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Dear AdSense Appeal Employee, First, thank you for taking the time to review this email and

considering Hatchling, Inc.s (the "Company") second appeal. Since the rejection of the Company's first appeal, we have conducted a more thorough review of our records to ensure that we were in compliance with the AdSense Online Standard Terms and Conditions ("TOS") and to provide what evidence we could of our compliance. We remain at a loss as to why the Company's account was disabled and are eager to provide whatever assistance we can to help get to the bottom of this matter. The Company remains interested in working with Google, and hopes to be able to resolve this matter in the near future. Please let us know if you have any questions about the information contained in this second appeal, or if there is any additional information that we could provide that would help you come to a decision. We believe that the Company and Google both benefited from the AdSense relationship and genuinely desire to fix any problems that are preventing us from working together. This appeal relates to an email the Company received from the Google AdSense Team dated April 18, 2011. The email stated that [a]fter reviewing our records, weve determined that your AdSense account poses a risk of generating invalid activity and informed the Company that its account had been disabled. The Company filed an appeal on that same day using the information that was readily available. That appeal was rejected shortly thereafter. This second appeal is meant to provide significantly more information about our practices and evidence of our compliance that we have been able to collect since the first appeal. As instructed by the AdSense Help file related to disabled accounts and appeals, we have now double- and triple- checked our implementation of AdSense on Hatchlings.com to ensure that we were not generating any invalid clicks through our negligence or otherwise. From this review, we have not discovered any invalid click activity or any other violation of the TOS. Below are the results of our investigation for each requirement contained in the TOS. We are covering all of the bases because we are unsure what particular area caused our account to be disabled. 1. Our Privacy Policy Informs Customers About Our Cookie Policy. As required by the last two sentences of Section 1 of the TOS, our privacy policy informs customers about our use of cookies, and the customers options related to those cookies. In particular, our privacy policy provides: Third Party Advertising We use third-party advertising companies, such as Google, to serve ads when you visit our website. These companies may use information (not including your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please see http://www.google.com/privacy_ads.html. With particular regard to Google and the DoubleClick DART cookie: please be advised that Google, as a third party vendor, uses cookies to serve ads associated with the Application;

Google's use of the DART cookie enables it to serve ads to your users based on their visit to your sites and other sites on the Internet and; Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy. 2. We Did Not Place Any Non-Google Ads on Our Pages that Users Would Reasonably Confuse With a Google Advertisement. Section 2, Subsection 5 of the TOS provides that the Company may not place ads that a user would reasonably confuse with a Google advertisement. The Company uses Googles Doubleclick for Publishers (DFP) ad manager to manage the ad inventory on its sites, including Hatchlings.com. DFP manages AdSense, a couple of other advertising companies, and the Companys own internal ads. All ads served by DFP were approved by DFP, and to the Companys knowledge there was nothing on the Companys sites that would have led a user to believe that a non-Google advertisement was a Google advertisement Numerous screenshots of the Hatchlings.com site are attached, showing the placement of ads as of the day the account was disabled. 3. The Company Has Not Disclosed Any Non-Public Beta Features. To our knowledge, we have not made any disclosures that violate the provisions of Section 2, Subsection 5 of the TOS related to beta features. The Company did not utilize any AdSense beta features and therefore could not violate this requirement. 4. To Our Knowledge, the Company Has Not Engaged in Any Prohibited Uses. Section 5 of the TOS provides a list of actions that constitute prohibited uses. Each is considered and examined in turn below, and are numbered in the same manner as in the TOS. The Company does not know of any prohibited uses and has not authorized or encouraged any third party to engage in any prohibited uses. (i) The Company has not utilized any automated, deceptive, or fraudulent practice to generate ad clicks on its site, or repeatedly manually clicked on any ads. Attached is our Google Analytics report for Hatchlings.com for the period including April 18, 2011. The activity does not appear to be unusually high, and we are unable to detect any activity that would violate this requirement. We do not see anything that indicates any inappropriate activity was occurring. However, without more guidance regarding what activity was flagged by the system we are unable to provide more detailed or relevant information, or address any particular concerns. Section 11 of the TOS appears to flesh out in more detail what constitutes an invalid click. We have questioned our employees and have no knowledge of any invalid clicks generated by the Company. We have not solicited clicks or other invalid activities from our users, or otherwise engaged in any similar practices that would violate the TOS. Besides analytics reports, we are unsure what evidence we could provide, or what specific claims that we need to disprove. (ii) The Company did not modify, edit, or otherwise change the order of information contained in any ad, or otherwise remove, obscure, or minimize any ads. Attached is a screenshot of Hatchlings.com as of April 18, 2011. We do not see any ads that violate this section. We use Googles standard code to serve the ads, and do not believe that we have made any modifications to that code. In addition, we have worked extensively with the AdSense

