Paul Andrew Mitchell, Sui Juris
c/o Forwarding Agent at:
11230 Gold Express Dr., #310-188
Gold River 95670-4484
CALIFORNIA, USA
In Propria Persona
All Rights Reserved
without Prejudice
District Court of the United States
Eastern Judicial District of California
Paul Andrew Mitchell, ) #CIV. S-01-1480 WBS DAD PS
)
Plaintiff, ) THIRD
SUPPLEMENT TO
) VERIFIED COMPLAINT FOR
v. ) DAMAGES AND INJUNCTION
) FOR COPYRIGHT INFRINGEMENT
AOL Time Warner, Inc., ) AND RELATED CLAIMS:
Steve Case, )
Lennert Leader, ) JURY DEMANDED
Randall J. Boe, )
Adit Seth, )
George R. Boyce, )
James R. Bramson, )
Daniel Levy, )
Jonathan Steuer, )
Brian Oblivion, )
Donald D. Hoffman, )
Karl Kleinpaste, )
California Institute of Technology, )
Cornell University, )
Embry-Riddle Aeronautical University, )
Florida Institute of Technology, )
Indiana University, )
Miami University of Ohio, )
Northeastern University, )
Pennsylvania State University, )
Princeton University, )
Stanford University, )
Stetson University, )
Swiss Federal Institute of Technology,)
University of Arkansas, )
University of California, )
University of Georgia, ) [continue next page:]
University of Kansas, )
University of Michigan, )
University of Oregon, )
University of Texas, and )
--------------------------------------)
James Daugherty-AA Research, )
Internet Domain INCORPTEK.COM, )
Justsystem Pittsburgh Research Center,)
Midwest Internet Exchange, Inc., [sic])
Internet Domain NEBONET.COM, )
Simple Network Communications, Inc., )
Snow Hill Enterprises, Inc., ) [continue next page:]
Luke Stevens, )
COWZ Technologies, )
The Works BBS, and )
--------------------------------------)
TEK Interactive Group, Inc., )
--------------------------------------)
Sean Strasburg, )
Michael McFarland, )
David Thorburn-Gundlach, )
Bob Isaacson, )
Tore Nestenius, )
C. J. Sollien, )
Chris Hansen, )
Floyd W. Shackelford, )
Network Solutions, Inc., )
The Thomson Corporation, )
Cosmic Awareness Communications, )
Sprawlnet.com, Inc., )
Four Peaks Technology Groups, )
Tzolkin Corporation, )
ParabolaX Research Group, )
William Harrity, )
THF Pictures, )
Synchron Data, )
Lyle Myhr, and )
Doe’s 98 thru 2,500, )
)
Defendants. )
______________________________________)
Page
PARTIES 5
VERIFIED CRIMINAL COMPLAINTS 13
DEMANDS FOR SUBSCRIBER IDENTITIES 17
VERIFICATION 25
After a final assessment of all electronic evidence in His possession, Plaintiff again supplements the Initial COMPLAINT within the period allowed for amending complaints without leave of the Court.
This THIRD SUPPLEMENT likewise makes no changes to the Initial COMPLAINT; it simply adds further facts and evidence, and names further Defendants, as revealed by Plaintiff’s final assessment of all electronic evidence in His possession. That final assessment was performed during the month of July 2001 A.D.
To repeat, no one ever requested and received permission to host any electronic versions of the subject book anywhere on the Internet, and no one ever requested and received permission to modify it and then to host or promote any counterfeit versions on the Internet. See 18 U.S.C. 1961(1)(B) and legislative history.
Plaintiff now formally names additional Defendants as Proper Parties by substituting their proper names, respectively, for a subset of the John Doe’s as found on the caption page of the Initial COMPLAINT:
Doe #79 is now Sean Strasburg.
Doe #80 is now Michael McFarland.
Doe #81 is now David Thorburn-Gundlach.
Doe #82 is now Bob Isaacson.
Doe #83 is now Tore Nestenius.
Doe #84 is now C. J. Sollien.
Doe #85 is now Chris Hansen.
Doe #86 is now Floyd W. Shackelford.
Doe #87 is now Network Solutions, Inc.
Doe #88 is now The Thomson Corporation.
Doe #89 is now Cosmic Awareness Communications.
Doe #90 is now Sprawlnet.com, Inc.
