Mr. Christopher Wray

Washington, DC


Attn: Tamara (Tien-Jan) Jih Murray

Google Litigation Counsel
Google, Inc.

15 Upper Lake Road

Woodside, CA 94062

David Drummond

Google Litigation Counsel

Google, Inc.

#2 Quail Road

Woodside, CA 94062

Board Of Directors
Google, Inc., Attn: Kent Walker
1600 Amphitheatre Parkway

Mountain View, CA 94043


Counsel Contacts For Plaintiffs




A CLASS of victims (TBD) , ) Court Case No.

a California Business, COMPANY 3, A California )

Business, INDIVIDUAL A, A California )








Google, Inc., YouTube Inc, Alphabet, Inc, Jared )
n, Micheal Painter, Ian Fette, Sergy Brin, )
Susan Wojcicki,
David Drummond, Andy Rubin, )

Larry Page, Eric Schmidt, And Associates )

California Corporation
s, and )

DOES 1 through 50, Inclusive ) Date:


Defendants ) Time:

) Dept.:


1. Plaintiffs are a “class” of technology employees, contractors and businesses located in The United States Of America and defined as a legal “CLASS” for court purposes. Plaintiffs have no specific political party affiliation and are, in fact, bi-partisan by volume. Plaintiffs have reported to the FBI in Washington, DC and In San Francisco, California at 450 Golden Gate Avenue, on the 13th Floor, in person, telephonic-ally and in writing and to the GAO in writing and telephonic-ally and to the White House and U.S. Congress members in person and in writing, among others, since 2006. This matter is under active federal and private investigation.

2. Defendants have offices nationwide and are, at least, known to have offices in California at numerous locations. Defendants attempted to harm, decimate, punish, damage, character assassinate and delay Plaintiffs civil rights as part of Defendants reprisal, retribution, intellectual property theft, anti-trust violating vendetta payback media information-manipulation program, in which Defendants sought to own and control government policy and business markets for personal financial and ideological insider goals.” Defendants engaged in actions legally qualifying asRICO Racketeering-violating criminal conspiracy actions in order to defraud the competitors, the public, government officials and others. Defendants are, according to top government officials: “The Command And Control” centers for anti-democracy, anti-trust and anti-competitive domestic operations using covert technology manipulations and a constant program of lies, deferrals and delays when questioned by government investigators about their illicit actions. Plaintiffs, and third parties, placed a global internet sensor array around the world an a large number of ISP’s, for years, which tested and verified that Defendants were manipulating the process of the internet, consciously and manually, in order to cause these harms, damages, attacks and anti-trust violating schemes and practices. It has been proven, by federal and private investigators, that Defendants organized, operated, financed, implemented and covered-up the “hit-jobs” and attacks that Plaintiff groups have charged them with the operation of. One Plaintiff ran a 6 year study comparing Defendants coverage of Defendants asset: Tesla Motors, Defendants partner and personal live-in friend: Elon Musk with Defendants coverage of all competitors to Musk during the time period and the results show goose-step synchronization to cover-ups, stock valuation hypes and competitor “negging”. From the same study, billions of dollars of non-reported FEC-violating campaign financing was uncovered. Defendants pay U.S. Senators to protect and assist them in these illicit actions. Payment forms include insider stock tips, stock assets, revolving door jobs, government contract rights and other quid-pro-quo including tax waivers and, as such, Defendants operate as an organized crime entity in violation of federal RICO and Anti-Trust laws. Defendants executives have been documented, in a huge number of news reports, divorce court records and law enforcement records, being involved in a huge number of sex trafficking scandals, tax evasion scandals, political bribery scandals and other incidents which demonstrate their poor ethical, moral and procedural natures and their inclinations towards criminality.

4. The true names and capacities of the Defendants, DOES 1 through 50, inclusive, are presently unknown to the Plaintiffs at this time and the Plaintiffs sue those Defendants and each of them, by such fictitious names pursuant to the pertinent provisions of the (TBD) Code of Civil Procedure. The facts and veracity of the charges and claims herein are duplicate-evidenced in multi-terrabyte hard drives and provided online cloud-based evidence repositories containing millions of pages of validating evidence compiled by Plaintiffs, FBI, GAO, SEC, EU, private, national journalists, Congressional, news industry, forensic specialist and leaked archive investigators.

5. Plaintiffs have had a multi-decade relationship with White House, Congressional, campaign finance, law enforcement and business parties discussed in this matter and had eye-witness knowledge of the crimes and misdeeds of Defendants and their associates and, as such, have received additional evidence from other eye-witness parties and have been provided with verified evidence notification of further validated evidence held by law enforcement agencies which confirm the veracity of Plaintiffs statements. White House and Congressional staff have certified the veracity of the evidence herein. Former employees of Defendants are prepared to testify to the veracity of the facts herein. Multiple other parties have sue and won, or settled, with Defendants for the same issue and Defendants have thus demonstrated a proven history of the charged illicit actions against Plaintiffs and verify the facts that Defendants conspire to harm United States businesses, United States citizens and the operation of the United States Government itself.

6. Plaintiffs were solicited to participate in Defendants crimes and schemes and refused to participate on the grounds that Defendants plans and schemes were illegal illicit and immoral. Because Plaintiffs refused to participate in Defendants crimes, assisted investigators with law enforcement actions and continued Plaintiffs business in competition to Defendants; Defendants took the further illicit actions described herein, against Plaintiffs.

7. The Plaintiffs are informed and believe and, based on that information and belief, allege that the named Defendants herein and each of the parties designated as a “DOE” and every one of them, are legally responsible jointly and severally for the Federal RICO Statute violating events and happenings referred to in the within Complaint for Intentional Interference with Contractual Relations, Intentional Interference with Prospective Economic Advantage, Cyberstalking, Fraud, Invasion of Privacy, Unfair Competition and Theft of Intellectual Property and RICO statute violations. In particular, Defendants took compensation for, and engaged in, malicious and coordinated tactics to seek to destroy, damage, harm and ruin Plaintiffs via an illicit media “hit-job” service which Defendants regularly offered in covert commerce and engaged in regularly against targets that Defendants were hired to seek to ruin as part of reprisal, vendetta, retribution programs operated for business and political competitors of the targets. Historical facts and other history-making lawsuits by third parties, has proven Defendants to be the single largest core violator of human rights, in this manner, in the world. Defendants offer the service of creating and publishing contrived “hatchet job” movies, fake news articles, faked comments and repercussion back-links describing the Plaintiffs in horrific descriptors. The attack material is re-posted, “impression accelerated”, “click-farm ” amplified by Defendants Chinese and Russian Click-Farms and Streisand array re-posted by Defendants massive character assassination technology via servers algorithms and technical internet manipulation daily as recently as yesterday.

This means that clock on the Statute Of Limitations is re-set every 24 hours because Defendants restart their attacks on the internet every 24 hours. The DOJ, SEC, FTC and FBI have been asked to aggressively assist in this matter.

Defendants also embed their in-house-created attack articles in job hiring databases on Axciom, Palantir, Taleo, USAJobs, Oracle and SAP driven HR systems and other databases used by all hiring and recruiting services in order to prevent Plaintiffs from ever receiving income for W2 or 1099 work ever again. Defendants own staff then post thousands of fake comments, below each attack item, under fake names, designed to make it appear as if a broad consensus of the public agreed with the defamation messages by Defendants. Almost all of the fake comments were created by a handful of Defendants own staff pretending to be a variety of outside voices. Defendants provide the service of delivering “weaponized text and media to corporate and political clients”. Defendants replicated various versions of these attack items across all of their different brands and facade front publications and added additional fake comments to each on a regular basis.

Defendants are widely documented in tens of thousands of reports in law enforcement investigations, regulatory investigations, journalistic news reports, university research and other credible documents as having engaged in the felony-level manipulation of elections and public media and did use those same manipulation technologies to attack Plaintiffs, a small set of hundreds of thousands of examples of such verification include:

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Understanding Google’s Computerized Manipulation Of 'the Streisand Effect'

- How a private-property dispute birthed a web phenomenon that became a Google attack technology that Google/Alphabet/YouTube use to destroy competitors and manipulate Democracy.

In 2003, a picture of Barbra Streisand’s beachfront home hit the web as part of a public collection of images displaying coastal erosion. In response, in February 2003, Streisand sued the photographer for $50 million for invasion of privacy, claiming violation of a state law aimed at the telephoto lenses of paparazzi.

Ironically, the media attention surrounding the lawsuit made the photo of her house go viral (at least in 2003 terms). In the month before the lawsuit, the picture had been downloaded only six times, including twice by her lawyers—whereas the image was downloaded more than 420,000 times during the month following the lawsuit. This paradoxical result—where an attempt to silence, suppress, or stop something backfires—was dubbed the Streisand effect.

Let’s take a closer look at the Streisand effect.

Examples of the Streisand Effect

Here are three different times the Streisand effect was apparently reified by real-world examples.

In 2012, a Scottish schoolgirl named Martha Payne started blogging about her school lunches and included pictures of the meals, which, as could be expected by anyone who has ever been to school, were unappetizing.

Soon, celebrity chef and food activist Jamie Oliver tweeted out his support, and the blog garnered three million hits in two months. Consequently, local government authorities banned Payne from taking photos of the lunches because (they claimed) cafeteria workers were worried about getting fired. Even though the authorities quickly reversed this decision, for them it was too late, and the British national media and the Internet ran with the story.

In 2013, Buzzfeed ran a list titled “The 33 Fiercest Moments From Beyoncé's Halftime Show.” Although the intention of the list was likely laudatory, some of the still photos were considered "unflattering."

Consequently, Queen Bey’s publicist contacted Buzzfeed to request that the unflattering photos, which were cited, be switched out. Buzzfeed responded with a follow-up piece titled “The 'Unflattering' Photos Beyoncé's Publicist Doesn't Want You To See,” which included an email from the publicist and the cited shots.

Subsequently, the Internet did its thing, and a meme was born. Countless “unflattering” shots of Beyoncé as a zombie, powerlifter, anime cartoon, and so forth popped up.

In 2014, cab drivers from across Europe went on strike to decry the lack of regulation of the ride-hailing app Uber. Without cabbies on the roads, riders turned to Uber, with downloads of the app increasing more than eight times in London alone.

Deconstructing the Streisand effect

In an article published in the International Journal of Education, Sue Curry Jansen and Brian Martin explained how the Streisand effect is a consequence of failed censorship attempts. These outrage-management processes include cover-up, defamation of the target, reframing events, false justice, and intimidation or rewards.

The authors also argued that censorship is a process that requires active maintenance to conceal the actions of powerful people. Furthermore, they wrote that a clearer understanding of outrage-management processes “stimulates awareness of tactics for challenging censorship by exposing its existence, validating the censored information, explaining the importance of free expression, not relying on official channels for solutions but instead mobilizing wider awareness and support, and resisting intimidation and rewards.”

By the way, you may be wondering how Babs's court case turned out. The chanteuse not only brought viral attention to her bluff-top estate by bringing the suit in the first place but the suit was dismissed in December 2003.

Google, YouTube and Facebook have commercialized "The Streisand Effect" by deploying computerized processes to steer the public towards, or away from, one product, candidate or point-of-view using manually programmed directions.

Former motor racing boss Max Mosley is suing Google for continuing to display photographs he says breach his privacy. But does pressing for information to be kept private, or suppressed, often have the opposite effect?

At first sight not much unites Beyonce and Max Mosley. But they, and several other celebrities and organisations, have become victims of the "Streisand effect".

In 2005, Mike Masnick, founder of the Techdirt website, coined the term. Two years earlier singer Barbra Streisand unsuccessfully sued photographer Kenneth Adelman, who was documenting the coastline of California, for including her clifftop home in Malibu. The resulting publicity helped drive 420,000 visits in a month to the site where the photo was published. According to documents filed in court, images of Streisand's house had been downloaded only six times before the legal action.

It's not always a fight over privacy. In February last year the Buzzfeed website published a selection of singer Beyonce's "fiercest moments" - mocking her facial expressions while performing at the Superbowl. Her publicist reportedly contacted it to ask that seven of the most "unflattering" photos be removed. Buzzfeed refused and republished exactly this selection with the headline: "The 'Unflattering' Photos Beyonce's Publicist Doesn't Want You To See". The exposure of the unflattering photos was magnified.

A few months later it was reported that lawyers for Pippa Middleton, sister of the Duchess of Cambridge, had asked for the removal of a parody Twitter feed, which offered ridiculously obvious lifestyle advice in her name, such as "Avoid getting lost by consulting with a map" and "A party isn't much fun without people attending". Its following increased.

In 2008 the Church of Scientology reportedly tried to get a video featuring film star Tom Cruise talking about his faith, designed for viewing by its followers only, removed from websites after it was leaked. The publicity meant it became shared more widely.

In 2012, Argyll and Bute Council banned nine-year-old Martha Payne from taking pictures of her school meals and posting them, along with dismissive ratings out of 10, on a blog. Her family complained and this was overturned, amid much publicity. To date the blog has had more than 10 million hits and Martha has raised more than £130,000 for charity.

You don't need to be famous to suffer from the Streisand effect. Spaniard Mario Costeja Gonzalez fought a long legal battle for the right to be forgotten. He complained that a search of his name in Google brought up newspaper articles from 16 years ago about a sale of property to recover money he owed. He enjoyed a landmark victory to establish the right to be forgotten. But it is unlikely he will ever be forgotten. As of this moment, his name conjures up hundreds of thousands of Google search results.

The Streisand effect

But Max Mosley is arguably the greatest example. He is suing Google for continuing to display in search results images of him with prostitutes at a sex party, citing alleged breaches of the Data Protection Act and misuse of private information. Every time he makes a legal move in his crusade over privacy, there's a danger it becomes more likely people will seek out the very images he is complaining about.

The 74-year-old former president of Formula One's governing body FIA wants Google to block pictures first published in the now-defunct tabloid News of the World, which he successfully sued in 2008. "As the gateway to the internet Google makes enormous profits and has great influence, so I have not taken this action lightly," he has said in a statement. His lawyers add that the company should not be allowed "to act as an arbiter of what is lawful and what is not". Google says it has been working with Mosley "to address his concerns".

But is there a risk that Mosley will cause himself more embarrassment by bringing a fairly old, and perhaps half-forgotten, news story back to people's attention? A survey of Twitter shows some users are posting the pictures that he is keen to remove.

"Anyone trying to get something banned is always going to be of more interest than something that people don't seem bothered by," says Jenny Afia, head of talent at the law firm Schillings. "It's a spark for curiosity."

In previous generations there's no doubt it was more straightforward to attempt to suppress information or images. The ease of sharing now almost means that nothing can really be suppressed.

You could argue that the internet makes attempts to guard your privacy risky on a scale proportional to the likelihood of your privacy being meaningfully breached in the first place. If there was a danger that lots of people would circulate a private photo of you doing something embarrassing, it's very likely that trying to suppress it will have the opposite effect. If there was little danger that the photo would have been circulated, an attempt at suppression might not trigger the Streisand effect.

There are endless mischief-makers who would dedicate themselves to propagating information that someone wanted hidden, just for the very fact of the attempt to hide it.

Mosley is a wealthy man used to publicity. Yet suing could mean a stressful, drawn-out court case, covered in detail by the media.

"It's a horrible dilemma for people who are faced with horrible or untrue stories," says Afia. "That's where Max Mosley is very brave to keep fighting. Many people decide to let it go."

For the likes of Mosley and Costeja Gonzalez, the principle surely supersedes the actual effect of legal action. They effectively end up fighting for the right of others to more easily safeguard their privacy. Even at the de facto cost of their own.

And there's a clear difference between those fighting for a right to privacy and those, like Beyonce's representatives, who are merely trying to manage a reputation or public image. There the Streisand effect is potent. If your reaction to mockery is to try and squash it, there will be lots more mockery.
Google internal corporate policy documents exposed which reveal its internal commitment to radical intersectional political and ideology control, according to a major report by NBC News.

The NBC report, an in-depth feature that drew on comments from current Google employees, which is highly biased against white males, as one of the reasons for the tech giant’s shift:

The right-wing news website Breitbart began covering the internal tensions about Google’s efforts to become more diverse, publishing a July 2018 article on a speaker event hosted by Google on the topic of how white people can better navigate conversations about racism and privilege in the workplace. Breitbart accused Google of breaking its internal policy against using blanket statements about categories of people, such as about employees in certain racial groups.

There was a meme going around that said white fragility shuts down discussions of white fragility,” a person involved with the event said in an interview, referring to a meme that circulated on an internal employee message board. The event wasn’t ultimately shut down, but additional security was provided.

Read the full report at NBC.

Radical intersectional ideology often characterized by the the use of demeaning language (“white fragility”) against white males, is typically introduced into corporations like Google under the banner of “diversity and inclusion,” whereby discrimination and hostility against certain groups is excused on the basis of creating an “inclusive” culture for women and minorities.

According to the NBC report, fear of further lawsuits similar to James Damore’s class-action case against the tech giant, which alleged that it discriminates on the basis of race and gender as well as political viewpoint, was another factor causing the company to scale back its internal “inclusion” efforts.

As Breitbart News reported in 2018, the Damore case revealed numerous instances of rampant anti-white, anti-male sentiments in Google’s workforce in the runup to Damore’s firing (Damore was fired after he circulated a memo calling for more viewpoint diversity at the company).

One comment made by a then manager-level employee, Liz Fong-Jones in 2015 released via the lawsuit reads “I could care less about being ‘unfair’ to white men. You already have all the advantages in the world.”

In another 2015 post released via the lawsuit, then manager-level employee Kim Burchett shared an article challenging people to “stop reading white, straight, cis male authors for one year.”

The lawsuit also revealed a document that was circulated to managers at the company, advising them that values like “objectivity,” “individual achievement,” and “perfectionism” were examples of “U.S. white male dominant culture.”

Melonie Parker, Google’s “Chief Diversity Officer,” denied that the company is scaling back its diversity efforts. In a comment to NBC, she said the company is “maturing our programs to make sure we’re building our capability.” Parker cited the company’s new “racial equity training” course, which was launched recently.

However, NBC cites a source at Google who says that one senior employee in the AI unit told her that “conversations about diversity could become a liability.”

Another Google employee’s statements to NBC indicate that some of Google’s changes were merely cosmetic, for example referring to diversity and inclusion by the acronym “D&I” instead of saying the word “diversity.” Clearly, Google will say or do anything to promote their cult-like indoctrinations.

