Archive for September, 2012

Guava v. Skyler Case

As I blogged two posts below, I was on vacation in a place where forests smell like ripe guava. I am not making it up and have plenty of pictures of the trees covered with yellow and red fruit. It is a smell of a paradise. However, the Guava that is getting rotten in the Cook County court (Illinois) stinks badly. I am talking about the most fraudulent case in Prenda’s history, Guava v. Skyler Case, which was ill-conceived on 6/29/2012.

The page dedicated to the Guava case is the most visited as of lately. You will find a brief description drafted by Raul and links to the relevant documents there. The page traffic and the number of comments back Raul’s guess that the number of “co-conspirators” is staggering. I encourage you to read the comments to understand the unprecedented extent of Prenda’s arrogance and bad faith.

It is widely suspected that Guava is no one else than Lighspeed Media Corporation, a company of a disgraced pornographer Steve Jones, whose market niche is underage-looking girls. He drew our attention this year after conspiring with John Steele to run a giant scam in the corrupt St. Clair county of Illinois with the help from a corrupt judge. We covered this case a lot: here is the page dedicated to it; follow the links to numerous posts from there. Currently this case is removed to the federal court and is about to collapse: crooks had audacity to add AT&T and Comcast as defendants, thus summoning the best lawyers in the industry to represent the defendants with bottomless pockets. Also, one of the best anti-troll lawyers, Booth Sweet, represents the main defendant in this case. Before Steele started chasing trouble by suing big guys, I did not know that he, in addition to his numerous “virtues,” is also a masochist.

Some things have happened on the Guava case since defendant’s attorney Adam Urbanczyk and Paul Duffy signed a brow-rising agreed order to allow subpoenas to be sent to the huge list of ISPs: attorney Erin Russell filed numerous motions to quash, which prompted the spillage of plaintiff counsel’s poisonous saliva. Ad hominem-laden plaintiff’s response is hard to read without the blood boiling sensation, yet it is rather good news: Erin seemingly hit the nerve, and the trolls are visibly angry. Paul Duffy signed this document, but I doubt he wrote it: you can sense the arrogance and insecurity of John Steele between the lines. In addition, you can compare the styles of this response and the complaint: they are obviously written by different people.

It is also necessary to mention that the judge on this case, Sanjay T Tailor, happened to be a technology savvy relatively young man, who took his time to look into this case, and he sensed the fraud: all the doubts about it were dissolved today.

9/25/2012 hearing

Today’s status hearing was very encouraging. Judge Tailor looked angry. Master Troll John Steele flew to Chicago in the midst of his hasty fleeing from Florida to Nevada (leaving formerly loyal but unmovable Mark Lutz behind). This unusual appearance clearly tells us that trolls are panicking, and Steele, who, unlike a bone-in-the-tongue Duffy, is capable of lying to judges in a smooth way, attempted to salvage the situation.

Judge started the status hearing by asking attorneys for plaintiff and defendant: “Are you in bed with each other?” Hope you did not spill your beverages. Everyone was shocked, and it all went downhill (for trolls) from there. Steele tried to preach some usual bullshit, but the judge was not amused. Judge Tailor was not convinced by the twisted logic that the so-called co-conspirators do not have standing despite the fact that they are accused of the same “crime” as the mysterious defendant, and are contacted with monetary demands. The hearing on motions (mostly Erin Russell’s clients) is set to the end of November, and undoubtedly the subpoenas will be quashed at least for those who reside outside of Illinois. I hope that the judge will not stop at that and will kill the case — banning crooks from utilizing the personal information of “co-conspirators” they already obtained from the ISPs. Moreover, I hope that Attorney General and/or federal investigators will pick up the baton from the judge.

Erin Russell was also at that hearing, and if I missed anything important, I hope she will comment below.

A carbon copy case: Arte de Oaxaca v. Mullen

A couple of days ago another frivolous case, Arte de Oaxaca v. Mullen, No. 12-L-9036, which is a carbon copy of the Guava case, was discovered in the Cook County docket. This case also has a single defendant (Stacey Mullen — is she a real person?) and an unknown number of co-conspirators (which is undoubtedly huge). The defendant is represented by Adam Urbanczyk (surprise!), and… there is another agreed order to allow discovery, signed by both Duffy and Urbaczyk, which is filed two business days (8/14/2012) after the complaint (8/10/2012), and prior to a formal defendant’s answer to allegations, which is still not filed. I am not even discussing the obvious: that this case does not belong to the county level and should have been immediately removed to the federal court.

