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Rusty Rendon
Disability: visually impaired
Represented by: Pacific Trial Lawyers
Number of lawsuits filed: hundreds
Targets: website violations
Below is an excerpt from Mr. Rendon's deposition taken in May, 2022.
Is Mr. Rendon an advocate for the visually impaired or is he a profiteer?
You be the judge.
Examination by attorney Ara Sahelian:
____________
19 Q. BY MR. SAHELIAN: All right. So paragraph 8 in this
12:57 20 Complaint -- and I will submit to you in nearly every
21 other Complaint that you have filed -- says plaintiff
22 genuinely wants to avail himself of defendant's goods and
23 services. Okay? In your mind, what does that mean?
12:58 24 A. Is that for me or --
25 Q. That's for you.
64
1 MR. RENDON. Oh, okay. Well, it essentially means that
2 I -- I want to -- to partake in the goods and services
3 just like everyone else.
4 Q. All right. So does that mean for each of the
12:58 5 businesses that you have sued, you want to buy their
6 products?
7 A. Yes.
12:58 8 Q. All right. Now going back to all of those
9 problematic features that you typically run across when
10 you get frustrated -- right? -- have you ever thought
11 about why that is, why these problems exist in your mind?
12:59 12 A. Well, maybe their website designers aren't
13 aware. Maybe it looks fine to a sighted person. I
14 believe they do, maybe they don't, I'm not sure.
15 But for the most part, maybe the web developer
16 just isn't aware that, "Oh, man, I should make this
17 accessible."
18 Q. All right. Have you ever over the years
12:59 19 formulated any other thoughts as to why these problems
20 are pervasive?
21 A. I think I just chalk it up to just the
22 developer's not being aware.
23 Q. Have you thought about what a good solution
24 might be?
25 MS. KNOWLES: Objection, calls for speculation.
1 Q. BY MR. SAHELIAN: I'm just thinking in your
13:00 2 mind, have you ever thought about what a solution might
3 be?
4 A. Well, there's got to be more awareness. They
5 have to be aware of the -- the guidelines that's there
6 for publishers.
13:00 7 Q. Again in your mind, any other -- any other
8 reason?
9 A. (No response.)
10 Q. Meaning any other reason why these things,
11 these issues that are frustrating to you, are pervasive?
12 A. No.
13:01 13 Q. How do you know when a case is settled?
14 A. My lawyers tell me that they are.
15 Q. All right. And by the way, don't tell me
16 anything specifics that your lawyers have told you.
17 Okay? Otherwise Victoria will never talk to me again.
13:02 18 So do you have a log or some sort of a
19 recordkeeping system for knowing which cases have
20 settled?
21 A. I don't know.
22 Q. Is that --? Well, that calls for a yes or a
13:02 23 no. Either you have one or you don't.
24 A. No, I don't have one.
25 Q. So as we sit here today, of the several
1 hundred cases that you have filed, you have no way of
2 telling me which ones have settled and which ones have
3 not; correct?
4 MS. KNOWLES: Objection, assumes facts not in
5 evidence, and calls for speculation. And misstates
13:03 6 testimony.
7 Q. BY MR. SAHELIAN: All right. I'll break it
8 down. Is it a fact, Mr. Rendon, that you have filed
9 several hundred lawsuits?
10 A. Yes.
11 Q. Is it a fact that some have settled?
12 A. Yes.
13:03 13 Q. And what do you base your conviction on that
14 some have settled?
15 A. Lawyers told me so.
16 Q. All right. What other reason do you base your
17 conviction on?
18 MS. KNOWLES: Objection. You're getting into the
19 territory of confidential discussions that are not going
20 to let him answer.
21 MR. SAHELIAN: No. I'm not. I already told him not
13:04 22 to -- not to get into attorney-client communications.
23 Q. So I'm asking other than attorney-client
24 communication, what other reasons do you have to convince
25 you that some of the cases, if not all, have settled
1 other than anything pertaining to conversations you've
13:04 2 had or communications you've had with your attorneys?
3 A. That's the only one.
4 Q. Would getting a check in the mail or money
5 deposited in your bank, would that be an indication that
6 a case is settled?
7 A. You have to repeat that. You cut out.
8 Q. Okay. Your window froze also. So I'll
9 rephrase the question.
