Proof of Service: YUE VS MIAO

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                                * Chun-Hui Miao 0 De =

1014 Greene St.

Columbia, SC 29208
Telephone: (803) 777-2583
E-Mail: miao@moore.sc.edu

Mh 21 2018

BASH CLERK OFTHE COURT
iil OF THe STATE QF CALIFORNIA

Pro Se
SUPERIOR COURT OF THE STATE OF CALIFORNIA. es
FOR THE COUNTY OF CONTRA COSTA 4
DONGXIAO YUE, Case No.: C17-02449
Plaintiff,
vs. DECLARATION OF CHUN-HUI MIAO IN

SUPPORT OF MOTION TO QUASH
1 Wa) SERVICE OF THE SUMMONS AND
CHUN-HUI MIAO, BIAN-WANG.COM COMPLAINT

Defendants
TRIAL DATE: NOT SET

| Department: 12
Judge: The Honorable Charles S. Treat

I, Chun-Hui Miao (“Miao”), declare as follows:

1: Iam the defendant of this lawsuit. I have personal knowledge of the matters stated hetein, and
if called upon to do so, I could and would competently so testify as to: those matters.

2. I submit this declaration in support of my Motion for Quash Service of the Summons and
Complaint.

3. 1am an individual who has been a resident of the state of South Carolina since 2005.
Furthermore, I have not:

. Lived in the State of California;

. Owned or leased real or personal property in the State of California;. Lam the sole owner of Bian-wang.com, a not-for-profit personal website that hosts an online

. In January 2013, I registered the domain “Bian-wang.com” with Hostlatte.com via the

. Bian-wang does not advertise, does not sell any products, nor does it charge a membership

. Users of Bian-wang interact via blogs and comments. I have not met in person any named

. Bian-wang does not require'users to offer identification credentials such as their legal names

eo e

. Owed or been required to pay taxes in the State of California;

. Maintained an office in the State of California;

. Maintained a registered agent for service in the State of California; or

. Conducted print, radio, television, Intemet, or any other advertising that wag

directed to California residents.

Chinese language discussion forum for a wide range of topics. While other anonymous
netizens have contributed useful ideas, I am the only one legally responsible for the website.

A judgment against Bian-Wang.com will be a judgment against Defendant Miao himself.

Internet. In February 2014, I transferred the domain to Namecheap.com and signed up for

their hosting service via the Internet. Both activities were undertaken in my local residence in|

the state of South Carolina.

fee. I do not receive any income from my ownership of Bian-wang.

parties or third parties, nor have I ever talked to anyone by telephone. All the interactions

took place on the Internet.

or residential addresses to sign up for an account. There are no Terms and Conditions for the

use of Bian-wang.com. When users register, they do not have to consent to anything.9, Bian-wang does not restrict readership or participation based on geographical locations.
Anyone with Internet access, regardless of residence or citizenship, can access and

participate in the site.

I declare under penalty of perjury under the laws of the State of California that the foregoing i:

true and correct and that this Declaration was executed on May 17, 2018 in Columbia, South

A=

Chun-Hui Miao

Carolina.