Plaintiff alleged that defendants WebLoyalty.com Inc. and Fandango, Inc. d/b/a fandango.com engaged in a "Coupon Click Fraud" scheme involving the fraudulent and deceptive sale of "Reservation Rewards" discount products to unwitting consumers who make legitimate online purchases from various web retailers, and the unauthorized of private credit and debit card account information by the web retailer to Webloyalty.
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| Date Filed | # | Document Text |
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| September 11, 2006 | 1 | Class Action COMPLAINT against Webloyalty.com, Inc., Fandango, Inc. Filing Fee: $350.00, receipt number 74943, filed by Joe W. Kuefler. (Attachments: # 1 Civil Cover Sheet)(Abaid, Kim) Modified on 3/27/2007 (Abaid, Kim). |
| October 4, 2006 | 2 | MOTION for Extension of Time to November 13, 2006 to Respond to the Complaint by Webloyalty.com, Inc., Fandango, Inc..(Abaid, Kim) |
| October 2, 2006 | 3 | MOTION for Leave to Appear Pro Hac Vice for admission of Stuart A. Davidson Filing fee $50.00 receipt number 75426 by Joe W. Kuefler. (Attachments: # 1 Affidavit of Stuart A. Davidson)(Abaid, Kim) Modified on 3/27/2007 (Abaid, Kim). |
| October 2, 2006 | 4 | MOTION for Leave to Appear Pro Hac Vice for admission of David J. George Filing fee $50.00, receipt number 75426 by Joe W. Kuefler. (Attachments: # 1 Affidavit of David J. George)(Abaid, Kim) |
| October 2, 2006 | 5 | MOTION for Leave to Appear Pro Hac Vice for admission of Eric A. Lee Filing fee $50.00, receipt number 75426 by Joe W. Kuefler. (Attachments: # 1 Affidavit of Eric A. Lee)(Abaid, Kim) |
| October 6, 2006 | 6 | SUMMONS Returned Executed Fandango, Inc. served on 9/18/2006, answer due 10/10/2006. (Abaid, Kim) Modified on 3/27/2007 (Abaid, Kim). |
| October 6, 2006 | 7 | SUMMONS Returned Executed Webloyalty.com, Inc. served on 9/20/2006, answer due 10/10/2006. (Abaid, Kim) |
| October 30, 2006 | 8 | NOTICE of Change of Address by Andrew J. Garcia on behalf of Lerach Coughlin Stoia Geller Rudman & Robbins LLP (Abaid, Kim) |
| October 31, 2006 | 9 | MOTION for Leave to Appear Pro Hac Vice for admission of C. Nichole Gifford by Webloyalty.com, Inc., Fandango, Inc..(Abaid, Kim) |
| October 31, 2006 | 10 | MOTION for Leave to Appear Pro Hac Vice for admission of Steven Lieberman by Webloyalty.com, Inc., Fandango, Inc..(Abaid, Kim) |
| October 31, 2006 | 11 | MOTION for Leave to Appear Pro Hac Vice for admission of Anne M. Sterba by Webloyalty.com, Inc., Fandango, Inc..(Abaid, Kim) |
| November 7, 2006 | 12 | NOTICE of Filing with the MDL Panel by Joe W. Kuefler (Attachments: # 1 Memorandum of Law in Support of Motion to Transfer# 2 Schedule of Actions in Support of Motion to Transfer# 3 Exhibit A# 4 Exhibit B# 5 Exhibit C# 6 Exhibit D# 7 Certificate of Service# 8 Revised - Schedule of Actions in Support of Motion to Transfer)(Abaid, Kim) |
| November 13, 2006 | 13 | ANSWER to Complaint by Webloyalty.com, Inc., Fandango, Inc..(Abaid, Kim) |
| November 13, 2006 | 14 | CORPORATE DISCLOSURE STATEMENT by Fandango, Inc.. (Abaid, Kim) |
| November 13, 2006 | 15 | CORPORATE DISCLOSURE STATEMENT by Webloyalty.com, Inc.. (Abaid, Kim) |
| November 13, 2006 | 16 | MOTION for Summary Judgment by Webloyalty.com, Inc., Fandango, Inc..(Abaid, Kim) |