13:05 10 A. Oh.
11 MR. SAHELIAN: Madam Court Reporter, did you hear my
12 question in full?
13 THE REPORTER: Yes.
14 MR. SAHELIAN: If you don't mind.
15 (The record was read as follows:
13:05 16 "Would getting a check in the mail or money
17 deposited in your bank, would that be an
18 indication that a case is settled?")
13:05 19 THE WITNESS: I guess.
13:05 20 Q. BY MR. SAHELIAN: Okay. You said you guess.
21 What goes through your mind when you see money being
22 deposited in your account?
23 A. Something must have happened.
24 Q. Would a case have been settled be one of the
25 things that comes through your mind?
1 A. It could be.
13:06 2 Q. Any other reason why there would be money
3 deposited in your account?
4 A. Nope.
5 Q. Is that a no?
6 A. No.
7 Wait. Yes, that is a no.
8 Q. In other words, your answer was a no?
9 A. Yes.
10 Q. Correct? All right. Just say correct or
11 incorrect. Or false. Okay?
13:06 12 A. Okay. Correct.
13 Q. All right. So to summarize, when you see
14 money appear in your bank account, you know that it's
15 a -- potentially a case that has settled. Correct or
16 incorrect?
17 A. Correct.
13:07 18 Q. All right. So when you see money deposited in
19 your account, do you follow up to see which case has
20 settled?
21 A. No.
22 Q. So your answer was a no; correct?
13:08 23 A. No.
24 Q. I'm sorry, just say -- so your answer was a
25 no. Correct or incorrect?
1 A. Hold on a sec. Correct.
2 Q. All right. If you need to take a break at any
3 time, Mr. Rendon, just let me know. Okay?
4 A. Okay.
5 Q. I want to make sure that you're comfortable
13:08 6 and your attorney is comfortable as well.
7 A. It just cuts out a lot. That's all.
8 Q. Yeah. Yes, Mr. Rendon, I'm having that -- I'm
9 having that problem too occasionally.
10 MS. KNOWLES: You want me to try the phone? Just to
11 try it? Or --
12 MR. SAHELIAN: Give it a try. Give it a try.
13 MS. KNOWLES: Let me -- I think I have to mute this.
13:08 14 Hold on.
13:12 15 (Discussion off the record.)
16 Q. BY MR. SAHELIAN: All right, Mr. Rendon, can
17 you hear me well?
18 A. You're okay.
19 Q. All right. Do you recall suing a company
13:12 20 called Shiekh Shoes?
21 A. I believe so, yes.
22 Q. Do you remember how Sheikh is spelled? In the
23 context --
24 A. No, I don't remember.
25 Q. -- in the context of the website name.
1 All right. I will submit to you it's S, as in
13:12 2 Sam, H-I-E-K-H. Do you remember suing them?
3 A. Yes, I believe so.
4 Q. All right. Do you know if the case is settled
5 or not?
6 ** MS. KNOWLES: Belated objection. Calls for
7 confidential settlement communications and attorney-
13:13 8 client privileged communication. I'm going to instruct
9 the witness not to answer.
10 Q. BY MR. SAHELIAN: All right. Do you know if
11 the case is terminated?
12 A. Yes.
13 Q. All right. When was the last time you checked
14 their website?
15 A. The last time I checked was while it was
16 pending.
13:14 17 Q. And when was that?
18 A. I don't remember.
19 Q. All right. What aspects of the website were
20 problematic in a follow-up where they corrected?
21 MS. KNOWLES: Objection, assumes facts not in
22 evidence.
23 THE WITNESS: Let's see.
24 MR. SAHELIAN: Counsel, do you want him to answer
25 the question?
1 MS. KNOWLES: If you can read it back, he can answer
2 if -- you know, if he knows.
3 MR. SAHELIAN: I'll rephrase it.
4 Q. Mr. Rendon, when you sued Shiekh Shoes, what
5 aspects of the website were problematic to you?
13:15 6 A. I -- I can't --. Excuse me. I can't remember
7 the specifics, but maybe -- maybe the headings were out
8 of order, the images weren't labeled properly, the text
9 fields didn't have alternative text. That's what I can
13:15 10 remember off the top of my head.
