites Designed to Harvest
16
Their Contact Information.
17
18
32.
Facebook users who clicked on Defendants’ ads on Facebook were redirected to
19
websites (which included various landing pages) controlled by Defendants. One of Defendants’
20
websites was hosted on the domain solar-energy-today.com, registered to Defendant Min Ge as the
21
domain name registrant, the registrant organization was ToLocal, and the registrant contact email
22
address was “payment@tolocal.com.” See Ex. 26. Defendants used a domain privacy service to
23
conceal their control of other websites, like solar-rebate.com.
24
33.
The Defendants’ landing pages asked the Facebook users and other visitors
25
(collectively “the visitors”) a series of questions under the false premise that the information was
26
necessary to determine their eligibility state-sponsored rebates and incentives. Typically, the visitors
27
were directed through a series of landing pages within Defendants’ websites that asked for different
28
types of information.
10
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 13
1
34.
The initial landing page hosted at solar-rebate.com first prompted the visitors to enter
2
their ZIP code and home ownership status. Ex. 27. The visitors were then directed to a secondary
3
landing page that prompted them to identify their electric utility provider, average monthly bill, and
4
other information about the home. Ex. 28. The visitors were then directed to a third landing page (Ex.
5
29) that prompted the visitors for their name, physical address, email address, and phone number, as
6
set forth in Figure 6.
Figure 6: Solar-Rebate.com Landing Page
7
8
9
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
35.
Defendants’ also hosted a website on the domain national-solar-rebate.com. This
website also prompted its visitors, through a series of sequential landing pages, to enter their contact
information. Ex. 30. The landing pages falsely quoted to its visitors that they could save “up to $3,360
or more” through solar rebates. Ex. 30.
28
11
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 14
1
36.
As shown in Figure 7, the website hosted at the domain solar-engery-today.com also
2
prompted its visitors, through a series of sequential landing pages, to enter their contact information.
3
Ex. 31. The landing pages prompted visitors to click through the site, by claiming, “this is the 1 simple
4
truth your power company doesn’t want you to know.” Ex. 31.
Figure 7: Solar-Energy-Today Landing Page
5
6
7
8
9
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
11
12
13
14
15
16
17
18
37.
On information and belief, Defendants intentionally directed their websites’ visitors
19
through multiple landing pages in order to conceal their true purpose (leads generation) until after the
20
visitors had already been prompted to enter information about themselves. Defendants collected, sold
21
or otherwise monetized Facebook users’ contact information by selling it for spam and robocall
22
marketing campaigns unrelated to state-sponsored solar initiatives or rebates.
23
D.
24
25
Defendants Unjustly Enriched Themselves and Their Unlawful Acts Have
Injured and Damaged Facebook
38.
Defendants’ breaches of Facebook’s TOS and Policies and other misconduct described
26
above have harmed Facebook, including by negatively impacting and interfering with Facebook’s
27
service. Defendants have negatively impacted the Facebook experience for users exposed to
28
Defendants’ false, misleading, and deceptive ads, thus harmed Facebook directly.
12
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 15
1
Hunton Andrews Kurth LLP
Facebook has suffered damages attributable to the efforts and resources it has used to
2
address the wrongdoings alleged in this Complaint, to investigate and mitigate Defendants’ conduct,
3
and to identify, analyze, and stop their injurious activities.
4
40.
Defendants’ scheme injured Facebook’s reputation, public trust, and goodwill.
5
41.
Defendants have been unjustly enriched by their activities at the expense of Facebook.
6
42.
Defendants received adequate consideration for their agreement with and contractual
7
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
39.
obligations to Facebook. Facebook’s TOS and Policies as to Defendants are just and reasonable.
8
FIRST CAUSE OF ACTION
9
(Breach of Contract)
10
43.
Facebook incorporates all other paragraphs as if fully set forth herein.
11
44.
Defendant Min Ge created multiple personal Facebook accounts and was an
12
administrator or moderator for the Social Energy Page, the Solar Rebate Page, and the Home Saving
13
Page. Additionally, Defendant Min Ge held the role of administrator of the Solar Energy Page from
14
March 2016 until May 2019. Defendants agreed to Facebook’s TOS and Policies when they created
15
their Facebook accounts and the Solar Energy Page.
16
45.
Since March 2018, Defendants’ have used the Solar Energy Page, Home Saving Page,
17
and Solar Rebate Page and purchased and ran ads using those Pages to enrich themselves. Because
18
Defendants used and targeted Facebook and Facebook users, Defendants are subject to Facebook’s
19
TOS and Policies.
20
46.
Defendant breached Facebook’s TOS and Policies by taking the actions described
21
above, including using deceptive, false, or misleading content in Facebook ads and landing pages in
22
violation of TOS 3.2.1, Pages Policy 2.1, and Advertising Policy 4.13, 12.1 and 12.4.
23
24
47.
accordance with its agreement with Defendants.
25
26
Facebook has performed all conditions, covenants, and promises required of it in
48.
Defendants’ breaches have caused Facebook damages in an amount in to be determined
at trial.
27
28
13
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 16
1
SECOND CAUSE OF ACTION
2
(Unlawful, Unfair, or Fraudulent Business Practices)
3
49.
Facebook incorporates all other paragraphs as if fully set forth herein.
4
50.
Defendants’ actions described above, constitute unlawful, unfair, or fraudulent acts or
5
practices in the conduct of a business, in violation of California’s Business and Professions Code
6
Section 17200 et seq., including actions that are forbidden by other state law.
7
8
9
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
11
51.
Defendants’ practices are unfair because they offend established public policy and are
substantially injurious to Facebook and its users.
52.
