Facebook v. Power Ventures: Fair use, misuse, and the fight for access to user-generated data



Tags: copyright, information, copying, content, facebook, circumvention, misuse, claims, extract, proprietary

Early last month, federal Judge Jeremy Fogel issued an order in the case of Facebook v. Power Ventures, a lawsuit over a third-party platform that allegedly attempts to "scrape" content for and from users on different social network sites into a single UI. Facebook sued Power, claiming violations of copyright, anti-circumvention regualtions, CAN-SPAM, and the Computer Fraud and Abuse Act. More on the case can be found here.

In the ruling, Judge Fogel primarily addressed the copyright and circumvention claims and whether to dismiss any of the claims outright because they were based on invalid legal theories. He refused to do so based on two cases that have troubled many copyright and internet scholars: MAI v. Peak, 991 F.2d 511 (9th Cir. 1993) and Ticketmaster v. RMG, 507 F.Supp.2d 1096 (C.D. Cal. 2007).

Fogel's reasoning, under these cases, is that any scraping of a webpage involves copying that webpage into a computer's memory in order to extract the underlying information contained therein. Even though this "copying" is ephemeral and momentary, it is enough to constitute a "copy" under Section 106 of the Copyright Act and therefore what we lawyers call a prima facie (or "on its face") case of infringement. Since Facebook's Terms of Service prohibit scraping (and thus, facebook has not given any license to third parties or users to do so), the copying happens without permission.

While there are many reasons to disagree with this analysis and with the MAI/RMG line of cases in general (see, e.g., Section 101 of the Copyright Act which defines a "copy" as a "material object" that is "fixed" such that it is "sufficiently permanent or stable to permit it to be perceived, reproduced, or otherwise communicated for a period of more than transitory duration."), there is an even larger set of problems with the implications of the decision, especially for the doctrines of fair use and copyright misuse.

Fair Use

In his order, Judge Fogel does not discuss fair use directly. In fact, it's unclear whether or not PV raised the issue. Perhaps they are waiting for a later stage in the case, such as summary judgment. However, Fogel does discuss the core of what would be at issue in the fair use arugment. When disucssing the copying that is alleged, he states:

Defendants correctly assert that Facebook does not have a copyright on user content, which ultimately is the information that Defendants' software seeks to extract. However, if Defendants first have to make a copy of a user's entire Facebook profile page in order to collect that user content, such action may violate Facebook's proprietary rights.


In other words, Fogel is arguing that intermediate or temporary copying of FB content in order to extract non-FB content may violate FB's copyrights. This type of argument, however, has been rejected by most courts. Intermediate copying, even extensively, of another's copyrighted works in order to extract non-proprietary information has been found to be fair use in numerous cases, including several in the Ninth Circuit Court of Appeals, the jurisdiction where Judge Fogel resides. See, e.g., Sega v. Accolade, 977 F.2d 1510 (9th Cir. 1992) and Sony v. Connectix, 203 F.3d 596 (9th Cir. 2000).

In both of these cases, direct competitors used intermediate copying of proprietary content in order to create alternative ways of using technology and accessing information. In Sega, it was to create brand new games that worked on Sega's Gensis console. In Connectix, it was to create a Playstation emulator for PCs so that PC users could play PS games. In finding these actions fair use, the courts emphasized that the ultimate end product of the process did not infringe any copyrights in the original copied works and that the purpose was pro-competitive -- the creation of other products and platforms for users to take advantage of technology and information products. I see no difference between these cases and what PV is trying to do here, especially since there seems to be no reasonable other way to access this information.

Copyright Misuse

Moreover, this is also a case that raises serious copyright misuse issues. Copyright misuse is a judge-created doctrine used to curb abuse of copyright licenses. For example, in one case, an attempt to restrict copyright licensees from creating competitive computer-aided design programs for 99 years was found to be abusive (in part because copyright only lasted 75 years at the time). The court found that the copyright owner was trying to effectively extend the term and scope of its copyright beyond what copyright law permitted, and that would prevent people from legitimately developing competitive software. The penalty was a loss of the ability to enforce the copyright.

Here, I see simiar issues. If FB is claiming that it is a violation of its copyrights to access user information on its website but yet concedes that they have no proprietary rights in user information, it would seem to me that this is just another attempt to extend the scope of its copyright beyond what copyright law gives it ownership over. In fact, in FB's papers, it appears to admit as much. Moreover, the case for misuse here appears much stronger that the 99-year-restriction case. Presumably users, who do own whatever rights exist to the information sought, have expressly given PV permission to gather this info. FB is blatantly interfering with PV's attempt to acquire information as an agent of its true owners. Seems like a pretty blatant copyright land grab to me. Perhaps this is why FB has tried so diligently (and now publicy) to convince users to assign over their rights to FB, so they can avoid the legal penalties for potentially anti-competitive conduct like locking out third-party web services the user might wish to engage.

Anti-Circumvention Claims

The anti-circumvention claims are a bit more complicated, so let me just say this. There exist in the law exceptions to these restrictions for reverse engineering and interoperability purposes. See 17 U.S.C. 1201(f). Whether or not these apply is very fact-intensive but possible. Moreover, as the court recognized, if there is no underlying copyright infringement, the case for a violation of the anti-circumvention laws is much much weaker. See Chamberlain v. Skylink, 381 F.3d 1178, 1203 (Fed. Cir. 2004).

In any case, this lawsuit is worth watching. I'm not sure if PV will keep on fighting or fold, but one hopes that if they do fight, they ring these two bells in the next round of briefing. Judge Fogel is a good guy and a smart judge and has generally been sensitive to promoting democractic and public values in technology law, so the right framing of the issue should hopefully help reach the right decision in this case or similar ones to come.

Not yet rated. Be the first:

<< Previous Article      Next Article >>


Comment

Name:

viagra no prescription said... Rating: 0   Vote +   Vote -  

KklgkJ Looking forward to reading more. Great article post.Really thank you! Cool.