| November 13, 2006 | 17 | MEMORANDUM in Support re 16 MOTION for Summary Judgment filed by Webloyalty.com, Inc., Fandango, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E)(Abaid, Kim) |
| November 13, 2006 | 18 | Statement of Facts re 16 MOTION for Summary Judgment filed by Webloyalty.com, Inc., Fandango, Inc.. (Abaid, Kim) |
| November 13, 2006 | 19 | DECLARATION of Tamra Lichtman re 16 MOTION for Summary Judgment by Webloyalty.com, Inc., Fandango, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8)(Abaid, Kim) |
| November 13, 2006 | 20 | DECLARATION of Shane O'Neill re 16 MOTION for Summary Judgment by Webloyalty.com, Inc., Fandango, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Abaid, Kim) |
| November 20, 2006 | 21 | MOTION for Extension of Time to File Response/Reply Unopposed to Response to Defendant's Motion for Summary Judgment by Joe W. Kuefler.(Abaid, Kim) |
| November 20, 2006 | 22 | Proposed Document(s) submitted by Joe W. Kuefler. Document received: Order re: Motion for Extension of Time to File Response to Defendants' Motion for Sumamry Judgment. (Abaid, Kim) |
| November 17, 2006 | 23 | NOTICE to The MDL PANEL - Revised Schedule of Actions in Support of Motion to Transfer and Coordinate or Consolidate Actions by Joe W. Kuefler (Abaid, Kim) |
| December 1, 2006 | 24 | MOTION for Discovery Rule 56(f) & Memorandum of Law by Joe W. Kuefler. (Attachments: # 1 Exhibit Discovery List# 2 Exhibit George Declaration# 3 Exhibit Defendants' Line-Item Response)(Abaid, Kim) |
| December 13, 2006 | 25 | MOTION for Extension of Time to December 22, 2006 to File Response/Reply by Webloyalty.com, Inc., Fandango, Inc..(Abaid, Kim) |
| December 22, 2006 | 26 | Opposition re 24 MOTION for Discovery Rule 56(f) & Memorandum of Law filed by Webloyalty.com, Inc., Fandango, Inc.. (Abaid, Kim) |
| December 26, 2006 | 27 | NOTICE - Reply filed with the MDL Panel - by Joe W. Kuefler (Abaid, Kim) |
| December 27, 2006 | 28 | NOTICE issued to Attorney Michael L. Greenwald regarding mandatory use of ECF in compliance with Local Rule 5.4. Failure to comply may result in the imposition of sanctions. (Abaid, Kim) |
| January 8, 2007 | 29 | Reply MEMORANDUM in Support re 24 MOTION for Rule 56(f) Discovery filed by Joe W. Kuefler. (Attachments: # 1 Exhibit CT BBB Report)(Abaid, Kim) |
| February 20, 2007 | 30 | MOTION for Sanctions by Webloyalty.com, Inc., Fandango, Inc..(Abaid, Kim) |
| February 20, 2007 | 31 | MEMORANDUM in Support re 30 MOTION for Sanctions filed by Webloyalty.com, Inc., Fandango, Inc.. (Abaid, Kim) |
| February 20, 2007 | 32 | DECLARATION re 30 MOTION for Sanctions, 31 Memorandum in Support of Motion by Webloyalty.com, Inc., Fandango, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7)(Abaid, Kim) |
| February 21, 2007 | 33 | NOTICE by Joe W. Kuefler Filing Transfer Order of Judicial Panel on Multidistrict Litigation and Request for Status Conference (Attachments: # 1 Exhibit A - MDL Transfer Order)(Abaid, Kim) |
| February 23, 2007 | 34 | Response by Webloyalty.com, Inc., Fandango, Inc. to 33 Notice (Other) of Filing Transfer Order of Judicial Panel on Multidistrict Litigation and Request for Status Conference. (Abaid, Kim) |
| March 5, 2007 | 35 | Opposition re 30 MOTION for Sanctions filed by Joe W. Kuefler. (Abaid, Kim) |