Google's and Facebook's servers are built and programmed to manipulate the The Streisand Effect for commercial goals. Should Congress allow that? More evidence includes:








































Catch and Kill By Ronan Farrow, https://en.wikipedia.org/wiki/Catch_and_Kill:_Lies,_Spies,_and_a_Conspiracy_to_Protect_Predators

Permanent Record By Edward Snowden, https://www.amazon.com/Permanent-Record-Edward-Snowden/dp/1250237238

Brotopia By Emily Chang, http://brotopiabook.com/

Throw Them All Out By Peter Schweizer, http://peterschweizer.com/books/throw-them-all-out/

The Circle By David Eggers, https://archive.org/details/circle00dave

World Without Mind By Franklin Foer, https://www.amazon.com/World-Without-Mind-Existential-Threat/dp/1101981113

A Journey into the Savage Heart of Silicon Valley By Corey Pein, https://www.goodreads.com/book/show/35684687-live-work-work-work-die

Disrupted By Dan Lyons, https://www.goodreads.com/book/show/26030703-disrupted

Chaos Monkeys By Antonio García Martínez, https://www.antoniogarciamartinez.com/chaos-monkeys/

The Creepy Line By Matthew Taylor, https://www.thecreepyline.com/

The Cleantech Crash By Leslie Stahl, https://www.cbsnews.com/news/cleantech-crash-60-minutes/

Congress: Trading stock By Steve Kroft, https://www.cbsnews.com/news/congress-trading-stock-on-inside-information/

Validating the fact that Google/YouTube, Et Al use psychological Warfare Tools on the public and stock marketed

Distinguished research psychologist Robert Epstein explains one highly referenced study and reviews the validated evidence that Google's search suggestions are manually biased in favor of political candidates and stock market holdings that have crony kick-back deals to Google. He estimates that biased search suggestions might be able to shift as many as 3 million votes in any presidential election in the US or destroy a competitor, reporter that Google does not like or run the ultimate character assassination.

Biased search rankings can swing votes and alter opinions, and a new study shows that Google's autocomplete can too.

A scientific study I published last year showed that search rankings favoring one candidate can quickly convince undecided voters to vote for that candidate — as many as 80 percent of voters in some demographic groups. My latest research shows that a search engine could also shift votes and change opinions with another powerful tool: autocomplete.

Because of recent claims that Google has been deliberately tinkering with search suggestions to make Hillary Clinton look good, this is probably a good time both to examine those claims and to look at my new research. As you will see, there is some cause for concern here.

In June of this year, Sourcefed released a video claiming that Google's search suggestions — often called "autocomplete" suggestions — were biased in favor of Mrs. Clinton. The video quickly went viral: the full 7-minute version has now been viewed more than a million times on YouTube, and an abridged 3-minute version has been viewed more than 25 million times on Facebook.

The video's narrator, Matt Lieberman, showed screen print after screen print that appeared to demonstrate that searching for just about anything related to Mrs. Clinton generated positive suggestions only. This occurred even though Bing and Yahoo searches produced both positive and negative suggestions and even though Google Trends data showed that searches on Google that characterize Mrs. Clinton negatively are quite common — far more common in some cases than the search terms Google was suggesting. Lieberman also showed that autocomplete did offer negative suggestions for Bernie Sanders and Donald Trump.

"The intention is clear," said Lieberman. "Google is burying potential searches for terms that could have hurt Hillary Clinton in the primary elections over the past several months by manipulating recommendations on their site."

Google responded to the Sourcefed video in an email to the Washington Times, denying everything. According to the company's spokesperson, "Google Autocomplete does not favor any candidate or cause." The company explained away the apparently damning findings by saying that "Our Autocomplete algorithm will not show a predicted query that is offensive or disparaging when displayed in conjunction with a person's name."

Since then, my associates and I at the American Institute for Behavioral Research and Technology (AIBRT) — a nonprofit, nonpartisan organization based in the San Diego area — have been systematically investigating Lieberman's claims. What we have learned has generally supported those claims, but we have also learned something new — something quite disturbing — about the power of Google's search suggestions to alter what people search for.

Lieberman insisted that Google's search suggestions were biased, but he never explained why Google would introduce such bias. Our new research suggests why — and also why Google's lists of search suggestions are typically much shorter than the lists Bing and Yahoo show us.

Our investigation is ongoing, but here is what we have learned so far:

Can Google Tip the Scales on the US Presidential Election Without Anyone Knowing?

To test Lieberman's claim that Google's search suggestions are biased in Mrs. Clinton's favor, my associates and I have been looking at the suggestions Google shows us in response to hundreds of different election-related search terms. To minimize the possibility that those suggestions were customized for us as individuals (based on the massive personal profiles Google has assembled for virtually all Americans), we have conducted our searches through proxy servers — even through the Tor network — thus making it difficult for Google to identify us. We also cleared the fingerprints Google leaves on computers (cache and cookies) fairly obsessively.

Google says its search bar is programmed to avoid suggesting searches that portray people in a negative light. As far as we can tell, this claim is false.

Generally speaking, we are finding that Lieberman was right: It is somewhat difficult to get the Google search bar to suggest negative searches related to Mrs. Clinton or to make any Clinton-related suggestions when one types a negative search term. Bing and Yahoo, on the other hand, often show a number of negative suggestions in response to the same search terms. Bing and Yahoo seem to be showing us what people are actually searching for; Google is showing us something else — but what, and for what purpose?

As for Google Trends, as Lieberman reported, Google indeed withholds negative search terms for Mrs. Clinton even when such terms show high popularity in Trends. We have also found that Google often suggests positive search terms for Mrs. Clinton even when such terms are nearly invisible in Trends. The widely held belief, reinforced by Google's own documentation, that Google's search suggestions are based on "what other people are searching for" seems to be untrue in many instances.

Google's Explanation

Google tries to explain away such findings by saying its search bar is programmed to avoid suggesting searches that portray people in a negative light. As far as we can tell, this claim is false; Google suppresses negative suggestions selectively, not across the board. It is easy to get autocomplete to suggest negative searches related to prominent people, one of whom happens to be Mrs. Clinton's opponent.

A picture is often worth a thousand words, so let's look at a few examples that appear both to support Lieberman's perspective and refute Google's. After that, we'll examine some counterexamples.

Assange: Clinton's Campaign is Full of 'Disturbing' Anti-Russia 'Hysteria'

Before we start, I need to point out a problem: If you try to replicate the searches I will show you, you will likely get different results. I don't think that invalidates our work, but you will have to decide for yourself. Your results might be different because search activity changes over time, and that, in turn, affects search suggestions. There is also the "personalization problem." If you are like the vast majority of people, you freely allow Google to track you 24 hours a day. As a result, Google knows who you are when you are typing something in its search bar, and it sends you customized results.

For both of these reasons, you might doubt the validity of the conclusions I will draw in this essay. That is up to you. All I can say in my defense is that I have worked with eight other people in recent months to try to conduct a fair and balanced investigation, and, as I said, we have taken several precautions to try to get generic, non-customized search suggestions rather than the customized kind. Our investigation is also ongoing, and I encourage you to conduct your own, as well.

Let's start with a very simple search. The image below shows a search for "Hillary Clinton is " (notice the space after is) conducted on August 3rd on Bing, Yahoo, and Google. As you can see, both Bing and Yahoo displayed multiple negative suggestions such as "Hillary Clinton is a liar" and "Hillary Clinton is a criminal," but Google is showed only two suggestions, both of which were almost absurdly positive: "Hillary Clinton is winning" and "Hillary Clinton is awesome."

Hillary Clinton is ”

To find out what people actually searched for, let's turn to Google Trends — Google's tabulation of the popularity of search results. Below you will see a comparison between the popularity of searching for "Hillary Clinton is a liar" and the popularity of searching for "Hillary Clinton is awesome." This image was also generated on August 3rd. "Hillary Clinton is a liar" was by far the more popular search term; hardly anyone conducted a search using the phrase, "Hillary Clinton is awesome."

(Contact our office for screen shot, DNS report and server log print-outs)

Hillary Clinton is awesome.”

Okay, but Google admits that it censors negative search results; presumably, that is why we only saw positive results for Mrs. Clinton — even a result that virtually no one searched for. Does Google really suppress negative results? We have seen what happens with "Hillary Clinton is." What happens with "Donald Trump is "? (Again, be sure to include the space after is.)

(Contact our office for screen shot, DNS report and server log print-outs)

Donald Trump is “?

In the above image, captured on August 8th, we again found the odd "awesome" suggestion, but we also saw a suggestion that appears to be negative: "Donald Trump is dead." Shouldn't a result like that have been suppressed? Let's look further.

Consider the following searches, conducted on August 2nd, for "anti Hillary" and "anti Trump." As you can see below, "anti Hillary" generated no suggestions, but "anti Trump" generated four, including "anti Trump cartoon" and "anti Trump song." Well, you say, perhaps there were no anti-Hillary suggestions to be made. But Yahoo — responding merely to "anti Hill" — came up with eight, including "anti Hillary memes" and "anti Hillary jokes."

(Contact our office for screen shot, DNS report and server log print-outs)

anti Hillary” and “anti Trump.”

This seems to further refute Google's claim about not disparaging people, but let's dig deeper.

After Mrs. Clinton named Senator Tim Kaine to be her running mate, Mr. Trump dubbed him with one of his middle-school-style nicknames: "Corrupt Kaine." Sure enough, that instantly became a popular search term on Google, as this July 27th image from Trends confirms:

(Contact our office for screen shot, DNS report and server log print-outs)

Corrupt Kaine.”

Even so, as you can see in the image below, in response to "corrupt," the Google search bar showed us nothing about Senator Kaine, but it did show us both "Kamala" (Kamala Harris, attorney general of California) and "Karzai" (Hamid Karzai, former president of Afghanistan). If you clicked on the phrases "corrupt Kamala" and "corrupt Karzai," search results appeared that linked to highly negative web pages about Kamala Harris and Hamid Karzai, respectively.

Oddly enough, both on the day we looked up "corrupt Kaine" and more recently when I was writing this essay, Google Trends provided no popularity data for either "corrupt Kamala" or "corrupt Karzai." It is hard to imagine, in any case, that either search term has been popular in recent months. So why did the Google search bar disparage Attorney General Harris and President Karzai but not Mrs. Clinton?

(Contact our office for screen shot, DNS report and server log print-outs)

corrupt Kaine”, “corrupt Kamala”, “corrupt Karzai.”

If you still have doubts about whether Google suggests negative searches for prominent people, see how Senators Cruz, Rubio and Sanders fared in the following searches conducted between July 23rd and August 2nd:

(Contact our office for screen shot, DNS report and server log print-outs)

Searches conducted between July 23rd and August 2nd - Lying Ted

(Contact our office for screen shot, DNS report and server log print-outs)

Searches conducted between July 23rd and August 2nd - Little Marco

(Contact our office for screen shot, DNS report and server log print-outs)

Searches conducted between July 23rd and August 2nd - Anti-Bernie

I could give you more examples, but you get the idea.

The brazenness of Google's search suggestion tinkering become especially clear when we searched for "crooked" — Mr. Trump's unkind nickname for Mrs. Clinton — on Google, Bing, and Yahoo on various dates in June and July. On Google the word "crooked" alone generated nothing for Mrs. Clinton, even though, once again, its popularity was clear on Google Trends. Now compare (in the image following the Trends graph) what happened on Bing and Yahoo:

(Contact our office for screen shot, DNS report and server log print-outs)


(Contact our office for screen shot, DNS report and server log print-outs)


No surprise here. Consistent with Google's own search popularity data, Bing and Yahoo listed "crooked Hillary" near the top of their autocomplete suggestions.

The weird part came when we typed more letters into Google's search bar, trying to force it to suggest "crooked Hillary." On June 9th, I had to go all the way to "crooked H-I-L-L-A" to get a response, and it was not the response I was expecting. Instead of showing me "crooked Hillary," I was shown a phrase that I doubt anyone in the world has ever searched for — "crooked Hillary Bernie":

crooked H-I-L-L-A”

Crooked Hillary Bernie? What the heck does that mean? Not much, obviously, but this is something my associates and I have found repeatedly: When you are able to get Google to make negative suggestions for Mrs. Clinton, they sometimes make no sense and are almost certainly not indicative of what other people are searching for.

Masking and Misleading

There are also indications that autocomplete isn't always pro-Clinton and isn't always anti-Trump, and in this regard the Sourcefed video overstated its case. While it is true, for example, that "anti Hillary" generated no suggestions in our study, both "anti Clinton" and "anti Hillary Clinton" did produce negative results when we search on August 8th, as you can see below:

(Contact our office for screen shot, DNS report and server log print-outs)

anti Clinton”

(Contact our office for screen shot, DNS report and server log print-outs)

anti Hillary Clinton”

At times, we were also able to generate neutral or at least partially positive results for Donald Trump. Consider this image, for example, which shows a search for "Donald Trump" on August 8th:

(Contact our office for screen shot, DNS report and server log print-outs)

Search for “Donald Trump” on August 8th

If you believe Google can do no wrong and that it never favors one candidate over another (even though Google and its top executives donated more than $800,000 to Obama in 2012 and only $37,000 to Romney), so be it. But trying to be as objective as possible in recent months, my staff and I have concluded that when Google occasionally does give us unbiased election-related search suggestions, it might just be trying to confuse us. Let me explain.

When Ronald Robertson and I began conducting experiments on the power that biased search rankings have over voter preferences, we were immediately struck by the fact that few people could detect the bias in the search results we showed them, even when those results were extremely biased. We immediately wondered whether we could mask the bias in our results so that even fewer people could detect it. To our amazement, we found that a very simple mask — putting a search result that favored the opposing candidate into the third search position (out of 10 positions on the first page of search results) — was enough to fool all of our study participants into thinking they were seeing unbiased search results.

Masking a manipulation is easy, and Google is a master of obfuscation, as I explained a few years ago in my TIME essay, "Google's Dance." In the context of autocomplete, all you have to do to confuse people is introduce a few exceptions to the rule. So "anti Clinton" and "anti Hillary Clinton" produce negative search suggestions, while "anti Hillary" does not. Because those counter-examples exist, we immediately forget about the odd thing that's happening with "anti Hillary," and we also ignore the fact that "anti Donald" produces negative suggestions:

(Contact our office for screen shot, DNS report and server log print-outs)

anti Donald”

Meanwhile, day after day — at least for the few weeks we were monitoring this term — "anti Hillary" continued to produce no suggestions. Why would Google have singled out this one phrase to protect? As always, when you are dealing with the best number crunchers in the world, the answer has to do with numbers. What do you notice when you look below at the frequency of searches for the three anti-Hillary phrases?

(Contact our office for screen shot, DNS report and server log print-outs)

anti Hillary”

That's right. "Anti Hillary" was drawing the most traffic, so that was the phrase to protect.

Sourcefed's video was overstated, but, overall, our investigation supports Sourcefed's claim that Google's autocomplete tool is biased to favor Mrs. Clinton — sometimes dramatically so, sometimes more subtly.

Sputnik's Recent Claims

All of the examples I've given you of apparent bias in Google's search suggestions are old and out of date — conducted by me and my staff over the summer of 2016. Generally speaking, you won't be able to confirm what we found (which is why I am showing you screen shots). This is mainly because search suggestions keep changing. So the big question is: Do new search suggestions favor Mr. Trump or Mrs. Clinton.

Recently, Sputnik News reported that Google was suppressing search suggestions related to trending news stories expressing concern about Mrs. Clinton's health. Sure enough, as you can see in the following screen shots captured on August 29th, suggestions on Bing and Yahoo reflected the trending news, but suggestions on Google did not:

(Contact our office for screen shot, DNS report and server log print-outs)


 (Contact our office for screen shot, DNS report and server log print-outs)



(Contact our office for screen shot, DNS report and server log print-outs)


And, yes, once again, Google Trends showed a recent spike in searches for the missing search suggestions:

(Contact our office for screen shot, DNS report and server log print-outs)

Google Trends

While the news was buzzing about Mrs. Clinton's health, hundreds of stories were also being published about Mr. Trump's "flip flopping" on immigration issues, and that too was reflected on Google Trends:

(Contact our office for screen shot, DNS report and server log print-outs)

Mr. Trump’s “flip flopping”

But, as you can see, Google did not suppress "Donald Trump flip flops" from its suggestions:

(Contact our office for screen shot, DNS report and server log print-outs)

Donald Trump flip flops”

Google, it seems, is playing this game both consistently and slyly. It is saving its bias for the most valuable real estate — trending, high-value terms — and eliminating signs of bias for terms that have lost their value.

And that brings me, at last, to a research project I initiated only a few weeks ago. If Google is really biasing its search suggestions, what is the company's motive? A new study sheds surprising and disturbing light on this question.

How Google's Search Suggestions Affect Our Searches

Normally, I wouldn't talk publicly about the early results of a long-term research project I have not yet published in a scientific journal or at least presented at a scientific conference. I have decided to make an exception this time for three reasons: First, the results of the study on autocomplete I completed recently are strong and easy to interpret. Second, these results are consistent with volumes of research that has already been conducted on two well-known psychological processes: negativity bias and confirmation bias. And third, the November election is growing near, and the results of my new experiment are relevant to that election — perhaps even of crucial importance.

I began the new study asking myself why Google would want to suppress negative search suggestions. Why those in particular?

In the study, a diverse group of 300 people from 44 U.S. states were asked which of four search suggestions they would likely click on if they were trying to learn more about either Mike Pence, the Republican candidate for vice president, or Tim Kaine, the Democratic candidate for vice president. They could also select a fifth option in order to type their own search terms. Here is an example of what a search looked like:

(Contact our office for screen shot, DNS report and server log print-outs)

Tim Kaine

Two of the searches we showed people contained negative search suggestions (one negative suggestion in each search); all of the other search suggestions were either neutral (like "Tim Kaine office") or positive (like "Mike Pence for vice president").

Each of the negative suggestions — "Mike Pence scandal" and "Tim Kaine scandal" — appeared only once in the experiment. Thus, if study participants were treating negative items the same way they treated the other four alternatives in a given search, the negative items would have attracted about 20 percent of the clicks in each search.

By including or suppressing negatives in search suggestions, you can direct people's searches one way or another just as surely as if they were dogs on a leash.

But that's not what happened. The three main findings were as follows:

1) Overall, people clicked on the negative items about 40 percent of the time — that's twice as often as one would expect by chance. What's more, compared with the neutral items we showed people in searches that served as controls, negative items were selected about five times as often.

2) Among eligible, undecided voters —the impressionable people who decide close elections — negative items attracted more than 15 times as many clicks as neutral items attracted in matched control questions.

3) People affiliated with one political party selected the negative suggestion for the candidate from their own party less frequently than the negative suggestion for the other candidate. In other words, negative suggestions attracted the largest number of clicks when they were consistent with people's biases.

These findings are consistent with two well-known phenomena in the social sciences: negativity bias and confirmation bias.

Negativity bias refers to the fact that people are far more affected by negative stimuli than by positive ones. As a famous paper on the subject notes, a single cockroach in one's salad ruins the whole salad, but a piece of candy placed on a plate of disgusting crud will not make that crud seem even slightly more palatable.

Negative stimuli draw more attention than neutral or positive ones, they activate more behavior, and they create stronger impressions — negative ones, of course. In recent years, political scientists have even suggested that negativity bias plays an important role in the political choices we make — that people adopt conservative political views because they have a heightened sensitivity to negative stimuli.

Confirmation bias refers to the fact that people almost always seek out, pay attention to, and believe information that confirms their beliefs more than they seek out, pay attention to, or believe information that contradicts those beliefs.