12/23/2012 12:08:23 PM 

http://bestmedicineonline.info said... Rating: 0   Vote +   Vote -  

lfba1z A round of applause for your blog article.Really looking forward to read more.

2/14/2013 10:58:33 PM 

buy clomid said... Rating: 0   Vote +   Vote -  

I loved your blog.Really thank you! Awesome.

2/19/2013 3:02:04 AM 

natural weight loss supplements said... Rating: 0   Vote +   Vote -  

Im thankful for the blog. Awesome.

2/21/2013 5:29:51 AM 

what can i do to get more twitter followers said... Rating: 0   Vote +   Vote -  

Im obliged for the blog article.Much thanks again. Cool.

2/26/2013 11:23:05 AM 

tips to make hair grow faster said... Rating: 0   Vote +   Vote -  

Im thankful for the post.Really looking forward to read more. Fantastic.

2/26/2013 1:02:55 PM 

earned money said... Rating: 0   Vote +   Vote -  

Awesome article post.Really thank you! Want more.

2/26/2013 2:43:01 PM 

Business Domains said... Rating: 0   Vote +   Vote -  

I value the blog post.Thanks Again. Really Great.

2/26/2013 3:06:33 PM 

who unfollowed me on instagram said... Rating: 0   Vote +   Vote -  

Muchos Gracias for your article post.Really looking forward to read more. Really Great.

2/26/2013 4:16:30 PM 

Cheap Android Phones said... Rating: 0   Vote +   Vote -  

Fantastic blog post.Really thank you! Cool.

2/26/2013 4:18:26 PM 

rio vaga said... Rating: 0   Vote +   Vote -  

Fantastic blog.Really looking forward to read more. Fantastic.

2/26/2013 5:53:04 PM 

seo said... Rating: 0   Vote +   Vote -  

Great, thanks for sharing this blog article.Really looking forward to read more. Awesome.

2/26/2013 2:22:11 PM 

who unfollowed me on instagram said... Rating: 0   Vote +   Vote -  

Thanks so much for the blog. Really Great.

2/26/2013 6:07:50 PM 

buy a franchise said... Rating: 0   Vote +   Vote -  

Really enjoyed this blog article. Will read on...

2/26/2013 7:29:45 PM 

colonie de vacances said... Rating: 0   Vote +   Vote -  

Very informative article post.Thanks Again. Much obliged.

2/26/2013 5:00:27 PM 

empower network products said... Rating: 0   Vote +   Vote -  

Thank you ever so for you post.Thanks Again. Great.

2/26/2013 6:51:40 PM 

kim kardashian thong said... Rating: 0   Vote +   Vote -  

Thanks-a-mundo for the blog article. Fantastic.

2/26/2013 8:00:20 PM 

trick photography ebook said... Rating: 0   Vote +   Vote -  

Muchos Gracias for your blog.Much thanks again. Cool.

2/26/2013 9:08:43 PM 

Kim Kardashian sextape said... Rating: 0   Vote +   Vote -  

Great article.Really looking forward to read more. Cool.

2/26/2013 8:44:32 PM 

how to get likes on instagram yahoo said... Rating: 0   Vote +   Vote -  

Im grateful for the blog. Cool.

2/26/2013 11:48:43 PM 

real instagram followers for sale said... Rating: 0   Vote +   Vote -  

Im grateful for the blog.Really thank you! Much obliged.

2/26/2013 9:54:19 PM 

Grigores sintages said... Rating: 0   Vote +   Vote -  

Thank you for your blog post.Really looking forward to read more. Keep writing.

2/27/2013 2:06:53 AM 

cheap nikon d3100 lenses said... Rating: 0   Vote +   Vote -  

A big thank you for your blog post.Really thank you! Awesome.

2/27/2013 12:26:37 AM 

women looking for men said... Rating: 0   Vote +   Vote -  

A round of applause for your article.Really looking forward to read more. Cool.

2/26/2013 10:39:41 PM 

wood working plans said... Rating: 0   Vote +   Vote -  

Say, you got a nice article.Really looking forward to read more. Want more.

2/27/2013 12:36:32 AM 

usa facebook fans said... Rating: 0   Vote +   Vote -  

I really enjoy the blog.Thanks Again. Really Cool.

2/27/2013 3:46:39 AM 

free instagram followers said... Rating: 0   Vote +   Vote -  

Thanks-a-mundo for the blog.Really thank you! Much obliged.

2/27/2013 2:33:40 AM 

get more clients said... Rating: 0   Vote +   Vote -  

Muchos Gracias for your blog post.Thanks Again. Really Cool.

2/26/2013 10:48:42 PM 

corporate travel insurance said... Rating: 0   Vote +   Vote -  

wow, awesome article post.Thanks Again. Cool.

2/27/2013 1:47:35 AM 

Ringtones said... Rating: 0   Vote +   Vote -  

I really like and appreciate your article post. Fantastic.

2/27/2013 4:28:59 AM 

hotels in kerala said... Rating: 0   Vote +   Vote -  

Really appreciate you sharing this blog post.Thanks Again. Awesome.

2/27/2013 3:42:56 AM 

roofer dallas said... Rating: 0   Vote +   Vote -  

I value the article post.Really looking forward to read more. Cool.

2/27/2013 7:32:08 AM 

earn extra money said... Rating: 0   Vote +   Vote -  

Really enjoyed this post.Really thank you! Much obliged.

2/27/2013 5:37:24 AM 

Multilingual SEO expert said... Rating: 0   Vote +   Vote -  

This is one awesome article.Thanks Again. Want more.

2/27/2013 9:27:25 AM 

race horse shares said... Rating: 0   Vote +   Vote -  

I loved your blog article.Much thanks again.

2/27/2013 12:13:06 PM 

how to get rid of a yeast infection quickly said... Rating: 0   Vote +   Vote -  

Im obliged for the post.Really looking forward to read more. Really Cool.

