Case 2:16-cv-05871-RSWL-AS Document 18-2 Filed 08/29/16 Page 1 of 6 Page ID #:279

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RYAN M. NISHIMOTO (State Bar No. 235208)

ryan.nishimoto@aporter.com
AMANDA SEMAAN (State Bar No. 293896)
amanda.semaan@aporter.com
ARNOLD & PORTER LLP
777 South Figueroa Street, Forty-Fourth Floor
Los Angeles, California 90017-5844
Telephone: 213.243.4000
Facsimile: 213.243.4199
Attorneys for Defendants
STEFAN DELGARDO ARGOTE, MATTHIAS
OLTMANN, TYRONE TOM PAUER, and
CHACHANI MISTI Y PICHU PICHU S.R.L.

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UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION

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RIOT GAMES, INC., a Delaware

corporation,

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Plaintiff,
v.
STEFAN DELGADO ARGOTE a/k/a ,
Ohm and Burberry; MATTHIAS
OLTMANN a/k/a Joduskame,
Rolle3k, and Sheppard; TYRONE
TOM PAUER a/k/a Beaving;
CHACHANI MISTI Y PICHU PICHU
S.R.L., a company organized under the
laws of Peru; and DOES 1-10,
inclusive,
Defendants.

Case No. 2:16-CV-5871-RSWL-AS

The Honorable Alka Sagar
DECLARATION OF JAIME
ROSALINO PRADO LIRA IN
SUPPORT OF DEFENDANTS
OPPOSITION TO PLAINTIFFS EX
PARTE APPLICATION FOR LEAVE
TO TAKE LIMITED IMMEDIATE
DISCOVERY

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DECLARATION OF JAIME ROSALINO PRADO LIRA IN SUPPORT OF DEFENDANTS OPPOSITION TO
PLAINTIFFS EX PARTE APPLICATION FOR LEAVE TO TAKE LIMITED IMMEDIATE DISCOVERY
36626655

Case 2:16-cv-05871-RSWL-AS Document 18-2 Filed 08/29/16 Page 2 of 6 Page ID #:280

DECLARATION OF JAIME ROSALINO PRADO LIRA

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I, Jaime Rosalino Prado Lira, declare as follows:

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I submit this declaration in support of Defendants Opposition to

Plaintiffs Ex Parte Application for Leave to Take Limited Immediate Discovery. I

have personal and firsthand knowledge of the facts set forth herein and, if called as a

witness, I could and would testify to the following.

2.

I am the director of Chachani Misti y Pichu Pichu S.R.L. (Chachani), a

company incorporated under the laws of the Republic of Peru with company number

11298751 and that has its registered office at Avenida Siglo XX nr 110-C, third floor,

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office 302, Arequipa, 040101, Peru.

3.

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acronym for Chachani Misti y Pichu Pichu S.R.L.

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Chachani also does business under the name CHAMISPI, which is an

Chachani owns and controls all rights to software known as

LeagueSharp or L#.
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Chachani is aware of and complying with its obligation to preserve

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documents and electronically stored information pursuant to the United States Federal

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Rules of Civil Procedure.

6.

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Chachani controls the website located at the domain www.joduska.me,

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including forums available at that domain. Posts to forums that violate Chachanis

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policies are hidden from public view by moderators, but are not deleted or otherwise

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destroyed. A copy of the websites Global Forum Rules is attached as Exhibit A to

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this declaration.

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-1DECLARATION OF JAIME ROSALINO PRADO LIRA IN SUPPORT OF DEFENDANTS OPPOSITION TO
PLAINTIFFS EX PARTE APPLICATION FOR LEAVE TO TAKE LIMITED IMMEDIATE DISCOVERY
36626655

Case 2:16-cv-05871-RSWL-AS Document 18-2 Filed 08/29/16 Page 3 of 6 Page ID #:281

it
I declare under penalty of peijuty under the laws of the Stale of Ca ilorpia that
the tbregoing is true and correct.
Executed this 28th dav of Atwist, 2016 in Arequipa. Peril

ii\ 1.I/
' t,t_
I
.
aa:Me Rt trddo Lira
C2 'AM I API a R,11.,,
CiERENTE OEN ERAL.