11 Q. All right. Insofar as you know, have all of
12 those issues been addressed and is the website accessible
13 to you today?
14 MS. KNOWLES: Objection, assumes facts not in
15 evidence.
16 Q. BY MR. SAHELIAN: Your answer, Mr. Rendon?
17 A. I don't know. I don't know.
18 Q. Have you purchased shoes from Shiekh Shoes?
19 A. No, I haven't.
13:15 20 Q. Have you purchased any items from Shiekh
21 Shoes?
22 A. No, I haven't.
23 Q. Now I know you're a healthy adult male, so I'm
24 not surprised that you also sued Frederick's of
25 Hollywood. Do you recall that?
1 A. I believe -- yes, I believe so.
13:16 2 Q. All right. Insofar as you know -- well,
3 strike that.
4 Did you find the website to be inaccessible to
5 you when you sued?
6 A. I don't remember.
7 Q. Can you tell me why you sued Frederick's of
8 Hollywood?
13:16 9 A. I can't remember.
10 Q. All right. Have you purchased anything from
11 Frederick's of Hollywood since you filed a lawsuit?
12 A. No.
13 Q. As you sit here today, can you tell me if the
14 Frederick's of Hollywood website is accessible to you?
13:17 15 A. I don't know.
16 MS. KNOWLES: Objection, vague as to time.
17 THE WITNESS: Oh.
18 MR. SAHELIAN: Well, I said as he sits here today.
19 That's not vague as to time.
20 MS. KNOWLES: He's sitting here today. But was it
21 accessible then or is it accessible to him today as he
22 sits here today.
23 MR. SAHELIAN: All right. Okay. Fair enough.
24 Q. Insofar as you know, Mr. Rendon, is
13:17 25 Frederick's of Hollywood's website currently accessible?
1 A. I don't know.
2 Q. All right. Insofar as you know, is
3 Frederick's of Hollywood --? Strike that.
4 Was Frederick's of Hollywood's website
5 accessible to you at any time after you filed the
13:18 6 lawsuit?
7 A. I don't know.
8 Q. Do you like beer?
9 A. No.
10 Q. I'm surprised you don't. You like lingerie,
11 but you don't like beer. Come on, man.
13:18 12 A. Well, the lingerie was not for me.
13 Q. All right. So you sued a company called Brew
14 City beer, do you recall?
15 A. Yes, I believe so, yeah.
13:19 16 Q. All right. Do you have any knowledge as to
17 whether the website, beer website, was accessible to you
18 subsequent to you filing the lawsuit?
19 A. I don't know.
20 Q. At any time subsequent to your filing the
21 lawsuit?
22 A. I don't know.
13:20 23 Q. Do you recall suing a company called Crysp
24 Denim Corporation?
25 A. Yes, I believe so.
74
1 Q. What do they sell?
2 A. I believe jeans.
3 Q. Good guess. That's like asking: Who's buried
13:20 4 in Grant's Tomb; right?
5 A. Exactly.
6 Q. All right. You're a bright man. So did you
7 ever -- strike that. Have you ever bought a pair of
8 jeans or any item from Crysp Denim?
9 A. Sorry, have I bought beer from them?
10 Q. No, no, no, no. Have you bought any item from
13:20 11 a company called Crysp Denim?
12 A. No, I haven't.
13 Q. Do you know if the website was accessible to
14 you at any time after you filed a lawsuit?
13:21 15 A. I don't know.
16 Q. Now you sued a company called Bracketron. Do
17 you know what they make?
18 A. I don't remember.
19 Q. That's bracket -- that's the word bracket with
20 R-O-N at the end. Do you have any recollection?
21 A. No, I don't remember.
13:22 22 Q. So I'm going to assume you have not purchased
23 any products from the company. Correct?
24 MS. KNOWLES: Objection. He testified he didn't
25 remember it.
1 MR. SAHELIAN: Well, he might have bought something
13:22 2 and still not remembered it.
3 Q. So have you bought any products from a company
4 called Bracketron?
5 A. I don't know.
6 Q. All right. I will submit to you they make
13:22 7 cell phone holders and other items for the car, such as a
8 computer stand for mounting on your dashboard and so on.
