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e-Babylon

The most recent (2/04) information we have received related to locating Raymond Babakhanipour -- mentioned several times below under different or no addresses -- is the following:

Raymond Babakhanipour
8361 Cedros Avenue, Apt. 102
Panorama City, CA 91402


25 E Easy St
Simi Valley, CA 93065
805-581-0900

Run by Aidin Yousif and Michael Zaya. Full time in-house counsel is William Dunlap. Vijay Nath is the CTO.

Aliases:

  • E-Babylon
  • Inkjets2toner.com
  • proinkjets.com
  • 123inkjets.com
  • 911inkjets.com
  • 00inkjets.com
  • 4yourprinter.com
  • 111inkjets.com
  • 007inkjets.com
  • 411inkjets.com
  • freecartridges.com
  • 123lasertoner.com
  • 123cartridges.com
  • inkjetorder.com

They are a big fax.com customer that sells inkjet refills. Cited by the FTC for misrepresentation and agreed to pay a $40,000 fine

When I confronted them with my suit against Inkjets2toner.com, they claimed they were only the fulfillment house, they did no marketing (they claimed was all done by SOHO Marketing who owns the website Inkjets2toner.com). They said they never owned the website. They sent me an About page from an old Inkjets2toner website saying it was brought to you by SOHO Marketing, and included the registration of SOHO Marketing (filed 5/22/02 in California), and the whois record showing Raymond Babakhanipour (who is a friend of Mike Zaya and appears to have vanished) in Simi Valley with the exact same zip code as eBabylon!! Gee, what a coincidence!

We all know that SOHO Marketing is a fax.com company. They don't sell anything but fax services, hence their name. And inkjets2toner.com was registered before SOHO Marketing existed using the same registrar as used Aidin's other companies.

Here's how the registration reads today:

Registrant:
INKJET2TONER #251

690-A La Ave
Simi Valley, California 93065
United States

Registered through: GoDaddy.com
Domain Name: INKJETS2TONER.COM
Created on: 17-Apr-02
Expires on: 17-Apr-04
Last Updated on: 02-Sep-03

Administrative Contact:
Babakhanipour, Raymond ashurisgod@yahoo.com
INKJET2TONER #251
690-A LA Ave
Simi Valley, California 93065
United States
(866) 259-5184
Technical Contact:
Babakhanipour, Raymond ashurisgod@yahoo.com
INKJET2TONER #251
690-A LA Ave
Simi Valley, California 93065
United States
(866) 259-5184

Domain servers in listed order:
NS1.SECURE.NET
NS2.SECURE.NET

There is a reason they paid $40,000 to the FTC to settle. They are scam artists and they lie (frequently).

The facts are this:

  • They modified their domain registration on Nov 19, 2002, and then again on Sep 2, 2003 to list Raymond, who works with Mike, but using different Simi Valley address. However, the zip code is exactly the same as the eBabylon zip (whoops!).
  • Unfortunately for them, you can't erase history. What they didn't realize is that two different people looked up their registration record and posted it to the net before they changed it. Want to know what the original registration said? You can probably guess the answer.... Inkjets2toner.com was originally registered to eBabylon by Aidin Yousif himself (see below for the entry). Here's a second posting but this one is for 123inkjets.com.

All of this leads us to ask a whole bunch of interesting questions:

  • If SOHO Marketing owns the website, then why isn't SOHO Marketing listed on the current contact record?
  • Isn't it a bit odd that the zip code (and the registrar they used) on the current owner matches eBabylon and not anything in the SOHO Marketing registration?
  • If eBabylon never owned the website, then how do we explain the fact that the original registration record (April 17, 2002) lists eBabylon and Yousif as the owner? This is documented in a usenet post (above).
  • If eBabylon never owned the website, then how do we explain the fact that the FAQ, when it was launched on May 30, 2002, is virtually identical to the FAQ of 123inkjets? (see http://web.archive.org for this and the statements below).
  • If eBabylon never did any of the marketing for inkjets, how is it that the company tagline "Quality and service since 1998" is identical for 123inkjets.com and inkjet2toner.com?
  • How is it that inkjets2toner.com, which appeared just one month after the domain name was created could be, according to their "Aboutus" page, "the leading online retailer of quality ..." and that they ship "over 80,000 orders per month". That seems very fast growth. Not to mention that they are lying since they just started.
  • Is it just coincidence that 123inkjets.com and inkjets2toner.com are both the leading retailer, that they both have the same tagline, and exactly the same number of number of satisfied customers every month???
  • Since SOHO Marketing didn't exist until May 22, 2002, how is it that inkjets2toner could advertise the "since 1998" date? 
  • if SOHO Marketing owns the site, then how come they registered the site 4 months before they registered their own SOHO Marketing website? And why did SOHO have Raymond, who is a friend of Mike, register it. That seems really odd, doesn't it?
  • Both 123inkjets.com and Inkjets2toner.com were registered using godaddy. But the SOHO Marketing site was registered using register.com. Why? Could it be that they aren't connected?
  • How do we explain the fact that the SOHO Marketing website never made (and still does not make) any mention of their main inkjet business?
  • How is it possible that SOHO Marketing, which was created on May 22, 2002 could achieve being the market leader with 80,000 ink jet orders per month just 7 days later when the inkjets2toner.com site was launched? That seems pretty impossible to have a month of data when the site has only been in existence for 1 week!
  • How did Yousif know to register the domain name for SOHO before they existed? And why did they change the registration to Ray (who is a friend of Mike) if they didn't have anything to hide?
  • Why has their attorney been sending out letter to everyone saying it is SOHO that does the marketing and they are just the fulfillment house when he knows that is obviously not the case?
  • Why can they not produce the contract that they allege that SOHO used to engage them if that was really the case?
  • How can the attorney believe, in his letter denying they own the website, that SOHO owns the website when the domain registration provided in the letter from the attorney lists Raymond who is Mike's friend (confirmed by both SOHO people and Yousif's new CTO)?
  • How come there is absolutely nothing in common with the domain registration for SOHO and inkjets2toner.com if they are the same company, yet there is everything in common with Yousif's other companies and inkjets2toner.com?
  • How come their attorney couldn't address any of these questions when I talked to him on the phone?
  • Why should we believe you are telling the truth now?

You get the drift... Yousif has a very distinct naming pattern for his sites. When faced with the junk fax suits, he changed the domain registrations and starts claiming he's just the fulfillment house. Sure, you can really put your trust a guy who paid $40,000 to the FTC to settle a fraud charge and where every data point you look at shows he's still lying.

Here's a copy of the original whois record for inkjets2toner. This is the one they don't give you! Note the title: Junk fax sighting. So they were sending out faxes using the original domain name registration. Then they decided to register in Baba's name so that they could claim they had nothing to do with it.

JUNK FAX SIGHTING
Date/Time Received: 06/03/02 09:06:46
Subject: Inkjet & Toner Bargain Blowout
Sales Name/Number: 800-440-7411/www.inkjets2toner.com
Remove Number: 800-457-5410
Notes:

Contact Info on website ...
Phone Number: (805) 306 - 1560
Fax Number: (805) 583 - 3001
Inkjets2toner.com Attn: RMA Dept - RMA# _______
25 E. Easy St.
Simi Valley, CA 93065

Whois ...
whois -h magic www.inkjets2toner.com

Registrant:
Aidin Yousif
E-Babylon, Inc.
25 East Easy St
Simi Valley, California 93065
United States

Registrar: Go Daddy Software (http://registrar.godaddy.com)
Domain Name: INKJETS2TONER.COM
Created on: 17-Apr-02
Expires on: 17-Apr-04
Last Updated on: 17-Apr-02

Administrative Contact:
Yousif, Aidin aidin@inkjetorder.com
E-Babylon, Inc.
25 East Easy St
Simi Valley, California 93065
United States
805-581-0900 x 1002 Fax -- 805-582-2307
Technical Contact:
Yousif, Aidin aidin@inkjetorder.com
E-Babylon, Inc.
25 East Easy St
Simi Valley, California 93065
United States
805-581-0900 x 1002 Fax -- 805-582-2307

Domain servers in listed order:
NS.RACKSPACE.COM
NS2.RACKSPACE.COM

By contrast, here's the registration for SOHO Marketing:

Organization:
SOHO Marketing, LLC
Nelson Frappier
13681 Newport Ave., Suite B, #276
Tustin, CA 92780
US
Phone: 111-000-0000
Email: californiamasterbaiter@attbi.com

Registrar Name....: Register.com
Registrar Whois...: whois.register.com
Registrar Homepage: http://www.register.com

Domain Name: SOHOLEADS.COM

Created on..............: Mon, Sep 16, 2002
Expires on..............: Thu, Sep 16, 2004
Record last updated on..: Thu, Nov 06, 2003

Administrative Contact:
SOHO Marketing, LLC
Nelson Frappier
13681 Newport Ave., Suite B, #276
Tustin, CA 92780
US
Phone: 111-000-0000
Email: californiamasterbaiter@attbi.com

Technical Contact, Zone Contact:
Register.Com
Domain Registrar
575 8th Avenue - 11th Floor
New York, NY 10018
US
Phone: 902-749-2701
Fax..: 902-749-5429
Email: domain-registrar@register.com

Domain servers in listed order:

NS1.SOHOLEADS.COM 209.67.50.203

Register your domain name at http://www.register.com

Here's a letter I sent William Dunlap since he never returned any of my telephone calls.