It is indeed a carbon copy: sloppy Steele & Duffy did not even proofread their pleadings, leaving “Skyler Case” in the “Prayer of Relief” section, which technically makes the entire complaint invalid.

Note that the judge on this case introduced some safeguards, which is encouraging:

We gave a lot of benefit of doubt to EFF-listed Adam Urbanczyk, but our patience is running thin, and if even the judge suspects collusion and does not hesitate to openly talk about it, we cannot pretend anymore that Adam plays a fair game and his actions can be somehow excused. He is welcome to comment here, and if he can answer our questions and explain his actions in a way that proves his good faith, I see no problem in apologizing, but I doubt such a miracle will happen. All this is really sad: Adam is very young and this ordeal won’t reflect positively on his future career, especially if this scam is investigated by the authorities.

Conclusion

Since I used words farce, fraud, frivolous describing much less brazen abuses of the court system by copyright trolls, I ran out of epithets. I cannot find proper words that describe this garbage. And it will get even worse: we will for sure witness more fraud if Prenda criminals are not deterred ASAP. What can you do? First and foremost, do not settle. It is unnecessary and only fuels the extortion machine. There are few situations when one simply cannot afford that his or her name is dragged through dirt, but most people pay out of irrational fear and the lack of research. If you have money to spend, better spend it on a trusted attorney. And, of course, complain, complain, complain: to the media, FBI, Attorneys General, Bar associations. One voice can be ignored, ten voices can be ignored, but hundreds and thousands? I do not think so.

Update: 10/04/2012 hearing

All subpoenas are stayed.

Today’s hearing brought no surprises: judge Tailor was still not convinced that the case is adversarial in nature and refused to buy any conspiracy claims. John Steele was sweating and throwing tantrums in the courtroom, which he continued doing on Twitter (check his childish vindictive rants today): Illinois Bar Association apparently still thinks that Steele’s behavior is a model of professional conduct for others to follow. #facepalm

But I digress. The hearing has resulted in the following sua sponte (!) order (I decrypted clerk’s handwriting below):

This matter coming before this court on non-party’s emergency TRO, and the parties agreeing to the non-parties requests to inform non parties ISP to withhold the information, the Court orders, in addition, the following:

  1. Outstanding subpoenas not yet complied with by Internet Service Providers are stayed with further order of this Court.
  2. The plaintiff shall not issue any further subpoenas until further order of this Court.
  3. Plaintiff has until Oct 12 to file its answer to the various matters filed by attorney Russell. Attorney Russell shall file and reply by Oct 19.
  4. The hearing regarding all matters pending before the court, including petitioners as yet filed motion to review subpoena compliance by third party ISPs. Oct 26, 2012 at 10:30 am
  5. Nov 27, 2012 date is stricken.
  6. Counsel for plaintiff is ordered to notify all subpoenaed Internet Service Providers immediately of the entry of this order immediately by email, send a hard copy by regular mail and attempt to contact by said ISPs by telephone.

Any doubts that this turd of a case is essentially killed? Once again, it was a sua sponte order: judge Tailor didn’t issue the order because anybody asked him to do it, it was totally his idea. He said that he has started getting letters addressed to him in chambers from John Does and felt he needed to put a stop to that.

Media coverage
Follow-up
Relevant pages
  • All the documents from the state “hacking,” allegedly collusive cases are located on this page. A discussion is going on there as well.
By Raul

The locusts came up over all the land of Egypt and settled on the whole country of Egypt, such a dense swarm of locusts as had never been before, nor ever will be again. They covered the face of the whole land, so that the land was darkened, and they ate all the plants in the land and all the fruit of the trees that the hail had left. Not a green thing remained, neither tree nor plant of the field, through all the land of Egypt.
Exodus 10:12

Once again copyright troll Mike Meier has caused yet another Judge in the Southern District of New York to issue an Opinion and Order, dated 9/4/2012, condemning the copyright troll business model.


Federal Judge
Harold Baer Jr.