2/27/2013 8:18:29 AM 

personal assistant jobs said... Rating: 0   Vote +   Vote -  

Very neat blog.Thanks Again. Really Cool.

2/27/2013 1:23:27 PM 

Maisha Alfonso said... Rating: 0   Vote +   Vote -  

Thanks for sharing, this is a fantastic post.Thanks Again. Awesome.

2/27/2013 3:23:15 PM 

pianists nyc said... Rating: 0   Vote +   Vote -  

I think this is a real great blog article.Thanks Again. Fantastic.

2/27/2013 2:15:29 PM 

Locksmith West Seattle said... Rating: 0   Vote +   Vote -  

I really liked your blog post.Really thank you! Will read on...

2/27/2013 9:25:21 PM 

Crysis 3 download said... Rating: 0   Vote +   Vote -  

Thanks again for the article post.Much thanks again. Great.

2/27/2013 7:24:17 PM 

marketing book said... Rating: 0   Vote +   Vote -  

Thanks-a-mundo for the article.Really thank you! Keep writing.

2/28/2013 1:27:44 AM 

50 plus match said... Rating: 0   Vote +   Vote -  

I really like and appreciate your blog article.Thanks Again. Really Cool.

2/28/2013 5:57:42 AM 

ginny simon said... Rating: 0   Vote +   Vote -  

Thanks for the article post.Really looking forward to read more.

2/27/2013 5:23:06 PM 

Garden Sauna said... Rating: 0   Vote +   Vote -  

Really informative article.Much thanks again. Awesome.

2/27/2013 11:26:05 PM 

ourmeds said... Rating: 0   Vote +   Vote -  

Thanks for the post. Much obliged.

2/28/2013 1:57:20 PM 

solar electric said... Rating: 0   Vote +   Vote -  

Very informative article.Thanks Again.

2/28/2013 2:34:39 PM 

Vpn said... Rating: 0   Vote +   Vote -  

Looking forward to reading more. Great blog.

2/28/2013 12:20:46 PM 

sunexpress ucak bileti|sunexpress ucak bileti said... Rating: 0   Vote +   Vote -  

Major thankies for the blog.Really thank you! Will read on...

3/1/2013 4:02:49 AM 

escort london said... Rating: 0   Vote +   Vote -  

Im thankful for the article.Thanks Again. Want more.

3/1/2013 5:57:45 AM 

focuri de artificii botezuri said... Rating: 0   Vote +   Vote -  

I really enjoy the article post.Much thanks again. Really Cool.

3/1/2013 6:07:29 AM 

GeForce GTX 690 said... Rating: 0   Vote +   Vote -  

I loved your article.Thanks Again. Really Cool.

3/1/2013 4:22:26 AM 

schweizer frauen suchen sex said... Rating: 0   Vote +   Vote -  

Im obliged for the blog article. Really Cool.

3/1/2013 4:53:16 AM 

adjustable dumbbells said... Rating: 0   Vote +   Vote -  

I value the blog.Really looking forward to read more. Awesome.

3/1/2013 7:32:42 AM 

social bookmarking said... Rating: 0   Vote +   Vote -  

Muchos Gracias for your post.Much thanks again.

3/1/2013 9:00:36 AM 

wordpress video tutorials said... Rating: 0   Vote +   Vote -  

Awesome article post.Really thank you! Fantastic.

3/1/2013 9:01:24 AM 

discount prices said... Rating: 0   Vote +   Vote -  

Awesome blog article.Really looking forward to read more. Want more.

3/1/2013 9:09:17 AM 

make money online said... Rating: 0   Vote +   Vote -  

I really enjoy the blog post. Great.

3/1/2013 10:44:38 AM 

medical blog said... Rating: 0   Vote +   Vote -  

I cannot thank you enough for the post.Much thanks again. Really Cool.

3/1/2013 12:32:11 PM 

guinness storehouse discount said... Rating: 0   Vote +   Vote -  

Thanks for sharing, this is a fantastic article. Really Cool.

3/1/2013 10:45:58 AM 

Bacelo Hotels reservation said... Rating: 0   Vote +   Vote -  

Thanks for the article.Really thank you! Keep writing.

3/1/2013 3:56:47 PM 

halovar said... Rating: 0   Vote +   Vote -  

Fantastic post. Fantastic.

3/1/2013 3:57:38 PM 

how to light video said... Rating: 0   Vote +   Vote -  

Thanks again for the post. Will read on...

3/1/2013 11:05:50 AM 

watch here said... Rating: 0   Vote +   Vote -  

A big thank you for your article.Thanks Again. Keep writing.

3/1/2013 1:52:42 PM 

Ferienwohnung cuxhaven said... Rating: 0   Vote +   Vote -  

wow, awesome article post.Really thank you! Really Cool.

3/1/2013 2:15:47 PM 

real casanova said... Rating: 0   Vote +   Vote -  

Really enjoyed this blog post.Much thanks again.

3/1/2013 5:22:14 PM 

lipo 6 said... Rating: 0   Vote +   Vote -  

I am so grateful for your blog post.Thanks Again. Keep writing.

3/1/2013 7:24:24 PM 

car insurance said... Rating: 0   Vote +   Vote -  

Fantastic article post.Thanks Again. Great.

3/1/2013 10:53:09 PM 

oxyelite usplabs said... Rating: 0   Vote +   Vote -  

Thank you for your article post.Thanks Again. Really Great.

3/1/2013 5:40:26 PM 

link wheels said... Rating: 0   Vote +   Vote -  

I appreciate you sharing this blog post. Awesome.

3/1/2013 6:02:45 PM 

so jealous of him said... Rating: 0   Vote +   Vote -  

Really appreciate you sharing this article post.Really thank you! Will read on...

3/1/2013 3:15:44 PM 

Social Bookmarking said... Rating: 0   Vote +   Vote -  

Really appreciate you sharing this blog.Much thanks again. Keep writing.

