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    UNITED STATES OF AMERICA
    FOR THE DISTRICT OF DIGITAL JUSTICE
    CLIENT ACQUISITION DIVISION

    UNITED STATES OF AMERICA,

    STATUS QUO WEBSITE PROVIDERS,

    Plaintiffs,

    v.

    BOSSEO LAW FIRM MARKETING COMPANY

    Defendant,

    Midl

    Case No. 2025-259964-SEO

    MOTION TO DISMISS UNDERPERFORMING WEBSITES WITH PREJUDICE

    Defendant Bosseo Law Firm Marketing Company, by and through its undersigned counsel, hereby moves this Court to dismiss all underperforming law firm websites with prejudice.

    In support thereof, Defendant states as follows:

    1. Failure to Perform. Plaintiffs’ websites have repeatedly failed to generate meaningful traffic, leads, or measurable results, in direct violation of the standards established in Search v. Rankings, 410 U.S. 404 (2025).

    2. Outdated Practices. Evidence will show that Plaintiffs continue to rely on stale, template-driven designs and insufficient content, contrary to the controlling precedent of Clients v. Competition, 512 F.2d 117 (2024), which holds that law firms are entitled to digital strategies commensurate with modern demand.

    3. Prejudice to Law Firms. Continued reliance on underperforming websites unfairly prejudices law firms by denying them access to qualified leads, broader visibility, and sustainable growth.

    Accordingly, under the principles of marketing justice and digital due process, this Court must dismiss underperforming websites with prejudice and enter judgment in favor of Bosseo Law Firm Marketing Company.

    WHEREFORE, Defendant respectfully requests that this Motion be granted, that all claims of Plaintiffs be dismissed with prejudice, and that the Court admit into evidence Exhibits A through C demonstrating the superior performance of Defendant’s websites.

    In support of this Motion, Defendant submits the following Exhibits, each providing clear evidence of Bosseo Law Firm Marketing Company’s superior performance and results.

    Exhibita
    Ex1
    Ehibitb
    Ex2
    Exhibitc
    Ex3
    Exhibitd
    Ex4
    Exhibite
    Ex5

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