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 WALLACE RAWSON

IN SUPPORT OF MOTION TO DISMISS

I, Wallace Rawson, of Lansing, Illinois, declare under 28 U.S.C. § 1746, that the following testimony is true and correct:

1. My full name is Wallace Rawson. I reside in Lansing, Illinois. The business I operate, RAD*TECH, INC., is located at 2858 Bernice Avenue, Lansing, Ilinois 60438. 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 Names < 4fordparts.com > and < 4fordtrucks.com >. I registered the Domain Names in approximately December, 1999. I never developed or deployed any World Wide Web sites at those addresses. The only thing ever published on the Web at these addresses has been a “free listing” page automatically established by Value Web, whenever any Domain Name is registered through them. These generic listing pages are and always have been completely passive. I have not at any time actively advertised these generic listing pages through such means as voluntarily submitting either Domain Name and/or URL to search engines or taking out banner advertisements. Nobody in the United States or Michigan has ever contacted me about either of these free generic listing pages.

4. I own a business called RAD*TECH, which sells original equipment manufacturer (OEM) and aftermarket parts for Ford automobiles and trucks. Selling automobile parts has been my family’s business for three generations.

5. In the past, I have visited the State of Michigan from time to time. The last time was to see friends who live there. These visits have been sporadic and infrequent, never even remotely qualifying as “continuous and systematic” activity. Moreover, none of these visits to Michigan had anything whatsoever to do with either the Internet Domain Name < 4fordparts.com > or < 4fordtrucks.com >.

6. The generic listing pages, which have been available on the Web since the time of registration, are completely passive. These pages do not enable visitors to buy or sell any goods or services or to engage in any commercial transactions over the Internet.

7. RAD*TECH has occasionally, and sporadically, supplied goods and services in Illinois, to fulfill orders placed by Michigan residents. These transactions have never had any Internet component, and have not involved either of the generic listing pages. RAD*TECH has no continuous and/or systematic supply relationships in the State of Michigan, and its business with Michigan residents is neither continuous nor systematic. Indeed, fulfillment of sporadic orders from Michigan residents represents no more than approximately 2% of RAD*TECH’s overall business. These orders are initiated by Michigan residents, not by me or by RAD*TECH, and Michigan residents understand they must contact RAD*TECH in Illinois in order to place such orders. I do not target any business solicitations to Michigan, nor does RAD*TECH. Once a year, RAD*TECH sends out bulk advertisements via the United States Postal Service to auto parts retailers nationwide. Michigan is not and never has been the focus of any special or particularized attention in such mailings. Some retailers from Michigan have at one time or another appeared on the distribution lists for these mass mailings, along with retailers from many other states. When RAD*TECH fulfills orders placed by customers outside the state of Illinois, it is my belief and understanding that Illinois law governs, and RAD*TECH purposefully avails itself of the benefits and protections of the law of the state of Illinois, not of any other arbitrary jurisdiction.

8. I have not transacted any business within the State of Michigan. Nor has RAD*TECH.

9. 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. Nor has RAD*TECH.

10. I have never owned, used or possessed any real or tangible personal property situated within the State of Michigan. Nor has RAD*TECH.

11. 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. Nor has RAD*TECH.

12. I have never personally sold any products or services to anyone within the State of Michigan. I have never personally entered into any contract for services to be rendered or for any materials to be furnished within the State of Michigan. RAD*TECH has never entered into any contract for services to be rendered or for any materials to be furnished within the State of Michigan.

13. 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.

14. 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.

15. 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. Nor has RAD*TECH. I have never had (and do not now have) any offices, real estate, bank accounts, or personal property in the State of Michigan. Nor has RAD*TECH. I have never had any sales representatives, sales agents, employees, or agents in Michigan. Nor has RAD*TECH.

16. I do not have, and have never had, any postal address, offices, residences, telephone listing, or telephone numbers in Michigan. Nor has RAD*TECH.

17. 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. Nor has RAD*TECH. 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. Nor has RAD*TECH.

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:__________________________ ______________________________________

WALLACE RAWSON

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