Facebook, Inc. v. Min Ge et al Document 2: Civil Case Cover Sheet

Superior Court of California, County of Santa Clara
Case No. 19CV348954
Filed May 30, 2019

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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 TRIAL
Page 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 TRIAL
Page 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 TRIAL
Page 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 TRIAL
Page 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 TRIAL
Page 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.

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COMPLAINT; DEMAND FOR JURY TRIAL
Page 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 TRIAL
Page 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 TRIAL
Page 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 TRIAL
Page 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.”

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///
COMPLAINT; DEMAND FOR JURY TRIAL
Page 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 TRIAL
Page 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 TRIAL
Page 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 TRIAL
Page 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 TRIAL
Page 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 TRIAL
Page 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.

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COMPLAINT; DEMAND FOR JURY TRIAL
Page 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 TRIAL
Page 18 EXHIBIT
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Page 19 05/21/2019 - tolocal.com homepage
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customers to your business and into your sales funnel.
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Learn more

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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
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Page 23 EXHIBIT
22
Page 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

24
Page 26 EXHIBIT
25
Page 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 STATE
Page 28 EXHIBIT
27
Page 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
" l
Page 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
29
Page 31 EXHIBIT
30
Page 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
31
Page 33 EXHIBIT
32
Page 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 «<
33
Page 35 EXHIBIT
34
Page 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
35
Page 37 EXHIBIT
36
Page 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 STATE
Page 39 EXHIBIT
38
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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
73
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Lease a system for as little as $0 down.
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78
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NATIONAL SOLAR
Norton
REBATE
111.1.1.
Get Your FREE Solar Quote...

Are you a homeowner?
Yes, I own my home.
No, I rent my home.
Save Money with Solar!
Continue
How Our Free Service Works:
Reduce or eliminate your energy costs. You could
• Fill out the quick form to apply for the program.
save thousands every year!
• Compare quotes from our network of
professional solar installers.
Purchase for up to 30-50% off with government
rebates & incentives.
• Receive a custom savings estimates with no
obligations or commitments.
Lease a system for as little as $0 down.
Protect against big utility's rising energy prices.
• Learn about government rebates available to
help cover the cost of installation.
Help improve the value of your home.
• Learn about $0 down financing options, with no
out of pocket expense.
© 2009-2017 The National Solar Rebate
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NATIONAL SOLAR
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SLY;
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SECURED, /
Do..4 WWI'S*,
Get Your FREE Solar Quote...
What is your zip code?
Ed
'
Continue
Go Back
Save Money with Solar!
How Our Free Service Works:
Reduce or eliminate your energy costs. You could
• Fill out the quick form to apply for the program.
save thousands every year!
• Compare quotes from our network of
professional solar installers.
Purchase for up to 30-50% off with government
rebates & incentives.
• Receive a custom savings estimates with no
obligations or commitments.
Lease a system for as little as $0 down.
Protect against big utility's rising energy prices.
• Learn about government rebates available to
help cover the cost of installation.
Help improve the value of your home.
• Learn about $0 down financing options, with no
out of pocket expense.
© 2009-2017 The National Solar Rebate
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save thousands every year!
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Lease a system for as little as $0 down.
• Receive a custom savings estimates with no
obligations or commitments.
Protect against big utility's rising energy prices.
• Learn about government rebates available to
help cover the cost of installation.
Help improve the value of your home.
• Learn about $0 down financing options, with no
out of pocket expense.
© 2009-2017 The National Solar Rebate
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0111continue
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save thousands every year!
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Purchase for up to 30-50% off with government
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Lease a system for as little as $0 down.
• Receive a custom savings estimates with no
obligations or commitments.
Protect against big utility's rising energy prices.
• Learn about government rebates available to
help cover the cost of installation.
Help improve the value of your home.
• Learn about $0 down financing options, with no
out of pocket expense.
© 2009-2017 The National Solar Rebate
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NATIONAL SOLAR
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Notton
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130.4.4re by WOW%
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NM.
I
Who is your current utility provider?
Other
Continue
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Save Money with Solar!
How Our Free Service Works:
Reduce or eliminate your energy costs. You could
• Fill out the quick form to apply for the program.
save thousands every year!
• Compare quotes from our network of
professional solar installers.
Purchase for up to 30-50% off with government
rebates & incentives.
Lease a system for as little as $0 down.
• Receive a custom savings estimates with no
obligations or commitments.
Protect against big utility's rising energy prices.
• Learn about government rebates available to
help cover the cost of installation.
Help improve the value of your home.
• Learn about $0 down financing options, with no
out of pocket expense.
© 2009-2017 The National Solar Rebate
85
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/
NATIONAL SOLAR
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Noi ton
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trl Ved$ 110,
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86
Page 88 EXHIBIT
87
Page 89 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 -

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
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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.
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