Doe #91 is now Four Peaks Technology Groups.
Doe #92 is now Tzolkin Corporation.
Doe #93 is now ParabolaX Research Group.
Doe #94 is now William Harrity.
Doe #95 is now THF Pictures.
Doe #96 is now Synchron Data.
Doe #97 is now Lyle Myhr.
Defendant Barrett Owens is believed to be an Internet user and proprietor doing business as (“dba”) Defendant A2Z Computers & Software, with offices in Collierville, Tennessee, USA.
Defendant James H. Daugherty is believed to be an Internet user and proprietor dba Defendant James Daugherty‑AA Research, with offices in Ferndale, Michigan, USA.
Defendant Tore Nestenius is believed to be an Internet user and proprietor dba Defendant Synchron Data, also known as (“aka”) Defendant Internet Domain ALGONET.SE, with offices in Stockholm, Sweden.
Defendant Mark Creamer is believed to be an Internet user and principal of Defendant Internet Domain BAYON.NET, with offices in Vestal, New York State, USA.
Defendant Christopher Kankel is believed to be an Internet user at one time affiliated with Defendant California Institute of Technology, with offices in Pasadena, California.
Defendant C I Host is an Internet Service Provider (“ISP”), with offices in Bedford, Texas, USA.
Defendant Desert Video Production is believed to be a business, with offices in Yuma, Arizona, USA.
Defendant Cyborganic Media is believed to be an ISP with offices in San Francisco, California, USA, and employing Defendant Jonathan Steuer.
Defendant Alias “Dimitri” is believed to be an Internet user, a principal of Defendant Internet Domain DEOXY.ORG, and an associate of Defendants Daniel Levy, Carrie Malcolm and Levity.
Defendant Carrie Malcolm is believed to be an Internet user and employee of Defendant Levity, with offices in New York City, New York State, USA.
Defendant David W. Starr is believed to be an Internet user dba Defendant ALH, with offices in Beverly Hills, California, USA, and associated with Defendant The ETEXT Archives.
Defendant Mitchell A. Goodkin is believed to be an Internet user, Intellectual Property Counsel and Senior Technology Licensing Specialist in the Office of the Vice President and General Counsel at Defendant University of Michigan in Ann Arbor, Michigan, USA.
Defendant Image’FX Productions, Inc. is believed to be a New York State corporation dba Internet Domain EXECNET.COM, with offices in Mount Vernon, New York State, USA.
Defendant EZ2 Network, Inc. is believed to be an ISP and California corporation with offices in Murietta, California.
Defendant Cybergate, Inc. is believed to be an ISP and Massachusetts corporation dba Channel 1 Communications and also dba Internet Domain FILELIBRARY.COM, with offices in Cambridge, Massachusetts, USA.
Defendant Josh Bempechat is believed to be an Internet user currently living in Oakland, California, USA, and a subscriber of Defendant Earthlink Network, Inc., an ISP with offices in Pasadena, California, USA, and Atlanta, Georgia, USA.
Defendant Hacked Archives [sic] is believed to be a business with offices in Abbingdon, Virginia, USA, and a subscriber of Defendant Internet Domain INCORPTEK.COM, an ISP with offices in Columbus, Mississippi, USA.
Defendant Telecode is believed to be a business with offices in Yuma, Arizona, USA, dba Internet Domain HACKERSCATALOG.COM.
Defendant InfoMagic, Inc. is believed to be an Arizona corporation with offices in Flagstaff, Arizona, USA, and associated with Defendants Tore Nestenius and Internet Domain ALGONET.SE.
Defendant Joe Szemiot is believed to be an Internet user employed by Defendant Intac Access Corporation, an ISP and New Jersey corporation with offices in Palisades Park, New Jersey, USA.
Defendant Internet Online Services is believed to be an ISP with offices in Hackensack, New Jersey, USA.
Defendant Justsystem Pittsburgh Research Center is believed to be an ISP and a consolidated subsidiary of Defendant Justsystem Corporation, a Japanese conglomerate and parent company with head offices in Tokushima-shi, Japan.
Defendant Leander Pearson is believed to be an Internet user dba Kingdom of Zion and Internet Domain KINGDOMOFZION.ORG, and associated with Defendant Burntfork Rural Systems, a business with offices in Burntfork, Wyoming, USA.