3/1/2013 11:35:58 PM 

create your own blog said... Rating: 0   Vote +   Vote -  

Thank you ever so for you blog post.Much thanks again. Cool.

3/1/2013 9:08:30 PM 

Digital camera image recovery said... Rating: 0   Vote +   Vote -  

wow, awesome blog post.Much thanks again. Keep writing.

3/2/2013 12:13:35 AM 

Get Twitter followers said... Rating: 0   Vote +   Vote -  

Hey, thanks for the article post. Really Cool.

3/2/2013 4:54:14 AM 

nulled scripts said... Rating: 0   Vote +   Vote -  

I cannot thank you enough for the article post.Really thank you! Really Great.

3/1/2013 9:31:27 PM 

note said... Rating: 0   Vote +   Vote -  

Enjoyed every bit of your article.Really looking forward to read more. Will read on...

3/2/2013 3:02:41 PM 

Get A Payday Loan said... Rating: 0   Vote +   Vote -  

Major thankies for the post. Really Great.

3/2/2013 12:38:08 AM 

camera brands said... Rating: 0   Vote +   Vote -  

Awesome post.Really looking forward to read more. Want more.

3/2/2013 5:55:12 AM 

personal injury attorney houston said... Rating: 0   Vote +   Vote -  

Very neat blog. Keep writing.

3/2/2013 1:42:59 AM 

How To Get More Views On YouTube said... Rating: 0   Vote +   Vote -  

Thanks for sharing, this is a fantastic article.Really looking forward to read more. Great.

3/3/2013 4:16:13 AM 

business credit said... Rating: 0   Vote +   Vote -  

Looking forward to reading more. Great blog post.Really thank you! Really Cool.

3/3/2013 5:55:10 AM 

die cutting said... Rating: 0   Vote +   Vote -  

Thanks for the blog.Really looking forward to read more. Keep writing.

3/2/2013 2:19:38 AM 

kitchens timperley said... Rating: 0   Vote +   Vote -  

Really informative article. Much obliged.

3/1/2013 10:10:08 PM 

seo services adelaide said... Rating: 0   Vote +   Vote -  

I appreciate you sharing this post.Thanks Again. Really Cool.

3/2/2013 2:22:59 AM 

customer service skills said... Rating: 0   Vote +   Vote -  

Really appreciate you sharing this article.Thanks Again. Cool.

3/2/2013 8:01:31 AM 

green coffee beans review said... Rating: 0   Vote +   Vote -  

Wow, great blog.Thanks Again. Cool.

3/2/2013 5:57:09 AM 

guitar online said... Rating: 0   Vote +   Vote -  

I loved your article.Much thanks again. Really Great.

3/2/2013 8:08:32 AM 

Emulin said... Rating: 0   Vote +   Vote -  

I think this is a real great blog post.

3/3/2013 7:33:43 AM 

kim kardashian sex tape said... Rating: 0   Vote +   Vote -  

Fantastic article post.Thanks Again. Cool.

3/2/2013 3:50:08 AM 

lingeries said... Rating: 0   Vote +   Vote -  

I really liked your blog article.Thanks Again. Great.

3/2/2013 10:09:33 AM 

What is a Domain Name said... Rating: 0   Vote +   Vote -  

A big thank you for your blog.Much thanks again. Will read on...

3/2/2013 6:30:37 AM 

lottery software said... Rating: 0   Vote +   Vote -  

I really like and appreciate your blog article.Much thanks again. Really Cool.

3/3/2013 4:23:12 PM 

gold buyers said... Rating: 0   Vote +   Vote -  

A round of applause for your blog post.Really thank you! Keep writing.

3/2/2013 4:11:01 AM 

calcinhas said... Rating: 0   Vote +   Vote -  

Enjoyed every bit of your blog post.Much thanks again. Fantastic.

3/2/2013 12:54:47 PM 

ipod repair houston said... Rating: 0   Vote +   Vote -  

Im obliged for the post. Really Cool.

3/3/2013 9:29:46 AM 

Campaign PAC said... Rating: 0   Vote +   Vote -  

I value the post. Awesome.

3/3/2013 6:34:49 PM 

authority roi scam said... Rating: 0   Vote +   Vote -  

Thank you for your blog.Really looking forward to read more. Really Cool.

3/3/2013 8:21:34 PM 

where can i buy dermatend said... Rating: 0   Vote +   Vote -  

Enjoyed every bit of your post.Really thank you! Cool.

3/3/2013 11:49:39 AM 

clear fx signals scam said... Rating: 0   Vote +   Vote -  

Great blog.

3/3/2013 10:08:10 PM 

Homecoming Dresses said... Rating: 0   Vote +   Vote -  

wow, awesome post.Much thanks again. Really Cool.

3/3/2013 1:25:28 PM 

papa john?s pizza menu said... Rating: 0   Vote +   Vote -  

Thanks for the post. Keep writing.

3/4/2013 5:10:11 AM 

bedbathandbeyond printable coupons said... Rating: 0   Vote +   Vote -  

Thanks for the article post. Really Great.

3/3/2013 3:02:50 PM 

car without title said... Rating: 0   Vote +   Vote -  

Appreciate you sharing, great post.Really thank you! Much obliged.

3/4/2013 5:28:21 AM 

Click here for Adiphene said... Rating: 0   Vote +   Vote -  

Really enjoyed this blog article.Really thank you! Cool.

3/3/2013 11:53:57 PM 

gillette mach 3 razor blades said... Rating: 0   Vote +   Vote -  

I appreciate you sharing this article post.Really thank you! Keep writing.

3/4/2013 8:38:16 AM 

augusta web design said... Rating: 0   Vote +   Vote -  

This is one awesome blog.Thanks Again. Want more.

3/4/2013 3:14:32 PM 

mercedes repair rocklin california said... Rating: 0   Vote +   Vote -  

Great, thanks for sharing this blog post.Really looking forward to read more. Awesome.