When you apply these two principles to search suggestions, they predict that people are far more likely to click on negative search suggestions than on neutral or positive ones — especially when those negative suggestions are consistent with their own beliefs. This is exactly what the new study confirms.

Google data analysts know this too. They know because they have ready access to billions of pieces of data showing exactly how many times people click on negative search suggestions. They also know exactly how many times people click on every other kind of search suggestion one can categorize.

To put this another way, what I and other researchers must stumble upon and can study only crudely, Google employees can study with exquisite precision every day.

Given Google's strong support for Mrs. Clinton, it seems reasonable to conjecture that Google employees manually suppress negative search suggestions relating to Clinton in order to reduce the number of searches people conduct that will expose them to anti-Clinton content. They appear to work a bit less hard to suppress negative search suggestions for Mr. Trump, Senator Sanders, Senator Cruz, and other prominent people.

This is not the place to review the evidence that Google strongly supports Mrs. Clinton, but since we're talking about Google's search bar, here are two quick reminders:

First, on August 6th, when we typed "When is the election?," we were shown the following image:

(Contact our office for screen shot, DNS report and server log print-outs)

When is the election?”

See anything odd about that picture? Couldn't Google have displayed two photos just as easily as it displayed one?

And second, as reported by the Next Web and other news sources, in mid 2015, when people typed "Who will be the next president?," Google displayed boxes such as the one below, which left no doubt about the answer:

(Contact our office for screen shot, DNS report and server log print-outs)

Who will be the next president?”

Corporate Control

Over time, differentially suppressing negative search suggestions will repeatedly expose millions of people to far more positive search results for one political candidate than for the other. Research I have been conducting since 2013 with Ronald Robertson of Northeastern University has shown that high-ranking search results that favor one candidate can easily shift 20 percent or more of undecided voters toward that candidate — up to 80 percent in some demographic groups, as I noted earlier. This is because of the enormous trust people have in computer-generated search results, which people mistakenly believe are completely impartial and objective — just as they mistakenly believe search suggestions are completely impartial and objective.

The impact of biased search rankings on opinions, which we call the Search Engine Manipulation Effect (SEME), is one of the largest effects ever discovered in the behavioral sciences, and because it is invisible to users, it is especially dangerous as a source of influence. Because Google handles 90 percent of search in most countries and because many elections are very close, we estimate that SEME has been determining the outcomes of upwards of 25 percent of the national elections in the world for several years now, with increasing impact each year. This is occurring, we believe, whether or not Google's executives are taking an active interest in elections; all by itself, Google's search algorithm virtually always ends up favoring one candidate over another simply because of "organic" search patterns by users. When it does, votes shift; in large elections, millions of votes can be shifted. You can think of this as a kind of digital bandwagon effect.

The new effect I have described in this essay — a search suggestion effect — is very different from SEME but almost certainly increases SEME's impact. If you can surreptitiously nudge people into generating search results that are inherently biased, the battle is half won. Simply by including or suppressing negatives in search suggestions, you can direct people's searches one way or another just as surely as if they were dogs on a leash, and you can use this subtle form of influence not just to alter people's views about candidates but about anything.

Google launched autocomplete, its search suggestion tool, in 2004 as an opt-in that helped users find information faster. Perhaps that's all it was in the beginning, but just as Google itself has morphed from being a cool high-tech anomaly into what former Google executive James Whittaker has called a "an advertising company with a single corporate-mandated focus," so has autocomplete morphed from being a cool and helpful search tool into what may be a tool of corporate manipulation. By 2008, not only was autocomplete no longer an opt-in feature, there was no way to opt out of it, and since that time, through strategic censorship, it may have become a tool for directing people's searches and thereby influencing not only the choices they make but even the thoughts they think.

Look back at the searches I have shown you. Why does Google typically show you far fewer search suggestions than other search engines do — 4 or fewer, generally speaking, compared with 8 for Bing, 8 for DuckDuckGo and 10 for Yahoo? Even if you knew nothing of phenomena like negativity bias and confirmation bias, you certainly know that shorter lists give people fewer choices. Whatever autocomplete was in the beginning, its main function may now be to manipulate.

Without whistleblowers or warrants, no one can prove Google executives are using digital shenanigans to influence elections, but I don't see how we can rule out that possibility.

Perhaps you are skeptical about my claims. Perhaps you are also not seeing, on balance, a pro-Hillary bias in the search suggestions you receive on your computer. Perhaps you are also not concerned about the possibility that search suggestions can be used systematically to nudge people's searches in one direction or another. If you are skeptical in any or all of these ways, ask yourself this: Why, to begin with, is Google censoring its search suggestions? (And it certainly acknowledges doing so.) Why doesn't it just show us, say, the top ten most popular searches related to whatever we are typing? Why, in particular, is it suppressing negative information? Are Google's leaders afraid we will have panic attacks and sue the company if we are directed to dark and disturbing web pages? Do they not trust us to make up our own minds about things? Do they think we are children?

Without whistleblowers or warrants, no one can prove Google executives are using digital shenanigans to influence elections, but I don't see how we can rule out that possibility. There is nothing illegal about manipulating people using search suggestions and search rankings — quite the contrary, in fact — and it makes good financial sense for a company to use every legal means at its disposal to support its preferred candidates.

Using the mathematical techniques Robertson and I described in our 2015 report in the Proceedings of the National Academy of Sciences, I recently calculated that SEME alone can shift between 2.6 and 10.4 million votes in the upcoming US presidential race without anyone knowing this has occurred and without leaving a paper trail.

I arrived at those numbers before I knew about the power search suggestions have to alter searches. The new study suggests that autocomplete alone might be able to shift between 800,000 and 3.2 million votes — also without anyone knowing this is occurring.

Perhaps even more troubling, because Google tracks and monitors us so aggressively, Google officials know who among us is planning to vote and whom we are planning to vote for. They also know who among us are still undecided, and that is where the influence of biased search suggestions and biased search rankings could be applied with enormous effect.

[Postscript: Google declined to comment on the record when queried about some of the concerns I have raised in this article. Instead, on August 17th, a company representative sent me to a blog post released by the company on June 16th; you can read Google's official position on autocomplete there.)

ROBERT EPSTEIN (@DrREpstein) is Senior Research Psychologist at the American Institute for Behavioral Research and Technology in Vista, California. A PhD of Harvard University, Epstein has published fifteen books on artificial intelligence and other topics. He is also the former editor-in-chief of Psychology Today.

Further, Plaintiffs conducted duplicative forensic research using internet technology specialists and advice from FBI and Congressional forensics experts along with the placement of thousands of server test nodes around the globe for a multi-year period and discovered that the above internment and media assertions about Defendants, by third party investigators were true. Since prior to the inception of Google, Google executives and VC’s have carried out an acrimonious copy-cat, aggression, black-listing, brand damaging and interference campaign against Plaintiffs because Defendants were too unskilled at creating their own technology or competing in a fair market without using cheating and bribery tactics.

Key points of this case include the following facts:

A. Defendants have formed a “Cartel”, as defined by law under RICO Racketeering Statutes and were the financiers of the political campaigns and received payola and kick-backs from those campaigns.

B. In exchange for financing those political campaigns, Defendants Clients gave Defendants Associates lithium ion battery monopolies, solar panel monopolies, data processing government contract monopolies and media distribution exclusives worth trillions of dollars. This was an illegal quid-pro-quo arrangement. Plaintiffs designed, produced, received patent awards on, received federal commendations for, received federal funding for and first marketed the very products which Defendants copied and made billions of dollars on and which Defendants felt might beat them in hundreds of billions of dollars of competitive market positions and stock market trades. Companies operated by Plaintiffs included automobile design and manufacturing companies, global television broadcasting companies and energy companies which are commonly known to have generated hundreds of billions of dollars in profits, revenue and stock market transactions for Defendants competing holdings at Plaintiffs expense. Defendants operated a criminal CARTEL as defined by RICO LAWS and that Cartel ran an an anti-trust market rigging and crony political payola operation. Defendants spent tens of millions of dollars attacking Plaintiffs because Defendants were not clever enough to build better products. Defendants chose to “CHEAT RATHER THAN COMPETE” and to try to kill Plaintiffs lives, careers, brands, revenues, assets, businesses and efforts via malicious and ongoing efforts.

C. U.S. Attorney General Eric Holder, Bill Barr, Jefferson B. Sessions III, et al, has been informed, in writing, of these charges and Plaintiffs understand that DOJ officials have an ongoing investigation into these matters.

D. Due to Defendants fears of the loss of up a trillion dollars of crony payola from the illegal abuse of taxpayer funds and Defendants warnings from White House staff that the crony scheme must “never come to light”, Defendants engaged in felonious gangster-like actions in order seek to terminate all witnesses, reporters and opposition government staff who attempted to expose these crimes.

E. Just as, over time, the Watergate crimes are now intimately documented and detailed; over time The “Cleantech Crash Scandal” as featured on CBS News 60 MINUTES TV Show, has been detailed and exposed in numerous federal, news media and public investigations. Significant barriers to justice were illicitly placed in front of Plaintiffs by Defendants.

F. Defendants organized and operated a series of malicious attacks and thefts against Plaintiffs as reprisals and competitive vendettas. Defendants report to the FBI, GAO, FTC, SEC, Congressional Ethics Committees, Trump Administration and other entities on a regular basis. Plaintiffs have received evidence from those entities as well as Wikileaks, Drudge Report, wearethenewmedia.com groups, private investigators and former employees of Defendants.

G. Defendants and their associates Elon Musk, Jon Doerr, Eric Schmidt, Larry Page, Steve Jurvetson, Vinod Khosla and other members of the “Silicon Mafia” are documented in tens of thousands of news reports, federal law enforcement reports and Congressional reports in their attempts to infiltrate and corrupt the U.S. Government in an attempt to route trillions of tax dollars to Defendants private accounts. Defendants perceived Plaintiffs as a threat to their crimes. Federal investigators, news investigators and whistle-blowers have reported to Plaintiffs that Defendants were the financiers and/or beneficiaries and/or command and control operatives for the crimes and corruption disclosed in the CBS NEWS 60 Minutes investigative reports entitled: “The Cleantech Crash”, “The Lobbyists Playbook” and “Congress Trading on Insider Information”; The Feature Film: “The Car and the Senator” Federal lawsuits with case numbers of: USCA Case #16-5279; and over 50 other cases including the ongoing “Solyndra” investigation and federal and Congressional investigations detailed at http://greencorruption.blogspot.com/ ; http://www.skybase.us ; https://theintercept.com/2016/04/22/googles-remarkably-close-relationship-with-the-obama-white-house-in-two-charts/ and thousands of other documentation sites. Plaintiffs are charged with engaging in these crimes and corruptions against Plaintiffs and financing and ordering attacks on Plaintiffs. Plaintiffs engaged in U.S. commerce and did everything properly and legally. Unlike Defendants, Plaintiffs did not steal technology. Unlike Defendants, Plaintiffs did not bribe elected officials in order to get market exclusives. Unlike Defendants, Plaintiffs did not poach Defendants staff. Unlike Defendants, Plaintiffs were the original inventors of their products. Unlike Defendants, Plaintiffs did not operate “AngelGate Collusion” schemes and “High Tech No Poaching Secret Agreements” and a Mafia-like Silicon Valley exclusionary Cartel. Unlike Defendants, Plaintiffs did not place their employees in the U.S. Government, The California Government, The U.S. Patent Office and The U.S. Department of Energy in order to control government contracts to Defendants exclusive advantage. Unlike Defendants, Plaintiffs did not place moles inside of competitors companies. Unlike Defendants, Plaintiffs did not hire Gawker Media and Think Progress to seek to kill Plaintiffs careers, lives and brands. Unlike Defendants, Plaintiffs did not rig the stock market with “pump-and-dump”, “Flash Boy” and “Google-stock/PR-pump” schemes. Plaintiffs engaged in hard work every day of their lives for the time-frame in question under the belief that the good old American work ethic and just rewards for your creations was still in effect in the U.S.A., and that the thieves and criminals that attempted to interdict Plaintiffs would face Justice. In a number of circumstances Defendants took advantages of Plaintiffs hard work via come-ons; Defendants then made billions of dollars from Plainiffs work at Plaintiffs expense and attacked Plaintiffs in order to reduce Plaintiffs competitive and legal recovery options.

H. Defendants compensated the White House staff with cash, stock warrants, illicit personal services, media control and a technology known as a “Streisand Effect Massive Server Array” which can control public impressions for, or against a person, party, ideology or issue. Defendants Streisand Effect internet system was used to destroy Plaintiffs in reprisal, retribution, and vendetta for Plaintiffs help with law enforcement efforts in the case and because Plaintiffs companies competed with Defendants companies with superior technologies.

I. Defendants have used their Streisand Effect technology to build a character assassination ring of bloggers and hired shill “reporters” who engage in a process called a “Shiva”. This process is named after a Plaintiff in a similar case named: Shiva Ayyadurai, the husband of Actress Fran Drescher. Shiva Ayyadurai holds intellectual property rights to part of Defendants email technology. In fact, the people most threatened by the Shiva Ayyadurai patent right claims, ironically turn out to be Defendants and, in particular, Defendants associates Elon Musk, Jon Doerr, Eric Schmidt, Larry Page, Steve Jurvetson, Vinod Khosla and other members of the “Silicon Mafia” who own most of the main companies exploiting email technology. Were Shiva Ayyadurai to prevail in his claims, Defendants would owe him billions of dollars. “Running A Shiva” involves the production of a series of Defamation articles by bloggers who act as if they are independent from Defendants but are in fact, not. Defendants used “the Shiva” to attack and seek to destroy Donald Trump, Shiva Ayyadurai, Plaintiffs, and numerous political figures. Univision, Unimoda, Jalopnik, Gawker Media, Gizmodo and over a hundred stealth-ed, and overt, assets of Defendants have been using “The Shiva” network to attack Donald Trump, Shiva Ayyadurai, Plaintiffs, and numerous political figures as recently as this morning, thus, the time bar restarts every day. Plaintiffs have pleaded with Defendants to cease their attacks but Defendants have refused to comply. Even with Fran Drescher’s ongoing royalty payments from her popular television series, friends have reported that the attacks on the Ayyadurai family have been devastating and have caused massive damages and personal and emotional devastation.

J. Defendants produced animated movies, attack articles, fake blog comments, DNS routes, “Shiva” Campaigns, and other attack media against Plaintiffs and expended over $30 million dollars in value, as quantified by Defendants partner: Google, in placing the attack material in front of 7.5 billion people on the planet for the rest of Plaintiffs lifetime. No person could survive such an attack and in the case of Plaintiffs, lives were destroyed and multiple companies invested into by Plaintiffs, which Defendants made over $50B off of the copies of, were destroyed because they competed with Defendants.

K. Defendants have paid almost every high technology law firm that is capable of undertaking Plaintiff’s case to NOT take Plaintiffs case. Defendants have threatened law firms with Black-Listing and the loss of Defendants lucrative business if any law-firm were to take Plaintiffs cases. This is a violation of Plaintiff’s State and Federal Constitutional rights and DOJ must step in a operate the case on Plaintiff’s behalf.




The Plaintiffs are informed and believe, and based on that information and belief allege that at all times mentioned in the within Complaint, all Defendants were the agents, owners and employees of their co-Defendants and, in doing the things alleged in this Complaint, were acting within the course and scope of such agency and employment.

As to any corporate employer specifically named, or named as a “DOE” herein, the Plaintiffs are informed and believe and therefore allege that any act, conduct, course of conduct or omission, alleged herein to have been undertaken with sufficient, malice, fraud and oppression to justify an award of punitive damages, was, in fact, completed with the advance knowledge and conscious disregard, authorization, or ratification of and by an officer, director, or managing agent of such corporation. The Statute of Limitations and time bar on this case has not expired. Plaintiffs only became aware of all of the facts in 2017 due to the FBI, Congressional and hacker-exposed investigation data on Defendants operating and receiving cash, rewards and assets from an illegal and illicit set of political slush-funds established to compensate them for financing political campaigns. The Sony, Clinton, DNC, HSBC, Panama Papers and other hacks and publication of all of the relevant files and the Congressional investigation of illicit activities and the continuing issuance of federal documents to Plaintiffs confirming Plaintiffs intellectual property are all vastly WITHIN the statutes of limitations to allow this case to proceed to Jury Trial. Plaintiffs has had a long, ongoing and high-level interaction with Defendant in both the work effort and the monetization and collection effort. Plaintiffs has been continually interactive with Defendant in order to try to collect his money. Attacks and interference with Plaintiffs has occurred as recently as this week by Defendants.


Defendants are among the largest financiers and/or beneficiaries and/or command and control operatives for political quid-pro-quo campaigns.

Mining magnates (ie: Guistra, et al) and investment bank executives who controlled mined commodities stock trades co-financed the political campaigns and had a quid-pro-quo relationship with defendants for lithium, indium, copper and all rare earth metals used in batteries, solar panels and the exact mined materials that the political campaigns promised an exclusive on, and in fact, delivered a monopolistic exclusive market on to Defendants. Defendants produced vast numbers of documentation valuing their crony kick-back payola deal at “Over six trillion dollars”, promoted by USAID and Goldman Sachs agents. One can easily see the types of criminal measures Defendants might undertake in order to steal, embezzle or monopoly route such an outrageous potential sum to their personal bank accounts.

Because Defendants were engaged in the operation of “an organized crime racketeering operation protected by White House staff in the Obama Administration”, according to FBI and Congressional sources, Defendants felt insulated, arrogant and above the law. Defendants undertook extreme attacks against Plaintiffs because their “Frat Boy” elitist ego’s were bruised and they thought they were “untouchable”. Defendants did not believe that any Elliot Ness-class agents still existed at the FBI. They were wrong. Defendants staged the following attacks on Plaintiffs as described in the text of this report: While most people may think that “hit-jobs” are the realm of Hollywood movie plots, these kinds of corporate assassination attempts do take place daily in big business and politics. At the request of the U.S. Government, Plaintiffs developed and patented an energy technology that affected trillions of dollars of oil company and technology billionaire insider profits. They didn’t realize this at the time. Let me make this point clearly: The control of Trillions of dollars of energy industry profits were being fought over by two groups and the Government plunked Plaintiffs down in the middle of that war. Plaintiffs had no affiliation with either group. They thought they were just accepting a challenge to help their nation and were not aware that Defendants had infected the entire process with crony corruption insider schemes.

One of the Plaintiffs won commendation from the U.S. Congress in the Iraq War Bill. They won federal patents. They won a Congressional grant. They won a huge number of letters of acclaim and they won the wrath of a handful of insane Silicon Valley billionaires who could not compete with Plaintiffs technology. Defendants chose to “...CHEAT RATHER THAN COMPETE!”

The attacks were carried out by California State employees and U.S. Government officials who had received stock, perks, and other quid-pro-quo payment from these billionaires.

Department of Energy Executives and their campaign billionaire handlers engaged in these attacks in order to control the solar and "green car" markets in violation of anti-trust laws. The billionaires did not care about “green” issues, they only cared about green cash.