Defendant X Mission is believed to be an ISP and limited liability company with offices in Salt Lake City, Utah, USA, and hosting Internet Domain KINGDOMOFZION.ORG.
Defendant L0pht Heavy Industries is believed to be an ISP and business located in Boston, Massachusetts, USA.
Defendant Levity is believed to be a consulting business with offices in New York City, New York State, USA.
Defendant Club Madness [sic] is believed to be a business with offices in Unionville, Ontario, Canada.
Defendant Maui Global Communications is believed to be an ISP with offices in Kihei, Hawaii, USA.
Defendant David Feustel is believed to be an Internet user and former subscriber of Defendant Midwest Internet Exchange, Inc. [sic], an ISP with offices in Fort Wayne, Indiana, USA, and succeeded by Defendant TEK Interactive Group, Inc., believed to be an ISP and Indiana corporation with offices in Fort Wayne, Indiana, USA.
Defendant Jeff Head is believed to be an Internet user and former subscriber of Defendant Internet Domain NEBONET.COM, an ISP with offices in Nephi, Utah, USA.
Defendant Kearney, Castillo & Blake is believed to be a business located in Haddon Heights, New Jersey, USA.
Phreak Network Solutions is believed to be a fictitious name registered with a false mailing address in the WHOIS database managed by Defendant Network Solutions, Inc.
Defendant J. Wyatt is believed to be an Internet user and former subscriber of Defendant Primenet aka Frontier Global Center, an ISP with offices in Phoenix, Arizona, USA.
Defendant Mike McArthur is believed to be an Internet user and former subscriber of Defendant Provide Net aka Provide.Net aka Sunset Online, an ISP with offices in Ypsilanti, Michigan, USA.
Defendant Simple Network Communications, Inc. is believed to be an ISP and California corporation with offices in San Diego, California, USA.
Defendant Snow Hill Enterprises, Inc. is believed to be an Alabama corporation with offices in Ozark, Alabama, USA.
Defendant Dave Alexander is believed to be an Internet user and principal of Defendant Cosmic Awareness Communications dba Society for the Protection of Individual Rights and Liberties (“S.P.I.R.A.L.”), with offices in Olympia, Washington State, USA.
Defendant John L. Dortch is believed to be an Internet user and former subscriber of Defendant Telalink Corporation, an ISP and Tennessee corporation with offices in Nashville, Tennessee, USA.
Defendant Thomson Financial Services is believed to be a business with offices in Medford, Massachusetts, and a wholly owned subsidiary of Defendant The Thomson Corporation, a Connecticut corporation with offices in Stamford, Connecticut, USA.
Defendant Transworld Mail Express is believed to be a business and ISP with offices formerly in Westminster, California, USA.
Defendant Jahred Held is believed to be an Internet user and former subscriber of Defendant Westworld Communications, an ISP and business with offices in Chatsworth, California, USA.
Defendant Luke Stevens is believed to be an Internet user and former employee of the Department of Physics and Space Science at Defendant Florida Institute of Technology, with offices in Melbourne, Florida, USA.
Defendant Msen, Inc. is believed to be an ISP and Michigan corporation with offices in Troy, Michigan, USA, and former host to Internet user and Defendant James H. Daugherty.
Defendant COWZ Technologies is believed to be a business with offices in Belmont, Massachusetts, USA, and a dba of Defendant Jason Scott infra, who is also an employee of Defendant Thomson Financial Services, a wholly owned subsidiary of Defendant The Thomson Corporation supra.
Defendant The Works BBS is believed to be a business with offices in Medford, Massachusetts, USA, and also a dba of Defendant Jason Scott infra.
Defendant AOL Prime Host is believed to be an ISP and wholly owned subsidiary of Defendant AOL Time Warner, Inc., with offices in Vienna, Virginia, USA.
Defendant Justsystem Corporation is the Japanese parent company of Defendant Justsystem Pittsburgh Research Center and of the Clairvoyance Corporation, a consolidated subsidiary with offices in Pittsburgh, Pennsylvania, USA.
Defendant Paul Southworth is believed to be an Internet user dba Defendant The ETEXT Archives, with offices in Ann Arbor, Michigan, USA, and affiliated with Defendant University of Michigan in Ann Arbor, Michigan.
