Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 1 of 28 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 HUNTON ANDREWS KURTH LLP Ann Marie Mortimer (State Bar No. 169077) amortimer@HuntonAK.com Jason J. Kim (State Bar No. 221476) kimj@HuntonAK.com Jeff R. R. Nelson (State Bar No. 301546) jnelson@HuntonAK.com 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 Telephone: (213) 532-2000 Facsimile: (213) 532-2020 Attorneys for Plaintiff FACEBOOK, INC. 11 12 UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION 14 15 16 FACEBOOK, INC., a Delaware corporation, 17 18 19 CASE NO.: 3:20-CV-04054 COMPLAINT; DEMAND FOR JURY TRIAL Plaintiff, v. 20 21 22 23 MOHAMED ZAGHAR, d/b/a Massroot8, Defendant. 24 25 26 27 28 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 2 of 28 1 Plaintiff Facebook, Inc. (“Facebook”) asserts the following: 2 Hunton Andrews Kurth LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 3 INTRODUCTION 1. Beginning no later than 2018 and continuing to the present, Defendant 4 operated an unlawful business using the website massroot8.com, which targeted 5 Facebook and its users. Defendant’s business was an online service designed to 6 improperly collect certain user data – namely, email address, mobile phone number, 7 gender, and date of birth. Defendant collected the data by using self-compromised 8 accounts and a computer program to control a network of computers or “bots,” which 9 pretended to be an Android device connected to the official Facebook mobile app. 10 Through this fraudulent mobile connection, Defendant’s service delivered automated 11 requests for user data to Facebook computers and transmitted the data to 12 massroot8.com. This data harvesting technique is known as “mobile scraping.” 13 2. Specifically, between April 23, 2020 to May 6, 2020, Defendant’s service 14 collected and used Facebook login credentials from approximately 5,500 users, in 15 order to access Facebook and scrape user data. This was not authorized by Facebook. 16 Facebook now seeks injunctive relief and damages to remedy and prevent Defendant’s 17 violations of Facebook’s Terms of Service, the Computer Fraud and Abuse Act, and 18 California Penal Code Section 502. 19 20 21 22 PARTIES 3. Plaintiff Facebook, Inc., is a Delaware corporation with its principal place of business in Menlo Park, San Mateo County, California. 4. Defendant Mohamed Zaghar is a resident of Morocco, and since 2014, 23 and at all times relevant to this Complaint, he owned and operated several websites, 24 including fast-likers.com, fast-autolikers.com, and massroot8.com. Exs. 1 – 4. 25 26 27 JURISDICTION AND VENUE 5. The Court has federal question jurisdiction over the federal cause of action alleged in this Complaint pursuant to 28 U.S.C. § 1331. 28 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 3 of 28 1 action alleged in the Complaint pursuant to 28 U.S.C. § 1367 because these claims 3 arise out of the same nucleus of operative facts as Facebook’s federal claim. 7. In addition, the Court has jurisdiction under 28 U.S.C. § 1332 over all 5 causes of action alleged in this Complaint because complete diversity exists and the 6 amount in controversy exceeds $75,000. 7 8. The Court has personal jurisdiction over Zaghar because he had multiple 8 Facebook accounts and thereby agreed to Facebook’s Terms of Service and agreed to 9 submit to the personal jurisdiction of this Court for litigating this matter. 10 Hunton Andrews Kurth LLP The Court has supplemental jurisdiction over the state law causes of 2 4 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 6. 9. In addition, the Court has personal jurisdiction over Zaghar because he 11 knowingly directed and targeted his conduct at California and at Facebook, which has 12 its principal place of business in California. Zaghar transacted business and engaged 13 in commerce in California by, among other things, using a California server to host 14 the website massroot8.com. Facebook’s claims arise directly from these California 15 contacts. 16 10. 17 18 19 Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) as the threatened and actual harm to Facebook occurred in this District. 11. Pursuant to Civil L.R. 3-2(c), this case may be assigned to either the San Francisco or Oakland division because Facebook is located in San Mateo County. 