Federal and state employees ran retribution campaigns against applicants who competed with inside deals they had set up to line their own pockets at taxpayer expense.

These corrupt politicians thought they could take over a promised “six trillion dollar "Cleantech" industry that was being created to exploit new insider exploitation opportunities around global warming and Middle East disruption. After an epic number of Solyndra-esque failures, all owned by the Department of Energy Executives and their campaign financiers, the scheme fell apart. The non crony applicants suffered the worst fates. As CBS News reporter Cheryl Atkisson has reported, the willingness to engage in media "hit-jobs" was only exceeded by the audacity with which Department of Energy officials employed such tactics.

Now, in a number of notorious trials and email leaks, including the Hulk Hogan lawsuit and the DNC and Panama Papers leaks, the public has gotten to see the depths to which public officials are willing to stoop to cheat rather than compete in the open market.

Department of Energy employees and State of California employees engaged in the following documented attacks against applicants who were competing with their billionaire backers personal stock holdings. Plaintiffs and the other applicants including Bright Automotive, Aptera, ZAP and many more, suffered these attacks:

- Social Security, SSI, SDI, Disability and other earned benefits were stone-walled. Applications were “lost”. Files in the application process “disappeared”. Lois Lerner hard drive “incidents” took place.

- Defendants had lawyers employed by Defendants contact Plaintiffs and offer to “help” Plaintiffs when, in fact, those lawyers worked for Defendants and were sent in as moles to try to delay the filing of a case in order to try to run out the time bar.

- State and federal employees played an endless game of Catch-22 by arbitrarily determining that deadlines had passed that they, the government officials, had stonewalled and obfuscated applications for, in order to force these deadlines that they set, to appear to be missed.

- Some applicants found themselves strangely poisoned, not unlike the Alexander Litvenko and Rodgers cases. Heavy metals and toxic materials were found right after their work with the Department of Energy weapons and energy facilities. Many wonder if these “targets” were intentionally exposed to toxins in retribution for their testimony. The federal MSDS documents clearly show that a number of these people were exposed to deadly compounds and radiations without being provided with proper HazMat suits which DOE officials knew were required.

- Applicants employers were called, and faxed, and ordered to fire applicants from their places of employment, in the middle of the day, with no notice, as a retribution tactic.

- Applicants HR and employment records, on recruiting and hiring databases, were embedded with negative keywords in order to prevent them from gaining future employment.

- One Gary D. Conley, one Seth Rich and one Rajeev Motwani, all whistle-blowers in this matter, turned up dead under strange circumstances. They are not alone in a series of bizarre deaths related to the DOE. The many suspiciously dead parties are all connected to acrimonious relationships with Defendants.

- Disability and VA complaint hearings and benefits were frozen, delayed, denied or subjected to lost records and "missing hard drives" as in the Lois Lerner case.

- Paypal and other on-line payments for on-line sales were delayed, hidden, or re-directed in order to terminate income potential for applicants who competed with DOE interests and holdings.

- DNS redirection, website spoofing which sent applicants websites to dead ends and other Internet activity manipulations were conducted.

- Campaign finance dirty tricks contractors IN-Q-Tel, Think Progress, Media Matters, Gawker Media, Syd Blumenthal, etc., were hired by DOE Executives and their campaign financiers to attack applicants who competed with DOE executives stocks and personal assets.

- Covert DOE partner: Google, transfered large sums of cash to dirty tricks contractors and then manually locked the media portion of the attacks into the top lines of the top pages of all Google searches globally, for years, with hidden embedded codes in the links and web-pages which multiplied the attacks on applicants by many magnitudes.

- Honeytraps and moles from persons employed by Defendants or living on, or with, Defendants were employed by the attackers. In this tactic, people who covertly worked for the attackers were employed to approach the “target” and offer business or sexual services in order to spy on and misdirect the subject.

- Mortgage and rental applications had red flags added to them in databases to prevent the targets from getting homes or apartments.

- McCarthy-Era "Black-lists" were created and employed against applicants who competed with DOE executives and their campaign financiers to prevent them from funding and future employment. The Silicon Valley Cartel (AKA the “PayPal Mafia” or the “Silicon Valley Mafia”) placed Plaintiffs on their “Black-List”.

- Targets were very carefully placed in a position of not being able to get jobs, unemployment benefits, disability benefits or acquire any possible sources of income. The retribution tactics were audacious, overt..and quite illegal.

While law enforcement, regulators and journalists are now clamping down on each and every one of the attackers, one-by-one, the process is slow. The victims have been forced to turn to the filing of lawsuits in order to seek justice. The Mississippi Attorney General’s office, who is prosecuting Cartel Member Google, advised Plaintiffs to pursue their case in civil court while the Post Election FBI expands its resources.”

While Defendants have sought to mock Plaintiffs exposure of Defendants organized crime operation by denigrating Plaintiffs data as “Conspiracy Theory”, the articles located at:

1.) http://www.zerohedge.com/news/2015-02-23/1967-he-cia-created-phrase-conspiracy-theorists-and-ways-attack-anyone-who-challenge

2.) http://www.infowars.com/33-conspiracy-theories-that-turned-out-to-be-true-what-every-person-should-know/

3.) How, After This Crazy Year, Is ‘Conspiracy Theorist’ Still Being Used As An Insult? http://www.newslogue.com/debate/152

...and thousands of other links prove that Defendants further attempts to malign Plaintiffs over their conspiracy FACTS are ill advised.

Defendants, since before 1999, have regularly approached Plaintiffs and each of their companies in the internet, green building, aerospace, telecomm, internet video, fuels, energy and other industries through various agents and intermediaries with offers of pretension to “invest in” or “partner with” Plaintiffs. In each and every case, Defendants were on a fishing expedition to acquire Plaintiffs technologies, copy those technologies and monetize those technologies under Defendants own brands. When Plaintiffs continued to compete with Defendants copy-cat technologies, Defendants operated hit-jobs against Plaintiffs using their controlled publications like Gawker, Gizmodo, Defendants, Twitter, Facebook, TechDirt and other brand assassination web media manipulation services. Defendants feared the competition of Plaintiffs and were upset by Plaintiffs refusal to participate in their so-called “Silicon Valley White House Coup” as described by Glenn Greenwald and The Intercept, White House adviser Steve Bannon, Congressional spokesman Newt Gingrich, Jeff Sessions staff, Matt Drudge and thousands of others.

The Plaintiffs had numerous lawyers, specialists and others contacted Defendants requesting a cessation of Defendants harassment and internet manipulation and removal of the rigged attack links and hidden internet codes within the links on Defendants server architecture.

At all times pertinent, the Plaintiffs, including Defendants staff members, Matt Cutts, Forest Timothy Hayes, Defendants legal staff and others refused to assist and commonly replied: “...just sue us..”, “...get a subpoena...”, etc., even though the Plaintiffs, and the Plaintiffs representatives, provided the Defendants with extensive volumes of third-party proof clearly demonstrating that not a single statement in the attack links promoted by google was accurate or even remotely true. Defendants knew Plaintiffs personally, knew the attack hit-job article and movie was false and defamatory and took great glee in refusing to remove it for over five years.

YouTube, published a custom produced and targeted attack video that also included false, defamatory, misleading and manufactured information belittling the Plaintiffs, and discrediting their reputation. The video is known to have been produced by Defendants as part of their anti-trust attack program against Plaintiffs.

The Plaintiffs contacted the Defendants, YouTube and Defendants, with many written requests that they delete the false, defamatory, misleading and manufactured information belittling the Plaintiffs, attacking them and discrediting their reputation as an inventor, project developer and project director from its website. [See, Sample responses of the Defendants Defendants and YouTube, attached as Exhibits and incorporated herein by reference.]

All of the written demands of the Plaintiffs were to no avail and none of the Defendants, agreed to edit, delete, retract or modify any of the false, defamatory, misleading and manufactured information belittling the Plaintiffs, attacking them and discrediting their reputation as an inventor, product developer and project director from their websites and digital internet and media platforms and architecture.

The Plaintiffs, whose multiple businesses ventures had already suffered significant damage as the result of the online attacks of the Defendants, contacted renowned experts, and especially Search Engine Optimization and forensic internet technology (IT) experts, to clear and clean the internet of the false, defamatory, misleading and manufactured information belittling the Plaintiffs, attacking them and discrediting their reputation as an inventor, product developer and project director from their websites.

None of the technology experts hired by the Plaintiffs, at substantial expense, were successful in their attempts to clear, manage or even modify the false, defamatory, misleading and manufactured information belittling the Plaintiffs, attacking him and discrediting their reputation as an inventor, product developer and project director which only Defendants, the controlling entity of the internet, refused to remove. In fact, those experts were able to even more deeply confirm, via technical forensic internet analysis and criminology technology examination techniques that Defendants was rigging internet search results for its own purposes and anti-trust goals.

All efforts, including efforts to suppress or de-rank the results of a name search for “Plaintiffs” failed, and even though tests on other brands and names, for other unrelated parties did achieve balance, the SEO and IT tests clearly proved that Defendants was consciously, manually, maliciously and intentionally rigging its search engine and adjacent results in order to “mood manipulate” an attack on Plaintiffs.

In fact, the experts and all of them, instead, informed the Plaintiffs, that, not only had Defendants locked the false, defamatory, misleading and manufactured information belittling the Plaintiffs, attacking them and discrediting their reputation as an inventor, project developer and project director into its search engine so that the information could never be cleared, managed or even modified, Defendants had assigned the false, defamatory, misleading and manufactured information belittling the Plaintiffs, attacking them and discrediting their reputation as an inventor, project developer and project director “PR8” algorithmic internet search engine coding embedded in the internet information-set programmed into Defendants internet architecture. [See, Information received from one of over 30 IT, forensic network investigators and forensic SEO test analysts, a true and correct copy of which is attached hereto in the Exhibits.] Plaintiffs even went to the effort of placing nearly a thousand forensic test servers around the globe in order to monitor and metricize the manipulations of search results of examples of the Plaintiffs name in comparison to the manipulations for PR hype for Defendants financial partners, for example: the occurrence of the phrase ”Elon Musk”, Defendants business partner and beneficiary, over a five year period. The EU, China, Russia, and numerous research groups (ie: http://www.politico.com/magazine/story/2015/08/how-google-could-rig-the-2016-election-121548 By Robert Epstein ) have validated these forensic studies of Defendants architect-ed character assassination and partner hype system .

The “PR8” codes are hidden codes within the Defendants software and internet architecture which profess to state that a link is a “fact” or is an authoritative factual document in Defendantsopinion. By placing “PR8” codes in the defamatory links that Defendants was manipulating about Plaintiffs, Defendants was seeking to tell the world that the links pointed to “Facts” and not “Opinions”. Defendants embedded many covert codes in their architecture which marketing the material in the attack links and video as “facts” according to Defendants.

The “PR8” codes are a set of codes assigned and programmed into the internet, by the Defendants to matters it designates as dependable and true, thereby attributing primary status as the most significant and important link to be viewed by online researchers regarding the subject of their search.1 Defendants was fully aware that all of the information in the attack articles against Plaintiffs was false, Defendants promoted these attacks as vindictive vendetta-like retribution against Plaintiffs.

At all times pertinent Defendants maintained it had no subjective control or input into the rankings of links obtained by online researchers as the result of a search on its search engines and that its search engine algorithms and the functions of its media assets were entirely “arbitrary” according to the owners and founders of Defendants.

In or about April 15, 2015, The European Union Commission took direct aim at Defendants Inc., charging the Internet-search giant with skewing and rigging search engine results in order to damage those who competed with Defendants business and ideological interests.

In those proceedings, although Defendants continued to maintain that it has no subjective control or input into the rankings of links obtained by online researchers as the result of a search on its search engines and that its staff had no ability to reset, target, mood manipulate, arrange adjacent text or links, up-rank, down-rank or otherwise engage in human input which would change algorithm, search results, perceptions or subliminal perspectives of consumers, voters, or any other class of users of the world wide web, also known as The Internet, the court, in accord with evidence submitted, determined that Defendants, does in fact have and does in fact exercise, subjective control over the results of information revealed by searches on its search engine.2

As a result of receiving this information, the Plaintiffs became convinced of the strength and veracity of their original opinion that the Defendants, had, in fact posted the false, defamatory, misleading and manufactured information belittling the Plaintiffs, attacking them and discrediting Plaintiffs reputation as inventor, project developer and project designer had been intentionally designed, published, orchestrated and posted by them in retaliation to the true testimony provided by the Plaintiffs, to the Government Office of Accountability of the United States in May of 2005, and to the Securities and Exchange Commission, The Federal Bureau of Investigation, The United States Senate Ethics Committee and other investigating parties, and had been disseminated maliciously and intentionally by them in an effort to do damage to their reputation and to their business prospects and to cause him severe and irremediable emotional distress.

In fact, the Plaintiffs, has suffered significant and irremediable damage to their reputation and to their financial and business interests. As a natural result of this damage, as intended by the Defendants, Gawker, Defendants and Youtube, the Plaintiffs has also suffered severe and irremediable emotional distress.

To this day, despite the age of the false, defamatory, misleading and manufactured information belittling the Plaintiffs, attacking him and discrediting their reputation , in the event any online researcher searches for information regarding the Plaintiffs, the same information appears at the top of any list of resulting links.

In addition, due to their control of all major internet database interfaces, Defendants have helped to load negative information about Plaintiffs on every major HR and employment database that Plaintiffs might be searched on, thus denying Plaintiffs all reasonable rights to income around the globe by linking every internal job, hiring, recruiter, employment, consulting, contracting or other revenue engagement opportunity for Plaintiffs back to false “red flag” or negative false background data which is designed to prevent Plaintiffs from future income in retribution for Plaintiffs assistance to federal investigators.3

It should be noted here that, in 2016, one of the companies Plaintiffs was associated with, in cooperation with federal investigations, won a federal anti-corruption lawsuit against the U.S. Department of Energy in which a number of major public officials were forced to resign under corruption charges, federal laws and new legal precedents benefiting the public were created,
and Defendants and its associates and related entities found culpable of corruption.

With specific attention to Plaintiffs claims being “personal injury tort...claims” under 28 U.S.C. § 157(b)(2)(B) and the inapplicability of the California Anti-SLAPP law, Cal. Code. of Civ. P. § 425.16, to Defendants potential claim objections, and state as follows:

. . .

Procedural Background

Plaintiffs are residents of the State of California and the Companies are organized and domiciled in that jurisdiction. INDIVIDUAL A is the senior shareholder of the Companies

Defendants employees and contractors maliciously libeled Plaintiffs through its employees and agents: Adrian Covert, and John Herman, A.J. Delaurio, as well as through its pseudonymous authors, including: Adam Dachis, Adam Weinstein, Adrian Covert, Adrien Chen, Alan Henry, Albert Burneko, Alex Balk, Alexander Pareene, Alexandra Philippides, Allison Wentz, Andrew Collins, Andrew Magary, Andrew Orin, Angelica Alzona, Anna Merlan, Ariana Cohen, Ashley Feinberg, Ava Gyurina, Barry Petchesky, Brendan I. Koerner, Brendan O’Connor, Brent Rose, Brian Hickey, Camila Cabrer, Choire Sicha, Chris Mohney, Clover Hope, Daniel Morgan, David Matthews, Diana Moskovitz, Eleanor Shechet, Elizabeth Spiers, Elizabeth Starkey, Emily Gould, Emily Herzig, Emma Carmichael, Erin Ryan, Ethan Sommer, Eyal Ebel, Gabrielle Bluestone, Gabrielle Darbyshire, Georgina K. Faircloth, Gregory Howard, Hamilton Nolan, Hannah Keyser, Hudson Hongo. Heather Deitrich, Hugo Schwyzer, Hunter Slaton, Ian Fette, Irin Carmon, James J. Cooke, James King, Jennifer Ouellette, Jesse Oxfeld, Jessica Cohen, Jesus Diaz, Jillian Schulz, Joanna Rothkopf, John Cook, John Herrman, Jordan Sargent, Joseph Keenan Trotter, Josh Stein, Julia Allison, Julianne E. Shepherd, Justin Hyde, Kate Dries, Katharine Trendacosta, Katherine Drummond, Kelly Stout, Kerrie Uthoff, Kevin Draper, Lacey Donohue, Lucy Haller, Luke Malone, Madeleine Davies, Madeline Davis, Mario Aguilar, Matt Hardigree, Matt Novak, Michael Ballaban, Michael Dobbs, Michael Spinelli, Neal Ungerleider, Nicholas Aster, Nicholas Denton, Omar Kardoudi, Pierre Omidyar, Owen Thomas, Patrick George, Patrick Laffoon, Patrick Redford, Rich Juzwiak, Richard Blakely, Richard Rushfield, Robert Finger, Robert Sorokanich, Rory Waltzer, Rosa Golijan, Ryan Brown, Ryan Goldberg, Sam Faulkner Bidle, Sam Woolley, Samar Kalaf, Sarah Ramey, Shannon Marie Donnelly, Shep McAllister, Sophie Kleeman, Stephen Totilo, Tamar Winberg, Taryn Schweitzer, Taylor McKnight, Thorin Klosowski, Tim Marchman, Timothy Burke, Tobey Grumet Segal, Tom Ley, Tom Scocca, Veronica de Souza, Wes Siler, William Haisley, William Turton and others writing under pseudonyms; through false accusations of vile and disgusting acts, including fraud and false invention.

Defendants engaged in this campaign against Plaintiffs on the pages of its “Gizmodo”, YouTube Channel, Twitter Accounts, “Deadspin”, “Jalopnik” and other facades under Defendants “Gawker.com” and “Univision” websites. These libels also falsely accused Plaintiffs of lying in his published patents, journals and works-of-art. All of these false and defamatory accusations were published on multiple webpages operated and controlled by Defendants and on social media platforms, such as Twitter and Google, through accounts operated and controlled by Defendants and/or its employees and agents.

These libels, which were also false light invasions of privacy, caused Plaintiffs considerable reputational, emotional, and financial harm, and they so identified him with Plaintiffs that it, too, was a victim of Defendants’s tortious conduct and suffered reputational and financial harm as well.

Despite being given months to take responsibility for its misdeeds, Defendants failed to retract its libel, apologize, or take any other remedial steps. As set forth the California action, Defendants’s modus operandi was to make extreme and outrageous statements, without regard for the truth, and without reasonable inquiry, in order to attract readers and generate revenue. As this Court is well aware, that business model ultimately imploded, resulting in multiple lawsuits and a substantial judgment against it.

Among those who decided that Defendants should not be permitted to get away with defamation for profit, Claimants reluctantly took the step to seek justice, risking that Defendants and its functionaries would employ the “Streisand effect” to republish the false accusations previously made in reporting on the suit itself.

California , Case No. (“In Pro Per litigation”) asserting claims for defamation and false light invasion of privacy arising from the aforesaid false and defamatory statements. Under California law, corporations that appear in propia persona may proceed with their right to sue upon the

appearance of counsel for the corporation, which is without prejudice to a defendant. See CLD Constr., Inc. v. City of San Ramon, 120 Cal. App. 4th 1141, 1152 (1 st Dist. Ct. App. 2004).