3/4/2013 12:30:02 AM 

kerdi shower kit said... Rating: 0   Vote +   Vote -  

I really liked your post.Really thank you! Keep writing.

3/5/2013 1:57:46 AM 

generic Viagra tablets said... Rating: 0   Vote +   Vote -  

Looking forward to reading more. Great post.Really thank you! Much obliged.

3/4/2013 5:05:05 PM 

buy traffic here said... Rating: 0   Vote +   Vote -  

Thank you for your blog post.Thanks Again. Great.

3/4/2013 12:08:06 PM 

sale Cytotec said... Rating: 0   Vote +   Vote -  

I appreciate you sharing this post.Much thanks again.

3/4/2013 11:51:25 PM 

fitness and diet said... Rating: 0   Vote +   Vote -  

Thank you for your blog post.Really looking forward to read more. Really Great.

3/4/2013 7:04:26 AM 

game development for iphone said... Rating: 0   Vote +   Vote -  

wow, awesome post.Thanks Again. Really Cool.

3/4/2013 8:44:49 AM 

Sodium CarboxyMethylCellulose said... Rating: 0   Vote +   Vote -  

A big thank you for your article post.Really thank you! Really Cool.

3/5/2013 12:16:36 AM 

how to use profollica said... Rating: 0   Vote +   Vote -  

Really appreciate you sharing this post.Really thank you! Will read on...

3/5/2013 4:36:13 AM 

how to make android apps said... Rating: 0   Vote +   Vote -  

I think this is a real great blog post.Really looking forward to read more.

3/4/2013 10:26:09 AM 

Summitt Energy said... Rating: 0   Vote +   Vote -  

Im obliged for the blog post.Much thanks again. Really Great.

3/5/2013 6:18:59 AM 

RISK assessor course said... Rating: 0   Vote +   Vote -  

Say, you got a nice post.Really looking forward to read more. Great.

3/5/2013 8:21:27 AM 

divorce attorneys in orange county said... Rating: 0   Vote +   Vote -  

Wow, great post.Thanks Again. Cool.

3/5/2013 6:29:36 AM 

resume builder said... Rating: 0   Vote +   Vote -  

Major thanks for the blog post. Really Great.

3/5/2013 10:16:58 AM 

be your boss said... Rating: 0   Vote +   Vote -  

Very good article.Much thanks again. Really Great.

3/5/2013 10:39:14 AM 

sex in essex said... Rating: 0   Vote +   Vote -  

Thanks again for the blog article.Really looking forward to read more. Really Cool.

3/5/2013 8:56:45 AM 

Inhibits uptake of heavy metals said... Rating: 0   Vote +   Vote -  

I really liked your blog article.Much thanks again. Want more.

3/5/2013 9:13:38 AM 

forex investments said... Rating: 0   Vote +   Vote -  

Thanks-a-mundo for the post.Really looking forward to read more. Great.

3/5/2013 2:08:16 PM 

how to squat properly said... Rating: 0   Vote +   Vote -  

I loved your blog post.Really looking forward to read more. Really Great.

3/5/2013 7:55:10 PM 

how to win your ex girlfriend back said... Rating: 0   Vote +   Vote -  

Very neat article.Much thanks again. Much obliged.

3/5/2013 12:13:58 PM 

cetona de zmeura said... Rating: 0   Vote +   Vote -  

I am so grateful for your article post.Much thanks again. Much obliged.

3/5/2013 5:58:41 PM 

Air Duct Cleaning Seattle said... Rating: 0   Vote +   Vote -  

Awesome blog.Really thank you! Great.

3/5/2013 11:33:12 PM 

Betting on Spread said... Rating: 0   Vote +   Vote -  

Thank you ever so for you blog article.Thanks Again. Really Cool.

3/5/2013 4:03:30 PM 

verifica strutturale said... Rating: 0   Vote +   Vote -  

Appreciate you sharing, great blog article.Really looking forward to read more. Cool.

3/5/2013 11:58:13 PM 

o level course said... Rating: 0   Vote +   Vote -  

Wow, great article post.Really thank you! Great.

3/5/2013 9:52:51 PM 

information said... Rating: 0   Vote +   Vote -  

A big thank you for your article post.

3/6/2013 7:40:52 AM 

jailbreak iphone 4 ios said... Rating: 0   Vote +   Vote -  

I cannot thank you enough for the article post.Really looking forward to read more. Much obliged.

3/6/2013 10:03:08 AM 

orgone said... Rating: 0   Vote +   Vote -  

A big thank you for your post.Really thank you! Want more.

3/6/2013 6:34:05 AM 

alternatives to zoloft said... Rating: 0   Vote +   Vote -  

Very neat blog.Thanks Again. Much obliged.

3/6/2013 1:26:41 AM 

order proscar online said... Rating: 0   Vote +   Vote -  

Thanks again for the article post.Much thanks again. Great.

3/6/2013 1:26:48 AM 

Summitt Energy Charity Golf Tournament said... Rating: 0   Vote +   Vote -  

Really appreciate you sharing this blog article. Cool.

3/6/2013 1:30:10 AM 

Arabic book said... Rating: 0   Vote +   Vote -  

Thank you ever so for you blog post.Really thank you! Keep writing.

3/6/2013 8:17:43 AM 

inbound marketing said... Rating: 0   Vote +   Vote -  

Thanks for sharing, this is a fantastic blog article.Really thank you! Really Cool.

3/6/2013 1:31:36 PM 

Welcome to DLC WELLNESS Thyroid Chicago! Natural Solutions for Hypothyroid Symptoms said... Rating: 0   Vote +   Vote -  

Im obliged for the blog post.Much thanks again. Much obliged.

3/6/2013 5:30:16 PM 

angel project indirapuram said... Rating: 0   Vote +   Vote -  

Muchos Gracias for your blog article. Fantastic.