Defendant Ram Samudrala is believed to be an Internet user dba Twisted Helices [sic], with offices in Menlo Park, California, USA. He is a former postgraduate student in the Department of Structural Biology, School of Medicine, Stanford University, with offices in Stanford, California, USA. He is believed to be currently employed at the University of Washington in Seattle, Washington State, USA.
Defendant Ruffin Prevost is believed to be an Internet user dba Defendant Avalon Tech, with offices in Studio City, California, USA, and a principal of Parascope, Inc., believed to be a California corporation also with offices in Studio City, California, USA.
Defendants Dan Turkette and Todd R. Eigenschink are believed to be Internet users and either principals or employees of Defendant TEK Interactive Group, Inc. supra.
Defendant Mail.com, Inc., is believed to be an ISP and New York State corporation with offices in New York City, New York State, USA.
Defendant Sector 13 is believed to be a dba of Defendant Thirteen Technologies LLC, a limited liability company, or corporation, with offices in Preston, Connecticut, USA.
Defendant Jason Scott is believed to be an Internet user, a principal of Defendants COWZ Technologies and The Works BBS supra, and an employee of Defendant Thomson Financial Services supra. Mr. Scott is believed to be a one-time inhabitant of South Boston, Massachusetts, USA.
Defendant Frank Ch. Eigler is believed to be an Internet user dba Defendant Elastic BBS, with offices in Toronto, Ontario, Canada.
Defendant Sean Strasburg is believed to be an Internet user and former employee of the Princeton Plasma Physics Laboratory at Princeton University, Princeton, New Jersey, USA.
Defendant Michael McFarland is believed to be an Associate Professor of Communication Studies and Theatre Arts at Stetson University in Deland, Florida, USA.
Defendant David Thorburn-Gundlach is believed to be an Internet user, a former user of computers owned and operated by Defendant University of Georgia in Athens, Georgia, USA, and a current customer of Defendant Thirteen Technologies, LLC dba Defendant Sector 13 supra.
Defendant Bob Isaacson is believed to be an Internet user and former associate of the Kansas University Virtual Curriculum Coordinator at Defendant University of Kansas in Lawrence, Kansas, USA.
Defendant C. J. Sollien is believed to be an Internet user and principal of Defendant Hacked Archives supra.
Defendant Chris Hansen is believed to be an Internet user; a subscriber of Defendant Tzolkin Corporation, an ISP and Massachusetts corporation with offices in Pepperell, Massachusetts, USA; and a subscriber of Defendant Four Peaks Technology Groups, an ISP and business with offices in Las Vegas, Nevada, USA.
Defendant Floyd W. Shackelford is believed to be an Internet user formerly dba Internet Domain FWSHACKELFORD.COM and presently dba Four Peaks Technology Groups supra.
Defendant Network Solutions, Inc. is believed to be a Virginia corporation with offices in Herndon, Virginia, USA.
Defendant Sprawlnet.com, Inc. is believed to be an ISP and Florida corporation with offices in Miami, Florida, USA, and host to Internet Domain FREEBSDBOX.COM which provides email services to Johnathan Sanders, believed to be a principal of Defendant Internet Domain INCORPTEK.COM supra.
Defendant ParabolaX Research Group is believed to be a business with offices in Lawrence, Kansas, USA, and Kansas City, Missouri, USA.
Defendant William Harrity is believed to be a film maker dba THF Pictures, with offices in Pasadena, California, USA.
Defendant Lyle Myhr is believed to be an Internet user and subscriber to Internet email services provided by Defendant Mail.com, Inc. supra.
On July 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Luke Stevens and served same on the Federal Bureau of Investigation (“FBI”) in North Miami Beach, Florida, USA (see Domain FIT.EDU).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Luke Stevens is attached as Exhibit F‑30.
On July 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Sean Strasburg and served same on the FBI in New York City, New York State, USA (see Domain PRINCETON.EDU).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Sean Strasburg is attached as Exhibit F‑31.
On July 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Michael McFarland and served same on the FBI in North Miami Beach, Florida, USA (see Domain STETSON.EDU).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Michael McFarland is attached as Exhibit F‑32.
On July 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant David Thorburn-Gundlach and served same on the FBI in Atlanta, Georgia, USA (see Domain UGA.EDU).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant David Thorburn-Gundlach is attached as Exhibit F‑33.