Defendants’ practices are fraudulent because they are likely to deceive Facebook and
its users into believing Defendants’ ads were genuine, when, as alleged above, they were not.
53.
As a result of Defendants’ acts and omissions, Facebook was injured in fact and lost
12
money and property in the form of, among other things, costs to investigate, remediate, and prevent
13
Defendants’ wrongdoings.
14
THIRD CAUSE OF ACTION
15
(Breach of Implied Covenant of Good Faith and Fair Dealing)
16
54.
Facebook incorporates all other paragraphs as if fully set forth herein.
17
55.
To the extent the Defendants did not breach Facebook’s express TOS and Policies,
18
Defendants deprived Facebook of the full benefits of its contracts, including Facebook’s contractual
19
rights under its TOS, Pages Policy, and Advertising Policies.
20
56.
Facebook suffered damages as a result of these violations.
21
REQUEST FOR RELIEF
22
WHEREFORE, Plaintiff Facebook requests judgment against Defendants as follows:
23
1.
That the Court enter judgment against Defendants that Defendants have:
24
a. Breached their contracts with Facebook in violation of California law;
25
b. Breached the implied covenant of good faith and fair dealing in violation of
26
27
28
California law; and
c. Engaged in unlawful, unfair, or fraudulent business practices in violation of
California law.
14
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 17
1
2.
That the Court enter an injunction enjoining and restraining Defendants and their
2
agents, employees, successors, and assigns, and all other persons acting in concert with or conspiring
3
or affiliated with Defendants from:
4
a. Accessing or attempting to access Facebook’s platform and computer systems;
5
b. Engaging in any activity that disrupts, diminishes the quality of, interferes with the
6
performance of, or impairs the functionality of Facebook’s platform and computer
7
system;
8
c. Engaging in any activity, or facilitating others to do the same, that violates
9
Facebook’s TOS and Policies;
Hunton Andrews Kurth LLP
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
10
11
3.
proven at trial.
12
13
4.
That Defendants account for, hold in constructive trust, pay over to Facebook and
otherwise disgorge profits derived from Defendants’ unjust enrichment.
14
15
That Facebook be awarded damages as permitted by law and in such amounts to be
5.
That Facebook be awarded a recovery in restitution equal to any unjust enrichment
enjoyed by Defendant.
16
6.
That Facebook be awarded its reasonable costs, including reasonable attorneys’ fees.
17
7.
That Facebook be awarded pre- and post-judgment interest as allowed by law.
18
///
19
///
20
///
21
///
22
///
23
///
24
///
25
///
26
///
27
///
28
///
15
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 18
1
2
8.
That the Court grant all such other and further relief as the Court may deem just and
proper.
3
4
Dated: May 30, 2019
HUNTON ANDREWS KURTH LLP
5
By:
6
7
8
9
Platform Enforcement and Litigation
Facebook, Inc.
Jessica Romero
Michael Chmelar
Stacy Chen
Hunton Andrews Kurth LLP
10
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
/s/ Ann Marie Mortimer
Ann Marie Mortimer
Jason J. Kim
Attorneys for Plaintiff
FACEBOOK, INC.
11
12
13
14
JURY TRIAL DEMAND
15
16
Plaintiff hereby demands a trial by jury on all issues triable to a jury.
17
18
Dated: May 30, 2019
HUNTON ANDREWS KURTH LLP
19
By:
20
21
22
23
/s/ Ann Marie Mortimer
Ann Marie Mortimer
Jason J. Kim
Attorneys for Plaintiff
FACEBOOK, INC.
Platform Enforcement and Litigation
Facebook, Inc.
Jessica Romero
Michael Chmelar
Stacy Chen
24
25
26
27
28
099900.12852 EMF_US 74233715v4
16
COMPLAINT; DEMAND FOR JURY TRIAL
PDF Page 19
EXHIBIT 1
17
PDF Page 20
05/21/2019 - tolocal.com homepage
• • •
4
Tt
C
Tolocal
I https i www.tolocal.com
TL
TOLOCAL
TO LOCALTO GLOBAL
Home
About
Services
ADVERTISING. DIGITAL
MARKETING. PUBLIC RELATIONS.
Tolocal provides cutting edge strategy, technology, and cross-channel marketing execution built to drive high-value
customers to your business and into your sales funnel.
Get Started!
Learn more
18
Contact
PDF Page 21
05/21/2019 - tolocal.com homepage
•
•
•
11 Tolocal
C
I
Q *
https www.tolocal.com
TL
TOLOCAL
10 LOCAL.I 0 GLOBAL
Home
About Tolocal
About
Services
Contact
•
Tolocal started 2014 as a dream to help businesses grow. We saw
companies reeling to adjust to a rapidly changing digital world and the
marketing landscape was full of traditional agencies, one-dimensional
specialists, and countless vendors peddling their particular product or
•
•
service. But there was nobody to help companies pull everything
together. So We Started Tolocal.
Our goal was to build an agency that focused on transparency,
sound business strategy, and in-depth multi-channel marketing
expertise. Today, Tolocal is a growing company with a wonderful team
and a strong stable of clients. We work hard, play hard, and we love what
•
we do.
•
What We Offer
(P"\ STRATEGY
BRANDING
.1:t ADVERTISING
Define the goals that mean success
Create an identity that matches the
Use the advanced targeting made
for your business and create the
experience your company delivers.
possible by digital channels to
19
•
PDF Page 22
05/21/2019 - tolocal.com homepage
TL
+
x
Tolocal
fl https:;’fwww.toiocal.com
TL
TOLOCAL
LOCAL
U GLOBAL
IO
Horne
About
Contact
l
Define the
goals; the
_
Em your buginess and
pian t0
make
DIGITAL
it
mean Euccegs
Cream an
create
Experience yeur
the-
identity that
matches the
company
delivers.
happen.