20 FACTUAL ALLEGATIONS 21 A. Background on Facebook 22 12. Facebook is a social networking website and mobile application that 23 enables its users to create their own personal profiles and connect with each other on 24 their personal computers and mobile devices. As of March 2020, Facebook daily 25 active users averaged 1.73 billion and monthly active users averaged 2.6 billion. 26 27 28 2 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 4 of 28 1 that each user create a Facebook account. To create a Facebook account, Facebook 3 requires each user to register with a unique username and password. 14. Registered users can create user profiles and include information about 5 themselves, including their email address, phone numbers, and date of birth. 6 Registered Facebook users can make connections on Facebook by becoming “Friends” 7 with other Facebook users. 8 Hunton Andrews Kurth LLP To access Facebook and view certain user profiles, Facebook requires 2 4 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 13. 15. Facebook provides its users with control over how to customize their 9 profiles and how much personal information to include in their profile. In addition, 10 Facebook’s privacy settings provide users with control over how much profile 11 information is viewable publicly, to other Facebook users, or to the users’ Friends. 12 16. Facebook uses a number of technical measures to secure its service. 13 These include measures designed to verify that users access the service through the 14 official Facebook mobile application (on Android or iPhone) and have proper access 15 to their account. For example, the official Facebook mobile application has a unique 16 application identification number and digitally signs requests sent to Facebook servers, 17 using a cryptographic key embedded in the application and a proprietary signature. 18 17. When a Facebook user logs into Facebook through the official Facebook 19 mobile app, his or her device connects with restricted computers that provide the user 20 with access to their profile and posts, as well as their Friends’ profile and posts (subject 21 to the Friends’ privacy settings). 22 B. Facebook’s Terms of Service 23 18. All Facebook users must agree to Facebook’s Terms of Service 24 (“Terms”) (available at https://www.facebook.com/terms.php) and other rules that 25 govern access to, and use of, Facebook. 26 27 28 3 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 5 of 28 19. 1 2 anything unlawful, misleading, [ ] or fraudulent” or facilitate or support others in doing 3 so. 4 Hunton Andrews Kurth LLP 20. Section 3.2.2 of Facebook’s Terms prohibits users from “do[ing] 5 anything that could . . . impair the proper working or appearance of [Facebook] 6 Products.” 7 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 Section 3.2.1 of Facebook’s Terms prohibits users from “do[ing] . . . 21. Section 3.2.3 of Facebook’s Terms prohibits “access[ing] or collect[ing] 8 data from [Facebook] Products using automated means (without our permission) or 9 attempt[ing] to access data you don’t have permission to access.” 10 C. Background on Scraping 11 22. “Web scraping” refers to the process of extracting data from a website 12 interface. This can be done manually (i.e. copy and paste by a person) or by using 13 automated means, such as specialized tools and software. Websites, including the 14 official Facebook site, are designed for human end-users and not for automated use, 15 and employ anti-scraping measures to prevent and detect web scraping. 16 23. “Mobile scraping” refers to the process of extracting data from a mobile 17 application by using a fraudulent mobile connection. A mobile application is a kind of 18 software specifically designed to run on a mobile device and connect to protected 19 computers. Mobile scrapers use specialized software to collect data pretending to be 20 an Android or iPhone device to connect to protected computers. Through this 21 fraudulent mobile connection, mobile scrapers deliver automated requests for data. 22 24. Automation tools and software are necessary for mobile scraping. 23 Facebook employs a number of measures to detect and disrupt unauthorized automated 24 requests on its systems, including monitoring use patterns that are inconsistent with a 25 human user, CAPTCHA, and disabling of accounts engaged in automated activity. 26 27 28 4 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 6 of 28 25. 