3/6/2013 1:33:52 PM 

antique silver jewelry said... Rating: 0   Vote +   Vote -  

Looking forward to reading more. Great post. Cool.

3/6/2013 11:35:42 AM 

justin tv said... Rating: 0   Vote +   Vote -  

Great article post.Thanks Again. Really Cool.

3/6/2013 11:46:26 AM 

press release said... Rating: 0   Vote +   Vote -  

Hey, thanks for the article post. Really Great.

3/6/2013 9:37:40 AM 

overcome fear driving said... Rating: 0   Vote +   Vote -  

Im obliged for the post.Really thank you!

3/6/2013 9:29:35 PM 

bayer levitra samples said... Rating: 0   Vote +   Vote -  

I appreciate you sharing this article post.Really looking forward to read more. Awesome.

3/6/2013 7:26:59 PM 

mystery shopping said... Rating: 0   Vote +   Vote -  

I cannot thank you enough for the blog post. Really Great.

3/7/2013 5:10:46 AM 

playa del carmen real estate said... Rating: 0   Vote +   Vote -  

Really informative blog article.Much thanks again. Awesome.

3/6/2013 3:30:47 PM 

friendship said... Rating: 0   Vote +   Vote -  

I am so grateful for your article.Thanks Again. Will read on...

3/7/2013 2:12:40 AM 

how to lose fat said... Rating: 0   Vote +   Vote -  

Thank you for your blog.Really thank you!

3/7/2013 7:54:17 AM 

electronic cigarette said... Rating: 0   Vote +   Vote -  

Really enjoyed this blog post. Fantastic.

3/7/2013 1:36:20 AM 

123Binary.com said... Rating: 0   Vote +   Vote -  

Im grateful for the post.Thanks Again. Awesome.

3/6/2013 7:28:56 PM 

Vitamix blender for P90x said... Rating: 0   Vote +   Vote -  

I loved your article post.Really thank you! Really Great.

3/7/2013 6:57:48 AM 

whitening teeth said... Rating: 0   Vote +   Vote -  

Thanks for the post.Really looking forward to read more. Really Great.

3/7/2013 8:45:19 AM 

pornhub said... Rating: 0   Vote +   Vote -  

Thanks so much for the article. Want more.

3/7/2013 3:22:54 AM 

web design said... Rating: 0   Vote +   Vote -  

Thanks for the post.Much thanks again. Cool.

3/7/2013 10:31:28 AM 

Brehmandur2 said... Rating: 0   Vote +   Vote -  

Wonderfull post! Thank you! Will read again and again.

3/7/2013 9:47:54 AM 

steakhouses in Myrtle Beach said... Rating: 0   Vote +   Vote -  

I truly appreciate this blog post. Great.

3/7/2013 9:50:48 AM 

Authentic Designer Handbags said... Rating: 0   Vote +   Vote -  

Hey, thanks for the post.Much thanks again. Much obliged.

3/7/2013 4:11:50 AM 

diet pills uk said... Rating: 0   Vote +   Vote -  

Enjoyed every bit of your post. Really Great.

3/7/2013 3:52:56 PM 

vj visuals said... Rating: 0   Vote +   Vote -  

Very good article post.Really looking forward to read more. Keep writing.

3/7/2013 1:54:12 PM 

the tao of badass download said... Rating: 0   Vote +   Vote -  

A round of applause for your article post. Much obliged.

3/7/2013 3:56:14 PM 

Online Nursery said... Rating: 0   Vote +   Vote -  

Fantastic article.Really thank you! Cool.

3/7/2013 7:56:56 PM 

locations said... Rating: 0   Vote +   Vote -  

Fantastic article.Thanks Again. Really Cool.

3/7/2013 2:06:44 PM 

Charleston SC construction said... Rating: 0   Vote +   Vote -  

Im grateful for the article post.Thanks Again. Cool.

3/7/2013 11:52:11 AM 

facebook quotes said... Rating: 0   Vote +   Vote -  

I cannot thank you enough for the article.Much thanks again. Really Cool.

3/7/2013 12:20:03 PM 

Fast life insurance quote UK said... Rating: 0   Vote +   Vote -  

Thank you for your article post.Really thank you! Great.

3/8/2013 3:33:44 AM 

comoganardineroeninternet.ws said... Rating: 0   Vote +   Vote -  

Really enjoyed this article. Much obliged.

3/7/2013 5:56:28 PM 

naperville il plastic surgeon said... Rating: 0   Vote +   Vote -  

I truly appreciate this article.Really looking forward to read more. Really Great.

3/7/2013 9:55:51 PM 

Easy Payday Loans said... Rating: 0   Vote +   Vote -  

Really informative post. Much obliged.

3/8/2013 1:47:50 AM 

phoenix seo said... Rating: 0   Vote +   Vote -  

Thanks for sharing, this is a fantastic blog.Much thanks again. Want more.

3/8/2013 1:53:19 AM 

2013 hostgator code said... Rating: 0   Vote +   Vote -  

Enjoyed every bit of your blog post.Much thanks again. Fantastic.

3/8/2013 6:44:35 AM 

Insurance Roof repair said... Rating: 0   Vote +   Vote -  

Very informative blog post. Awesome.

3/7/2013 11:54:47 PM 

dui attorney in denver said... Rating: 0   Vote +   Vote -  

A big thank you for your blog.Thanks Again. Want more.

3/8/2013 7:07:10 AM 

stainless steel handrail said... Rating: 0   Vote +   Vote -  

Looking forward to reading more. Great post.Really looking forward to read more. Really Great.

3/8/2013 4:48:49 PM 

social work said... Rating: 0   Vote +   Vote -  

Muchos Gracias for your blog.Really looking forward to read more. Really Great.

3/9/2013 1:37:52 PM 

clixzoo said... Rating: 0   Vote +   Vote -  

Really appreciate you sharing this blog. Really Cool.

3/8/2013 8:46:32 AM 

buy Youtube views said... Rating: 0   Vote +   Vote -  

I value the article post. Fantastic.