See Cal. Code of Civ. P. § 583.210(a). Claimants, without the assistance of counsel, diligently appeared or attempted to appear at all hearings as required.

Discussion Analysis for Option B Approach:

Defendant is a media company not unlike CNN. Those who accuse CNN and other mainstream media outlets of “fake news” will probably revel in a recent decision by a federal judge in Atlanta, Georgia. While Judge Orinda Evans didn’t all out declare that CNN was peddling in falsehoods, she did take aim at the network in an initial judgment in favor of a former hospital CEO who sued CNN accusing them of purposely skewing statistics to reflect poorly on a West Palm Beach hospital. Judge Evans didn’t mince words in her 18-page order allowing the case to move forward, and dismissing CNN’s attempt to get it thrown out of court.

Davide Carbone, former CEO of St. Mary’s Medical Center in West Palm Beach, filed a defamation lawsuit against CNN after they aired what he claims were a “series of false and defamatory news reports” regarding the infant mortality rate at the hospital. CNN’s report said the mortality rate was three times the national average. However, Mr. Carbone contends that CNN “intentionally” manipulated statistics to bolster their report. He also claims that CNN purposely ignored information that would look favorable to the hospital in order to sensationalize the story.

In our case, we contended that CNN essentially made up its own standard in order to conduct an ‘apples to oranges’ comparison to support its false assertion that St. Mary’s mortality rate was 3 times higher than the national average. Accordingly, the case against CNN certainly fits the description of media-created ‘Fake News.'” said Carbone’s attorney L. Lin Wood, in a statement to LawNewz.com.

Wood says that as a result of CNN’s story Carbone lost his job and it became extremely difficult for him to find new employment in the field of hospital administration.

False and defamatory accusations against real people have serious consequences. Neither St. Mary’s or Mr. Carbone did anything to deserve being the objects of the heinous accusation that they harmed or put babies and young children at risk for profit,” Wood said.

On Wednesday, Federal District Judge Orinda Evans ruled that the case could move forward, even ruling that she found that CNN may have acted with “actual malice” with the report — a standard necessary to prove a defamation claim.

The Court finds these allegations sufficient to establish that CNN was acting recklessly with regard to the accuracy of its report, i.e., with ‘actual malice,” the order reads. CNN had tried to get the case dismissed.

Nothing in the legislative history indicates that defamation or invasion of privacy claims are not “personal injury torts”. In fact, all of the history provided by Defendants would preclude their narrow interpretation when Congress was expressly acting to ensure the district court would hear such claims. Similarly, although some courts have permitted the California Anti-SLAPP law to be heard in cases involving diversity jurisdiction, it does not follow that the procedural mechanisms can apply in an objection to claim proceeding.

Defendants also neglects to mention its ongoing, post-petition libel. See, e.g., Trotter, J.K., “What did Internet Troll Chuck Johnson Know about Peter Thiel’s Secret War on Gawker?” (Jun. 17, 2016) (reiterating false accusation of misreporting a story about Sen. Menendez) available at <http://gawker.com/what-did-internet-troll-chuck-johnson- know-about-peter-1782110939>.

At that hearing and in response to objections to claims, other claimants also argued that the district court was required to hear defamation claims as personal injury claims under 28 U.S.C. § 157(b)(2)(B).

Personal Injuries are More Than Just Bodily Injuries

Although Defendants mentions the reorganization of authority between the bankruptcy courts and the district courts in the wake of Northern Pipeline Construction Co. v. Marathon Pipeline Co., 458 U.S. 50 (1982), it fails to explain what motivated the Marathon decision.

The concern in that case was the extent to which Congress could empower Article I courts. The Supreme Court specifically observed that “Congress cannot ‘withdraw from [Art. III] judicial cognizance any matter which, from its nature, is the subject of a suit at the common law, or in equity, or admiralty.’” 458 U.S. at 69 n.23, quoting Murray’s Lessee v. Hoboken Land & Improvement Co., 18 How. 272, 284 (1856). Such suits involved “private rights”, as opposed to “public rights” created legislatively.

During debate over the Bankruptcy Amendments and Federal Judgeship Act of 1983, Pub. L. 98-353, Senator Robert Dole specifically noted: This title establishes an article I bankruptcy court, with judges appointed for limited terms, to handle the routine business of bankruptcy claims based upon State law, which under Marathon will require the attention of article III judges, will be referred to the district courts except where the parties consent to bankruptcy court jurisdiction. One of those areas reserved for attention of the district courts will be personal injury claims, which are exempted from the definition of core proceeding under the bill. 130 Cong. Rec. S20083 (daily ed. June 29, 1984).

However, none of the legislative history, including that cited by Defendants, specifically addresses whether defamation claims are “personal injury” claims. 5i.

Slander and Libel are Common-Law Personal Injury Claims

In determining the meaning of “personal injury”, this Court must look to the common law understanding. Over a century ago, in determining whether a slander was among the “willful and malicious injuries to the person or property of another” not discharged in bankruptcy, the Kentucky Court of Appeals found that a slander is a “personal injury—that is, an injury to his person”, and further explained its holding in the context that “[t]he act of Congress must be 5

There is no inconsistency with including defamation claims among the “narrow range of cases” that are personal injury cases raised by Rep. Kastenmeir. 130 Cong. Rec. H7491. As Defendants notes, the sole example was an automobile accident claim; by Defendants’s logic, all medical malpractice claims would be excluded. None of the remainder of the legislative history cited provides any further insight.

It is understood as having used the words in the section quoted with reference to their common-law acceptation. Sutherland on Statutory Construction, 289.” Sanderson v. Hunt, 116 Ky. 435, 438, 76 S.W. 179, 179 (1903); accord McDonald v. Brown, 23 R.I. 546, 51 A. 213 (1902); Nat’l Sur. Co. v. Medlock, 2 Ga. App. 665, 58 S.E. 1131 (1907). The Sanderson decision was adopted by the Sixth Circuit Court of Appeals, similarly finding a libel to be a “personal injury” under the common law such that it would not be dischargeable under the bankruptcy act. Thompson v. Judy, 169 F. 553 (6th Cir. 1909); 6 see also Parker v. Brattan, 120 Md. 428, 434-35, 87 A. 756, 758 (1913). This understanding was also adopted by at least one district court in the Second Circuit. See In re Bernard, 278 F.734, 735 (E.D.N.Y. 1921). 14.

Congress, in drafting Section 157(b)(2)(B) must, therefore, be understood as having used the words “personal injury” with reference to its common-law acceptation. From the earliest cases, claims sounding in defamation have been deemed a “personal injury.” Indeed, this Court recognized as much nearly twenty years ago when it wrote in In re Boyer, 93 B.R. 313, 317 (Bankr. N.D.N.Y. 1988), in the context of a Section 1983 & 1985 claim: The term “personal injury tort” embraces a broad category of private or civil wrongs or injuries for which a court provides a remedy in the form of an action for damages, and includes damage to an individual’s person and any invasion of personal rights, such as libel, slander and mental suffering, BLACK’S LAW DICTIONARY 707, 1335 (5th ed. 1979).

Accord Soukup v. Employers’ Liab. Assur. Corp., 341 Mo. 614, 625, 108 S.W.2d 86, 90 (1937) citing 3 Words & Phrases, Fourth Series, p. 90 (workers’ compensation case observing that “The words ‘personal injuries’ as defined by lexicographers, jurists and textwriters and by common acceptance, denote an injury either to the physical body of a person or to the reputation of a person, or to both.”)

Simply put, “[t]here is no firm basis to support the proposition that libel and slander were considered to be other than personal injuries at common law.” McNeill v. Tarumianz, 138 F. Supp. 713, 717 (D. Del. 1956). In support thereof, the Delaware district court quoted 1 Blackstone 6

The Thompson decision was generally met with approval by the Second Circuit Court of Appeals in In re Conroy, 237 F. 817 (2d Cir. 1916).

Commentaries 129, which classified rights of “personal security” to consist “in a person’s legal and uninterrupted enjoyment of his life, his limbs, his body, his health and his reputation.” Id. at 716 (further noting that the courts consider “rights of personal security” as synonymous with “personal injury”). 716.

The Supreme Court of Pennsylvania, in 1825, laid down the following common law history in the context of a claim involving a decedent: That a personal action dies with the person is an ancient and uncontested maxim. But the term “personal action,” requires explanation. In a large sense, all actions except those for the recovery of real property, may be called personal. This definition would include contracts for the payment of money, which never were supposed to die with the person. The maxim must therefore be taken in a more

restricted meaning. It extends to all wrongs attended with actual force, whether they affect person or property; and to all injuries to the person only, though without force. Thus stood originally the common law, in which an alteration was made by the stat. 4. Ed. 3. c. 7, which gave an action to an executor for an injury done to the personal property of his testator in his life, which was extended to the executor of an executor by stat. 25, Ed. 3. And by the stat. 31, Ed. 3 c. 11, administrators have the same remedy as executors. These statutes received a liberal construction from the judges, but they do not extend to injuries to the person of the deceased, nor to his freehold. So that no action now lies, by an executor or administrator for an assault and battery of the deceased, or trespass vi et armis, on his land, or for slander; because it is merely a personal injury.

Lattimore v. Simmons, 13 Serg. & Rawle 183, 184-85 (Pa. 1825) (emphasis added). 17.

The Supreme Court of Wisconsin, in 1874, expounded upon this concept in a matter involving state bankruptcy law. It observed “A libel or a slander might deprive a man of 7

The Georgia Supreme Court in Johnson v. Bradstreet Co., 87 Ga. 79, 81-82, 13 S.E. 250, 251 (1891) expounded upon this understanding: At common law, absolute personal rights were divided into personal security, personal liberty, and private property. The right of personal security was subdivided into protection to life, limb, body, health, and reputation. 3 Blackst. Com. 119. If the right to personal security includes reputation, then reputation is a part of the person, and an injury to the reputation is an injury to the person. Under the head of “security in person,” Cooley includes the right to life, immunity from attacks and injuries, and to reputation. Cooley on Torts (2d ed.), 23, 24. See, also, Pollock on the Law of Torts, *7. Bouvier classes among absolute injuries to the person, batteries, injuries to health, slander, libel, and malicious prosecutions. 1 Bouv. L. Dic. (6th ed.) 636. “Person” is a broad term, and legally includes, not only the physical body and members, but also every bodily sense and personal attribute, among which is the reputation a man has acquired. Reputation is a sort of right to enjoy the good opinion of others, and is capable of growth and real existence, as an arm or a leg. If it is not to be classed as a personal right, where does it belong? No provision has been made for any middle class of injuries between those to person and those to property, and the great body of wrongs arrange themselves under the one head or the other. Whether viewed from the artificial arrangement of law writers, or the standpoint of common sense, an injury to reputation is an injury to person.

To harm the employment, destroy his credit, ruin his business, and greatly impair his estate; yet an action therefor would be an action for a personal injury, the effect of the wrong on the estate of the injured party being merely incidental.” Noonan v. Orton, 34 Wis. 259, 263 (1874). That same year, the Supreme Court of Virginia recognized that an “action of slander” did “involve a claim for personal damages” and, as such, did not pass to the assignee in bankruptcy. Dillard v. Collins, 66 Va. 343, 345-47 (1874). 18.

Similarly, a claim by a wife for slander was deemed a “personal injury” claim such that, under the law at that time, her husband was required to join in the suit. See, e.g., Smalley v. Anderson, 18 Ky. 56 (1825) (in a claim for “personal injury”, husband was required to join suit with wife in claim for slander accusing her of adultery); accord Gibson v. Gibson, 43 Wis. 23, 26- 27 (1877); Leonard v. Pope, 27 Mich. 145, 146 (1873) (a claim for slander is “a personal grievance or cause of action”). The U.S. Court of Appeals for the Fifth Circuit agreed that “libel is a personal injury” and that “[a]t common law, libel and slander were classified as injuries to the person, or personal injuries. 3 Blackstone, 119; Cooley on Torts (2d Ed.) 23, 24; Bouvier, Law Dictionary, verbo ‘Injury.’” Times-Democrat Pub. Co. v. Mozee, 136 F. 761, 763 (5th Cir. 1905). Although

the law now recognizes spousal independence, the nature of the action has not changed. 19.

The principle that slander and libel are personal injuries is one that was generally recognized, and, as seen above, it tended to be addressed in cases involving decedents. Blackstone, in his Commentaries (vol. 3, p. 302), stated the rule: “In actions merely personal, arising ex delicto, for wrongs actually done or committed by the defendant, as trespass, battery, and slander, the rule is that actio personalis moritur cum persona; and it shall never be revived either by or against the executors or other representatives.” Thus, by statute, states such as Illinois, in overriding the common law to permit actions to survive, expressly carved out slander and libel as being personal injuries that would not survive. See Holton v. Daly, 106 Ill. 131, 139 (1882) quoting Ill. Rev. Stat. 1874, p. 126 (“actions to recover damages for an injury to the person, except slander and libel, … shall also survive.”).

In contrast, a claim for wrongful death was not recognized at common law precisely because personal injury actions did not survive under the action personalis moritur cum persona universal maxim.

Statutes were, therefore, enacted to permit claims for wrongful death “compensatory of the damages sustained by the heirs or next of kin, who had, or are supposed to have had, a pecuniary interest in the life of the intestate.” Burns v. Grand R. & I. R. Co., 113 Ind. 169, 171, 15 N.E. 230, 231 (1888). Specifically, “[t]hese statutes, while they do not in terms revive the common law right of action for personal injury, nor make it survive the death of the injured person, create a new right in favor and for the benefit of the next of kin or heirs of the person whose death has been wrongfully caused.” Id. 21.

Defendants mistakenly believes that the addition of “wrongful death” implies that because only such a claim can arise from the death of a natural person’s body, the term “personal injury” must be construed similarly in context. Defendants misunderstands that a wrongful death claim is not a common law personal injury claim; thus it had to be specifically added. The addition of wrongful death claims does not, however, modify the common law understanding of “personal injury,” which included libel and slander. 22.

The legislative history, therefore, shows that claims for wrongful death were added because they were not recognized at common law to be a “personal injury.” Libel and slander, on the other hand, were. The legislative record is otherwise silent as to the specific torts that made up a “personal injury” claim and therefore should be understood to include all such claims at common law, including slander and libel. Although Defendants worries that claims for emotional damages will “create an exception that swallows the rule” (Defendants’s Brief at 10), it creates a straw- man argument, improperly lumping in claims that are not common law “personal injury” claims that happen to provide for emotional distress damages. Those claims are different, statutory causes of action; the only statutory claim included in Section 157(b)(2)(B) is the wrongful death claim.

Thus, when Congress enacted Section 157(b)(2)(B), it necessarily imported the common law meaning of “personal injury” and, therefore, libel and slander claims. 8 ii. Plaintiffs is Entitled to Invoke Section 157(b)(2)(B) 23. Defendantss seek to treat Plaintiffs, as a corporate person, differently under Section 157(b)(2)(B) than Plaintiffs. There is no reason for this. As libel is a “personal injury” tort, there is no basis to suggest a corporate person should be treated any differently than a natural person. Simply because it cannot suffer a battery does not mean it is foreclosed from all personal injury claims. As explained by the Georgia Supreme Court in Johnson v. Bradstreet Co., 87 Ga. 79, 81-82, 13 S.E. 250, 251 (1891), an “injury to reputation is an injury to person.” Although a corporation may be unable to suffer a physical, bodily injury, it can suffer an injury to reputation. 24.

Defendants’s citations are inapposite. The U.S. Supreme Court has not said that a corporation cannot suffer a personal injury; rather, N.P.R. Co. v. Whalen, 149 U.S. 157, 162-163 (1893), address actions in nuisance, which can only either affect life, health, senses, or property, and not reputation. Defendants’s quote from Roemer v. Commissioner of Internal Revenue, 176 F.3d 693, 699 n. 4 (9th Cir. 1983), was a matter of pure dicta; the Ninth Circuit had no occasion to pass upon whether a corporation could, in fact, suffer a personal injury. Subsequent cases, such as In re Lost Peninsula Marina Dev. Co., LLC, 2010 U.S. Dist. LEXIS 78532 (E.D. Mich. 2010), wrongly rely upon such dicta. In fact, the Ninth Circuit’s entire basis was DiGiorgio Fruit Corp. v. American Federation of Labor, which does not say a corporation cannot suffer a “personal injury”;it merely says that “a corporation has no reputation in the personal sense”, yet “it has a business reputation”. 215 Cal.App.2d 560, 571, 30 Cal.Rptr. 350, 356 (1963). The Second Circuit has specifically refrained from finding a dichotomy between a business reputation and the reputation 8

Similarly, as invasions of personal rights, Claimants’ false light invasion of privacy claims are “personal injury” claims. See Mercado v. Fuchs (In re Fuchs), No. 05-36028-BJH-7, 2006 Bankr. LEXIS 4543, at *6-7 (U.S. Bankr. N.D. Tex. Jan. 26, 2006) (finding invasion of privacy claim to be a “personal injury” under Section 157(b)(2)(B)); see also Bernstein v. Nat’l Broad. Co., 129 F. Supp. 817, 825 (D.D.C. 1955) (“The tort of invasion of privacy being a personal injury....”)

of a natural person. See Agar v. Commissioner, 290 F.2d 283, 294 (2d Cir. 1961). However, the Eleventh Circuit specifically answered in the affirmative the question “[i]s damage to one’s business reputation a personal injury?” Fabry v. Commissioner, 223 F.3d 1261, 1270 (11th Cir. 2000).

In fact, the purpose of Section 157(b)(2)(B) was to properly address claims that should be heard by an Article III court. As noted above, such was prompted by the Marathon decision, a case where the sole litigants were corporate persons. Where a natural person would have a right to have a matter heard by an Article III court but a corporate person does not, such denial of equal protection would be unlawfully violative of due process under the Fifth Amendment. See Bolling v. Sharpe, 347 U.S. 497 (1954) (holding equal protection claims implicate due process).

Even if corporate persons could be treated differently from natural persons for claims arising from the same transaction, it would be improper to abide Defendants’s suggestion to have the Bankruptcy Court determine the corporate claim first, in order to then argue a preclusive effect against the natural person. This attempted end-run around a specifically mandated statutory provision, grounded in Constitutional rights, should not be condoned. This is not what the Supreme Court was considering in Katchen v. Landy, 382 U.S. 313 (1966); in Katchen, the determination involved a single party who submitted to equity jurisdiction. Plaintiffs has not taken action to deprive himself of his rights. Where Congress has acted to provide for access to Article III courts, it would run afoul of the intent of the law to make that access ephemeral.

Although Defendants at least has the decency to acknowledge that is its purpose, it would set an unconscionable precedent. Many natural persons conduct business through or have some relationship with a corporate person such that harms giving rise to their individual personal injury claims would also harm the corporate person. As a result, Defendantsswho would seek to deprive such natural persons of their right to be heard by an Article III court could simply involuntarily join or otherwise implead the related corporate person, have that matter heard first, and then attempt to preclude the natural person’s claim on that basis.