WEB DEVELOPMENT
Launch. the online lead generatior‘:
Wansfos'm your webgize from
campaigns
digitai billboard to a
will
help you get
found and get grswing.
Happy
clients
possible by digital channeis
reac h
MARKETING
that
Use the advanced targeting made
3.50:1 r
I10
ideal cusiomers.
PUBLIC RELATIONS
Reach the media outiets your
a
Quitomers read and build
business
engine your customers Ewe.
tine
reputatiom you deserve.
‘2’
2
I
3
15K
25
Awards won
Cups of Coffee
Projects completed
Get
In
Touch
20
PDF Page 23
05/21/2019 - tolocal.com homepage
TL
X
Tolocal
+
fl https://www.toiocal.com
TL
TOLOCAL
LOCAL
GLOBAL
[O
About
Horne
IO
I
Phone
w
Emall
3x 3.5a}
Address
03c:
TL
TOLOCAL
TO LOCALTO GLOBAL
21
11L,
Services
PDF Page 24
EXHIBIT 2
22
PDF Page 25
05/22/19 - TOLOCAL, INC. https://businesssearch.sos.ca.gov Articles of Incorporation
3704513
FILED
SECRETARY OF STATE
STATE OF CAI IPORNIA
ARTICLES OF INCORPORATION
ACC
AUG 20 2014
OF
TOLOCAL, INC.
ARTICLE I
NAME
The name of this corporation is: ToLocal, Inc.
ARTICLE H
PURPOSE
The purpose of the corporation is to engage in any lawful act or activity for which a
corporation may be organized under the General Corporation Law of California other than
the banking business, the trust company business or the practice of a profession permitted
to be incorporated by the California Corporations Code.
ARTICLE III
INITIAL AGENT FOR SERVICE OF PROCESS
The name and address in the State of California of the corporation's initial agent for
service of process is:
NAN SHEN
2570 North First Street, 2 nd Floor
San Jose, CA 95131
ARTICLE IV
CORPORATE ADDRESS
The initial street address of the corporation is:
1
23
Xot/
PDF Page 26
3704513
2370 North First Street, 2nd Floor
San Jose, CA 95131
ARTICLE V
AUTHORIZED CAPITAL
5.1
General. The corporation is authorized to issue 10,000,000 shares of stock,
all of which shall be common stock, no par value.
5.2
Common Stock. Each holder of common stock shall be entitled to one vote
for each share of common stock held of record on all matters on which stockholders
generally are entitled to vote, subject to the provisions of law.
ARTICLE VI
INDEMNIFICATION
The Corporation shall indemnify its directors, officers, employees, and agents to the
fullest extent permitted by law.
Date: August 15, 2014
NAN SHEN, Incorporator
2
24
PDF Page 27
EXHIBIT 3
25
PDF Page 28
05/22/19 - ToLocal, Inc - https://businesssearch.sos.ca.gov/ Statement of Information
State of California
,,.
Secretary of State
•-t4., -1.10: -,
Statement of Information
(Domestic Stock and Agricultural Cooperative Corporations)
FEES (Filing and Disclosure): $25.00.
If this is an amendment, see instructions.
IMPORTANT — READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
1 CORPORATE NAME
TOLOCAL, INC.
FM08983
FILED
In the office of the Secretary of State
of the State of California
APR-14 2017
2. CALIFORNIA CORPORATE NUMBER
This Space for Filing Use Only
C3704513
No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.)
3 If there have been any changes to the information contained in the last Statement of Information filed with the California Secretary
of State, or no statement of information has been previously filed, this form must be completed in its entirety.
If there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed to Item 17.
Complete Addresses for the Following (Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
4.
STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
2100 GENG RD. SUITE 100., PALO ALTO, CA 94303
5.
STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE IN CALIFORNIA, IF ANY
2100 GENG RD. SUITE 100., PALO ALTO. CA 94303
6.
MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM 4
Names and Complete Addresses of the Following Officers
(The corporation must list these three officers. A comparable title for the specific
officer may be added; however, the preprinted titles on this form must not be altered.)
7.
CHIEF EXECUTIVE OFFICER/
MIN GE
8.
SECRETARY
MIN GE
9.
CITY
STATE
ZIP CODE
ADDRESS
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
2100 GENG RD. SUITE 100., PALO ALTO, CA 94303
CHIEF FINANCIAL OFFICER/
YU GE
ADDRESS
2100 GENG RD. SUITE 100., PALO ALTO, CA 94303
ADDRESS
2100 GENG RD. SUITE 100., PALO ALTO, CA 94303
Names and Complete Addresses of All Directors, Including Directors Who are Also Officers
(The corporation must have at least one
director. Attach additional pages, if necessary.)
10. NAME
MIN GE
ADDRESS
CITY
STATE
ZIP CODE
2100 GENG RD. SUITE 100., PALO ALTO, CA 94303
11. NAME
ADDRESS
CITY
STATE
ZIP CODE
12. NAME
ADDRESS
CITY
STATE
ZIP CODE
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY:
Agent for Service of Process If the agent is an individual, the agent must reside in California and Item 15 must be completed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State a
certificate pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS
MIN GE
15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA. IF AN INDIVIDUAL CITY
STATE
ZIP CODE
2100 GENG RD. SUITE 100., PALO ALTO, CA 94303
Type of Business
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
INTERNET SERVICE
17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
04/14/2017
DATE
SI-200 (REV 0112013)
JIA ZHANG
EXECUTIVE ASSISTANT
TYPE/PRINT NAME OF PERSON COMPLETING FORM
TITLE
Page 1 of 1
26
SIGNATURE
APPROVED BY SECRETARY OF STATE
PDF Page 29
EXHIBIT 4
27
PDF Page 30
05/22/19 - ToMongoAd https://businesssearch.sos.ca.gov/ Articles of Incorporation
3815123
FILED
ARTICLES OF INCORPORATION
SECRETARY OF STATE
STATE OF CAI IPORNIA
OF
Global Capital Express Inc.