Account Managers assigned to our account over the last few years to maximize the click-through rate on our site. We believe we have had a good working relationship with the AdSense team, utilizing many of the changes they suggested to maximize the performance of our AdSense ads. (iii) The Company did not frame, minimize, or otherwise inhibit the full display of a webpage accessed by clicking on an ad on our page. (iv) The Company did not redirect any ads or search results away from the advertiser or search results page. The Company also did not place any intermediary content between the ad link and the resulting page. (v) The Company does not host or display any pornographic, hate-related, violent, or illegal content. To the Companys knowledge, no users have uploaded such content or otherwise used Hatchlings.com for such purposes. (vi) All ads served through the Companys AdSense account were located on the Companys sites and properties, and only in accordance with the TOS as discussed elsewhere in this appeal. (vii) The Company does not crawl, spider, or index information obtained from the ads, or any other information derived therefrom. (viii) The Company has reviewed the Program Policies on the Google website and believes that it is in compliance with such policies. However, given the large number of policies and the non-specific reference in this section, it is possible that we have missed something. Without more information about the asserted potential violation, we are unable to say with more certainty that we are in compliance with each and every policy. To the extent there is a violation, such violation is inadvertent and would be immediately remedied if given the opportunity. (ix) The Company does not distribute worms, viruses, Trojans, or other malware through its site. All cookies are delivered in compliance with our privacy policy and the TOS. (x) The Company has not created a new AdSense account since we were informed that our account was disabled. (xi) The Company prides itself on the high quality of its software products and attempts to provide a high quality gaming experience for our customers. We know of no action or practice that would reflect poorly upon Google, and we have not taken any action to disparage Google or otherwise tarnish Googles reputation. In addition to the above, we have not engaged or encouraged any third parties to violate the above terms on our behalf, or otherwise attempted to accomplish any prohibited action. 5. The Company Has Not Violated Its Confidentiality Obligations. To the Companys knowledge, neither it nor its employees have disclosed any of Googles confidential information or otherwise violated the terms of Section 7 of the TOS.

6. The Representations and Warranties of the Company Remain Accurate. To the knowledge of the Company, the representations and warranties contained in Section 13 of the TOS remain accurate. The Company does not know of any violation of the applicable law, the violation of any intellectual property rights of a third party, and complies with the CAN-SPAM Act of 2003. The Company has not received any notices or claims to the contrary from any third party or governmental entity. In sum, the Company has not been able to determine what activity led to the disabling of its AdSense account. All we know is that we never clicked our own ads and never encouraged any other people to click on the ads on our site. We have reviewed the TOS and the other policies provided by Google. From the language in the email notifying us of the disabled account, it indicated that there was a risk of invalid activity. As we have stated, we are more than willing to modify our practices to minimize any actual or perceived risk, but we cannot determine what actions are required without more guidance. We also cannot determine if the risk ever materialized because we cannot access our AdSense reports since the account has been disabled. We understand Googles need to protect its advertisers and prevent people from gaming the system. In fact, the Company uses AdWords to generate traffic for its sites. However, we do not believe that our Company and its use of AdSense is what the TOS is meant to prohibit. If it is, we will need more guidance and access to more information related to our AdSense account if we are going to be able to sort this out or make any required changes. Please help us resolve this matter. We think everyone will benefit if we can get to the bottom of the issue. We believe we had an excellent relationship with our AdSense Account Managers, and wish to do so again in the future. We remain willing and able to provide any additional information that will help resolve this matter going forward. Thank you in advance for your consideration. Sincerely, Bradley Dwyer Hatchlings, Inc. www.hatchlings.com

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