9 Do you have any recollection of visiting their website?
10 A. Lately or --
11 Q. At any time.
13:23 12 A. Yes. Believe so.
13 Q. All right. Do you have a recollection of
14 having sued them?
15 A. Yes, I believe so.
16 Q. All right. Was the site accessible to you at
13:23 17 any time after you filed the lawsuit?
18 A. I don't remember.
19 Q. Would you happen to have that written down
20 anywhere?
21 ** MS. KNOWLES: Objection, calls for attorney-client
22 privileged information. I'm sorry, I direct the witness
23 not to answer.
13:24 24 Q. BY MR. SAHELIAN: Would you happen to have
25 noted that fact down anywhere prior to informing your
1 attorneys?
13:25 2 A. No.
3 Q. All right. Does the company Savory Spice
4 remind you of a lawsuit?
5 A. Yes, I believe so.
13:25 6 Q. Do you recall suing the company?
7 A. Yes, I believe so.
8 Q. Was the site made accessible to you at any
9 time after you filed a lawsuit?
10 A. I don't know.
11 Q. Have you purchased any products from the
13:25 12 company at any time?
13 A. I don't know.
14 Q. Would you be able to find out if you looked at
15 your credit card records?
16 A. Probably.
13:26 17 Q. Does the company Cambria, Cambria Company?
18 MS. KNOWLES: Is there a question?
19 Q. BY MR. SAHELIAN: Does the -- does that --?
20 Is that a company that you sued?
21 A. Yes, I believe so.
22 Q. Do you know what they sell?
23 A. I don't remember.
13:27 24 Q. If I were to represent to you that they sell
25 kitchen counters, would that refresh your memory?
1 A. No.
13:27 2 Q. Is the website, their website accessible to
3 you currently?
4 MS. KNOWLES: Objection, calls for speculation.
5 THE WITNESS: I don't know.
6 Q. BY MR. SAHELIAN: Have you checked their
13:27 7 website subsequent to filing a lawsuit to see if it is
8 accessible to you?
9 A. I don't know.
13:28 10 Q. What is Saturdays Surf?
11 A. I don't remember.
12 Q. Do you remember any company that you've sued
13 with a name Saturdays?
14 A. Yes, I believe so.
15 Q. All right. Do you have any recollection of
13:28 16 what they sell?
17 A. No, I don't.
18 Q. All right. Is their website accessible
19 currently?
20 MS. KNOWLES: Objection, calls for speculation.
21 THE WITNESS: I don't know.
22 Q. BY MR. SAHELIAN: Was their website accessible
13:29 23 at any time after you filed suit?
24 A. I don't know.
25 Q. Did you ever sue a company called Paul Stuart?
1 A. Yes, I believe so.
2 Q. What do they sell?
3 A. I don't remember.
13:30 4 Q. Have you verified that their lawsuit --?
5 Strike that.
6 Have you verified that their website has been
7 made accessible to you subsequent to your lawsuit?
8 A. I don't know.
13:30 9 Q. Have you purchased any products from them at
10 any time?
13:30 11 A. I don't remember.
12 Q. One moment. I'm adjusting my chair. All
13:31 13 right. Does the company name Sidney Garber refresh your
14 memory relative to a lawsuit?
15 MS. KNOWLES: Objection, vague.
16 Q. BY MR. SAHELIAN: All right. I'll be direct.
17 Did you sue a company called Sidney Garber, S-I-D-N-E-Y,
13:31 18 G-A-R-B-E-R?
19 A. Yes, I believe so.
20 Q. What do they sell?
21 A. I don't remember.
22 Q. Have you verified that their website has been
23 made accessible to you subsequent to filing your lawsuit?
13:32 24 A. I don't know.
25 Q. Does the company Red Wing Shoes trigger your
13:32 1 memory as to lawsuit?
2 A. Yes, I believe so.
3 Q. Have you bought anything at any time from Red
4 Wing Shoes?
5 A. I don't remember.
6 Q. Have you verified that their website has been
7 made accessible to you subsequent to filing your lawsuit?
8 A. I don't remember.
13:33 9 Q. Would there be a way of knowing that you
10 verified?
11 MS. KNOWLES: Objection, calls for confidential and
12 privileged attorney-client privileged communication.
13 To the extent you can answer it outside of our
14 communications, you can answer.