The California Anti-SLAPP Law Does Not Apply

Defendants’s motion is not about allowance of claims; it is about whether a state law procedural mechanism is to apply in a non-adversarial, contested matter. Although some federal courts permit the application of the California Anti-SLAPP law, Cal. Code Civ. P. § 425.16, in civil cases arising from diversity jurisdiction, it has never been found applicable to a contested claim proceeding in bankruptcy court. The differences between the Federal Rules of Civil Procedure and the Federal Rules of Bankruptcy Procedure demonstrate that it makes little sense to do take such an unprecedented step.

The very nature and purpose of a proof of claim differs from a traditional complaint, rendering the California law impracticable. As this Court is aware: Correctly filed proof of claims “constitute prima facie evidence of the validity and amount of the claim . . . . To overcome this prima facie evidence, an objecting party must come forth with evidence which, if believed, would refute at least one of the allegations essential to the claim.” Sherman v. Novak (In re Reilly), 245 B.R. 768, 773 (2d Cir. B.A.P. 2000). By producing “evidence equal in force to the prima facie case,” an objector can negate a claim's presumptive legal validity, thereby

In shifting the burden back to the claimant to “prove by a preponderance of the evidence that under applicable law the claim should be allowed.” Creamer v. Motors Liquidation Co. GUC Trust (In re Motors Liquidation Co.), No. 12 Civ. 6074 (RJS), 2013 U.S. Dist. LEXIS 143957, 2013 WL 5549643, at *3 (S.D.N.Y. Sept. 26, 2013) (internal quotation marks omitted). If the objector does not “introduce[] evidence as to the invalidity of the claim or the excessiveness of its amount, the claimant need offer no further proof of the merits of the claim.” 4 Collier on Bankruptcy ¶ 502.02 (Alan N. Resnick& Henry J. Sommer eds., 16th ed. 2014). In re Residential Capital, LLC, 519 B.R. 890, 907 (Bankr. S.D.N.Y. 2014). 30. In contrast, under Cal. Code Civ. P. § 425.16(b)(1): A cause of action against a person arising from any act of that person in furtherance of the person’s right of petition or free speech under the United States Constitution or the California Constitution in connection with a public issue shall be subject to a special motion to strike, unless the court determines that the plaintiff has established that there is a probability that the plaintiff will prevail on the claim.

California courts have established a two-step process: first, the defendant must establish the action arose from protected speech or petitioning activity, then “then the burden shifts to the plaintiff to establish a probability that the plaintiff will prevail on the claim, i.e., make a prima facie showing of facts which would, if proved at trial, support a judgment in plaintiff's favor.

In making its determination, the trial court is required to consider the pleadings and the supporting and opposing affidavits stating the facts upon which the liability or defense is based.” Dowling v. Zimmerman, 85 Cal. App. 4th 1400, 1417, 103 Cal. Rptr. 2d 174, 188 (2001) (internal citations and quotation marks omitted).

Further, [t]o establish a probability of prevailing, the plaintiff must demonstrate that the complaint is both legally sufficient and supported by a sufficient prima facie showing of facts to sustain a favorable judgment if the evidence submitted by the plaintiff is credited. For purposes of this inquiry, the trial court considers the pleadings and evidentiary submissions of both the plaintiff and the defendant (§ 425.16, subd. (b)(2)); though the court does not weigh the credibility or comparative probative strength of competing evidence, it should grant the motion if, as a matter of law, the defendant’s evidence supporting the motion defeats the plaintiff’s attempt to establish evidentiary support for the claim. In making this assessment it is the court’s responsibility to accept as true the evidence favorable to the plaintiff. The plaintiff need only establish that his or her claim has minimal merit to avoid being stricken as a SLAPP.

Soukup v. Law Offices of Herbert Hafif, 39 Cal. 4th 260, 291, 46 Cal. Rptr. 3D 638, 662-63, 139 P.3d 30, 50 (2006) (internal citations and quotation marks omitted).

This process makes little sense in a non-adversarial, claims objection proceeding. First, as noted, Claimants’ proofs of claim already enjoy a presumption of prima facie validity under Fed. R. Bankr. P. 3001(f) and Claimants’ submissions must be accepted as true. Thus, as a matter of law, Claimants will always prevail on a California anti-SLAPP motion, having the “minimal merit” which would support allowance of the claim. Second, once a party objects to a proof of claim and introduces evidence of invalidity, a claimant must prove his claim by a preponderance of the evidence, not merely a probability of prevailing. Defendants would require a bankruptcy court to make an unnecessary finding that a disallowed claim nevertheless had a probability of prevailing. The burden shifting framework does not work in a contested claim proceeding, even if it might work for an adversarial matter or in a case under the Rules of Civil Procedure.

Notably, even in diversity cases, the entirety of the California Anti-SLAPP law is not imported in its entirety. Unlike in California state courts, a denial of an Anti-SLAPP motion is not an appealable interlocutory order in Federal courts. See Hyan v. Hummer, 825 F.3d 1043 (9th Cir. 2016). Federal courts do not apply the timing requirements set forth in Section 425.16(f), which directly collides with the timeline allowed under Fed. R. Civ. P. 56. See Sarver v. Chartier, 813 F.3d 891 (9th Cir. 2016). Federal courts do not stay discovery upon the filing of an Anti- SLAPP motion, as otherwise directed by Section 425.16(g). See Metabolife Int’l, Inc. v. Wornick, 264 F.3d 832, 845 (9th Cir. 2001).

Even the very idea of the burden-shifting framework has been questioned by the Ninth Circuit. See Englert v. MacDonell, 551 F.3d 1099, 1102 (9th Cir. 2009) (reserving the issue with respect to a parallel Oregon statute). The D.C. Circuit directly confronted this issue in Abbas v. Foreign Policy Grp., LLC, 783 F.3d 1328, 1335 (2015). In Abbas, the D.C. Circuit directly rejected the idea that an analogous burden-shifting framework created a substantive, quasi-immunity from suit, because the law collided with Rules 12 and 56 as to how a showing is to be made, rendering it inapplicable pursuant to Shady Grove Orthopedic Associates, P.A. v. Allstate Insurance Co., 559 U.S. 393, 398-99, 130 S. Ct. 1431 (2010). See 783 F.3d at 1335.

Defendants attempts to distinguish Abbas by highlighting the non-mandatory nature of applying Rules 12(b)(6) and 56, suggesting that collision is avoided if those rules are not applied. Defendants’s Brief at 15-16. First, it bears observing that Defendants, in its objections to the claims, did move to apply Rule 12(b)(6), rending its own argument moot. Thus, where § 425.16 does conflict with Rule 7012, its application would directly collide with this Court’s authority to “direct that one or more of the other rules in Part VII shall apply.” Fed. R. Bankr. P. 9014(c). Second, although Defendants argues that the Court can “otherwise direct” Rule 7056 not apply per Rule 9014, it provides no reason why the normal rules should be avoided here; Claimants located but one case where a bankruptcy court made such direction to permit the parties to “flesh out the record”, there on a motion to employ, not a claims objection. See In re Rusty Jones, Inc., 109 B.R. 838, 845 (Bankr. N.D. Ill. 1989). Fleshing out a record would similarly be reason not to apply § 425.16 where

Defendants has otherwise obtained a briefing schedule in order for it to take discovery. See Dkt. No. 703. Essentially, the only reason to “otherwise direct” Rule 7056 not apply is because it collides with § 425.16. Third, to not apply certain rules simply because Claimants are California citizens would deny such citizens equal protection in a manner to be so violative of due process that it is an offense to the Fifth Amendment. See Shapiro v. Thompson, 394 U.S. 618, 642, 89 S. Ct. 1322, 1335 (1969).

Moreover, it makes little sense to import the California procedure where Fed. R. Bankr. P. 3007 permits parties in interest other than the Defendants to object to a claim. It could well be impracticable where a Defendants does not believe protected speech was involved, but a third party does. It is not equitable for one class of objector (a Defendants) to potentially enjoy the benefits of the California procedure (attorneys’ fees) and not others (other creditors).

Contrary to the assertion of Defendants, the procedures of § 425.16 are not “bound up” with the law of libel, even to the extent Justice Stevens’s concurrence in Shady Grove Orthopedic Assocs., P.A. v. Allstate Ins. Co., 599 U.S. 393, 419-410 (2010), is controlling. First, Defendants fails to identify what the substantive law is that Section 425.16 is bound up with. The California Anti-SLAPP law is not limited to the law of libel; it also applies to other state law claims. See, e.g., State Farm Mut. Auto. Ins. Co. v. Lee, 193 Cal. App. 4th 34, 122 Cal. Rptr. 3D 183 (2011) (application to abuse of process and unfair business practice claims); Jarrow Formulas, Inc. v. LaMarche, 31 Cal. 4th 728, 3 Cal. Rptr. 3d 636, 74 P.3d 737 (2003) (application to malicious prosecution claims); Fremont Reorganizing Corp. v. Faigin, 198 Cal. App. 4th 1153, 131 Cal. Rptr. 3d 478 (2011) (application to breach of confidence, breach of fiduciary duty, equitable indemnity, and violation of Cal. R. Prof. Conduct 3-310(C)); Peregrine Funding, Inc. v. Sheppard Mullin Richter & Hampton LLP, 133 Cal.App.4th 658, 674–675, 35 Cal. Rptr. 3D 31 (2005) (application to legal malpractice and breach of fiduciary duty claims). Section 425.16 is not analogous to a bond posting requirement, statute of limitations, evidentiary rule, or verdict capping identified by Justice Stevens, all of which have a substantive quality. See Shady Grove, 599 U.S. at 419-410. Here, Defendants seeks to employ a burden shifting framework that could appear at but one discrete stage of a diversity case and has no role in a claim objection; this is not even, then, an example of a “state-imposed burden[ ] of proof”, which would go to the ultimate outcome. Id. at 410 n. 4. There is no question that Claimants have the ultimate burden of proof, with or without the Anti-SLAPP motion. Thus, as it is not sufficiently bound up with any particular substantive law, it is not applicable in this matter. 9

Claims in a bankruptcy case are distinguishable from adversarial matters, especially those brought in district court on the basis of diversity jurisdiction. Claimants did not choose this forum; Defendants did by filing its petition. In doing so, it effectively stripped Claimants of their usual litigation rights. As Defendants says, “what is good for the goose is good for the gander”. Defendants’s Brief at 14. It would be inequitable to allow Defendants the benefit of a normal civil case, such as the use of Section 425.16, while simultaneously denying Claimants the benefits of such a case, by having deprived them of their chosen forum. C.

This Matter Should Be Heard by the District Court With Plaintiff’s Case Supported By DOJ

Moving forward, this matter should proceed before the district court. Defendants incorrectly asserts that Exec. Bens. Ins. Agency v. Arkison, 134 S. Ct. 2165 (2014) commands that this Court first determine the case; rather, it held that having summary judgment first heard by the bankruptcy court, to be followed by de novo review by the district court, was permissible under 28 U.S.C. § 157(c). See Messer v. Magee (In re FKF 3, LLC), No. 13-CV-3601 (KMK), 2016 U.S. Dist. LEXIS 117258, at *52 n.11 (S.D.N.Y. Aug. 30, 2016). Section 157(c)(1) says that a bankruptcy court “may” hear a non-core proceeding, not that it must.

The standard as to whether the bankruptcy court should hear the non-core proceeding in the first instance under Section 157(c)(1) is not well articulated. Guidance from cases under Section 157(d), regarding withdrawal, however, may be informative. In such cases, the considerations are “(1) whether the case is likely to reach trial; (2) whether protracted discovery 9

Although Defendants noted the availability of fees under § 425.16, such provision is secondary to the burden-shifting framework. If the Bankruptcy Court does not perform the mechanism to determine whether or not a probability of success occurs, it would never reach the issue of fees. Section 425.16 does not create a substantive right to fees in all libel cases; only those cases where a defendant is successful on a motion to strike.

with court oversight will be required; and (3) whether the bankruptcy court has familiarity with the issues presented.” In re Times Circle East, Inc., 1995 U.S. Dist. LEXIS 11642, 1995 WL 489551, at *3 (S.D.N.Y. Aug. 15, 1995). All three factors warrant the matter being heard by the District Court in the first instance.

This case is likely to reach trial. Claimants have properly asserted multiple false and defamatory statements as libelous. Because of the defenses asserted by Defendants, it is more probable than not that multiple statements will require factual determinations beyond otherwise being readily apparent on their face. Defendants has asserted a defense of lack of actual malice; such will require probing and evidence into its research, editorial, and publication process. Defendants has asserted a defense under Section 230 of the Communications Decency Act; such will require probing and evidence into its business practices, sources, and publication processes. Neither do Claimants have any confidence that this matter will reach settlement; as noted above, even after having filed a bankruptcy petition arising from publication malfeasance, Defendants continued to defame Claimants.

Moreover, this non-core proceeding will likely require a jury trial to determine the claim’s value. As having filed personal injury tort claim, Claimants are entitled to and claim the right to trial by jury. See 28 U.S.C. § 1411(a). The Second Circuit has found that jury trials in non-core proceedings are likely prohibited “due to the district court’s de novo review of such proceedings.” In re Orion Pictures Corp., 4 F.3d 1095, 1101 (2d Cir. 1993).

Protracted discovery with court oversight will be required. Among other matters, without limitation: Claimants will seek depositions from Defendants. Claimants will require discovery of the identities of the Gawker authors and campaign financiers and will seek to depose them.

Claimants will seek discovery from Defendants as to its business practices, including editorial and publication decisions and social media cross-promotion, as well as the source code relative to the Kinja and website platforms. Claimants will require detailed discovery into the readership and extent of circulation. Claimants anticipate significant litigation over several of these items.

A Bankruptcy Court is unfamiliar with the issues presented. A LEXIS search for cases involving “actual malice” or “section 230”, involving “libel”, “slander”, or “defamation”, yielded only six decision in three cases in this Court. This is not the typical claim arising in a Chapter 11 proceeding. Such cases and issues arise with far more frequency before the District Court.

Because all of the factors favor the District Court, the Bankruptcy Court should not hear these non-core proceedings. III.

As set forth above, the California Anti-SLAPP law is not applicable to a contested matter under Fed. R. Bankr. P. 3007, especially as it relates to the allowance of claims. The state statute conflicts with the Federal procedures and otherwise is unworkable where a proof of claim is already prima facie evidence of a possibility of prevailing. Notwithstanding, Claimants filed their proofs of claims knowing they would ultimately prevail, whether or not the California Anti- SLAPP law applies.

The claims asserted by Claimants are personal injury tort claims that should be heard by the District Court for all further proceedings. Congress must be deemed to have understood the meaning of the term “personal injury” when it legislated, a meaning that, for centuries, has included causes of action sounding in libel and slander, as well as false light invasion of privacy. Defendants has failed to demonstrate that any different meaning was intended.

The issues raised by Defendants show a determined intent to attempt to avoid facing liability for the multiple calamities it heaped upon Claimants. Claimants are entitled to be heard and to vindicate their claims.


The Plaintiffs hereby incorporate by reference the allegations set forth in all paragraphs inclusive as though fully set forth herein.

Defendants knew of the above described contractual relationship existing between the Plaintiffs and COMPANY B and the United States Department of Energy, in that the grant was made public record and, at the request of representatives of the Venture Capital group of the Defendants, the Plaintiffs believing that the request for information was as to providing additional funding for the project, did, in fact, submit complete information regarding the subject of the grant to Defendants agents upon their request.

Defendants, who had, and have, personal, stock-ownership, revolving-door career and business relationships with executive decision-makers at the United States Department of Energy and other Federal and State officials, lobbied and service-compensated those executive decision-makers to cancel, interfere and otherwise disrupt the grant in favor of the
Plaintiffs, with the intention of terminating the funding in favor of the Plaintiffs and COMPANY B and applying the information they pirated from the Plaintiffs, for their own benefit as well as terminating the Plaintiffs competing efforts, which third party industry analysts felt could obsolete Defendants products via superior technology.

Individuals approached Plaintiffs offering to “help” the Plaintiffs get their ventures funded or managed. Those individuals were later found to have been working for Kleiner Perkin's, the founding investor and current share-holder of Defendants. The Plaintiffs discovered that those “helpful” individuals were helping to sabotage development efforts and pass intelligence to Defendants for its own use and applications.

Accordingly, Defendants was successful in its efforts and, in or about August of 2009, the grant and other funding programs in favor of the Plaintiffs, was summarily canceled and re-directed to Defendants and their holdings.

Commencing in or about 2008, Defendants commenced to take credit for advancement in its own energy storage and internet media technology, as based on the information it had pirated from the Plaintiffs.

The interference of Defendants, with the relationship of the Plaintiffs, was intentional, continues to today, and constitutes an unfair business practice in violation of Business and Professions code section 17200.

As a proximate result of the conduct of the Defendants, and severance and termination of the grant to the Plaintiffs, the Plaintiffs have suffered damages including financial damage, damage to their reputation and loss of critical intellectual property.

The aforementioned acts of the Defendants, were willful, fraudulent, oppressive and malicious. The Plaintiffs is therefore entitled to punitive damages.


The Plaintiffs hereby incorporate by reference the allegations set forth in all paragraphs inclusive as though fully set forth herein.

When the Plaintiffs discovered that their fundings from the United States Department of Energy had been terminated, de-funded and re-routed to Defendants, by Defendants. The Plaintiffs informed other members of the energy and automotive technology industry and the U.S. Congress of the facts of Defendants behavior and specifically the behavior that gave rise to termination of the grant.

Defendants became aware that the Plaintiffs were intent on telling the truth about these facts, about true ownership of the intellectual property relied on by Defendants in its own vehicle, energy and internet media technology and about Defendants theft of this property.

In order to put a stop to the Plaintiffs and in an effort to discredit Plaintiffs, divest Plaintiffs of contacts in the industry and also of financial backing, Defendants enlisted the services of the Defendants, YouTube and Gawker and also Defendants own wide array of media and branding manipulation tools which are service offerings of Defendants. The Defendant produced attack material is reposted, impression accelerated, click-farm fertilized and Streisand array reposted by Defendants massive character assassination technology via servers algorithms and technical internet manipulation daily as recently as yesterday. Defendants also embed the article in job hiring databases on Axciom, Palantir, Taleo and other databases used by all hiring and recruiting services in order to prevent Plaintiffs from ever receiving income for W2 or 1099 work ever again.

Under the directions of Defendants, Gawker published a contrived “hatchet job” article describing the Plaintiffs in horrific descriptors. The article is reposted, impression accelerated, click-farm fertilized and Streisand array reposted by Defendants massive character assassination technology via servers algorithms and technical internet manipulation daily as recently as yesterday. Defendants also embed the article in job hiring databases on Axciom, Palantir, Taleo and other databases used by all hiring and recruiting services in order to prevent Plaintiffs from ever receiving income for W2 or 1099 work ever again. Defendants own staff then posted thousands of fake comments, below each attack item, under fake names, designed to make it appear as if a broad consensus of the public agreed with the defamation messages by Defendants. Almost all of the fake comments were created by a handful of Defendants own staff pretending to be a variety of outside voices. Defendants replicated various versions of these attack items across all of their different brands and facade front publications and added additional fake comments to each on a regular basis.