3/9/2013 10:02:56 AM 

Digital xxx sex porn said... Rating: 0   Vote +   Vote -  

I really like and appreciate your blog article. Awesome.

3/9/2013 2:58:32 AM 

prerequisites for nursing said... Rating: 0   Vote +   Vote -  

Very informative blog post.Much thanks again. Really Great.

3/9/2013 11:50:07 AM 

escortdate said... Rating: 0   Vote +   Vote -  

I really liked your blog post.Really thank you! Fantastic.

3/10/2013 4:03:55 AM 

Phen375 weight loss pill said... Rating: 0   Vote +   Vote -  

Very good blog.Much thanks again. Really Great.

3/8/2013 8:52:37 PM 

funny pictures said... Rating: 0   Vote +   Vote -  

Enjoyed every bit of your blog.Really thank you! Much obliged.

3/8/2013 8:54:43 AM 

Insanity vs P90x workout said... Rating: 0   Vote +   Vote -  

Muchos Gracias for your blog.Much thanks again. Fantastic.

3/10/2013 12:05:29 PM 

Warz Hack said... Rating: 0   Vote +   Vote -  

I value the blog post.Thanks Again. Cool.

3/8/2013 4:43:07 AM 

Tao of Badass said... Rating: 0   Vote +   Vote -  

A big thank you for your article post.Really looking forward to read more. Really Great.

3/10/2013 1:55:32 PM 

anniversary said... Rating: 0   Vote +   Vote -  

Im grateful for the article.Thanks Again. Awesome.

3/11/2013 2:09:25 AM 

seo dubai,seo ksa,seo qatar said... Rating: 0   Vote +   Vote -  

I loved your blog post.Really thank you! Will read on...

3/11/2013 4:08:52 AM 

ryan deiss ultimate list building system said... Rating: 0   Vote +   Vote -  

Muchos Gracias for your blog.Really thank you! Really Great.

3/8/2013 6:50:35 PM 

SEO said... Rating: 0   Vote +   Vote -  

A big thank you for your blog article. Awesome.

3/8/2013 10:53:16 PM 

Croatian Translators Malaysia said... Rating: 0   Vote +   Vote -  

Im obliged for the post.Really thank you! Will read on...

3/11/2013 4:27:42 AM 

increase traffic said... Rating: 0   Vote +   Vote -  

Thanks for the post.Thanks Again. Fantastic.

3/8/2013 5:19:44 AM 

Kelly Parkes New Single said... Rating: 0   Vote +   Vote -  

Very neat article.Thanks Again. Much obliged.

3/11/2013 12:19:47 AM 

dating after 50 said... Rating: 0   Vote +   Vote -  

Thanks again for the blog article. Keep writing.

3/11/2013 6:28:34 AM 

Assisted Living Palm Springs said... Rating: 0   Vote +   Vote -  

Appreciate you sharing, great article.Much thanks again. Want more.

3/11/2013 3:23:36 PM 

accommodation reservations said... Rating: 0   Vote +   Vote -  

Hey, thanks for the blog.Really thank you! Cool.

3/13/2013 12:17:49 AM 

viagra online said... Rating: 0   Vote +   Vote -  

Fantastic blog.Really looking forward to read more. Really Cool.

3/11/2013 5:29:44 PM 

official site said... Rating: 0   Vote +   Vote -  

I really liked your article post.Much thanks again. Cool.

3/9/2013 12:55:55 AM 

fulltraffic said... Rating: 0   Vote +   Vote -  

Wow, great post. Really Great.

3/12/2013 5:30:48 AM 

buy viagra pills said... Rating: 0   Vote +   Vote -  

Thanks for the post.Really thank you! Will read on...

3/11/2013 5:30:04 PM 

alternative cancer treatments said... Rating: 0   Vote +   Vote -  

I am so grateful for your blog article.Really thank you! Really Cool.

3/11/2013 8:20:11 AM 

photos from ipad to computer said... Rating: 0   Vote +   Vote -  

I appreciate you sharing this article post. Awesome.

3/12/2013 5:22:02 PM 

order zoloft online said... Rating: 0   Vote +   Vote -  

Great post.Much thanks again. Fantastic.

3/8/2013 9:13:16 AM 

buy viagra 100mg said... Rating: 0   Vote +   Vote -  

This is one awesome blog.Really thank you! Awesome.

3/13/2013 5:45:06 AM 

make online money said... Rating: 0   Vote +   Vote -  

Really informative blog article.Thanks Again. Great.

3/8/2013 10:46:41 AM 

cheap cialis online said... Rating: 0   Vote +   Vote -  

Im obliged for the blog article. Cool.

3/13/2013 4:36:49 AM 

Titan Koffer guenstig kaufen said... Rating: 0   Vote +   Vote -  

Appreciate you sharing, great blog.Much thanks again. Cool.

3/13/2013 4:02:41 AM 

Buy Admission Essay said... Rating: 0   Vote +   Vote -  

Great, thanks for sharing this article post.Really looking forward to read more. Really Cool.

3/11/2013 8:30:47 AM 

meet singles said... Rating: 0   Vote +   Vote -  

I loved your post.Really looking forward to read more. Great.

3/13/2013 7:48:51 AM 

Tahitian Noni said... Rating: 0   Vote +   Vote -  

I value the blog article.Much thanks again. Want more.

3/11/2013 10:11:17 AM 

cheap generic imitrex online said... Rating: 0   Vote +   Vote -  

Awesome post. Really Cool.

3/13/2013 4:36:53 AM 

become a sports agent said... Rating: 0   Vote +   Vote -  

I think this is a real great article post.Really thank you! Keep writing.

3/12/2013 1:35:56 AM 

Wedding Disc Jockeys said... Rating: 0   Vote +   Vote -  

I am so grateful for your article. Will read on...