15 THE WITNESS: Okay. I don't know.
13:34 16 Q. BY MR. SAHELIAN: Do you know of a company
17 called Michael Stars?
18 A. Yes, I think so.
19 Q. What do they sell?
20 A. I don't remember.
13:34 21 Q. Did you sue them?
22 A. Yes.
23 Q. Have you verified that their website has been
24 made accessible to you subsequent to filing your lawsuit?
25 A. I don't know.
13:35 1 Q. Did you sue a company called Dooney,
2 D-O-O-N-E-Y?
3 A. Yes, I believe so.
4 Q. Do you know what they sell?
5 A. I don't remember.
6 Q. Okay. Have you verified that their website
13:35 7 has been made accessible to you subsequent to your filing
8 your lawsuit?
9 A. I don't know.
10 Q. Have you sued a company called Browning North
11 America?
12 A. Yes, I believe so.
13 Q. Do you know what they sell?
13:36 14 A. I don't remember.
15 Q. Have you verified that their website has been
16 made accessible to you subsequent to your filing your
17 lawsuit?
18 A. I don't know.
13:36 19 Q. Did you sue a company called Cuvee Coffee?
20 That's C-U-V double E, Coffee.
21 A. Yes, I believe so.
22 Q. Have you bought anything from the company at
23 any time?
24 A. I don't remember.
25 Q. Have you verified that their website has been
13:36 1 made accessible to you subsequent to filing your lawsuit?
2 A. I don't remember.
3 Q. Did you sue a company called Giancarlo
4 "Saloon"?
5 A. Yes, I believe so.
6 Q. What do they sell?
7 A. I don't remember.
13:37 8 Q. Have you bought anything from them?
9 A. I don't remember.
10 Q. At any time?
11 A. I don't remember.
12 Q. Have you verified that their website has been
13:37 13 made accessible to you subsequent to filing your lawsuit?
14 A. I don't know.
15 Q. Did you sue a company called Bonanza?
16 A. Yes, I believe so.
17 Q. What do they sell?
18 A. I don't remember.
13:38 19 Q. Have you bought anything from them at any
20 time?
21 A. I don't remember.
22 Q. Have you verified that their website has been
23 made accessible to you subsequent to filing your lawsuit?
24 A. I don't know.
13:38 25 Q. Did you sue a company called Ruby Tuesday?
1 A. Yes, I believe so.
2 Q. What do they sell?
3 A. I believe they are a restaurant.
4 Q. All right. Have you bought anything from them
5 at any time?
6 A. I don't remember.
7 Q. Have you verified that their website has been
8 made accessible to you subsequent to filing your lawsuit?
13:39 9 A. I don't know.
10 Q. Have you sued a company called BSH?
11 A. Yes, I believe so.
12 Q. Have you bought anything from them at any
13 time?
13:39 14 A. I don't remember.
15 Q. Have you verified that their website has been
16 made accessible to you subsequent to filing your lawsuit?
17 A. I don't know.
18 Q. Have you sued the company called Cufflinks?
19 A. Yes, I believe so.
13:40 20 Q. Do you know what they sell?
21 A. Cufflinks.
22 Q. That was a stroke of genius, Mr. Rendon. All
23 right. Have you bought anything from them at any time?
24 A. I don't remember.
13:40 25 Q. Have you verified that their website has been
1 made accessible to you subsequent to filing your lawsuit?
2 A. I don't know.
3 Q. All right. Have you sued a company called
4 B-O-T-K-I-E-R, and I don't know how it's pronounced?
5 A. (Laughter.) Yes, I believe so.
6 Q. All right. What do they sell?
7 A. I don't remember.
13:41 8 Q. Have you bought anything from them at any
9 time?
10 A. I don't remember.
11 Q. Have you verified that their website has been
12 made accessible to you subsequent to filing your lawsuit?
13 A. I don't know.
14 MS. KNOWLES: Ara, --
15 MR. SAHELIAN: Yes?
16 MS. KNOWLES: -- can I put you on hold for just one
17 second? If your plan is to go through all several
13:41 18 hundred, that's fine, it's your deposition, but I'd like
19 to get a revised estimate to our respective families if
20 that's -- I don't think we're going to do that in an hour
21 if that's your expectation.