1 2 mobile app, they often restructure and format it, and can save and store it for further 3 use, such as lead generation and pricing competition and optimization. 4 D. Background on Defendant Zaghar 5 26. At various times between May 2007 and February 2019, Zaghar created 6 and used approximately ten Facebook accounts and agreed to Facebook’s Terms. 7 Zaghar also created and controlled several Facebook apps and Pages. 8 Hunton Andrews Kurth LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 When web and mobile scrapers extract the desired data from a website or 27. Zaghar created and used certain Facebook accounts before receiving a 9 cease and desist letter from Facebook. Facebook disabled his known accounts on or 10 about July 11, 2018, when it sent the cease and desist letter to Zaghar. Subsequently, 11 Zaghar created at least three Facebook accounts using the aliases “Ixo Ver,” and “Zag 12 Har.” 13 28. Between August 2014 and September 2016, Zaghar controlled and 14 operated the website fast-likers.com. Exs. 1 and 4. Between February 2016 and 15 October 2018, Zaghar used the domain fast-autolikers.com to host his website. Exs. 16 2 and 4. 17 29. Between September 2014 and July 2018, Zaghar operated the fast- 18 likers.com and fast-autolikers.com websites. On those websites, which no longer 19 operate, Zaghar offered a scraping service with various functionalities, including the 20 ability to extract the mobile phone number and email address of a Facebook user. 21 Zaghar also offered fake engagement services, including the ability to artificially 22 increase the number of a users’ Facebook friends. Zaghar advertised the fast-liker.com 23 and fast-autolikers.com services on YouTube using the name “TheMrZaghar.” Ex. 5. 24 30. Beginning no later than October 27, 2018, Zaghar began operating the 25 website massroot8.com and redirecting users of the fast-autolikers.com website to the 26 massroot8.com website. Ex. 4. As explained in more detail below, Zaghar offered 27 another scraping service on massroot8.com. 28 5 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 7 of 28 1 E. Facebook’s Prior Enforcement Against Zaghar 2 31. On or about July 11, 2018, Facebook sent Zaghar a cease and desist letter 3 by FedEx and email. In the letter, Facebook demanded that Zaghar stop violating 4 Facebook’s Terms, revoked his access to Facebook, and notified Zaghar that his 5 conduct may violate the Computer Fraud and Abuse Act (18 U.S.C. § 1030), as well 6 as Section 502 of the California Penal Code. Facebook also deleted apps, pages, and 7 user accounts associated with Zaghar. Hunton Andrews Kurth LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 8 32. On July 19, 2018, Zaghar sent an email to Facebook’s attorneys stating 9 that he “closed” the fast-autolikers.com website and deleted any Facebook user data 10 he collected as a result of operating that website. He also provided a list of Facebook 11 user account IDs that allegedly used his service. 12 33. By August 5, 2018, Zaghar posted on fast-autolikers.com that the site was 13 “closed,” and that he had been contacted “by Facebook lawyers that [sic] if the site is 14 not stopped, they will sue [ ] because the site violates Facebook’s privacy policy.” 15 Zaghar also wrote that Facebook learned that his website was “helping people to know 16 their friends ’information [sic] and this is causing them harm so Facebook has disabled 17 [a]ll the accounts of the owner of the site . . . and the owner of the site was permanently 18 banned from using Facebook . . . .” Ex. 6. 19 F. Zaghar’s Scraping Service Violates Facebook’s Terms 20 34. After Facebook revoked Zaghar’s access to Facebook and sent Zaghar 21 the cease and desist letter, he violated Facebook’s Terms by creating approximately 22 three new Facebook user accounts and accessing Facebook for the purpose of scraping 23 non-publicly viewable user data. Specifically, Zaghar used mobile scraping in order 24 to obtain data from Facebook protected computers. 25 35. In or around October 27, 2018, Zaghar began using the website 26 massroot8.com to engage in new scraping activity targeting Facebook and its users. 27 Specifically, Zaghar’s fast-autolikers.com website began directing users to the website 28 6 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 8 of 28 1 massroot8.com. Ex. 7. As a result, anyone who tried to visit the fast-autolikers.com 2 website would instead visit the massroot8.com website. 