Jaime Rosalino Prado

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1.6
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"()
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DECLARATION OF JAIME ROSALiN0 PRADO L1RA IN SUPPORT OF DEFE1.4DANTS' OPPOSITION To
PLAINTIFFSEXPARTE APPLICATION FOR LEAVE TO
LIMITED IMNAKDIATE DISCOVERY

Case 2:16-cv-05871-RSWL-AS Document 18-2 Filed 08/29/16 Page 4 of 6 Page ID #:282

EXHIBIT A

Case 2:16-cv-05871-RSWL-AS Document 18-2 Filed 08/29/16 Page 5 of 6 Page ID #:283

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Global Forum Rules (Last Updated: 2516-56-oe)

1. Leaking ! Unauthorized use of Code
2. Invites

Administrator
Ital SHADY'S

GrHub. 1M e hSharpLeague
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3.."g
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4 Content
5. Spawning
6 Avatar! Signature
IF Behavior
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10. Disciplinary Measures

Leaking ! Unauthorized use of Code

LeagueSharp assemblies are protected by the standard Glhub license as long as no other license is picked.
Leagues harp assemblies that use the Library "LeagueS harp.0 ommor are protected by the GNU license and have to be released open-source.
LeagueS harp assemblies and tools must be delivered with the plain source, not encrypted/protected or anything else.
LeagueSharp assemblies must not contain any text or drawings that encourage up/0[es in the Assembly Database. Please limit this to the assembly
thread.
Tne LeagueSharp Loader supports local and Gill-lob sources - no 3rd party Loaders are allowed_
Leaking of internal projects and information is strictly disallowed_
If you use/copy any code made by another developer please give proper creels_ Any kind of variable, full plug-in (in cases of AID-Assembles) or
modified assemblies can be defined as code and requires a proper credential if you don't fork it.
Keep in mind that giving out credits doesn't hurl anybody but shows that you respect the work by other developers_
Any assembly that tracks a user in any way will be deleted. Some examples are (But not limited to): Countries, games played. IP addresses, and Lot
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Do not send private messages to users asking for invites unless they explicitly state to do so_

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Keep forum topics on topic No random posts/replies to boost your post count
All content on the forums must be written in English or tagged as foreign post ("[BR] LF du o0")
Cracked/TorrentethIllegal programs/software/scam-related-content is not allowed by any means on the forums.
Posts regarding topics such as "Which Assembly is Best" or "Which Champion Carries Hard in Sob Queue" are forbidden on the forum.
Tutorials and discussions about the chargeback of Riot Points is not allowed.
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Please do not troll regarding L# being updated, asking others to PM staff/members as a confuses other members_
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No cracking discussion related to League is allowed_
No screamers of any sort are allowed to be posted

Case 2:16-cv-05871-RSWL-AS Document 18-2 Filed 08/29/16 Page 6 of 6 Page ID #:284

No cracked or verified accounts are allowed to be posted_
Begging/Asking for assembly votes is not allowed.
No refer links of any kind_

Spamming
Spamming is characterized by the initiation of threads or posts that contribute nothing to a forum, be it off topic or on topic.
Don't bump topics that haven't been replied over 3 Months.
If you want to talk about something that is drastically removed from the topic of a forum, please take it to the Off-Topic Forum_ The Off-Topic Forum was
set up and designed for members to discuss issues not related to a specific game_
Cross-Posting is when you post the same message multiple times in various threads or forums. Continuing to post a similar message will result in an
immediate ban_

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If we find that an image you post in your signature is offending to anyone it will be immediately removed and your account will be disabled_ Be sure to
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Do not harass or attack other communities or their members (this includes streams) in the context of LeagueSharp
Global Forum Rules disc retionally apply to any other form of communication (such as TeamSpeak) that is officially hosted by LeagueSharp.

Shoutbox
The Global Rules apply to the Shoutbox
The following rules only apply for the Shoutbox:
1. You're only allowed to talk in English and German in the Shoutbox.
2. Any kind of eDrama will be punished with a 24h shoutbox ban.

a Spoilers more recent than 1 month will be punished with a warning point_ Next infractions will lead to a permanent shoutbox ban_
4. Please do not use the shoutbox to request anything, use the proper section for it (e.g. Matchmaking).

Account Sharing
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Staff members will. never ask you for your password! If a member/staff member asks for your password immediately contact one of the community
managers (Zethos, Hestia, Zezzy, or iM eh) regarding this issue_

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Every warning point or ban can be appealed by messaging Super Moderators or higher staff members_ Appeals will only be reviewed if the
message explains the case and gives indication on why the punishment was unjust.
Severe infractions wilt be immediately punished with a permanent ban.

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