22 THE REPORTER: You want this on the record?
23 MR. SAHELIAN: No, we can keep it on the record.
13:42 24 MS. KNOWLES: Either way.
25 MR. SAHELIAN: It's 1:42 currently. Correct?
84
1 MS. KNOWLES: Yes.
2 MR. SAHELIAN: Do you have a flight to catch,
3 Victoria?
4 MS. KNOWLES: No. But I have two small children,
5 and I live four hours from here so...
6 MR. SAHELIAN: I hear you. I hear you. Okay. Do
13:42 7 you have to pick them up?
8 MS. KNOWLES: It's absolutely your deposition. I
9 just would like to let his family know and my family
10 know.
11 MR. SAHELIAN: I get it. I raised a daughter so I
12 know what you're going through.
13 What would be --? How soon would you have to
14 leave to be able to pick them up and so on?
15 MS. KNOWLES: That time has come and gone.
13:43 16 MR. SAHELIAN: Okay. I get it. Are you having a,
17 by the way, drive on the 99?
18 MS. KNOWLES: Yes.
19 MR. SAHELIAN: I'm very sorry for you.
20 MS. KNOWLES: Yes.
21 MR. SAHELIAN: I hate the 99. All right. We'll try
22 to wrap this up in half an hour.
23 MS. KNOWLES: Okay. Do you mind taking a five-er so
24 I can just let those respective parties know that.
25 MR. SAHELIAN: By all means. Please do.
1 MS. KNOWLES: All right. Thank you. Let me just
13:43 2 send a quick text.
13:47 3 (Recess.)
13:48 4 Q. BY MR. SAHELIAN: Mr. Rendon, you mentioned
5 that you spend a lot of time with your daughter in
6 helping her with school and so on. How often do you go
13:48 7 on the Internet to try out various websites for
8 accessibility?
9 A. All the time.
10 Q. And --
11 A. Quite frequently.
12 Q. And how many times a month do you file
13:48 13 lawsuits?
14 A. I don't know.
15 Q. Do you file more than ten a month or 50?
16 A. Huh. I don't -- I don't know.
17 Q. A month, that is. How many roughly do you
13:49 18 file a month?
19 A. No, I don't know. Probably ten or more.
20 Q. Do you have any record anywhere? Other than
21 whatever your attorneys might have in their offices, do
13:49 22 you have any record in your possession that would show
23 that you actually go back and test these websites after
24 you file a lawsuit?
25 A. No. I don't have record.
1 Q. All right.
2 MS. KNOWLES: I'm sorry, Ara, you said outside of
13:50 3 communications with counsel. Right?
4 MR. SAHELIAN: Correct.
5 THE WITNESS: Oh, sorry.
6 MS. KNOWLES: Did you hear his answer?
7 MR. SAHELIAN: I did.
8 THE REPORTER: I didn't.
9 THE WITNESS: No, I don't have a record.
10 MR. SAHELIAN: All right. Counsel, we can stipulate
11 if you want that --. You know what? No, no, let's just
13:51 12 keep going.
13 Q. Mr. Rendon, did you sue a company called
14 Danner, D-A-N-N-E-R?
15 A. Yes, I believe so.
16 Q. What do they sell?
17 A. I think boots. I'm not --
18 Q. Well --
19 A. I'm not sure.
20 Q. You're right. You're right. Have you bought
21 anything from --
13:52 22 A. Woo-hoo.
23 Q. -- them at any time?
24 A. No, I don't remember.
25 Q. Have you verified that their website has been
1 made accessible to you subsequent to filing your lawsuit?
2 A. I don't remember.
3 Q. At any time subsequent to filing your lawsuit?
4 A. I don't remember.
13:52 5 Q. Did you sue a company called Discount Dance?
6 A. Yes, I believe so.
7 Q. What do they sell?
8 A. Maybe stuff for ballet?
9 Q. Correct. Have you bought anything from them
10 at any time?
11 A. I don't remember.
12 Q. Have you verified that their website has been
13:52 13 made accessible to you at any time subsequent to filing
14 your lawsuit?
15 A. I don't remember.
16 Q. You said you don't drink wine. What alcoholic
17 products do you drink?
18 MS. KNOWLES: Objection to the extent it misstates
19 testimony.