The judge in this case, is Judge Harold Baer, who was assigned three of Meier’s lawsuits: Media Products v. Does 1-26 (12-cv-3719), Media Products v. Does 1-40 (12-cv-3630) and Patrick Collins v. Does 1-4 (12-cv-2962). In the beginning of his order, Judge looks back to his initial decision to permit Meier expedited discovery in order to learn the personal identifying information of the Does by means of subpoenas to various ISPs. Even at that time the judge had concerns about these determinations. Accordingly (emphasis supplied in this and the subsequent quotes),

To satisfy my concerns, I provided a period of time during which Doe defendants would remain anonymous and could move to quash the subpoena or take other actions before their identifying information was turned over to Plaintiffs. Such protective orders have become commonplace in BitTorrent suits. My hope was that this would allow Plaintiffs to overcome the hurdle of the anonymity of infringement on the Internet while at the same time shielding Doe defendants from the coercive tactics employed by Plaintiffs. The relatively small group of lawyers who police copyright infringement on BitTorrent have customized the concept of extracting quick settlements without any intention of taking the case to trial.

The judge then embarks on a discussion of the difficult question of “whether the joinder of tens and sometimes hundreds or thousands of unnamed defendants in these cases is proper,” when it comes to the trolls’ swarm theory of joinder in BitTorrent lawsuits. While not deciding the issue, the Judge notes that

It is this swarm that Plaintiffs have relied on in grouping Doe defendants together in a common suit. Ironically, there are swarms on both sides, for copyright locusts have descended on the federal courts, exacting low-cost settlements from embarrassed John Does and then moving on to the next District.

In footnote 2, which accompanies this quote, the judge ponders the waste of judicial resources caused by copyright troll lawsuits:

[i]t is difficult to even imagine the extraordinary amount of time federal judges have spent on these cases.

Judge Baer seemingly takes his cue from Judge Wright, who asserted that the courts are not “cogs in a plaintiffs copyright-enforcement business model. The Court will not idly watch what is essentially an extortion scheme, for a case that [Plaintiffs have] no intention of bringing to trial.” Joining with Judge Marrero, Baer orders the severance and dismissal without prejudice of all Does except the Doe 1. The judge is

also troubled by the fact that some Doe defendants have already been voluntarily dismissed at this early stage in the litigation; it suggests as suspected that the pressure on Doe defendants to settle their case quickly and thereby avoid embarrassment and litigation costs — when they may not even have committed any infringement — is all too real.

According to Judge Baer, this unfair pressure tactic employed by the trolls,

if left unchecked, could turn copyright protection on its head. Congress intended to incentivize the creation of useful arts by providing a statutory right and a means of enforcement that would reward authors for their labors, hardly the Plaintiffs’ strategy here. […] In the BitTorrent pornography cases, settlements are for notoriously low amounts relative to the possible statutory damages, but high relative to the low value of the work and minimal costs of mass litigation. Cases are almost never prosecuted beyond sending demand letters and threatening phone calls.

Of final interest is one portion of Judge Baer’s order, which warns Troll Meier as follows:

…that Plaintiffs shall not contact any Doe defendant who does not remain in this or a subsequently-filed case, and any pending settlement not with John Doe 1 in each named case shall immediately cease. If after 14 days Plaintiffs have not reinstituted cases against the remaining Doe defendants, Plaintiffs shall destroy whatever personal information they presently have for those defendants and shall not use the information for any purpose. If any Doe defendant no longer named in a case is contacted following entry of this Order, I encourage them to contact the Court.

Below is the entire Order and Opinion:

 

In closing, I wish to thank Ray Beckerman, Esq., who was the first to point to this fine Opinion and Order as well as Mike Meier for, once again, increasing the federal judiciary’s arsenal to hinder this wasteful and predatory abuse of the federal courts.

Of course, the obvious music video to embed would be Bob Marley’s “Exodus” but I think this one is more apt:

 

Media Coverage

9/24/2012 Techdirt: Another Judge Blasts Copyright Trolls by Mike Masnick.

A short (on the European scale) break

Posted: September 7, 2012 by SJD in Housekeeping
Tags:

I’m traveling for the next 2-3 weeks starting this Saturday and won’t be able to spend more than half an hour a day on this site. Nonetheless, I will be checking my email a couple of times a day (given the Internet availability — may be totally cut off the world during the next week) and will reply to urgent requests. If anyone is willing to write a post, I will be happy to proofread/format and publish it. DieTrollDie has keys from the site and will be able to help with urgent moderation of comments (e.g. if too much personal information is revealed).