3 to scrape their Facebook Friends’ contact information, such as email address, phone 5 number, gender, and date of birth. Zaghar did not charge users a fee to access and use 6 the massroot8.com website. Instead, Zaghar ran advertisements on his website to 7 generate revenue. 9 Hunton Andrews Kurth LLP On the massroot8.com website, Zaghar offered his customers the ability 4 8 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 36. 37. To use Zaghar’s scraping service, massroot8.com customers first had to create an account on massroot8.com. Zaghar’s customers registered with 10 massroot8.com with an email address, first and last name, and a password. Zaghar’s 11 customers also needed a valid Facebook username and password in order to use the 12 service. After registering with massroot8.com, Zaghar required his customers to link 13 their Facebook account to their massroot8.com account and share their Facebook login 14 credentials with the service. As a result, Zaghar’s customers self-compromised their 15 Facebook account by relinquishing control of their username and password. 16 38. After Zaghar collected the user’s access information, his scraping 17 software enabled the automated and improper collection of data from Facebook. In 18 order to evade Facebook’s technical restrictions against web scraping, Zaghar’s 19 scraping software engaged in mobile scraping by emulating Facebook’s official 20 Facebook Android app to connect a bot with Facebook restricted endpoints, and send 21 automated requests to Facebook as if a human user was logging into the Facebook app. 22 Zaghar and his customers could not use the scraping software to access any Facebook 23 user data that they were not otherwise authorized to view by their Facebook Friends. 24 39. Zaghar’s scraping software was programmed to request user data from 25 Facebook and transmit it to massroot8.com, where it was accessible to his customers 26 on a dashboard. 27 28 7 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 9 of 28 1 approximately 5,500 Facebook users’ credentials to obtain, through automated means, 3 their Facebook Friends’ email address, mobile phone number, and date of birth. In 4 large part, this data was not publicly viewable, rather, only registered Facebook users 5 who were logged into Facebook and were Facebook Friends with Zaghar’s customers 6 could view the data. 41. Facebook has taken various technical enforcement measures against 8 Zaghar and his customers, including disabling Zaghar’s user accounts on Facebook 9 and Instagram and requiring his customers to create new passwords in order to secure 10 Hunton Andrews Kurth LLP Between April 23, 2020 and May 6, 2020, Zaghar’s service used 2 7 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 40. their Facebook accounts. 11 G. Zaghar’s Acts Harmed Facebook 12 42. Zaghar’s scraping service and his violations of Facebook’s Terms have 13 caused Facebook to expend valuable resources to investigate and remediate his 14 conduct. 15 43. Facebook has suffered damages attributable to the efforts and resources 16 it has used to address Zaghar’s conduct described in this Complaint in an amount to 17 be determined at trial, and in excess of $75,000. 18 FIRST CAUSE OF ACTION 19 (Breach of Contract) 20 44. Facebook realleges and incorporates all preceding paragraphs here. 21 45. Between 2007 and 2019, Zaghar created multiple Facebook accounts and 22 agreed to Facebook’s Terms. Facebook’s Terms constitute an agreement between 23 Facebook users and Facebook. 24 46. In addition, since at least 2015, Zaghar collected and used Facebook 25 users’ login credentials. These users’ accounts were also governed by Facebook’s 26 Terms and Policies. Because Zaghar’s unlawful business used the Facebook platform, 27 28 8 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 10 of 28 1 including targeting Facebook user accounts that were governed by Facebook’s Terms, 2 Zaghar further agreed to be bound by Facebook’s Terms. 3 Hunton Andrews Kurth LLP Despite his agreement to Facebook’s Terms, Zaghar breached and 4 continues to breach Terms sections 3.2.1, 3.2.2, and 3.2.3 by (a) accessing and using 5 Facebook after Facebook revoked his access; (b) scraping data from Facebook using 6 automated means without Facebook’s permission; (c) sending code to Facebook that 7 masquerades as the Facebook mobile app, which is “unlawful, misleading, [ ] or 8 fraudulent;” and (d) facilitating others to scrape data from Facebook without 9 Facebook’s permission through the massroot8.com website. 