20 MR. SAHELIAN: You're right.
21 Q. You stated you don't drink beer. My
13:53 22 apologies. What other alcoholic drinks do you --? Or do
23 you drink any alcohol?
24 A. Occasionally.
25 Q. All right.
1 A. Yes. Not a past time for me.
2 Q. All right. When you do, what do you drink?
3 A. Whatever's there. (Laughter.)
4 Q. All right. Do you remember suing a company
13:54 5 called Montelena? Montelena --
6 A. Yeah, I believe so.
7 Q. -- Winery?
8 A. Yes, I believe so.
9 Q. All right. Have you bought anything from them
10 at any time?
11 A. I don't remember.
12 Q. Have you verified that their website has been
13 made accessible to you at any time subsequent to filing
14 your lawsuit?
15 A. I don't remember.
13:54 16 Q. Did you sue a company called Tracksmith?
17 A. Yes, I believe so.
18 Q. What do they sell?
19 A. Running equipment.
20 Q. Excellent. Have you bought anything from them
21 at any time?
22 A. I don't remember.
13:54 23 Q. Have you verified that their website has been
24 made accessible to you at any time subsequent to filing
25 your lawsuit?
1 A. I don't remember.
2 Q. All right. Did you sue a company called
3 Eventbrite?
4 A. Yes, I believe so.
5 Q. What do they sell?
13:55 6 A. Hum. I think they are an -- an event-planning
7 platform, I believe.
8 Q. All right. Have you bought anything from them
9 at any time?
10 A. I don't remember.
11 Q. Have you verified that their website has been
12 made accessible to you at any time subsequent to filing
13 your lawsuit?
14 A. I don't remember.
13:55 15 Q. Have you sued a company called Hint, H-I-N-T?
16 A. Yes, I believe so.
17 Q. What do they sell?
18 A. Booze. I don't remember, I'm sorry.
19 Q. All right. Have you bought anything from them
20 at any time?
21 A. I don't remember.
22 Q. Have you verified that their website has been
13:56 23 made accessible to you at any time subsequent to filing
24 your lawsuit?
25 A. I don't remember.
1 Q. Have you sued the company called Punch Bowl?
2 A. Yes, I believe so.
3 Q. What do they sell?
4 A. I don't remember.
5 Q. Have you bought anything from them at any
6 time?
7 A. I don't remember.
13:56 8 Q. Have you verified that their website has been
9 made accessible to you at any time subsequent to filing
10 your lawsuit?
11 A. I don't remember.
12 Q. All right. Have you sued a company called
13 Tuesday Morning?
14 A. Yes, I believe so.
15 Q. What do they sell?
16 A. I don't remember.
13:57 17 Q. Have you bought anything from them at any
18 time?
19 A. I don't remember.
20 Q. Have you verified that their website has been
21 made accessible to you at any time subsequent to filing
22 your lawsuit?
23 A. I don't remember.
24 Q. Okay. Have you sued a company called AbbVie?
13:57 25 That's A-B-B-V-I-E.
1 A. Yes, I believe so.
2 Q. What do they sell?
3 A. I don't remember.
4 Q. Have you bought anything from them at any
5 time?
6 A. I don't remember.
7 Q. Have you verified that their website has been
8 made accessible to you at any time subsequent to filing
9 your lawsuit?
10 A. I don't remember.
13:58 11 Q. All right. Have you sued a company called
12 Szerer -- I'll spell it -- S-z-e-r-e-r, Ventures.
13 A. I believe so.
14 Q. Do you know what they sell?
13:58 15 A. I don't remember.
16 Q. Have you bought anything from them at any
17 time?
18 A. I don't remember.
19 Q. Have you verified that their website has been
20 made accessible to you at any time subsequent to filing
21 your lawsuit?
22 A. I don't remember.
23 Q. All right. Have you sued a company called
13:59 24 Touch Dolls?
25 A. Yes, I believe so.
1 Q. I have to say, Mr. Rendon, you have exquisite
2 talent to find interesting websites. What do they sell?
3 A. I don't remember.
4 Q. All right. Have you bought anything from them
5 at any time?
6 A. I don't remember.
14:00 7 Q. Have you verified that their website has been
8 made accessible to you at any time subsequent to filing
9 your lawsuit?