3/13/2013 9:41:33 AM 

gift ideas for mother said... Rating: 0   Vote +   Vote -  

Really informative blog post.Really thank you! Cool.

3/13/2013 3:18:17 PM 

buy viagra 100mg said... Rating: 0   Vote +   Vote -  

Major thankies for the blog article.Really thank you! Much obliged.

3/13/2013 5:45:15 AM 

Volcano Vaporizers said... Rating: 0   Vote +   Vote -  

I really liked your blog post.Really looking forward to read more. Keep writing.

3/14/2013 7:45:49 AM 

banner brokers said... Rating: 0   Vote +   Vote -  

Appreciate you sharing, great post.Really looking forward to read more. Keep writing.

3/13/2013 2:12:37 AM 

preschool curriculum said... Rating: 0   Vote +   Vote -  

Very informative blog.Much thanks again. Awesome.

3/13/2013 5:55:24 AM 

Scottish Whisky Online said... Rating: 0   Vote +   Vote -  

I think this is a real great post.Much thanks again. Will read on...

3/13/2013 11:34:02 AM 

Wein online kaufen said... Rating: 0   Vote +   Vote -  

Very neat blog post.Really thank you! Much obliged.

3/14/2013 1:32:58 PM 

Million Dollar Online Earning Blueprint with Free Joining said... Rating: 0   Vote +   Vote -  

Im thankful for the blog article. Really Great.

3/14/2013 9:42:22 AM 

viagra fur die frau said... Rating: 0   Vote +   Vote -  

Looking forward to reading more. Great post.Really thank you! Really Great.

3/13/2013 5:11:29 PM 

youtube views said... Rating: 0   Vote +   Vote -  

A big thank you for your article post.Really thank you! Fantastic.

3/14/2013 11:38:07 AM 

europe and german food delviery service Cebu said... Rating: 0   Vote +   Vote -  

Really enjoyed this blog article.Much thanks again. Keep writing.

3/13/2013 7:03:39 PM 

Phoenix said... Rating: 0   Vote +   Vote -  

Thanks for sharing, this is a fantastic blog post.Really looking forward to read more. Much obliged.

3/14/2013 11:08:53 PM 

buy cheap generic cialis online said... Rating: 0   Vote +   Vote -  

Thanks for the blog article. Really Cool.

3/13/2013 4:37:01 AM 

motivational quotes said... Rating: 0   Vote +   Vote -  

Im obliged for the article.Much thanks again. Really Great.

3/13/2013 1:25:35 PM 

beautiful girls said... Rating: 0   Vote +   Vote -  

Very neat blog post.Much thanks again. Cool.

3/14/2013 7:20:20 PM 

10mg levitra said... Rating: 0   Vote +   Vote -  

wow, awesome blog article.Thanks Again. Really Great.

3/12/2013 2:46:15 AM 

sharing said... Rating: 0   Vote +   Vote -  

Thanks for sharing, this is a fantastic blog.Really looking forward to read more. Really Cool.

3/15/2013 4:49:46 AM 

whey proteinpulver said... Rating: 0   Vote +   Vote -  

Hey, thanks for the article post.Really thank you! Want more.

3/12/2013 3:39:37 AM 

buy twitter followers cheap no password said... Rating: 0   Vote +   Vote -  

Really enjoyed this article post.Thanks Again.

3/14/2013 3:29:14 PM 

inspiring motivational quotes said... Rating: 0   Vote +   Vote -  

Very informative post.Much thanks again. Really Cool.

3/15/2013 10:33:07 AM 

work at home said... Rating: 0   Vote +   Vote -  

Major thankies for the article post. Awesome.

3/14/2013 5:24:56 PM 

Make your Facebook posters here said... Rating: 0   Vote +   Vote -  

Thanks a lot for the blog article. Want more.

3/15/2013 6:44:09 AM 

trophy manufacturers said... Rating: 0   Vote +   Vote -  

Great, thanks for sharing this blog article. Really Great.

3/15/2013 4:19:23 PM 

numbness in hands said... Rating: 0   Vote +   Vote -  

Enjoyed every bit of your blog.Much thanks again. Will read on...

3/15/2013 2:24:37 PM 

healtcare Internet marketing said... Rating: 0   Vote +   Vote -  

Thank you for your post.Thanks Again. Really Great.

3/16/2013 1:54:19 AM 

generic viagra said... Rating: 0   Vote +   Vote -  

Very neat article post.Really thank you! Great.

3/15/2013 12:56:02 AM 

frauenviagra.net said... Rating: 0   Vote +   Vote -  

Thanks so much for the blog.Really looking forward to read more. Cool.

3/15/2013 12:28:32 PM 

HGH supplements said... Rating: 0   Vote +   Vote -  

wow, awesome blog. Really Cool.

3/15/2013 8:38:44 AM 

golf said... Rating: 0   Vote +   Vote -  

Appreciate you sharing, great blog article.Really looking forward to read more. Fantastic.

3/15/2013 1:00:30 AM 

tao of badass review said... Rating: 0   Vote +   Vote -  

Major thanks for the post.Much thanks again.

3/15/2013 2:56:06 AM 

Web Designing in Bermuda said... Rating: 0   Vote +   Vote -  

Thank you ever so for you article.Really looking forward to read more. Will read on...

3/14/2013 9:13:15 PM 

Salvage Cars for sale said... Rating: 0   Vote +   Vote -  

Thanks a lot for the blog.Really thank you! Awesome.

3/15/2013 6:13:09 PM 

hiphop remix contest said... Rating: 0   Vote +   Vote -  

Great, thanks for sharing this blog post. Keep writing.

3/8/2013 12:49:46 PM 

Buy Levitra said... Rating: 0   Vote +   Vote -  

Thanks again for the post.Really thank you! Fantastic.

3/15/2013 7:32:43 PM 

order said... Rating: 0   Vote +   Vote -  

Looking forward to reading more. Great post.Much thanks again. Will read on...

3/8/2013 2:48:24 PM