Do not feed the trolls while I’m out!

The lucrative business of copyright trolling has its limitations. One of the main limitations is lawyer manpower. It is relatively easy to harvest IP addresses from Bittorent swarms: poorly written software is cheap to maintain, especially given zero incentive to reduce the high number of false positives. On the other hand, when it comes to filing and maintaining dozens of cases, no software can replace actual licensed attorneys, and a single attorney cannot jump over his head and handle dozens of cases at once, albeit those cases are based on the same template. We have been witnessing what happens when a troll lawyer does not have enough self-respect to curb his greed and is overwhelmed with the number of frivolous cases he filed. Monster lawsuits that list thousands of Does were relatively easier to maintain, but they are a matter of the past: the probability of a judge busting such a case is too high, so trolls are forced to divide Does into smaller chunks to diversify their forum-shopping portfolio.

So what’s the problem? Hire more underemployed third-rate lawyers! Not so fast: finding a lawyer who is willing to bring his reputation to the altar of the Mammon is not that easy. Prenda’s Brett “Pinocchio” Gibbs’s job posting is still up for more than a month, and we witness lawyers that were conned into collaboration by master trolls running away after they realize what kind of manure they stepped in and decide that they don’t want to live with the stink.


Ralf Pytlik, Sales manager
at copyrightdefenders.com

Today I had a chance to look inside of the troll kitchen: embedded below is an email sent by one of the “troll wholesalers”, copyright-defenders.com, to various IP lawyers across the country in a hope that some would agree to be a part of a lucrative shakedown conspiracy.

Copyright-defenders.com is a German mob operation, same as Excubitor. All shakedowns they architect are based on a dubious super-secretive software and disingenuous declarations of its president Matthias Schröder-Padewet, who also supplies his “impeccable evidence” to Randazza. These fraudsters were “lucky” to work with the cream bottom slime of troll lawyers: Kenneth “Felon” Ford, Evan “Chutzpah” Stone¹ and Paul “Anal” Lesko.

As one of the attorneys who received this email commented,

…it was interesting that they are very misleading to the attorneys they are trying to recruit in that they affirmatively claim that all persons whose names are turned over are identified infringers. I think this is where some less sophisticated attorney could really get tripped up as it has already been judicially determined that an IP address does not actually identify a human let alone an infringer. I also think it is interesting that there is no indication that the attorneys have to do anything other than send “letters.” No talk about litigation, defense, discovery etc… Apart from the obvious abuse of process aspects, and I am not an expert on this, but at first glance this would seem to be a false and misleading business practice which is generally illegal under various state laws.

I hope that any lawyer who receives such email will do his research and inevitably stumble upon this post. I’m sure he will think twice before associating himself with this mob-like business and damaging his career (and karma).

Another interesting document: Excubitor service contract — it was sent to various US lawyers last year (although this contract is clearly specific to Germany, for some reason it has been written in English and distributed here).

Thanks to the readers who provided leads and links for this post.

Featured comment

houstonlawy3r says:
September 6, 2012 at 7:07 pm

I have heard about their recruitment attempts from other attorneys who were contacted by them. Apparently, even hungry lawyers can see through their pretty little website and smell a scam. I’d be surprised if the copyright troll attorneys who sign on would ever get paid. As a rule, anyone who courts you and tells you that you’ll make a million bucks (and they’ll do all the work) — RUN.


¹Mick Haig (Michael Heinz) is not only a troll pornographer but also the director/secretary of Excubitor USA. Remember the meme created by Raul: “Plaintiff’s principal, Steve Jones, retained Steve Jones to use Steve Jones’s forensic software to identify…”?

The header says it: this case is over for now. Although this dismissal is without prejudice, which means that the Does can be pursued in the future, the time is on their side — because they have more time to educate themselves and become less shakedown-prone, and because copyright trolling disease cannot last forever: the crisis is over, the recovery has started (IMO).

The dismissal happened immediately after a defendant’s attorney Charles Thomas removed this case to the federal court (PAED). I believe that there is more than one reason for this rather unexpected dismissal:

  • This particular federal court is ripe for getting rid or trolls for good.
  • Comcast was serious about not giving away its customers’ identities easily.
  • As I tweeted and wrote in comments, I had a gut feeling that Liberty Media’s counsel Jordan Rushie is not a greedy scum like the majority of the bittorent trolls, but rather a guy who was deceived by Marc Randazza, and who actually believed that he was doing the right thing. I hope that he realized that it is better to keep away from mass-suing individuals, especially given the flawed infringement detection methods that result in many innocents dragged into this misery.
  • I hope that the publicity we helped to create was also a factor. I doubt that Pennsylvania’s pre-complaint discovery loophole will be abused again in order to generate shakedown lists.