| March 5, 2007 | 36 | DECLARATION re 35 Opposition to Motion for Sanctions by Joe W. Kuefler. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Abaid, Kim) |
| March 15, 2007 | 37 | MOTION for Leave to File Reply to Plaintiff's Opposition to Defendants' Motion for Sanctions by Webloyalty.com, Inc., Fandango, Inc.. (Attachments: # 1 Exhibit 1)(Abaid, Kim) |
| March 21, 2007 | 38 | Judge Joseph L. Tauro : ORDER entered. ORDER consolidating cases(Abaid, Kim) |
| February 16, 2007 | 39 | Certified copy of MDL Transfer Order in MDL Case 07-1820 received from the Judicial Panel on Multidistrict Litigation requesting transfer of cases in Webloyalty.com, Inc., Marketing and Sales Practices Litigation for consolidated pretrial proceedings. MDL cases assigned to Judge Tauro. (Abaid, Kim) |
| April 10, 2007 | 40 | Judge Joseph L. Tauro : ORDER entered. Status Conference set for 4/24/2007 02:15 PM in Courtroom 20 before Judge Joseph L. Tauro.(Abaid, Kim) |
| April 17, 2007 | 41 | Proposed Document(s) submitted by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo. Document received: Plaintiffs' Proposed Agenda for April 24, 2007 Status Conference. (George, David) |
| April 17, 2007 | 42 | Proposed Document(s) submitted by Webloyalty.com, Inc., Fandango, Inc., Priceline.com, Inc., Nelson Garrett, Maxim O. Khokhlov, Valueclick Inc., E-Babylon Inc.. Document received: Defendants' Proposed Agenda Submitted in Response to the Court's Order Dated April 10, 2007. (Mitrou, Joan) |
| April 24, 2007 | 43 | REPLY to Response to Motion re 30 MOTION for Sanctions Leave to File Granted on April 24, 2007 filed by Webloyalty.com, Inc., Fandango, Inc.. (Mitrou, Joan) |
| April 24, 2007 | 44 | Judge Joseph L. Tauro : ORDER entered 30 Motion for Sanctions is DENIED. By May 25, 2007, Plaintiffs shall file a Motion for Leave to File a Consolidated Class Action Complaint. Defendants shall respond by June 15, 2007. (Abaid, Kim) |
| May 7, 2007 | 46 | MOTION for Leave to Appear Pro Hac Vice for admission of Kenneth A. Wexler by Joe W. Kuefler. (Attachments: # 1 Certification)(Abaid, Kimberly) |
| May 7, 2007 | 47 | MOTION for Leave to Appear Pro Hac Vice for admission of Mark J. Tamblyn by Joe W. Kuefler. (Attachments: # 1 Certification)(Abaid, Kimberly) |
| May 24, 2007 | 48 | MOTION for Leave to File Consolidated Amended Complaint by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo. (Attachments: # 1 Text of Proposed Order)(George, David) |
| May 24, 2007 | 49 | EXHIBIT re 48 MOTION for Leave to File Consolidated Amended Complaint by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo. (George, David) |
| May 29, 2007 | 50 | MEMORANDUM in Support re 48 MOTION for Leave to File Consolidated Amended Complaint filed by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo. (George, David) |
| June 15, 2007 | 51 | RESPONSE to Motion re 48 MOTION for Leave to File Consolidated Amended Complaint filed by Webloyalty.com, Inc., Fandango, Inc., Priceline.com, Inc., Nelson Garrett, Maxim O. Khokhlov, Valueclick Inc., E-Babylon Inc., Webloyalty.com, Inc., Marketing and Sales Practices Litigation. (Wolohojian, Gabrielle) |
| June 18, 2007 | 52 | Judge Joseph L. Tauro : ORDER entered. 48 Motion for Leave to File Consolidated Amended Complaint is ALLOWED WITHOUT OPPOSITION. Plaintiffs shall file their consolidated amended complaint no later than June 22, 2007. It is hereby ordered that Gael Mahony of the firm, Holland and Knight, LLP of Boston is appointed Special Master for the above captioned action. (Abaid, Kimberly) |