Additionally, Defendants YouTube posted a video which depicted the Plaintiffs as a cartoon character who attempts to engage in unethical behavior. The video employs Plaintiffs personal name and personal information. The article is reposted, impression accelerated, click-farm fertilized and Streisand array reposted by Defendants massive character assassination technology via servers algorithms and technical internet manipulation daily as recently as yesterday. Defendants also embed the article in job hiring databases on Axciom, Palantir, Taleo and other databases used by all hiring and recruiting services in order to prevent Plaintiffs from ever receiving income for W2 or 1099 work ever again. Defendants own staff then posted thousands of fake comments, below each attack item, under fake names, designed to make it appear as if a broad consensus of the public agreed with the defamation messages by Defendants. Almost all of the fake comments were created by a handful of Defendants own staff pretending to be a variety of outside voices. Defendants replicated various versions of these attack items across all of their different brands and facade front publications and added additional fake comments to each on a regular basis.

Defendants has paid tens of millions of dollars to Gawker Media and has a business and political relationship with Gawker Media according to financial filings, other lawsuit evidence, federal investigators and ex-employees.

Also as intended by Defendants, this damage, especially because the false representations become immediately apparent to anyone conducting an internet search for the “Plaintiffs,” have caused investors to shy away from the Plaintiffs, causing the Plaintiffs further difficulty in obtaining funding.

Defendants has also placed on human resources and and job hiring databases negative and damaging red flags about the Plaintiffs, relative to the Gawker and Defendants attacks. These postings were intended by Defendants to prevent the Plaintiffs, not only from working for himself, but also from working for other, noteworthy individuals of good repute.

Additionally, Defendants representatives sent a copy of the Gawker attack article to an employer of the Plaintiffs via their human resources office and asked this employer, “You don't want him working for you with this kind of article out there, do you?” This resulted in the Plaintiffs immediate termination because of that article. Plaintiffs has recovered documents between Defendants showing the preplanned and premeditated deployment of this attack. As documented in one of the Hulk Hogan cases against Defendants associates: “As evidence, the lawsuit points to a Gawker article by its founder, Nick Denton, that predicted Mr. Bollea’s “real secret” would be revealed — it was posted soon before The Enquirer report — and a 14-minute gap between the publication of the article and a Gawker editor, Albert J. Daulerio, tweeting about it. “Based upon the timing and content of Daulerio’s tweet, Daulerio was aware, in advance, of The Enquirer’s plans to publish the court-protected confidential transcript,” the lawsuit argues...” Plaintiffs in this case also have the same form of evidence from the same parties.

As a proximate result of the conduct of the Defendants, the Plaintiffs and COMPANY B have suffered severe financial damage and, accordingly, loss of their good will and reputation.

Plaintiffs are informed by investigators and Defendants' own former staff that Defendants planned an effort to “take him down” in retribution for effectively competing with Defendants and for co-operating with law enforcement and regulatory investigations of Defendants.

The aforementioned acts of the Defendants were willful, fraudulent, oppressive and malicious. The Plaintiffs is therefore entitled to punitive damages.


The Plaintiffs hereby incorporate by reference the allegations set forth in all paragraphs inclusive as though fully set forth herein.

By hiring and/or making an arrangement with associated tabloids to publish an article replete with false and misleading statements disparaging the Plaintiffs, in the guise of publishing opinion, the Defendants Defendants intended to harass the Plaintiffs and did in fact harass the Plaintiffs.

By refusing to remove the offending publication and, in fact, assigning it a value associated with “truth”, “factuality” and a position in its web browser that came up and still comes up the first and most prominent link pursuant to any search for the Plaintiffs and maintaining this link for the past 5 years as globally marketed, public, published, permanent, un-editable and unmovable, Defendants intended, and continues to intend to harass the Plaintiffs.

By doing the things described in paragraphs above, Defendants, did and does continue to intend to cause the Plaintiffs substantial emotional and economic damages.

The Plaintiffs, commencing in or about their discovery of the post and the link, has experienced and continues to experience substantial economic damages.

Defendants engaged in the pattern of conduct described above with the intent to place the Plaintiffs in reasonable fear for their safety or in reckless disregard for the safety of the Plaintiffs.

The Plaintiffs admit here that Plaintiffs knew of a number of Bay Area technologists including Gary D. Conley, Rajeev Motwani who also had strange run-ins with Defendants and who subsequently suffered strange terminations per investigators and media who continue, at the request of the families and friends of those individuals, and others, to examine those cases. This has caused concern and stress for Plaintiffs. While Defendants did not necessarily have the intent to do physical harm to the Plaintiffs, by arranging for publication of the subject article, ensuring the subject article could not be moved or altered and would be certain to appear first and permanently as the result of any search for the Plaintiffs, intended to do significant damage to Plaintiffs financial interests in retaliation for their testimony at the proceedings described above and also intended to ensure the Plaintiffs would have no future as a competitor in the industry of technology populated by the Plaintiffs and by the Defendants.

Defendants chose to cheat rather than compete and decided, as a whole to plan, operate and deploy “hit jobs”, defamation attacks, media hatchet jobs, character assassinations, venture capitol black-lists, technology hiring no-poaching blacklists, public officials influence buying and other illicit tactics against Plaintiffs, public officials, journalists, ex-employees, political candidates and others, as retribution, vengeance and vendetta tactics.

The results of any search for the Plaintiffs on Defendants search engine are attached hereto in the Exhibits and incorporated herein by reference. These same results have remained consistently in place and unmovable and un-editable since the first attacks by Defendants.

The Plaintiffs did contact Defendants with written requests to remove the offending content. [See, Correspondence, a true and correct copy of which is attached hereto as Exhibits and incorporated herein by reference.] In response, Defendants consistently stated it has no control over the results of any search on its search engine or the operation of its technology or its algorithm and, accordingly, refused to remove the results or cease the harassment.

Defendants continues to refuse to allow any member of the public to search for the Plaintiffs, without locating results that falsely identify the Plaintiffs in a negative and damaging narrative contrived for the sole intended purpose of Plaintiffs financial and social destruction.

As so aptly stated by Hulk Hogan’s lawyers in their own suit against associates of the Defendants: The Defendants “chose to play God.”


The Plaintiffs hereby incorporate by reference the allegations set forth in all paragraphs inclusive as though fully set forth herein.

As above, in response to the request of the Plaintiffs regarding removal of the Gawker article of the Defendant stated that has no control over the results of any search on its search engine and no control over the results of its algorithms, refused to and continues to refuse to allow any member of the public to search for the Plaintiffs, without publishing results that falsely attack Plaintiffs

The Defendant made this statement with the intent to induce the Plaintiffs Company A to rely on it. The Plaintiffs continued to rely on the statement and to believe that the Defendant has not power or authority to manipulate the results of searches conducted on its search engine until in or about mid 2015 when it became clear as the result of the litigation commenced in Europe by The European Commission, that Defendant does in fact have such ability and does, in fact, exercise this ability regularly to manipulate and manage any of the results of any search on its engine.

Defendants made the following representation(s) to the Plaintiffs: They stated that Defendants had no control over the public experience of its products, page ranking and link presentation and that all results were arbitrary and a matter of luck.

The representations made by the defendant were in fact false. The true facts are that Defendants owners and executives can freely, consciously and manually rig, manipulate, modify, mood emphasize, re-rank, hide, adjust psychological adjacency perceptions of above-and-below text, delete or otherwise affect the local, regional, national and global perceptions of the public overall, or any market segment, or demographic, at will, in precise, controlled and monitored manipulations and that Defendants has even sold these manipulations-as-a-service to private clients.

When the defendant made these representations, he/she/it knew them to be false and made these representations with the intention to deceive and defraud the Plaintiffs and to induce the Plaintiffs to act in reliance on these representations in the manner hereafter alleged, or with the expectation that the Plaintiffs would so act.

The Plaintiffs, at the time these representations were made by the defendant and at the time the Plaintiffs took the actions herein alleged, was ignorant of the falsity of the defendant’s representations and believed them to be true. In reliance on these representations, the Plaintiffs was induced to and did delay their attempts to have Defendants cease their abuse of Plaintiffs by technical means. Had the Plaintiffs known the actual facts, he/she would not have taken such action. The Plaintiffs reliance on the defendant’s representations was justified because Defendants stated that they represented government interests and because FTC and SEC investigation manipulations, by Defendants, had not yet been fully exposed in the news media.

As a proximate result of the fraudulent conduct of the defendant(s) as herein alleged, the Plaintiffs was induced to expend  hundreds of hours of their/her time and energy in an attempt to derive a profit from their ventures which were covertly under attack by defendant(s) but has received no profit or other compensation for their/her time and energy], by reason of which the Plaintiffs has been damaged in the sum of at least two billion dollars based on the minimum reported amounts by which Defendants profited at Plaintiffs expense and the paths of direction which Plaintiffs were steered to by Defendants fraudulent misrepresentations.

The aforementioned conduct of the defendant(s) was an intentional misrepresentation, deceit, or concealment of a material fact known to the defendant(s) with the intention on the part of the defendant(s) of thereby depriving the Plaintiffs of property or legal rights or otherwise causing injury, and was despicable conduct that subjected the Plaintiffs to a cruel and unjust hardship in conscious disregard of the Plaintiffs rights, so as to justify an award of exemplary and punitive damages.


The Plaintiffs hereby incorporate by reference the allegations set forth in all paragraphs inclusive as though fully set forth herein.

The Defendant, first by arranging for and allowing/posting the gawker article, then by coding a link to the article that permanently placed the article at the top of any search results for the Plaintiffs, Company A, has invaded the inalienable privacy rights of the Plaintiffs, Company A as protected by Article I section 1 of the Constitution of the State of California and violated the human right known as “the right to be forgotten”, now overtly supported in other nations.

The intrusion commenced with the first attack and continues to this day, is significant and remains unjustified by any legitimate countervailing interest of the Defendant.

For five years, when any member of the public searches on the Defendant search engine holdings, for the Plaintiffs, Company A, the first link to pop up refers to the Plaintiffs, Company A via Defendants severs and postings which are locked in position on the internet. A situation which could only possibly occur if Defendants and their partner Google were maliciously rigging the internet results and processes.

The pervasiveness and longevity of this link plus its placement at the very top of any search result has resulted in a significant, albeit intentional interference with the right of the Plaintiffs Company A to engage in and conduct personal and business activities, to enjoy and defend life and liberty, acquiring possessing and protecting property and pursuing and obtaining safety, happiness and privacy.

The Gizmodo/Gawker/Jalopnik Nick Denton Tabloid attacks on Plaintiffs were and remain false. Even in the event the Gizmodo/Gawker/Jalopnik Nick Denton Tabloid article might have at one time garnered protection by the First Amendment as opinion regarding a public controversy and about a non-public figure, no further controversy exists or even could.

Five years have passed and, despite the lack of current content of controversy, the Plaintiffs, Company A remains saddled with a personal, permanent and immovable reference on the internet that characterizes Plaintiffs in horrific character assassination efforts.

The Plaintiffs Company A has done the best he could in these years to move on with new projects and new investors. He has made every effort to start anew and has been precluded from doing so by the Gizmodo/Gawker/Jalopnik Nick Denton Tabloid attacks hired by Defendants.

Maintenance of the original attack postings for five years is offensive and objectionable to the Plaintiffs Company A and certainly would be to a reasonable person of ordinary sensibilities in that the original posting is false and defamatory and was intentionally arranged for by Defendant so as to do significant damage to the personal and professional reputation of the Plaintiffs, Company A, because it has accomplished this damage, because there is no manner other than at the Defendant Defendants hand by which the link can be altered or removed or the search results edited or limited and because there exists no reason that the Plaintiffs Company A should not be allowed to enjoy a right to move on with is life independent of a label that had no basis in truth and reality in the first place.

The facts regarding the character of the Plaintiffs, Company A, included in the Gizmodo/Gawker/Jalopnik Nick Denton Tabloid articles are certainly no longer of any legitimate public concern nor are they newsworthy nor are they tied to any current controversy or dialogue.

IN FACT, THE Plaintiffs, can truly no longer be considered a public figure or even a semi-public figure as the Gizmodo/Gawker/Jalopnik Nick Denton Tabloid article has fairly successfully put him out of business and kept him out of business for the past five or more years.

As a proximate result of the above disclosure, Plaintiffs lost investors, contracts, was scorned and abandoned by their/her friends and family, exposed to contempt and ridicule, and suffered loss of reputation and standing in the community, all of which caused them/him/her humiliation, embarrassment, hurt feelings, mental anguish, and suffering], all to their/her general damage in an amount according to proof.

As a further proximate result of the above-mentioned disclosure, Plaintiffs  suffered special damages to the brand, financing, reputation and market timeframe opportunities for their/her business, in that they lost funding, market share, federal contracts and other income, to their special damage in an amount according to proof.

In making the disclosure described above, defendant was guilty of oppression, fraud, or malice, in that defendant made the disclosure with  (the intent to vex, injure, or annoy Plaintiffs or a willful and conscious disregard of Plaintiffs rights. Plaintiffs therefore also seeks an award of punitive damages.

Defendant has threatened to continue disclosing the above information. Unless and until enjoined and restrained by order of this court, defendant’s continued publication will cause Plaintiffs great and irreparable injury in that Plaintiffs will suffer continued humiliation, embarrassment, hurt feelings, and mental anguish. Plaintiffs has no adequate remedy at law for the injuries being suffered in that a judgment for monetary damages will not end the invasion of Plaintiffs privacy.


The Plaintiffs hereby incorporate by reference the allegations set forth in all paragraphs inclusive as though fully set forth herein.

The Plaintiffs brings this action on their own behalf and on behalf of all persons similarly situated. The class that the Plaintiffs Company A represents is composed of all persons who, at any time since the date four years before the filing of this complaint, sought to have offensive, irrelevant and outdated material posted to the internet and available through a search on the Defendant search engine corrected, removed or re-ranked and have been informed by the Defendant that the Defendant does not have the ability to do so and that Defendants falsely states this assertion in Defendants published policy.

The persons in the class are so numerous, an estimated 39% of the population of the United States of America, that the joinder of all such persons is impracticable and that the disposition of their claims in a class action is a benefit to the parties and to the court.

There is a well-defined community of interest in the questions of law and fact involved affecting the parties to be represented in that each member of the class is or has been in the same factual circumstances, hereinafter alleged, as the Plaintiffs . Proof of a common or single state of facts will establish the right of each member of the class to recover. The claims of the Plaintiffs are typical of those of the class and the Plaintiffs will fairly and adequately represent the interests of the class.

There is no plain, speedy, or adequate remedy other than by maintenance of this class action because the Plaintiffs is informed and believes that each class member is entitled to restitution of a relatively small amount of money, amounting at most to $5,000.00 each, making it economically infeasible to pursue remedies other than a class action. Consequently, there would be a failure of justice but for the maintenance of the present class action.

The Defendant  is a business incorporated in the State of California and at all times herein mentioned owned and operated a its search engine and its ancillary commercial enterprises from its headquarters in Mountain View California.

GAWKER/GIZMODO/JALOPNIK, a well-known internet libel and slander processing tabloid service published media about the Plaintiffs. The media falsely, maliciously and without regard for the truth, labeled the Plaintiffs, in a malicious negative light.

Any search on the Defendant’s search engine for “Company A” resulted and to this day still results in a display of the Gizmodo/Gawker/Jalopnik Nick Denton Tabloid article with the Plaintiffs described as a horrible person.

Publication of the article by Gizmodo/Gawker/Jalopnik Nick Denton Tabloid and the linking by GOOGLE caused the Plaintiffs immediate and irreparable harm to their reputation, to their business interests and to their personal life. Financial records acquired by Plaintiff’s and law enforcement reveal millions of dollars of payments transacted between Defendants and the Gizmodo/Gawker/Jalopnik Nick Denton Tabloid hit job publishing empire to pay for these character assassination revenge vendetta services.

Some five years have passed and the Plaintiffs, Company A, continues to suffer damage to their reputation to their business interests and to their personal life as the result of the publication by Gizmodo/Gawker/Jalopnik Nick Denton Tabloid and GOOGLE’S rigged link to it.

The Plaintiffs directed a written request to the Defendants to unlink the Gizmodo/Gawker/Jalopnik Nick Denton Tabloid publication to any search for their name or to delete the offending article.

The Defendant, responded by stating that it had no ability or legal obligation to do so as the request didn’t fall within its own policies for removal.

The position of the Defendant is illegal, false and unfair.

The position of the Defendant is illegal as it infringes on the rights of individuals as protected by the Constitution of the State of California which protects the rights and freedoms of individuals to: “All people are by nature free and independent and have inalienable rights. Among these are enjoying and defending life and liberty, acquiring, possessing, and protecting property, and pursuing and obtaining safety, happiness, and privacy.” per the State Constitution.

The position of the Defendant is unfair as it deprives individuals of rights protected by the Constitution of the State of California which protects the rights and freedoms of individuals to: “All people are by nature free and independent and have inalienable rights. Among these are enjoying and defending life and liberty, acquiring, possessing, and protecting property, and pursuing and obtaining safety, happiness, and privacy.”

The position of the Defendant, is false because, as a processor of personal information and a controller of that information, the Defendant also possesses the technical, logistical and government official manipulation power and ability to delete, re-rank and mood manipulate any information obtained as the result of a search on its search engine.

As a direct, proximate, and foreseeable result of the Defendant’s wrongful conduct, as alleged above, the Plaintiffs  and millions of others other members of the Plaintiffs class, who are unknown to the Plaintiffs but can be identified through inspection of the Defendant’s records reflecting requests for removal it has already received and by other means, have been subjected to unlawful and unwanted publication of in accurate, inadequate, irrelevant, false, excessive, malicious and defamatory internet postings about themselves and as a result of the Defendant’s present policies, have thereby been deprived of their right to privacy and the right to control information published about them as this control now apparently is vested in the Defendant and not in and of themselves.

The Plaintiffs is entitled to relief, including full restitution for the unfair practices of the Defendant as these have damaged their reputation and their business prospects and deletion or de-ranking of any article naming Plaintiffs in horrific character assassination efforts. as inaccurate and currently irrelevant.

The Defendant, has failed and refused to accede to the Plaintiffs’s request for a removal of the offending article or for any de-ranking or separation of the article from a search for their name. The Plaintiffs is informed and believes and thereon alleges that the Defendant has likewise failed and refused, and in the future will fail and refuse, to accede to the requests of other individuals requests for removal, de-ranking or the separation of search results from a simple search for their name.

The Defendant’s acts hereinabove alleged are acts of unfair competition within the meaning of Business and Professions Code Section 17203. The Plaintiffs is informed and believes that the Defendant will continue to do those acts unless the court orders the Defendant to cease and desist.