1St AUG I I 7015
1. The name of the corporation is Global Capital Express Inc.
2. The purpose of the corporation is to engage in any lawful act or activity for which a
corporation may be organized under the General Corporation Law of California other than the
banking business, the trust company business or the practice of a profession permitted to be
incorporated by the California Corporations Code.
3. The name and street address in the State of California of this corporation's initial agent
for service of process is:
Min Ge, 2225 East Bayshore Rd. Suite 100, Palo Alto, California 94303
4. The initial street address of this corporation is 2225 East Bayshore Rd. Suite 100, Palo
Alto, California 94303.
5. a) The corporation is authorized to issue two classes of shares, each with $0.001 as par
value, designated "Common Stock" and "Preferred Stock", respectively. The number of shares
of Common Stock authorized to be issued is 10,000 and the number of shares of Preferred Stock
authorized to be issued is 10000.
b) The Preferred Stock may be issued from time to lime in such number of series as the
Board of Directors may determine. The Board of Directors is authorized to determine or alter
the rights, preferences, privileges and restrictions granted to or imposed upon any wholly
unissued series of Preferred Stock, and to fix the number of shares of any series of Preferred
Stock and the designation of any such series of Preferred Stock. Subject to compliance with
applicable protective voting rights which may be granted to the Preferred Stock or any series of
Preferred Stock in Certificates of Determination or the corporation's Articles of Incorporation,
the Board of Directors is also authorized, within the limits and restrictions stated in any
resolution or resolutions of the Board of Directors originally fixing the number of shares
constituting any series, to increase or decrease (but not below the number of shares of such
series then outstanding) the number of shares of any series subsequent to the issue of the shares
of that series. In case the number of shares of any series shall be so decreased, the shares
constituting such decrease shall resume the status which they had prior to the adoption of the
resolution originally fixing the number of shares of such series.
6. The liability of the directors of the corporation for monetary damages shall be
eliminated to the fullest extent permissible under California law.
28
Cil
" l
PDF Page 31
3815123
7. This corporation is authorized to provide indemnification of agents (as defined in
Section 317 of the California Corporations Code) through bylaw provisions, agreements with
agents, vote of shareholders or disinterested directors or otherwise, in excess of the
indemnification otherwise permitted by Section 317 of the California Corporations Code,
subject only to the applicable limits set forth in Section 204 of the California Corporations Code
with respect to actions for breach of duty to the corporation and its shareholders.
8. Any repeal or modification of the foregoing provisions of Sections 6 and 7 by the
shareholders of this corporation shall not adversely affect any right or protection of an agent of
this corporation existing at the time of such repeal or modification.
I, the undersigned, as the sole incorporator of the corporation, declare that I am the person
who executed these Articles of Incorporation, which execution is my act and deed.
Executed on 8/10/2015.
LegalZoom.com, Inc., Incorporator
By: Cheyenne Moseley, Assistant Secretary
29
PDF Page 32
EXHIBIT 5
30
PDF Page 33
•
I
Ong°
••
PS:
.sos.ca.gov
Articles of Incorporation
•usmesssearc
C 3816123
Added For Imagind
I • 20 ti
e I ica e o • menemen o
po 8 2 61 3
t#11.4
3s C125
Certificate of Amendment of Articles of Incorporation
let/
The undersigned certify that
FILED
Secretary of State
State of C2lifomia
MAR 2 8 2016
I. They are the paid prepare: of Global Capital Express Inc., a California corporation, Entity
Number C3815723.
2. Article 1 of the Articles of Incorporation of this corporation is amended to read as follows*
1. The name of the corporation is TomongoAd Inc.
3. The foregoing amendment of Articles of Incorporation has been duly approved by the board of
directors.
4. The foregoing amendment of Articles of Incorporation has been duly approved by the required
vote of shareholders in accordance with Section 902, California Corporations Code. The total
number of outstanding shares of the corporation is 10,000. The number of shares voting in favor
of the amendment equaled or exceeded the vote required The percentage vote required was more
than 50%.
We further declare under penalty of perjury under the laws of the State of California that the
matters set forth in this certificate are true and correct of our own knowledge.
DATE: /VW 2 3,
?Of ( 2
Min Ge, President
to Ge, Secretary
31
PDF Page 34
EXHIBIT 6
32
PDF Page 35
Exhibit 6 - 05/22/19 - Whois screenshot from centralops.com for tomongoad.com
Queried whois.godaddy.com with "tomongoad.com"...