On July 11, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Bob Isaacson and served same on the FBI in Kansas City, Missouri, USA (see Domain UKANS.EDU).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Bob Isaacson is attached as Exhibit F‑34.
On July 12, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Dave Alexander and served same on the FBI in Seattle, Washington State, USA (see Domain SPIRAL.ORG).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Dave Alexander is attached as Exhibit F‑35.
On July 12, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Tore Nestenius and served same on the FBI in Richmond, Virginia, USA (see Domain ALGONET.SE).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Tore Nestenius is attached as Exhibit F‑36.
On July 12, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant C. J. Sollien and served same on the FBI in Richmond, Virginia, USA (see Domain HACKEDARCHIVES.COM).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant C. J. Sollien is attached as Exhibit F‑37.
On July 12, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Chris Hansen and served same on the FBI in Boston, Massachusetts, USA (see Domain TZO.COM).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Chris Hansen is attached as Exhibit F‑38.
On July 12, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Floyd W. Shackelford and served same on the FBI in Los Angeles, California, USA (see Domain 4PEAKSTECH.COM).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Floyd W. Shackelford is attached as Exhibit F‑39.
On July 12, 2001 A.D., Plaintiff executed a VERIFIED CRIMINAL COMPLAINT against Defendant Lyle Myhr and served same on the FBI in New York City, New York State, USA (see Domain EMAIL.COM).
A true and correct copy of said CRIMINAL COMPLAINT against Defendant Lyle Myhr is attached as Exhibit F‑40.
On July 6, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to Defendant William Harrity at Defendant THF Pictures, 106 Palmetto Drive, Suite “D”, Pasadena 91105, CALIFORNIA, USA. (See Domain THFPIX.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to Defendant William Harrity at Defendant THF Pictures supra, is attached at Exhibit G‑81.
On July 25, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Tzolkin Corporation, 11 Main Street, Pepperell 01463, MASSACHUSETTS, USA. (See Domain TZO.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Tzolkin Corporation supra, is attached at Exhibit G‑82.
On July 25, 2001 A.D., Plaintiff wrote and mailed a NOTICE OF INTENT TO SUE via first class U.S. Mail to the CEO at Defendant Four Peaks Technology Groups, P.O. Box 27740, Las Vegas 89126, NEVADA, USA. (See Domain 4PEAKSTECH.COM.)
A true and correct copy of said NOTICE OF INTENT TO SUE, as mailed to said CEO at Defendant Four Peaks Technology Groups supra, is attached at Exhibit G‑83.
On July 6, 2001 A.D., Plaintiff wrote and mailed a MIRANDA WARNING via first class U.S. Mail to Defendant William Harrity at Defendant THF Pictures, 106 Palmetto Drive, Suite “D”, Pasadena 91105, CALIFORNIA, USA. (See Domain THFPIX.)
A true and correct copy of said MIRANDA WARNING, as mailed to Defendant William Harrity at Defendant THF Pictures supra, is attached at Exhibit H‑81.
On July 25, 2001 A.D., Plaintiff wrote and mailed a MIRANDA WARNING via first class U.S. Mail to the CEO at Defendant Tzolkin Corporation, 11 Main Street, Pepperell 01463, MASSACHUSETTS, USA. (See Domain TZO.COM.)
A true and correct copy of said MIRANDA WARNING, as mailed to said CEO at Defendant Tzolkin Corporation supra, is attached at Exhibit H‑82.
On July 25, 2001 A.D., Plaintiff wrote and mailed a MIRANDA WARNING via first class U.S. Mail to the CEO at Defendant Four Peaks Technology Groups, P.O. Box 27740, Las Vegas 89126, NEVADA, USA. (See Domain 4PEAKSTECH.COM.)
A true and correct copy of said MIRANDA WARNING, as mailed to said CEO at Defendant Four Peaks Technology Groups supra, is attached at Exhibit H‑83.
On July 10, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the Chief Executive Officer (“CEO”) at Defendant James Daugherty‑AA Research, P.O. Box 20273, Ferndale 48220‑0273, MICHIGAN, USA. (See Domain A‑ALBIONIC.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant James Daugherty‑AA Research supra, is attached as Exhibit J‑80.