Read about this dismissal on Charles Thomas’ site.

On August 7, 2012 our very own Raul made a live guest appearance on the Stupid America Internet radio show created and hosted by Jeremy Stillwagner. Raul was talking about… well, you know what he was talking about: copyright trolls, our sites (fightcopyrighttrolls.com and dietrolldie.com), why and how we help to destroy this mob-like “business.”

Regular readers of this site probably won’t hear anything new, but because the target audience of this show most likely never heard about the issue, and due to the host’s and Raul’s efforts, the program turned out to be very informative and easy to follow — “copyright trolling for dummies” I would say.

I recommend downloading the mp3 of this show and listening while driving, strolling or just sitting and staring at the wall. Send the link to your friends — so they would learn about the ongoing unprecedented abuse of the court system; spread the word.

Download this show.

by Raul

In the Southern District of Florida (FLSD) there has been a recent development, involving a lawsuit, in which both Judge Cecilia M. Altonaga and Judge Patricia A. Seitz have dismissed former Prenda Law INC associate’s (Joseph Perea) lawsuits — each against a single John Doe. This merits a little examination. Cutting through the legal mumbo jumbo, the judges dismissed the lawsuits because they did not buy Perea’s arrogant justifications for a sleazy litigation tactic.

Listening… what is this “sleazy litigation tactic”?

Basically, Perea, as an associate of Prenda and now allegedly as a solo practitioner, will file a troll lawsuit in the FLSD and immediately make a motion for expedited discovery to issue third party subpoenas to ISPs — so as to discover the personal identifying information of the targeted John Does to shake them down for settlements. Typically, the motion would be granted. However, here is the sleazy part: instead of having the subpoenas issued out of the presiding FLSD court, Perea has them issued by Prenda’s “founding partner” Paul Duffy out of the Nothern District of Illinois (ILND) or the District of Columbia (DCD).

It also bears some examination as to whether Duffy, who is not licensed to practice law in Florida, can issue subpoenas that pertain to a Florida federal lawsuit.

Confused? That is the point. Almost any pro se John Doe would be in a quandary and would naturally file a motion to quash/sever or issue a protective order in the FLSD, but he would then face this greasy argument in opposition by Perea:

Because Movant failed to bring his motion before the court that issued the subpoena, his motion should be denied.

That’s right: Perea is arguing that the court that authorized the subpoena in the first place (FLSD) has no authority to hear a challenge to that same subpoena — because it was issued out of another court (which the authorizing judge had no idea was going to occur).

What has been the reaction of Doe Defenders?

It is beyond the scope of this post to examine every individual example of a Doe Defender (an attorney who defends the Doe) taking issue with this shady litigation tactic and the steps they have taken to combat it. However, there are two examples that ought to be mentioned.

Doe Defender William R. Wohlsifer pointed to this tactic in the lawsuit Sunlust Pictures v. Does 1-120 (FLSD 12-cv-20920) arguing in support of a (successful) motion to quash the subpoena and dismiss the lawsuit. In her Omnibus Order of 7/23/2012 granting the motion, Judge Seitz wonders (in footnote 10):

Pursuant to FED. R. CIV. P. 45 (c)(1), parties have an obligation to “avoid imposing undue burden or expense on a person subject to the subpoena.” Additionally, FED. R. CIV. P. 1 requires that the parties proceed in a cost-efficient manner. It is unclear why the subpoenas were issued in another judicial district for information about Doe Defendants who allegedly reside in this district.

Mr. Wohhlsifer currently has a motion pending before Judge Seitz to have the plaintiff pay his attorneys’ fees because the defendant is a prevailing party. I hope he is as successful with this motion as he was with the motion to quash the subpoena and dismiss the complaint.

The second example of a Doe Defender taking issue with this sleazy litigation tactic is Kubs Lalchandani — in the lawsuit Bubblegum Productions v. Does 1-80 (FLSD 12-cv-20367), which resulted in Perea finding himself in a pot of hot water. This case is noteworthy as well, because it marks the first time that Judge Seitz (in footnote 9) questions the sleazy litigation tactic involving the third party subpoenas.