| June 22, 2007 | 53 | AMENDED COMPLAINT against all defendants Consolidated Amended Complaint, filed by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo.(George, David) |
| July 16, 2007 | 54 | NOTICE by Gael Mahony Scheduling Notice for 8/21/07 (Mahony, Gael) |
| July 20, 2007 | 55 | ANSWER to Amended Complaint by Webloyalty.com, Inc., Fandango, Inc., Priceline.com, Inc., Nelson Garrett, Maxim O. Khokhlov, Valueclick Inc., E-Babylon Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8# 9 Exhibit 9# 10 Exhibit 10# 11 Exhibit 11# 12 Exhibit 12# 13 Exhibit 13# 14 Exhibit 14# 15 Exhibit 15)(Mitrou, Joan) |
| July 20, 2007 | 56 | MOTION for Summary Judgment by Webloyalty.com, Inc., Fandango, Inc., Priceline.com, Inc., Nelson Garrett, Maxim O. Khokhlov, Valueclick Inc., E-Babylon Inc..(Mitrou, Joan) |
| July 20, 2007 | 57 | MEMORANDUM in Support re 56 MOTION for Summary Judgment filed by Webloyalty.com, Inc., Fandango, Inc., Priceline.com, Inc., Nelson Garrett, Maxim O. Khokhlov, Valueclick Inc., E-Babylon Inc.. (Attachments: # 1 Exhibit A)(Mitrou, Joan) |
| July 20, 2007 | 58 | Statement of Material Facts L.R. 56.1 re 56 MOTION for Summary Judgment filed by Webloyalty.com, Inc., Fandango, Inc., Priceline.com, Inc., Nelson Garrett, Maxim O. Khokhlov, Valueclick Inc., E-Babylon Inc.. (Mitrou, Joan) |
| July 20, 2007 | 59 | DECLARATION re 56 MOTION for Summary Judgment of Tamra Lichtman by Webloyalty.com, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8# 9 Exhibit 9# 10 Exhibit 10# 11 Exhibit 11# 12 Exhibit 12# 13 Exhibit 13# 14 Exhibit 14# 15 Exhibit 15# 16 Exhibit 16# 17 Exhibit 17# 18 Exhibit 18# 19 Exhibit 19# 20 Exhibit 20# 21 Exhibit 21# 22 Exhibit 22# 23 Exhibit 23# 24 Exhibit 24# 25 Exhibit 25# 26 Exhibit 26# 27 Exhibit 27# 28 Exhibit 28# 29 Exhibit 29# 30 Exhibit 30# 31 Exhibit 31# 32 Exhibit 32# 33 Exhibit 33# 34 Exhibit 34# 35 Exhibit 35# 36 Exhibit 36# 37 Exhibit 37# 38 Exhibit 38# 39 Exhibit 39# 40 Exhibit 40# 41 Exhibit 41# 42 Exhibit 42# 43 Exhibit 43# 44 Exhibit 44# 45 Exhibit 45# 46 Exhibit 46# 47 Exhibit 47# 48 Exhibit 48# 49 Exhibit 49)(Mitrou, Joan) |
| July 20, 2007 | 60 | DECLARATION re 56 MOTION for Summary Judgment of Shane O'Neill by Fandango, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Mitrou, Joan) |
| July 20, 2007 | 61 | DECLARATION re 56 MOTION for Summary Judgment of Michael Masone by Priceline.com, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Mitrou, Joan) |
| July 20, 2007 | 62 | DECLARATION re 56 MOTION for Summary Judgment of Nelson Shane Garrett by Nelson Garrett, Maxim O. Khokhlov. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Mitrou, Joan) |
| July 20, 2007 | 63 | DECLARATION re 56 MOTION for Summary Judgment of Veronica Miller by Valueclick Inc., E-Babylon Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3)(Mitrou, Joan) |