Dear Mr. Dunlap,

I am in receipt of your letter of Oct 28, 2003 in which you imply that Inkjets2toner.com is a site owned an operated by SOHO Marketing and that e-Babylon is merely a fulfillment house for SOHO. In that letter, you provided a copy of the inkjets2toner.com domain registration that, contrary to your assertion, has no connection to SOHO Marketing whatsoever, yet bears the exact same zip code as E-Babylon! In addition, the phone number on the domain registration belongs to a "Dr. Wiggins" who is a gynecologist. I hardly consider this "evidence" that you have provided to me to be convincing.

At the present time, as a result of the tone in your letter to me, and your company's history of fraud, spam, and dishonesty, I have now decided to ask the court for $1,500 per fax for each of the 10 faxes I received; a total of $15,000, rather than the $5,000 I had originally sought. Unfortunately, I will have to do this one fax at a time, as provided under the law. So instead of one trip up here to defend your client, you will be required to make 10 trips. 

However, I am willing to consider dropping my 10 suits against your firm if you will provide me with a signed and notarized affidavit, under penalty of perjury, from the following individuals, that inkjets2toner.com was, and always was, owned, created by, and operated by SOHO Marketing and that Aidin Yousif has never registered the domain for inkjets2toner.com nor marketed in any way for inkjets2toner.com:

Aidin Yousif
Michael Zaya
William Dunlap
Raymond Babakhanipour

If Mr. Babakhanipour cannot be located, then a sworn and notarized affadivit from an officer of SOHO Marketing would suffice listing the dates of Mr. Babakhanipour's employment with SOHO Marketing and an explanation as to why, since SOHO Marketing is located in Tustin, that they provided a Simi Valley address on the domain registration. The affidavit would also have to include a reasonable explanation for the fact that Mr. Babakhanipour is not currently an employee of SOHO, nor have any of the employees there that we know of ever heard of Mr. Babakhanipour. It should also include a credible explanation as to how Mr. Babakhanipour and SOHO Marketing could have registered the inkjets2toner.com one month before SOHO even existed and why it was registered with a Simi Valley address.

In addition, Mr. Dunlap, you would need to supply me with a copy of the contract that SOHO Marketing signed with your firm to provide fulfillment services for SOHO Marketing for SOHO's inkjet sales, and your personal affadivit, sworn and notarized, that this agreement is the original and complete agreement between the firms, and that there are no other agreements (such as insertion orders) that exist between SOHO Marketing (or any other fax broadcasting firm associated with Kevin Katz or fax.com) and any of the inkjet sales firms associated with Mr. Yousif and Mr. Zaya.

As you know, the penalty for perjury in California is a term of not more than 4 years in jail. I trust that you will remind each of the individuals of this before they sign their affidavits.

I eagerly await your response.

=============

I received the following email from Vijay (their CTO). All the staff at eBabylon know Raymond:

From: Vijay Nath [mailto:new2_ny2@yahoo.com]
Sent: Saturday, November 08, 2003 9:02 AM
Subject: Re: are you still CTO at eBabylon?

Steve:

Yes, I am still CTO at Ebabylon .. Mike is still the Owner and my
boss ... I know ray well to but baba has left ebabylon ...

Is there anything else you would like to share?

Regards,

Vijay

--- Steve Kirsch <steve.kirsch@propel.com> wrote:
> do you know Mike Zaya and Raymond Babakhanipour?

=====================

Raymond and Mike also had some kind of business selling framed pictures. As far as SOHO, I think SOHO was just an affiliate for the inkjet folks...so fax.com faxed, had Soho, the call center take the calls and orders and Kevin and Frank Frappier kept the profits...at least that is how I think it worked. As you know, SOHO eventually became Lighthouse Marketing. The website for SOHO is soholeads.com and it is registered to:

SOHO Marketing, LLC
Nelson Frappier
13681 Newport Ave., Suite B, #276
Tustin, CA 92780 US Phone: 111-000-0000
Email: californiamasterbaiter@attbi.com

Kevin has treated Nelson like shit. It is his son Frank who is the top salesman for fax.com.
Here is his real address:
18091 Norwood park pl. Tustin 92780
(714)-730-9154 - Home

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