10 A. I don't remember.
11 Q. All right. Have you sued a company called
12 Evelyn & Arthur?
13 A. Yes, I believe so.
14 Q. What do they sell?
14:00 15 A. I don't remember.
16 Q. Have you bought anything from them at any
17 time?
18 A. I don't remember.
19 Q. Have you verified that their website has been
20 made accessible to you at any time subsequent to filing
21 your lawsuit?
22 A. I don't remember.
14:01 23 Q. Have you sued a company called House of
24 Cheatham?
25 A. Yes, I believe so.
1 Q. That's C-H-E-A-T-H-A-M. All right?
2 A. Yes.
3 Q. Do you know what they sell?
4 A. I don't remember.
5 Q. Have you bought anything from them at any
6 time?
7 A. I don't remember.
14:01 8 Q. Have you verified that their website has been
9 made accessible to you at any time subsequent to filing
10 your lawsuit?
11 A. I don't remember.
12 Q. All right. Have you sued a company called
13 Felix Gray?
14 A. Yes, I believe so.
14:01 15 Q. Do you know what they sell?
16 A. I don't remember.
17 Q. Have you bought anything from them at any
18 time?
19 A. I don't remember.
20 Q. Have you verified that their website has been
21 made accessible to you at any time subsequent to filing
22 your lawsuit?
23 A. I don't remember.
14:02 24 Q. Have you sued a company called Harlequin?
25 A. Yes. I believe so.
94
1 Q. All right. What do they sell?
2 A. Books.
3 Q. Excellent. Have you bought anything from them
4 at any time?
5 A. I don't remember.
14:02 6 Q. Have you verified that their website has been
7 made accessible to you at any time subsequent to filing
8 your lawsuit?
9 A. I don't remember.
10 Q. All right. Have you sued a company called
11 Coulter Ventures with a website called Rogue Fitness dot
12 com?
13 A. Yes, I believe so.
14 Q. Have you bought anything from them at any
15 time?
14:03 16 A. I don't remember.
17 Q. Have you verified that their website has been
18 made accessible to you at any time subsequent to filing
19 your lawsuit?
20 A. I don't remember.
21 Q. All right. Have you sued a company called
22 Conde Nast Entertainment?
23 A. Yes, I believe so.
14:03 24 Q. What service do they provide or what goods do
25 they sell?
1 A. I don't remember.
2 Q. Okay. Have you bought anything from them at
3 any time?
4 A. I don't remember.
5 Q. Have you verified that their website has been
6 made accessible to you at any time subsequent to filing
7 your lawsuit?
8 A. I don't remember.
9 Q. All right. Have you sued a company called
14:04 10 Proper Cloth?
11 A. Yes, I believe so.
12 Q. All right. What do they sell?
13 A. Clothing.
14 Q. Excellent. Have you bought anything from them
15 at any time?
16 A. I don't remember.
17 Q. Have you verified that their website has been
18 made accessible to you at any time subsequent to filing
19 your lawsuit?
14:04 20 A. I don't remember.
21 Q. All right. Have you sued a company called
22 Everlast Worldwide, Inc.?
23 A. Yes, I believe so.
24 Q. What do they sell?
14:05 25 A. Gloves.
1 Q. Excellent.
2 A. Like boxing gloves.
3 Q. Excellent. Have you bought anything from them
4 at any time?
5 A. Yes.
6 Q. Okay. Great. What did you buy?
7 A. Muay Thai gloves.
8 Q. All right. Have you verified that their
14:05 9 website has been made accessible to you at any time
10 subsequent to filing your lawsuit?
11 A. I don't remember.
12 Q. All right. This one's a real tough one to
13 figure out. Have you sued a company called Jessup
14 Cellars?
15 A. Yes, I believe so.
16 Q. I'm going to give you a hint, Mr. Rendon.
14:06 17 Cellars is spelled C-E double-L-A-R-S. So with that
18 hint, what do they sell?
19 A. Wine.
20 Q. Awesome. Have you bought anything from them
21 at any time?
22 A. I don't remember.
23 Q. Have you verified that their website has been
24 made accessible to you at any time subsequent to filing
25 your lawsuit?
1 A. I don't remember.