Domain Name: tomongoad.com
Registry Domain ID: 2263395382DOMAINCOM-VRSN
Registrar WHOIS Server: whois.godaddy.com
Registrar URL: http://www.godaddy.com
Updated Date: 2019-05-15T15:27:42Z
Creation Date: 2018-05-14T18:41:35Z
Registrar Registration Expiration Date: 2020-05-14T18:41:35Z
Registrar: GoDaddy.com, LLC
Registrar IANA ID: 146
Registrar Abuse Contact Email: abuse@godaddy.com
Registrar Abuse Contact Phone: +1.4806242505
Domain Status: clientTransferProhibited http://www.icann.org/epp#clientTransferProhibited
Domain Status: clientUpdateProhibited http://www.icann.org/epp#clientUpdateProhibited
Domain Status: clientRenewProhibited http://www.icann.org/epp#clientRenewProhibited
Domain Status: clientDeleteProhibited http://www.icann.org/epp#clientDeleteProhibited
Registrant Organization: ToLocal Inc
Registrant State/Province: California
Registrant Country: US
Registrant Email: Select Contact Domain Holder link at https://www.godaddy.com/whois/results.aspx?domain=tomongoad.com
Admin Email: Select Contact Domain Holder link at https://www.godaddy.com/whois/results.aspx?domain=tomongoad.com
Tech Email: Select Contact Domain Holder link at https://www.godaddy.com/whois/results.aspx?domain=tomongoad.com
Name Server: DEMI.NS.CLOUDFLARE.COM
Name Server: JASON.NS.CLOUDFLARE.COM
DNSSEC: unsigned
URL of the ICANN WHOIS Data Problem Reporting System: http://wdprs.internic.net/
>>> Last update of WHOIS database: 2019-05-23T17:00:00Z «<
33
PDF Page 36
EXHIBIT 7
34
PDF Page 37
INC. articles of incor • oration
A07797 39
FILED
37045/3
CERTIFICATE OF AMENDMENT OF
ARTICLES OF INCORPORATION
Secretary of State
State of California
Tc. JAN 1 4 2016 C
OF
TOLOCAL, INC.
The undersigned certify that:
1. They are the President and the Secretary, respectively, of TOLOCAL, INC., a
California corporation.
2. Article V (5.1) of the Articles of Incorporation of this corporation is amended to read
as follows:
The total number of shares of all classes of stock that the corporation is authorized
to issue is One Hundred Million (100,000,000), no par value.
3. The foregoing amendment of Articles of Incorporation has been duly approved by
the board of directors.
4. The foregoing amendment of Articles of Incorporation has been duly approved by
the required vote of shareholders in accordance with Section 902, California
Corporations Code. The total number of outstanding shares of the corporation is
2,000,000. The number of shares voting in favor of the amendment equaled or
exceeded the vote required. The percentage vote required was more than 50%.
We further declare under penalty of perjury under the laws of the State of California that
the matters set forth in this certificate are true and correct of our own knowledge.
DATED:
ppc
"Vic
Mi6 GE, President
Yu GE, Secretary
35
PDF Page 38
EXHIBIT 8
36
PDF Page 39
Information
_
,,...,
.
State of California
.
S
Secretary of State
Statement of Information
. ....
(Domestic Stock and Agricultural Cooperative Corporations)
FEES (Filing and Disclosure): $25.00.
If this is an amendment, see instructions.
IMPORTANT — READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
I_
CORPORATE NAME
FD97229
FILED
In the office of the Secretary of State
of the State of California
TOMONGOAD INC.
JUN-02 2016
2. CALIFORNIA CORPORATE NUMBER
This Space for Filing Use Only
C3815723
No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.)
If there have been any changes to the Information contained In the last Statement of Information flied with the California Secretary
3
of State, or no statement of Information has been previously filed, this form must bo completed In Its entirety.
7 If there has been no change in any of the information contained in the last Statement of Information fled with the California Secretary
--1 of State. check the box and proceed to Item 17.
Complete Addresses for the Following
4.
(Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE
CITY
STATE
ZIP CODE
5. STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE IN CALIFORNIA. IF ANY
2100 GENG ROAD. SUITE #100. PALO ALTO. CA 94303
CITY
STATE
ZIP CODE
6.
CITY
STATE
ZIP CODE
2100 GENG ROAD, SUITE #100, PALO ALTO, CA 94303
MAILING ADDRESS OF CORPORATION. IF DIFFERENT THAN ITEM 4
Names and Complete Addresses of the Following Officers (The corporation must list these three Officers. A comparable title for
the spook
officer may be added: however. the preprinted titles on this form must not be altered.)
7.
CHIEF EXECUTIVE OFFICER/
MIN GE
8.
SECRETARY
MIN GE
9.
CITY
STATE
ZIP CODE
ADDRESS
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
2100 GENG ROAD, SUITE #100, PALO ALTO, CA 94303
CHIEF FINANCIAL OFFICER/
MIN GE
ADDRESS
2100 GENG ROAD, SUITE #100. PALO ALTO, CA 94303
ADDRESS
2100 GENG ROAD. SUITE #100. PALO ALTO, CA 94303
Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one
director. Attach additional pages, If necessary.)
10. NAME
MIN GE
ADDRESS
CITY
STATE
ZIP CODE
2100 GENG ROAD, SUITE #100, PALO ALTO. CA 94303
it. NAME
ADDRESS
CITY
STATE
ZIP CODE
12. NAME
ADDRESS
CITY
STATE
ZIP CODE
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS. IF ANY:
Agent for SeTVICI) of Process
If the agent is an individual, the agent must reside in California and Item 15 Mat be competed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of Stale a
certiecato pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS
MIN GE
15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA. IF AN INDIVIDUAL CITY
STATE
ZIP CODE
2100 GENG ROAD, SUITE #100, PALO ALTO. CA 94303
Type of Business
16 DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
ONLINE INTERNET SERVICE
Ir. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE. THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS. IS TRUE AND CORRECT.
06/02/2016
DATE
SI-200 (REV 01/2013)
CHEYENNE MOSELEY
AUTH. REP.
TYPE/PRINT NAME OF PERSON COMPLETING FORM
TITLE
37
Page 1of 1
SIGNATURE
APPROVED BY SECRETARY OF STATE
PDF Page 40
EXHIBIT 9
38
PDF Page 41
Solar Energy Today
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION NEW YORK HOMEOWNERS: There is a new 2018
Gov. sponsored initiatives that offers you the best solar deal
NOW, Gov, Cuomo will release $10 million solar incentives for
NY home solar expansion.