10 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 47. 11 12 13 48. Facebook has performed all conditions, covenants, and promises required of it in accordance with its agreements with Zaghar. 49. Zaghar’s breaches have caused Facebook to incur damages in an amount to be determined at trial, and in excess of $75,000. 14 SECOND CAUSE OF ACTION 15 (Computer Fraud and Abuse Act, 18 U.S.C. § 1030) 16 50. Facebook realleges and incorporates all preceding paragraphs here. 17 51. Since at least October 2018, Zaghar accessed Facebook protected 18 computers, namely, restricted endpoints, without authorization in order to scrape data 19 from Facebook. 20 52. Facebook computers are “protected computers” as defined by 18 U.S.C. 21 § 1030(e)(2)(B) because they are “used in or affecting interstate commerce or 22 communication.” 23 53. Zaghar violated 18 U.S.C. § 1030(a)(2) because he intentionally accessed 24 and caused to be accessed a Facebook protected computer without authorization and 25 obtained information. 26 Facebook’s official Facebook Android app and misused Facebook login credentials in 27 order to fraudulently login to Facebook and scrape data, including certain users’ email 28 More specifically, Zaghar’s scraping service emulated 9 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 11 of 28 1 address, mobile phone number, and date of birth, that was not publicly viewable 2 beyond their group of Facebook Friends. 3 Hunton Andrews Kurth LLP Zaghar violated 18 U.S.C. § 1030(a)(4) because he knowingly and with 4 intent to defraud, accessed Facebook protected computers, by sending unauthorized 5 commands and requests, and by means of such conduct furthered the intended fraud 6 and obtained something of value. 7 unauthorized commands and requests to Facebook that falsely represented themselves 8 as Facebook’s official Android app for the purpose of scraping and obtaining access 9 to and data from Facebook, the value of which exceeded $5,000. 10 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 54. 11 12 55. Zaghar’s intended fraud included sending Zaghar caused a loss to Facebook in an amount in excess of $5,000 during a one-year period. 56. Zaghar’s actions caused plaintiff to incur a loss as defined by 18 U.S.C. 13 § 1030(e)(11), including the expenditure of resources to investigate and remediate 14 Zaghar’s fraud and unauthorized access. Plaintiff is entitled to compensation for 15 losses and any other amount to be proven at trial. 16 THIRD CAUSE OF ACTION 17 (California Penal Code § 502) 18 57. Facebook realleges and incorporates all preceding paragraphs here. 19 58. Zaghar knowingly accessed and without permission used Facebook’s 20 computers, computer system, or computer network in order to wrongfully obtain data 21 in violation of California Penal Code § 502(c)(1)(B). 22 59. Zaghar knowingly and without permission used or caused to be used 23 Facebook’s computer services, as defined by § 502(b)(4), in violation of California 24 Penal Code § 502(c)(3). 25 60. Zaghar knowingly and without permission accessed and caused to be 26 accessed Facebook’s computers, computer systems, or computer networks after 27 Facebook disabled his accounts in violation of California Penal Code § 502(c)(7). 28 10 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 12 of 28 61. 1 2 of Zaghar’s actions. Facebook, therefore, is entitled to compensatory damages, in an 3 amount to be proven at trial, as well as injunctive relief and attorney’s fees under 4 California Penal Code § 502(e)(1) and (2). 5 62. Hunton Andrews Kurth LLP Because Zaghar willfully violated California Penal Code § 502 and given 6 the clear and convincing evidence that Zaghar committed “fraud” as defined by 3294 7 of the California Civil Code, Plaintiff is entitled to punitive damages under California 8 Penal Code § 502(e)(4). 