On July 10, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant A2Z Computers & Software, P.O. Box 906, Collierville 38027‑0906, TENNESSEE, USA. (See Domain A2ZNET.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant A2Z Computers & Software supra, is attached as Exhibit J‑81.
On July 10, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant Cyborganic Media, 2261 Market Street, Suite 100, San Francisco 94114, CALIFORNIA, USA. (See Domain CYBORGANIC.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant Cyborganic Media supra, is attached as Exhibit J‑82.
On July 10, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant INTAC Access Corporation, 256 Broad Avenue, Palisades Park 07650, NEW JERSEY, USA. (See Domain INTAC.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant INTAC Access Corporation supra, is attached as Exhibit J‑83.
On July 10, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant Levity, P.O. Box 1013, Cooper Station, New York City 10276‑1013, NEW YORK STATE, USA. (See Domain LEVITY.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed said the CEO at Defendant Levity supra, is attached as Exhibit J‑84.
On July 10, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant Network Solutions, Inc., 505 Huntmar Park Drive, Herndon 20170, VIRGINIA, USA. (See Domain NETWORKSOLUTIONS.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant Network Solutions, Inc. supra, is attached as Exhibit J‑85.
On July 10, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant Cosmic Awareness Communications, P.O. Box 115, Olympia 98507, WASHINGTON STATE, USA. (See Domain SPIRAL.ORG.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant Cosmic Awareness Communications supra, is attached as Exhibit J‑86.
On July 10, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant The Thomson Corporation, Metro Center, One Station Place, Stamford 06902, CONNECTICUT, USA. (See Domain THOMSON.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant The Thomson Corporation supra, is attached as Exhibit J‑87.
On July 2, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to Michael Steinfeld at Defendant Sprawlnet.com, Inc., 1811 N.E. 146th Street, Miami 233181, FLORIDA, USA. (See Domain INCORPTEK.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to Michael Steinfeld at Defendant Sprawlnet.com, Inc. supra, is attached as Exhibit J‑88.
On July 2, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant Sprawlnet.com, Inc., 3165 N.E. 184th Street, Suite 6302, Miami 33160, FLORIDA, USA. (See Domain INCORPTEK.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant Sprawlnet.com, Inc. supra, is attached as Exhibit J‑89.
On June 27, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant Tzolkin Corporation, 11 Main Street, Pepperell 01463, MASSACHUSETTS, USA. (See Domain TZO.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant Tzolkin Corporation supra, is attached as Exhibit J‑90.
On June 27, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant Four Peaks Technology Groups, P.O. Box 27740, Las Vegas 89126, NEVADA, USA. (See Domain 4PEAKSTECH.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant Four Peaks Technology Groups supra, is attached as Exhibit J‑91.
On June 27, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to Defendant Floyd W. Shackelford dba Internet Domain 4PEAKSTECH.COM, P.O. Box 27740, Las Vegas 89126, NEVADA, USA. (See Domain 4PEAKSTECH.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to Defendant Floyd W. Shackelford supra, is attached as Exhibit J‑92.
On June 26, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant AOL Time Warner, Inc., 22000 AOL Way, Dulles 20166, VIRGINIA, USA. (See Domain AOL.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant AOL Time Warner, Inc. supra, is attached as Exhibit J‑93.
On June 26, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant ParabolaX Research Group, 1223 Ohio Street, Lawrence 66044, KANSAS, USA. (See Domain PBX.ORG.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant ParabolaX Research Group supra, is attached as Exhibit J‑94.
On June 26, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant ParabolaX Research Group, 510 West 123 Ter., Kansas City 64114, MISSOURI, USA. (See Domain PBX.ORG.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant ParabolaX supra, is attached as Exhibit J‑95.
On May 21, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant Mail.com, Inc., 11 Broadway, Suite 660, New York City 10004, NEW YORK STATE, USA. (See Domain EMAIL.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant Mail.com, Inc. supra, is attached as Exhibit J‑96.
On May 21, 2001 A.D., Plaintiff wrote and mailed a DEMAND FOR SUBSCRIBER IDENTITY via first class U.S. Mail to the CEO at Defendant Mail.com, Inc., 399 Thornall Street, 6th Floor, Edison 08837, NEW JERSEY, USA. (See Domain EMAIL.COM.)