Enter your zip code and answer 3 simple questions. If you are
lucky enough to live in an active zip code, you can get paid ...
•
-4 V-
_
Aifi
•••••;....•
•
•••
Last Week! New York State Sponsored Solar Incentive
Application Ends in 5 Days, Receive FREE Quotes & Get...
Solar programs are so popular that people throughout the
United States are signing up at a record pace. If you act now,...
BIGSAVINGUSA.COM
39
Get Offer
PDF Page 42
EXHIBIT 10
40
PDF Page 43
p
Solar Energy Today
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION CALIFORNIA HOMEOWNERS: There is a new
2018 program that offers you the best solar deal NOW. Gov.
Brown will release $10 million solar incentives for CA home
solar expansion.
Enter your zip code and answer 3 simple questions. If you are
lucky enough to live in an active zip code, you can get paid ...
a
•„
a
4)
Last Week! California Statewide Sponsored Solar
Application Ends in 5 Days, Get FREE Quotes Now..
Solar programs are so popular that people throughout the
United States are signing up at a record pace. If you act now,...
BIGSAVINGUSA.COM
41
Get Offer
PDF Page 44
EXHIBIT 11
42
PDF Page 45
Solar Energy Today
/
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION FLORIDA HOMEOWNERS: There is a new 20'18
Gov. sponsored initiatives that offers you the best solar deal
NOW. Gov. Rick Scott will release $10 million solar incentives
for FL home solar expansion.
Enter your zip code and answer 3 simple questions. If you are
lucky enough to live in an active zip code, you can get paid ...
ow.
•
11:
Last Week! Florida State Sponsored Solar Incentive
Application Ends in 5 Days, Receive FREE Quotes & Get...
Solar programs are so popular that people throughout the
United States are signing up at a record pace. If you act now,...
BIGSAVINGUSA.COM
43
Get Offer
PDF Page 46
EXHIBIT 12
44
PDF Page 47
Solar Energy Today
r
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION TEXAS HOMEOWNERS: There is a new 2018
program that offers you the best solar deal NOW. Gov. Brown
will release $10 million solar incentives for TX home solar
expansion.
Enter your zip code and answer 3 simple questions. If you are
lucky enough to live in an active zip code, you can get paid ...
/
-
se
a .
41
.
.
ne',,,
iii: e
- 4;11.„
44r
Last Week! Texas Sponsored Solar Application Ends in 5
Days, Get FREE Quotes Now..
Solar programs are so popular that people throughout the
United States are signing up at a record pace. If you act now,...
BIGSAVINGUSA.COM
45
Get Offer
PDF Page 48
EXHIBIT 13
46
PDF Page 49
Solar Energy Today
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION NEW JERSEY HOMEOWNERS: There is a new
2018 Gov. sponsored initiatives that offers you the best solar
deal NOW. Gov. Murphy will release $10 million solar
incentives for NJ home solar expansion.
Enter your zip code and answer 3 simple questions. If you are
lucky enough to live in an active zip code, you can get paid ...
!!!!!r3r
•
••
411Ik
e a fr
f
No.
Last Week! NEW JERSEY Endorsed Solar Incentive
Application Ends in 5 Days, Receive FREE Quotes & Get...
Solar programs are so popular that people throughout the
United States are signing up at a record pace. If you act now,...
BIGSAVINGUSA.COM
47
Get Offer
4
PDF Page 50
EXHIBIT 14
48
PDF Page 51
*
Solar Energy Today
sponsored • Palo for by SOLAR ENERGY TODAY
ATTENTION CALIFORNIA HOMEOWNERS: There is a new 2018
policy that your power provider doesn't want you to know
about. Governor Jerry Brown will release $100 million solar
incentives for California solar expansionlf you are lucky
enough to live in an active zip code, you can get paid to go
solar. Check it out and see if you qualify!
It4
'Ad
California Government Set To Give sou. Panels To
Homeowners At No Cost Down, Policy Effective Already
Limited to 150 applicants per day. Only some rig codes are
eltteble in each state. Those Tat..
NATIONALSOtAll-PCIIATECOM
49
Apply Now
PDF Page 52
EXHIBIT 15
50
PDF Page 53
'pp
Solar Energy Today
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION DELAWARE HOMEOWNERS: There is a new
policy that your power provider doesn't want you to know
about. The Gov. John Carney will release $100 million solar
incentives for DE home solar expansion. If you are lucky
enough to live in an active zip code, you can get paid to go
solar. Check it out and see if you qualify!
I
47
47
Delaware Government Set To Give Solar Panels To Homeowners At No
Cost Down
Click HERE to see how much solar energy incentives you are eligible for
before the program expires. DE homeowners only
URBIGSAVINGS.COM
51
PDF Page 54
EXHIBIT 16
52
PDF Page 55
,A1
Solar Energy Today
17 Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION NEW MEXICO HOMEOWNERS: There is a new
2018 policy that your power provider doesn't want you to
know about. The Gov. Susana Martinez will release $100
million solar incentives for NM home solar expansion. If you
are lucky enough to live in an active zip code, you can get
paid to go solar. Check it out and see if you qualify!
•
New Mexico Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. NM homeowners...
URBIGSAVINGS.COM
53
Learn More
PDF Page 56
EXHIBIT 17
54
PDF Page 57
Solar Energy Today
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION NEW JERSEY HOMEOWNERS: There is a new
2018 policy that your power provider doesn't want you to
know about. Your New Governor, Phil Murphy, will release
$100 million solar incentives for New Jersey solar expansion.