How did the single Doe lawsuit dismissals come about?

District Judge Patricia A .Seitz

Perhaps discouraged by the severances granted in the Sunlust and Bubblegum lawsuits, or perhaps in furtherance of Prenda’s much ballyhooed “new” business model to bring suits against individual John Does, in late July and in August Perea began filing individual John Doe lawsuits on behalf of Prenda clients Ingenuity 13 and AF holdings. In AF holdings v. Doe (FLSD 12-cv-22147), Perea draws Judge Seitz, who on 8/8/2012 issues an Order denying his motion to take early discovery of the personal identifying information of the John Doe. Judge Seitz writes:

Paintiff has not provided an adequate justification as to why the Court should authorize it to issue a subpoena from the District of Columbia for information it can obtain from a subpoena issued from the Southern District of Florida, where this lawsuit is pending and where Plaintiff alleges the sole Defendant resides and/or committed the alleged infringing activity. The Court has an interest in managing the discovery it authorizes in a lawsuit it is presiding over. This management includes challenges to the subpoenas, which the Court cannot address if the subpoenas are issued elsewhere.

And (emphasis is mine):

Finally, Plaintiffs insistence on issuing a subpoena from the District of Columbia, a judicial forum that has no connection to this lawsuit, appears to be a litigation tactic. In another BitTorrent copyright infringement case pending before this Court, Plaintiff s counsel issued a subpoena from the U.S. District Court for the District of Columbia to obtain subscriber information from Comcast for Doe Defendants who allegedly reside and/or committed infringing activity in the Southern District of Florida. Bubble Gum Productions, LLC v. Does 1-80, Case No. 12-20367-C1V-SEITZ/SIMONTON, (DE 13-1). Thereafter, a number of the Doe Defendants tiled motions to sever or, in the alternative, to quash the subpoenas in this Court. On July 19, 2012, the Court issued an Order Granting Defendants’ Motions to Sever, Dismissing Claims Against Does 2-80 Without Prejudice, and Vacating the Portion of its Order Granting Early Discovery as to Does 2-80. Id. at (30). However, the Court could not quash the subpoenas as to Does 2-80 because they had been issued from the District of Columbia. See Fed. R. Civ. P. 45(c)(3)(A).Four days after issuance of the Court’s July 19, 2012 Order, Plaintiff tiled a Renewed Motion to Compel Compliance with Subpoena against Comcast in the District of Columbia, and failed to inform the D.C. Court in that Motion of this Court’s July 19, 2012 Order. BubbleGum Productions, LLC v. Comcast Cable Communications, LLC, Case No.12-00382-MC-HUVELLE, (DE 6). The D.C. Court was subsequently informed of this Court’s Order by Comcast and denied Plaintiff’s Motion and issued an Order to Show Cause because it viewed Plaintiff’s actions as an attempt to perpetuate a fraud upon the court.

Judge Seitz has since killed at least one other Perea’s single Doe lawsuit on this ground.


District Judge Cecilia Altonaga

Subsequently, Perea files a lawsuit Ingenuity 13, LLC v. Doe (FLSD 12-cv-22756), draws Judge Altonaga and, again, files a motion to take early discovery. Judge Altonaga, like Judge Seitz, denies the motion with leave to refile, provided Perea supplies a justification for the questionable litigation tactic. On 8/23/2012 Perea refiles along with his “justifications” that ooze with hubris and sarcasm, and which space does not permit elaboration on. (I’ll leave that to the comments :)) Judge Altonaga handed down an Order on 8/29/2012, denying the discovery because:

Plaintiff wholly fails to address why Comcast’s production or inspection cannot be made in the Southern District of Florida where John Doe resides, and therefore, why the subpoena cannot be issued in this judicial district.

And:

Plaintiff does not specify what burden will be imposed on it should the subpoena issue from this district as opposed to the District of Columbia. Indeed, as Plaintiff has brought suit in this district, Plaintiff presumably is also available to receive discovery here.

It is my hope that denying troll motions to take early discovery on the basis of this dishonest litigation tactic spreads far and wide.

In closing, I wish to leave you with a music video by a band that elects to innovate in the Internet rather than sue it.