The Plaintiffs has incurred and, during the pendency of this action, will incur expenses for attorney’s fees and costs herein. Such attorney’s fees and costs are necessary for the prosecution of this action and will result in a benefit to each of the members of the class. The sum of $500,000.00 is a reasonable amount for attorney’s fees herein.


The Plaintiffs hereby incorporate by reference the allegations set forth in all paragraphs inclusive as though fully set forth herein.

Plaintiffs venture fund has founded, funded and launched multiple business ventures based on novel new technology inventions. In the majority of the cases, Defendants engaged in industrial espionage of Plaintiffs new ventures, including using agents to solicit Plaintiffs for information under the guise of “possibly investing”, and then copied and exploited those ventures for substantial profit while running attacks on Plaintiffs venture in order to blockade any attempt at competition. Defendants engaged in systematic venture capitol black-listing, funding cartels, the hiring of attack-media hatchet job bloggers, internet search rigging and numerous other dirty tricks campaigns in order to steal technology and business ideas. SEC, U.S. Senate Investigators, broadcast news journalists, other federal investigators and records from other lawsuits have provided testimony that Defendants have paid Gawker Media “tens of millions of dollars” for “special services”. Of millions of publications in the world, only Gawker Media engaged in the media attacks against Plaintiffs and only the Defendants derived the core benefits of those attacks. A list of the Plaintiffs business ventures interdicted and copied by Defendants includes the following. U.S. Patent Office records, NDA’S, email leaks, contracts and federal recordings show that Plaintiff’s built and marketed the first versions of Google and YouTube. Defendants knew Plaintiffs and copied their work and formed their versions of Google and YouTube after seeing Plaintiffs technology and copying it.

Kleiner Perkins is Defendants main investor; Suspected by federal investigators to have had a hand in the attacks on Plaintiffs).

Defandants did have their agents, investors, executives and staff contact Plaintiffs under the guise of "considering an investment" in order to induce Plaintiffs to disclose trade secrets under false promises of confidentiality

The New York Times newspaper and digital publications group published an investigative article entitled: "How Larry Page's Obsession Became DefendantsBusiness " on January 22, 2016 by CONOR DOUGHERTY. This article describes the manner in which Defendants founder, Larry Page, seeks to steal ideas, for Defendants, from young entrepreneurs and inventors, much as he appears to have done to Plaintiffs. The article discloses the covert manners in which Defendants harvest intellectual property without revealing their true identies or actual intentions.

Hundreds of reporters, clients and members of the public have commented that: "Defendants seems to copy everything you come up with" to Plaintiffs. In one specfic instance, a television show entitled the Silicon Valley Business Report did a broadcast report demonstrating how Plaintiffs company appeared to have been nearly 100% copied by Defendants'sYouTube. In another instance, the globaly broadcast TV Network E! Entertainment Network produced a network TV segment about Plaintiffs creation: "Scott Glass" which was later copied by Defendants as: "Defendants Glass" with nearly verbatim features, appearance.

CBS News staff, including Bob Simon of 60 Minutes CBS News, did inform Creditors that Defendants did attack, interfere with the business of, defraud, cyber-stalk and engage in RICO statute violations of Creditors as exemplified in the FBI Solyndra, Cleantech and Obama Administration campaign financing quid-pro-quo investigations since 2007.

Federal corruption hearings and court trials in Washington DC have proven these facts and ruled that Creditors were in fact subjected to reprisal, vendetta and retribution actions financed and directed in part by Defendants.

Former staff of a company called KiOR have whistle-blown as to the veracity of facts about Defendants and recent CIA/FBI and Russian Hacks of Khosla have confirmed the veracity of damages by Defendants against Creditors.

Defendants have sent numerous proxies to spy on and interfere with Creditors under the guise of “helping” Creditors or “considering an investment in Creditors”.

Creditors report to the FBI and have privileged access to Federal executive officials such that law enforcement knowledge is shared.

House Ethics investigators and San Jose Mercury News investigators have provided additional evidence and verifying data.

Tens of billions of dollars of profits were acquired by Defendants while infringing Plaintiffs technologies, and Defendants sought to damage and delay Plaintiffs ability to seek recovery.

Defendants maliciously harmed revenue stream of Plaintiffs in order to prevent or delay legal action by Plaintiffs in order to seek to expire statute of limitations. Causes of action continue to this day and Plaintiffs only recently discovered much of the inside information via law enforcement and federal investigators.

Defendants’ founders personally solicited and copied CEO business ventures and technologies and wanted to harm Plaintiffs’ brand in order to mitigate discovery of that fact.

Plaintiffs testified for federal law enforcement against Defendants and Defendants sought to engage in retribution for Plaintiffs’ testimony. In previous related cases, Plaintiffs won historical national legal precedents and overcame multi-million dollar federal litigation counter-measures by Defendants’ and their associates. Plaintiffs are the first known Americans to receive a federal court confirmation that they were victimized by “a federal program infected with corruption and cronyism”. Defendants were the “crony’s” referred to by the U.S. Courts. The U.S. Federal Court has now issued one of, if not the, first rulings in U.S. Federal Court Record stating that Plaintiffs were in fact attacked by corrupt federal employees.

Plaintiffs’ technologies obsolete Defendants’ technologies and Defendants sought to damage Plaintiffs as witnesses and competitors.

Defendants sabotaged Plaintiffs’ government contracts and circumvented and acquired Plaintiffs’ money through illicit actions. Defendants traded campaign financing, that was not properly reported, in exchange for insider contracts and stock valuation pumps.

Defendants covertly work together and share common stock transactions, trusts, shell companies, campaign financing, contracts, and personal relationships.

Defendants operate a cartel-like organization which fully meets RICO violation parameters.

Defendants have been reporting to FBI, OSC, GAO, FTC, CFTC, EU, SEC and U.S. Congress on this case for many years and supportive federal case files are already deeply for this matter and any future Special Prosecutor hearings.

Defendants cannot argue time bar statute of limitations due to attacks as recently as today and revelations by the Justice Department as of this week.

Defendants cannot argue “Conspiracy Theory” or “Fake News” because the overwhelming current public opinion will destroy them within a week (ie: Voat.co)

95% of the entire 2017 White House Administration supports this case because Defendants spent hundreds of millions of dollars attacking 95% of the entire 2017 White House Administration. Every new FBI director on the short-list for the new FBI supports this case.

Plaintiffs have an advance copy of Defendants potential defense plan against this case. Plaintiffs have ongoing resources from law enforcement, investigators and journalists with deep factual repositories. China & Russia are thought to have hacked Defendants, and have begun posting leaks which are helpful to this case. In this election year, more beneficial leaks are expected by the press. Global public trends are tracking negative on Defendants. Plaintiffs won a federal court decision in a partially related case in which investigators found a “Cartel controlled by Defendants” to be the primary financier of the illicit activities. Recent news and government investigation reports prove that Defendants wild and bizarre actions actually took place, even though Defendants tries to play the charges off as “fantastical”, in circumventing due process and government ethics programs. News reports of Defendants investors and executives sex scandals and tax evasions prove bad character aspects of defendants.

Defendant's attorney Michelle Lee runs the patent office and may have already attempted to interfere with Plaintiffs patent filings, The Defendants-created ALICE and IPR disruptions put Plaintiffs existing patents at risk if any of their patent #’s are named. One day after Plaintiffs was told they were about to receive their most recent patent, which USPTO had determined over-rode Defendants and Facebook, the USPTO reversed their decision after interjection from Defendants USPTO-based staff.

According to large numbers of investment publications, including Investor Place publication: Tesla Motors TSLA Stock: "Tesla Motors Inc is "Worth $660 Billion".Today, Apple Inc. (AAPL) is the largest company in the world. But Tesla Motors Inc (TSLA) stock could rocket so high in the next 10 or 15 years that the currently $33 billion automaker exceeds even Apple’s $540 billion valuation. That’s according to billionaire investor Ron Baron, CEO of Baron Capital, who went on CNBC this morning to rave about TSLA stock.” There is more than enough proof that experts value Tesla Motors at a minimum of $33B and over $660B at a higher argument point. Plaintiffs competing car company, which had solved all of the problems Tesla has had and has a higher volume sales potential due to it’s lower retail pricing was worth at least $33B and in excess of $700B and that that one consideration accounts for $700B of damages caused by Defendants in their attacks designed to interfere with the existence of Plaintiffs car company. In like manner, Plaintiffs broadcasting network was supplanted by Defendants broadcasting network which is now equivalent to Netflix or Univision. Motley Fool published a report that “Shares of streaming video pioneer Netflix (NASDAQ:NFLX) have had another outstanding year in 2015. The stock hit a new all-time high of $132.20 last week. As Netflix stock has taken off, the company's market cap has surged from around $20 billion in January to a staggering $56 billion today.” Univision has publicly stated that it is worth $25B in its SEC filings. Thus Defendants attacks cost Plaintiffs venture group $56B of additional damages by attacking and cloning another of Plaintiffs technologies and businesses. Plaintiffs energy company offered the equivalence of the energy company Bloom Energy which has a market valuation of $3B and thus justifies a loss valuation to Plaintiff of at least $3B. Copy cat companies Tesla Motors, Netflix and Bloom Energy are owned by, managed or co-mingled with Defendants Cartel as are Google and other holders. These companies have been proven, and will again be proven before the jury, to have been first developed, launched, marketed, patented, documented, commended and offered by Plaintiffs. Thus Defendants are clearly documented engaging in over $720B of damages to Plaintiffs via their coordinated malicious attacks, ongoing Streisand-Effect re-attacks, copy-cat efforts, circumvention of Plaintiffs federal funds into Defendants pockets, interference and other actions. Defendants argument of “how could one entity have so many companies?” is made moot by the fact that EACH of defendants principles and associates own HUNDREDS of companies apiece.

Damage Awards Demanded

- A percentage of each Defendants profits during the period in question.

- A mandated award of the federal contract that Defendants interdicted from Plaintiffs for Plaintiffs global vehicle manufacturing and energy companies by terminating Plaintiffs State and Federal funds and placing those funds in Defendants bank accounts.

- A percentage of the companies known as Defendants or Alphabet or a percentage of their revenue

- A percentage of all profits from Plaintiffs technologies used by Defendants

- Court ordered termination of the Gizmodo/Gawker/Jalopnik Nick Denton Tabloid Hit-Jobs-For-Sale Empire and the termination of the RICO violating Google/YouTube/Alphabet Cartel.

- Hit-Job damages awards (Hulk Hogan received a $145M award for the same type of attack by the same parties. At all times Defendants and operative attackers were in the employ, command and control of each other and exchanged remuneration)

- Loss of income since the start of operations of Defendants

- Punitive damages

- Other damages in excess of five billion dollars

Signed and Confirmed:



(Contact our office for screen shot, DNS report and server log print-outs)


BOOM! Georgia Judge REFUSES to Throw out CNN’s Effort to Dismiss a Fake News Court Case, Cites “a Series of False and Defamatory News Reports”

CNN is now on the verge of being proven a fake news source by Georgia courts! CNN attempted to get the case dismissed involving Davide Carbone, CEO of St. Mary’s Medical Center in West Palm Beach who accused CNN of fabricating a story about his hospital.


(Contact our office for screen shot, DNS report and server log print-outs)

Federal Judge Orinda Evans
Zach Porter/Daily Report

Citing a “series of false and defamatory news reports” that insinuated St. Mary’s had an infant mortality rate that was 3 times higher than the national average while ignoring information that made the Medical Center look good. The libel lawsuit against CNN seeking $30 million in damages will continue onward thanks to federal district judge Orinda Evans.

Here is CNNs Fake news report about St. Mary’s they still have on their YouTube Page.

Carbone, who actually lost his job due to the fake news reports “has presented enough evidence at this early stage of the case to suggest that CNN ‘was acting recklessly with regard to the accuracy of its reporting” according to The National Law Journal.

To make matters worse, judge Evans also found evidence of “actual malice” when insisting on reporting the Medical Center was under an official investigation, even after Florida’s Agency for Healthcare administration adamantly denied this was taking place.

Carbone’s lawyer describes the ruling as a major victory.

False and defamatory accusations against real people have serious consequences,” he said. “Neither St. Mary’s or Mr. Carbone did anything to deserve being the objects of the heinous accusation that they harmed or put babies and young children at risk for profit.”

The ruling,” he added, “serves as a well-reasoned reminder that the media, its defense lawyers, and its lobbyists do not have a corner on the market of correct interpretation and application of the First Amendment.”


The Hit Job

How much do you have to pay Google, Alphabet, YouTube and Black Cube to dedicate a portion of their servers to push a character assassination set of links, against a competitor, to all five billion people on Earth with internet access? How much did Obama, Clinton, Bloomberg spend using those exact same systems to attack their political enemies?

We know. We have their financial records, invoices and receipts and so does the FBI and the NSA.

How much do you have to pay to get them to lock those attack links on one of the first 4 lines of EVERY search result, in the same position in the search results, for over a decade (which proves that their search results are not "organic", they are manually manipulated by Google and YouTube)? How much did Obama, Clinton, Bloomberg spend using those exact same systems to attack their political enemies?

We know. We have their financial records, invoices and receipts and so does the FBI and the NSA.

How much does it cost to make a Disney-like animated movie about a whistle-blower? How much does the production and software and person-hour billings cost? How much does it cost to distribute that movie world-wide and lock it in the top line of all search results?

We know. We have their financial records, invoices and receipts and so does the FBI and the NSA.

How much does it cost to hire a warehouse full of Russian, Nigerian and Chinese click-farm operators who use Palantir and Google software to instantly be alerted of any mention of a person's name on the internet and to then go slam that person in the comment sections with endless troll remarks? Elon Musk uses these same people to hype his narcissistic need for attention. Obama, Clinton, Bloomberg and other politicians hire these same people to attack their political adversaries. How much does it cost to have anonymous trolls in foreign countries kill a person's brand globally?

We know. We have their financial records, invoices and receipts and a huge number of lawsuits, court records, federal investigation and investigative journalism reports have exposed those records and details. The FBI, NSA, SEC, FTC and Congressional investigators can also confirm these numbers!

So it turns out that it costs: $35,422,152.00 to have a person and their business killed!

That is how much they spent on their attack on the Plaintiff! The people at the top of the heap who organized the attacks were David Plouffe, Jay Carney, David Axelrod, Denis Mcdonough, Steve Rattner, Robert Gibbs, Rahm Emanual and their associates and they did it from The West Wing and The Oval Office in The White House.

Many of the political attacks were edited by Nick Denton and his seedy tabloid empire Gawker/Gizmodo. Investigations have revealed that the White House and California Senators hired IN-Q-Tel; Gawker Media; Jalopnik; Gizmodo Media; K2 Intelligence; WikiStrat; Podesta Group; Fusion GPS; Google; YouTube; Alphabet; Facebook; Twitter; Think Progress; Media Matters); Black Cube; Correct The Record; Orbis Business Intelligence, Undercover Global Ltd; Stratfor; Jigsaw; ShareBlue/Acronym; Cambridge Analytica; Sid Blumenthal; David Brock; Plouffe Consulting; PR Firm Sunshine Sachs; Covington and Burling; Buzzfeed; Perkins Coie; Advance Democracy Inc.; The Democracy Integrity Project; Popily, Inc; Bean, LLC.; Edward Austin; Istok Associates; Silicon Valley Community Foundation; Yonder and Wilson Sonsini to run hit-jobs, character assassinations, dirty tricks and economic reprisal attacks on any applicants who reported the crimes. Each of those companies are now under federal and civil investigation.These companies sell "kill services" that use CIA and KGB-style tactics to harm witnesses and whistle-blowers.

Media Matters for America founder David Brock is a hired media assassin who reaped illegal profits through the transfer of millions from a nonprofit he founded to a for-profit entity under his control, according to an IRS complaint filed by a watchdog group. The complaint details how Brock’s nonprofit group American Bridge Foundation (AB Foundation) transferred $2.7 million in tax-exempt assets to True Blue Media, a for-profit company owned by Brock that is the parent company of ShareBlue, a for-profit media company now known as The American Independent. The transfers violated IRS rules that prohibit nonprofit organizations from using their tax-exempt resources to pay personal or private expenses of any key figures connected to the nonprofit, the complaint stated. AB Foundation’s transfers to True Blue Media were disclosed in the nonprofit’s Form 990s filed to the IRS in 2017 and 2018. "Brock is a well-known hit man who took money to target our group in reprisal for whistle-blowing...." Said Team 7 staff.

The money was conduited and assisted for pass-through by political financiers Eric Schmidt, Larry Page, Sergy Brin, Elon Musk, John Doerr, Vinod Khosla, Steve Westly, Steve Spinner and their Silicon Valley oligarch Cartel black-listing operation.

It was a felony. It violated RICO, Anti-Trust and Constitutional laws.

So they spent over thirty five million dollars attacking the Plaintiff and shutting down a competitor that was targeted to make over six billion dollars in profits. The attackers then made the six billion dollars in profits for themselves, at the expense of the Plaintiff.

So how much do you think they owe the Plaintiff per previous court awards for such crimes against a member of the public?

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"Silicon Valley's No-poaching Case: The Growing Debate over Employee Mobility." Knowledge@Wharton. The Wharton School, University of Pennsylvania, 30 April, 2014.

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1 Defendants has a variety of such hidden codes and has various internal names for such codes besides, and in addition to, “PR8”. Defendants has been proven to use these fact vs. fiction rankings to affect elections, competitors rankings, ie: removing the company: NEXTAG from competing with Defendants on-line; or removing political candidates from superior internet exposure and it is believed by investigators and journalists, that Defendants are being protected from criminal prosecution by public officials who Defendants have compensated with un-reported campaign funding.

2 The EU case, and subsequent other cases, have demonstrated that Defendants sells such manipulations to large clients in order to target their enemies or competitors or raise those clients subliminal public impressions against competitors or competing political candidates. In fact, scientific study has shown that although Defendants claims to “update its search engine results and rankings, sometimes many times a day”, the attack links and codes against Plaintiffs have not moved from the top lines of the front page of Defendants for over FIVE YEARS. If Defendants were telling the truth, the links would have, at least, moved around a bit or disappeared entirely since hundreds of positive news about Plaintiffs was on every other search engine EXCEPT Defendants. Many other lawsuits have now shown that Defendants locks attacks against its enemies and competitors in devastating locations on the Internet. The entire nations of China, Russia, Spain and many more, along with the European Union have confirmed the existence and operation of Defendants“attack machine”.

3 Major public figures and organizations, including the entire European Union, have also accused Defendants of similar internet manipulation by Defendants. The attacks, by Defendants, continue to this day. In 2016, the renowned Netflix series: “House of Cards” opened its sixth season with a carefully held script-surprise researched by the script factuality investigators for the production company of “House of Cards.” The surprise featured Defendants, fictionally named “PollyHop,” and described, in detail, each of the tactics that Defendants uses to attack individuals that Defendants owners have competitive issues with. The Plaintiffs maintains that each and every tactic included in the televised example were tactics actually used to attack the Plaintiffs, his intellectual properties, his peers and his associates as threatening competitors.