If you are lucky enough to live in an active zip code, you can
get paid to go solar. Check it out and see if you qualify!
•
e•;
.•
•
0.•
•
•-
•
..
^CZ
.
•
‘,.1.• •
fr ri
•••
4 40
4
S
$
44
I"
•
—
O
New Jersey Government Set To Give Solar Panels To
Homeowners At No Cost Down, Policy Effective Already
Limited to 150 applicants per day. Only some zip codes are
eligible in each state. Those that...
SOLAR-ENERGY-TODAY.COM
55
Apply Now
PDF Page 58
EXHIBIT 18
56
PDF Page 59
Solar Energy Today
'
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION ARIZONA HOMEOWNERS: There is a new 2018
policy that your power provider doesn't want you to know
about. The Gov. Doug Ducey will release $100 million solar
incentives for AZ home solar expansion. If you are lucky
enough to live in an active zip code, you can get paid to go
solar. Check it out and see if you qualify!
W
T
IPL
14/
I
g•
Arizona Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. AZ homeowners only
URBIGSAVINGS.COM
57
Learn More
PDF Page 60
EXHIBIT 19
58
PDF Page 61
Solar Energy Today
ot
Sponsored • Paid for by SOLAR ENERGY TODAY
ATTENTION NEW YORK HOMEOWNERS: There is a new 2018
policy that your power provider doesn't want you to know
about. Governor Andrew Cuomo will release $100 million
solar incentives for New York solar expansion. If you are lucky
enough to live in an active zip code, you can get paid to go
solar. Check it out and see if you qualify!
t 91
--wathei-4.,
New York State Government Set To Give Solar Panels To
Homeowners At No Cost Down, Policy Effective Already
Limited to 150 applicants per day. Only some zip codes are
eligible in each state. Those that...
SOLAR-ENERGY-TODAY.COM
59
Apply Now
PDF Page 62
EXHIBIT 20
60
PDF Page 63
Home Saving Net
Sponsored • Paid for by National Solar Rebate
ATTENTION CALIFORNIA HOMEOWNERS: There is a new
policy just be signed. The new Gov. Gavin Newsom will release
$15 million solar incentives for keeping supporting CA home
solar expansion. If you are lucky enough to live in an active zip
code, you can get paid to go solar. Check it out and see if you
qualify!
LIVE
Ic
C
Fore
CAUFORMR GOVERNOR
44N
56N
lOW
Mit ASSIMILT OST. le
•
48-
td BAKER
California Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. CA homeowners only
URBIGSAVINGS.COM
61
Learn More
PDF Page 64
EXHIBIT 21
62
PDF Page 65
Home Saving Net
Sponsored • Paid for by National Solar Rebate
ATTENTION CONNECTICUT HOMEOWNERS: There is a new
policy just be signed. The new Gov. Ned Lamont will release
$15 million solar incentives for keeping supporting CT home
solar expansion. If you are lucky enough to live in an active zip
code, you can get paid to go solar. Check it out and see if you
qualify!
;It
*
*
4.
*
1
•
M`
Connecticut Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. CT homeowners only
URBIGSAVINGS.COM
63
Learn More
PDF Page 66
EXHIBIT 22
64
PDF Page 67
Home Saving Net
SWIPE
Sponsored • Paid for by National Solar Rebate
ATTENTION ILLINOIS HOMEOWNERS: There is a new policy
just be signed. The new Gov. J. B. Pritzker will release $15
million solar incentives for keeping supporting IL home solar
expansion. If you are lucky enough to live in an active zip
code, you can get paid to go solar. Check it out and see if you
qualify!
r" -•amJB
4
FOr -1114 ;#.7
& Juliana
FOR ILLINOIS
Illinois Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. IL homeowners only
URBIGSAVINGS.COM
65
Learn More
PDF Page 68
EXHIBIT 23
66
PDF Page 69
Home Saving Net
.24
Sponsored • Paid for by National Solar Rebate
ATTENTION MASSACHUSETTS HOMEOWNERS: There is a
new policy just be signed. The re-elected Gov. Charles Baker
will release $15 million solar incentives for keeping supporting
MA home solar expansion. If you are lucky enough to live in an
active zip code, you can get paid to go solar. Check it out and
see if you qualify!
•
•
I
•
•
•
•
■
t
II
Massachusetts Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. MA homeowners only
URBIGSAVNGS.COM
67
Learn More
PDF Page 70
EXHIBIT 24
68
PDF Page 71
0
Home Saving Net
Sponsored • Paid for by National Solar Rebate
ATTENTION COLORADO HOMEOWNERS: There is a new
policy just be signed. The new Gov. Jared Polis will release
$15 million solar incentives for keeping supporting CO home
solar expansion. If you are lucky enough to live in an active zip
code, you can get paid to go solar. Check it out and see if you
qualify!
I
ti
a
rm.
Colorado Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. CO homeowners only
URBIGSAVINGS,COM
69
Learn More
PDF Page 72
EXHIBIT 25
70
PDF Page 73
Home Saving Net
••••
Sponsored • Paid for by National Solar Rebate
ATTENTION IDAHO HOMEOWNERS: There is a new policy just
be signed. The new Gov. Brad Little will release $15 million
solar incentives for keeping supporting ID home solar
expansion. If you are lucky enough to live in an active zip
code, you can get paid to go solar. Check it out and see if you
qualify!