| August 1, 2007 | 64 | MOTION for Discovery PLAINTIFFS' MOTION FOR RULE 56(F) DISCOVERY AND INCORPORATED MEMORANDUM OF LAW by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo. (Attachments: # 1 Exhibit A# 2 Exhibit B - Part I# 3 Exhibit B - Part II# 4 Exhibit B - Part III# 5 Exhibit B - Part IV# 6 Exhibit B - Part V# 7 Exhibit B - Part VI# 8 Exhibit B - Part VII# 9 Exhibit B - Part VIII# 10 Exhibit B - Part IX# 11 Exhibit B - Part X# 12 Exhibit B - Part XI# 13 Exhibit B - Part XII# 14 Exhibit C - Part I# 15 Exhibit C - Part II# 16 Exhibit C - Part III# 17 Exhibit C - Part IV# 18 Exhibit C - Part V# 19 Exhibit C - Part VI# 20 Exhibit C - Part VII# 21 Exhibit C - Part VIII# 22 Exhibit C - Part IX# 23 Exhibit C - Part X# 24 Exhibit D)(George, David) |
| August 1, 2007 | 65 | DECLARATION re 64 MOTION for Discovery DECLARATION OF DAVID J. GEORGE MADE IN SUPPORT OF PLAINTIFFS' MOTION FOR RULE 56(F) DISCOVERY by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo. (George, David) Modified on 8/9/2007 (Abaid, Kimberly). |
| August 8, 2007 | 66 | Opposition re 64 MOTION for Discovery PLAINTIFFS' MOTION FOR RULE 56(F) DISCOVERY filed by Webloyalty.com, Inc., Fandango, Inc., Priceline.com, Inc., Nelson Garrett, Maxim O. Khokhlov, Valueclick Inc., E-Babylon Inc.. (Attachments: # 1 Exhibit A)(Mitrou, Joan) Modified on 8/9/2007 (Abaid, Kimberly). |
| August 21, 2007 | 67 | NOTICE by Gael Mahony of Scheduling Order for Rule 16 Conference (Mahony, Gael) |
| September 10, 2007 | 68 | MOTION for Leave to Appear Pro Hac Vice for admission of Charles D. Marshall by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo. (Attachments: # 1 Affidavit of Charles D. Marshall)(Abaid, Kimberly) |
| September 10, 2007 | 69 | MOTION for Leave to Appear Pro Hac Vice for admission of Robert S. Green by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo. (Attachments: # 1 Affidavit of Robert S. Green)(Abaid, Kimberly) |
| September 13, 2007 | 70 | TRANSCRIPT of Scheduling Conference held on August 21, 2007 before Special Master Gael Mahony. Court Reporter: Carol Lynn Scott. The original transcripts are maintained by the Clerk's Office. Copies may be obtained by contacting the court reporter at 617/330-1377 or the Clerk's Office. (Scalfani, Deborah) |
| September 20, 2007 | 71 | JOINT STATEMENT re scheduling conference Pursuant to Rules 16 and 26(f) of the Federal Rules of Civil Procedure. (Attachments: # 1 Plaintiff's Proposed Scheduling Order# 2 Defendants' Proposed Scheduling Order)(George, David) |
| September 20, 2007 | 72 | CERTIFICATE OF CONSULTATION Pursuant to Local Rule 16.1(D)(3). (George, David) |
| October 11, 2007 | 73 | NOTICE of Change of Address or Firm Name by David J. George (George, David) |
| October 11, 2007 | 74 | Letter/request (non-motion) from Gabrielle Wolohojian to Special Master Mahony. (Wolohojian, Gabrielle) |
| October 12, 2007 | 75 | NOTICE of Change of Address or Firm Name by Mark J. Tamblyn (Tamblyn, Mark) |
| October 30, 2007 | 76 | NOTICE by Gael Mahony SCHEDULING ORDER (Mahony, Gael) |
| November 1, 2007 | 77 | Joint MOTION to Establish Date for Answer to Second Amended Consolidated Complaint by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo. (Attachments: # 1 Exhibit A)(George, David) |
| November 7, 2007 | 78 | Letter/request (non-motion) from Gabrielle R. Wolohojian. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Mitrou, Joan) |
| November 9, 2007 | 79 | Order of Special Master on a Motion. Motions terminated:. (Mahony, Gael) |
| November 9, 2007 | 80 | Second AMENDED COMPLAINT against all defendants (Consolidated), filed by Joe W. Kuefler, Kim Crouse, Monica S. Staaf, Alcides Melo.(George, David) |
