UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

FORD MOTOR COMPANY, et al.,

Plaintiffs

v. Case No. 00-71544

Hon. Gerald E. Rosen

GREAT DOMAINS.COM, INC., et al., United States District Judge

Defendants

____________________________________/

DECLARATION OF ALFONSO FIERO

IN SUPPORT OF MOTION TO DISMISS

I, Alfonso Fiero, of Bell Harbor, New York, declare under 28 U.S.C. § 1746, that the following testimony is true and correct:

1. My name is Alfonso Fiero. I reside at 173 Beach 139 St., Bell Harbor, New York, 11694. I am over 18 years of age and competent to make this affidavit.

2. I have first-hand and personal knowledge of the matters stated in this Declaration, except where statements are specifically identified as based upon information and belief, and as to those statements, I am so informed after reasonable investigation and believe them to be true. If called upon to testify to the statements in this Declaration, I could and would competently do so under oath.

3. I own the Internet Domain Name < lincolntrucks.com >. I registered the Domain Name on January 3, 2000. I have not developed or deployed a World Wide Web site at that address. Since no Website ever existed at the < lincolntrucks.com > address, no Michigan resident could even have seen such a Website, much less interacted with it.

4. I have never visited the state of Michigan. I have never been physically present anywhere in or near the state of Michigan.

5. I have not transacted any business within the State of Michigan.

6. I have never done any tortuous act within the State of Michigan, or caused any tortuous act to be done, or consequences to occur within the State of Michigan.

7. I have never owned, used or possessed any real or tangible personal property situated within the State of Michigan.

8. I have never contracted to insure any person, property, or risk located within the State of Michigan at the time of contracting or at any other time.

9. I have never sold any products or services to anyone within the State of Michigan. I have never entered into any contract for services to be rendered or for any materials to be furnished within the State of Michigan, by me or by anyone else. I have never derived any revenue from any goods used or services rendered within the State of Michigan.

10. I have never acted as a director, manager, trustee, or other officer of any corporation incorporated under the laws of, or having its principal place of business within, the State of Michigan.

11. I have never maintained a domicile in the State of Michigan – while subject to a marital or family relationship which is the basis of any claim for divorce, alimony, separate maintenance, property settlement, child support, or child custody -- or otherwise.

12. I have never been registered with the State government of Michigan to transact business in Michigan, to employ Michigan residents, or to collect or pay Michigan taxes. I have never had (and do not now have) any offices, real estate, bank accounts, or personal property in the State of Michigan. I have never had any sales representatives, sales agents, employees, or agents in Michigan.

13. I do not have, and have never had, any postal address, offices, residences, telephone listing, or telephone numbers in Michigan.

14. I have never engaged in any continuous and/or systematic pattern of activity, commercial or otherwise, involving or directed toward the State of Michigan at any time. I have never engaged in any other persistent course of activity directed at Michigan and I have never purposefully availed myself of the State of Michigan, or of the benefits and protections of its laws, at any time whatsoever.

I declare under penalty of perjury under the laws of the United States of America, including 28

U.S.C. § 1746, that the foregoing is true and correct.

Date:__________________________ ______________________________________

ALFONSO FIERO

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