9 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 Facebook suffered and continues to suffer damages and a loss as a result PRAYER FOR RELIEF 10 Facebook seeks judgment awarding the following relief: 11 (a) An injunction restraining Zaghar from accessing Facebook; 12 (b) An injunction requiring Zaghar to identify the location of any and all data 13 obtained from Facebook, delete any and all data obtained from Facebook, including 14 users’ Facebook credentials, and to identify any and all entities with whom Zaghar 15 shared data obtained from Facebook; 16 17 (d) Attorney’s fees, costs, and expenses, including but not limited to those incurred in connection with the investigation and remediation of Zaghar’s misconduct; 20 (e) 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 Compensatory and punitive damages in an amount to be determined at trial; 18 19 (c) Pre-judgment and post-judgment interest; and 11 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 13 of 28 1 (f) All other equitable or legal relief the Court deems just and proper. 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 Dated: June 18, 2020 HUNTON ANDREWS KURTH LLP By: /s/ Ann Marie Mortimer Ann Marie Mortimer Jason J. Kim Jeff R. R. Nelson Attorneys for Plaintiff FACEBOOK, INC. Platform Enforcement and Litigation Facebook, Inc. Jessica Romero Michael Chmelar Stacy Chen 15 16 17 18 19 20 21 22 23 24 25 26 27 28 12 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 14 of 28 DEMAND FOR JURY TRIAL 1 2 Plaintiff hereby demands a trial by jury on all issues triable to a jury. 3 4 Dated: June 18, 2020 HUNTON ANDREWS KURTH LLP 5 6 By: 7 8 9 Hunton Andrews Kurth LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 /s/ Ann Marie Mortimer Ann Marie Mortimer Jason J. Kim Jeff R. R. Nelson Attorneys for Plaintiff FACEBOOK, INC. Platform Enforcement and Litigation Facebook, Inc. Jessica Romero Michael Chmelar Stacy Chen 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 073923.0000052 EMF_US 80628387 13 COMPLAINT; DEMAND FOR JURY TRIAL Case No. 3:20-cv-04054 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 15 of 28 EXHIBIT 1 2019-12-12 - Screenshot from domaintools.com Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 16 of 28 < Older 2016-08-21 - (3 years ago) Domain Name: FAST - LIKERS.COM Registry Domain ID : 1871438950 DOMAIN COM- VRSN Registrar WHOIS Server : whois.godaddy . com Registrar URL : http : //www . godaddy . com Update Date: 2015 - 08 - 27T08 : 44 : 05Z Creation Date: 2014 - 08 - 1 7 Tl2:44 : 30Z Registrar Registration Expiration Date : 2016 - 08 - 17Tl2:44:30Z 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: Mr Zaghar Registrant Organization : MrZaghar Registrant Street : h Registrant Street : h Registrant City: h Registrant State / Province : Marshall Islands Registrant Postal Code : 80007 Registrant Country: MA Registrant Phone : +212.6 7 05783214 Registrant Phone Ext: Registrant Fax : Registrant Fax Ext : Registrant Email : t hemrzaghar@outlook.com Registry Admin ID: Not Available From Registry Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 17 of 28 EXHIBIT 2 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 18 of 28 2019-12-12 - Screenshot from fast-likers.com as of 2016-07-30 via archive.org IN T t!ltN t r A t (MIVt ms~uge~m,mm~ ,_ lh_ n ,_p:-"//'-fa_s_t-_li_ ke_r_ s._co_m __,/_h_ om_ e__________________________ __,II Go I JUN ◄ 40 ca11tures version 4 of fost-llkers so fost without problems with outofollowL!.. u.,J.! ., h....,- :,fo.~ .:,...,Ii~_..;,,. ._.,,t,1I ~ • fast-autolil 0 -- .:, SIGNIN I G ABOUT __ : .:tfi comment, and subscribe. 8 CHANNELS f ix • . 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I SIGNIN I Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 25 of 28 EXHIBIT 6 Case 3:20-cv-04054 Document 1 Filed 06/18/20 Page 26 of 28 2020-05-01 - Screenshot from fast-autolikers.com as of 2018-08-05 via archive.org • • f- 0 ➔ C ••• J::=::=I : : : Apps INTt• LJ ~ Locked X + ~ 11 web.archive.org/web/20180805101255/http://fast-autolikers.com/ Facebook A•Cllt\lC g~ aehmoomno ...at Altair I Home Lexis Advance®-... L, My Drive - Google ... 11 Ad Library tm Ads Portal g TTP Dashboard 11 ~1 1Go I JUL ~l h_tt_p_:/_/_fa_s_t-_a_u_to _ l_ik_e_r_ s ._co _m _ / ________________________________ Ad Library Report ... SEP ► 2019 106 captures 12 Jan 2016 - 5 Sep 2019 :···,:, ·.... Perks * Q lj 0 Talas Blog II 11 Cisco ... ~ !;I ID ml 0 Schwab • (JD • Ci) (i) .. )) 0 11 ,.. About this caRture t at website c ose . This site has been closed. We have been contacted by Facebook lawyers that if the site is not stopped, they will sue us because the site violates Facebook's privacy policy. 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