A true and correct copy of said DEMAND FOR SUBSCRIBER IDENTITY, as mailed to said CEO at Defendant Mail.com, Inc. supra, is attached as Exhibit J‑97.
On July 9, 2001 A.D., Plaintiff wrote and mailed via first class U.S. Mail an INVOICE FOR DAMAGES to the CEO of Defendant The Thomson Corporation, Metro Center, One Station Place, Stamford 06902, CONNECTICUT, USA. (See Domain THOMSON.COM.)
A true and correct copy of said INVOICE FOR DAMAGES, as mailed to said CEO at Defendant The Thomson Corporation supra, is attached as Exhibit L‑1.
On July 9, 2001 A.D., Plaintiff wrote and mailed via first class U.S. Mail an INVOICE FOR DAMAGES to Defendant Tore Nestenius at Defendant Synchron Data dba Defendant Internet Domain ALGONET.SE, P.O. Box 1160, Stockholm 111 91, SWEDEN. (See Domain ALGONET.SE.)
A true and correct copy of said INVOICE FOR DAMAGES, as mailed to Defendant Tore Nestenius at Defendant Synchron Data supra, is attached as Exhibit L‑2.
On July 10, 2001 A.D., Plaintiff wrote and mailed via first class U.S. Mail a NOTICE AND DEMAND FOR SPECIFIC PERFORMANCE to the Designated Agent at Defendant EarthLink Network, Inc., 3100 New York Drive, Pasadena 91107, CALIFORNIA, USA. (See Domain EARTHLINK.NET.)
A true and correct copy of said NOTICE AND DEMAND, as mailed to said Designated Agent at Defendant EarthLink Network, Inc. supra, is attached as Exhibit L‑3.
On July 16, 2001 A.D., Plaintiff wrote and mailed via first class U.S. Mail a standard NOTICE OF DEFAULT to all Internet domains that had failed to produce any certified authorizations as required by Plaintiff’s prior NOTICES AND DEMANDS FOR AUTHORIZATION.
A true and correct copy of said standard NOTICE OF DEFAULT, as mailed to domain DIRECLYNX.NET, is attached as Exhibit L‑4.
Plaintiff attaches the published OPINION of U.S. District Judge Lewis A. Kaplan in Universal City Studios, Inc., et al. v. Reimerdes et al., Docket #00‑CIV‑0277‑LAK, August 20, 2000 A.D. (USDC, S.D.N.Y.) (Internet hyperlinks to stolen intellectual property are copyright infringements.) See Exhibit L‑5.
Plaintiff also attaches the legislative history of the Anticounterfeiting Consumer Protection Act of 1996, from the House Congressional Record, June 4, 1996; and, in particular, of the amendments to 18 U.S.C. 1961(1)(B) (RICO predicate acts). See Exhibit L‑6.
The Initial COMPLAINT, FIRST, SECOND and THIRD SUPPLEMENT’s are made Exhibits L‑7, L‑8, L‑9 and L‑10, respectively.
Plaintiff incorporates by reference Exhibits “F‑30” thru “F‑40”, “G‑82” thru “G‑83”, “H‑82” thru “H‑83”, “J‑80” thru “J‑97”, and “L‑1” thru “L‑10” as if set forth fully herein.
Exhibit “A” Cover Sheets
Exhibit “B” Cover Sheets
Exhibit “C” Cover Sheets
Exhibit “D” Cover Sheets
Exhibit “E” Cover Sheets
Exhibit “F” Cover Sheets
Exhibit “G” Cover Sheets
Exhibit “H” Cover Sheets
Exhibit “I” Cover Sheets
Exhibit “J” Cover Sheets
Exhibit “K” Cover Sheets
Exhibit “L” Cover Sheets
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I, Paul Andrew Mitchell, Sui Juris, Plaintiff in the above entitled action, hereby verify under penalty of perjury, under the laws of the United States of America, without the “United States” (federal government), that the above statement of facts and laws is true and correct, according to the best of My current information, knowledge, and belief, so help me God, pursuant to 28 U.S.C. 1746(1).
Dated: September 10, 2001 A.D.
Signed: /s/ Paul Andrew Mitchell
___________________________________________
Printed: Paul Andrew Mitchell, B.A., M.S., Sui Juris