•
sl
%
its
I
•
S
Idaho Government Set To Give Solar Panels To
Homeowners At No Cost Down
Click HERE to see how much solar energy incentives you are
eligible for before the program expires. ID homeowners only
URBIGSAVINGS.COM
71
Learn More
PDF Page 74
EXHIBIT 26
72
PDF Page 75
5 / 22 /2019 solar-energy-today.com WHOIS 09 / 08 / 2017 domaintools - Min Ge
solar-energy-today.corn
Advanced
Filters: solar-energy-today.com
4
4101
III■
Pivot Engine
pDNS
Visualization
Stats
IP Tools
Whois History
Hosting History
Screenshot History
solar-energy-today.com
Historical Records
39 records found
2018-06-13
changes
2018-06-12
changes
> 2017-09-08
changes
2017-02-22
changes
2016-10-13
changes
2016-07-18
changes
2016-03-12
changes
2015-05-06
changes
2015-05-02
changes
2015-03-08
changes
2014-12-19
changes
2014-10-06
changes
2014-07-15
changes
Domain Name: solar-energy-today.com
Registry Domain ID: 2011197288_DOMAIN_COM-VRSN
Registrar WHOIS Server: whois.godaddy.com
Registrar URL: http://www.godaddy.com
Updated Date: 2017-02-23T01:08:43Z
Creation Date: 2016-03-10T20:31:46Z
Registrar Registration Expiration Date: 2018-03-10T20:31:46Z
Registrar: GoDaddy.com, LLC
Registrar IANA ID: 146
Registrar Abuse Contact Email: abuse@godaddy.com
Registrar Abuse Contact Phone: +1.4806242505
Domain Status: clientTransferProhibited http://www.icann.org/epp#clientTransferProhibited
Domain Status: clientUpdateProhibited http://www.icann.org/epp#clientUpdateProhibited
Domain Status: clientRenewProhibited http://www.icann.org/epp#clientRenewProhibited
Domain Status: clientDeleteProhibited http://www.icann.org/epp#clientDeleteProhibited
Registry Registrant ID: Not Available From Registry
Registrant Name: Min Ge
Registrant Organization: ToLocal Inc
Registrant Street: 2225 East Bayshore Rd. Suite 100
Registrant City: Palo Alto
Registrant State/Province: California
Registrant Postal Code: 94303
Registrant Country: US
Registrant Phone: +1.6509990391
Registrant Phone Ext:
Registrant Fax:
Registrant Fax Ext:
Registrant Email: payment@tolocal.com
Registry Admin ID: Not Available From Registry
Admin Name: Min Ge
Admin Organization: ToLocal Inc
Admin Street: 2225 East Bayshore Rd. Suite 100
Admin City: Palo Alto
73
3/21/19 Screenshot of http://solar-rebate.com/ as on 06/29/2018 via http://archive.org
C
U https,rweb.archaorg/wecc20170617022141Thttp //solar -rotate conV
*Si
co 1
him tisolar-rebate.somi
64 .aptuiec
law
s es
1
el • JAI
JUN JUL
17 00'
2016 2017 201$
You may be eligible for a new US solar program.
Solar
FIND OUT IF YOU QUALIFY NOWT
Rebate
STEP THREE
Find Out if You Qualify Below. Only takes 30 seconds!
First Name
Last Name
`4•IlUe"ti re•efiei!.!JS
City
TX
Email
77777
Phone
•
•
SUBMIT —#
Tr"
i
■ SAVE 70% On your monthly electric bills
Save Money with Solar!
Get Your FREE Solar Quote...
0 Copyright 2017 Sohn Rebate All Aphis Reserved
79
II Up to 30-50% off with government rebates & incentives.
III Lease a system for as little as SO down
Homo
Privacy Policy
Terms of Use
With little to $0 down, you could be on your
"Go Green and Save Green ,
way to significantly reducing your electric bill in a matter of weeks.
with Clean Power -
0
For billing and service inovres
Call 245rs a day 7 days a week
For bilimp and seNrce inquires
Call 24nr5 a day 7 days a week
Old BO Dale BO Prepared June 15
New BO Dale Bill Prepared July 15
Your account summary
AsnOue101your an tramp cede
Pmfimamt rammed on May 01. Thad,0,
MM.= MheM0
New chmmea
Iron, prenous cyme
Tell Annuli Due by JuM
5126 76
Your account summary
.1126 76
Ameunl 01 you, Lam Wong cycle
Payment mowed on July 51-ThankYou
50 OS
513561
Mona Unpaid
New charges
513561
Trial Amoral( Due by Nome 01
horn premous cycle
S13564
4135 64
$0.00
57 23
CS7.23
Old Bill : 5135.64
Total Savings: $128.41
• kcruk.. 'MUMS wk. v.+ DCF.1)44400+ "MIT. vOu Pun...
L.M. Mug 30u. rrneu
So, how does this program work? You no longer have to buy solar panels, the policy let's
you lease solar panels for as little as $0 upfront. Until now, solar panels cost $10's of
thousands of dollars to purchase and install and unless you were building a new home or
had that much extra cash sitting around, the cost was more than the benefit. The solar
panels had to be purchased. It was impossible for companies to offer rent or lease
agreements because they would lose money.
NOTE: You are not locked into your power company policy If you've
already paid your current policy, you can very easily switch to solar power.
With average savings of 50% when you own, these online services are gaining massive
popularity. One of the most trusted, secure and effective free online service that provides
home owners the best local rates is this website Over 500,000 consumers have already
trusted this website to get significant discounts. If you too would like to receive the
benefits of using this free service you can click here or the button below. Then just enter
your state information and click continue to determine if your eligible.
HOW DO I SEE IF I QUALIFY
Step 1: Click your state on the map to instantly check your zip code for free
Step 2: Once you go through a few questions, you will have the opportunity to compare the
best quotes in your area.
88