Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ----------------------------------------------------------x ENIGMA SOFTWARE GROUP USA, LLC, : : Plaintiff, : : -against: Case No.: 1:16-cv-00057-PAE : BLEEPING COMPUTER LLC and : DOES 1-10, : : Defendants. : ----------------------------------------------------------x DEFENDANT’S ANSWER, AFFIRMATIVE DEFENSES AND COUNTERCLAIMS IN RESPONSE TO PLAINTIFF’S SECOND AMENDED COMPLAINT Defendant Bleeping Computer, LLC (“Bleeping” or “Defendant”), by and through undersigned counsel, hereby answers the allegations of the Second Amended Complaint (the “Complaint”), filed by Plaintiff Enigma Software Group USA, LLC (“Plaintiff” or “Enigma”), paragraph by corresponding paragraph, as follows: 1. Admitted Plaintiff seeks the relief sought but denied it is entitled to any relief. 2. Admitted Bleeping owns the domain name referenced and operates certain functions on the associated website while other functions are performed by volunteers, and that some of the statements referenced have appeared on the website, otherwise denied. 3. Admitted that some of the statements asserted have appeared on Bleeping’s website, otherwise denied. 4. Deny knowledge or information sufficient to form a belief as to the state of mind of consumers as referenced, admitted that Bleeping’s website if publicly available to be accessed by anyone, otherwise denied. 5. Admitted that Bleeping’s website provides information regarding anti-malware Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 2 of 29 software, otherwise deny knowledge or information as to what might be most important to particular users and otherwise denied. 6. Deny knowledge or information as to the state of mind of users, otherwise denied. 7. Admitted that Bleeping receives commissions on certain sales of certain anti- malware products, including Plaintiff’s products, otherwise denied. 8. Admitted that Bleeping has received commissions for the sale of software products through hyperlinks, including commissions received from Plaintiff, otherwise denied. 9. Denied. 10. Admitted that Bleeping receives commissions from sales of Malwarebytes and other software companies, including Plaintiff; deny knowledge or information sufficient to form a belief as to the true competitive relationship between the parties referenced, otherwise denied. 11. Denied that Bleeping does not receive and has not received commission from Plaintiff and otherwise denied. 12. Denied. 13. Denied. 14. Denied. 15. Denied. Parties 16. Admitted that Plaintiff alleges it is a Florida limited liability company, otherwise deny knowledge or information sufficient to form a belief as to the remaining allegations. 17. Admitted. 18. Denied. 2 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 3 of 29 Jurisdiction & Venue 19. The allegations of paragraph 19 consist of jurisdictional allegations to which no response is required. 20. Denied. 21. Admitted that Enigma markets computer security products, otherwise deny knowledge or information sufficient to form a belief as to the remaining allegations. 22. Admit the FTC has published the statements asserted. 23. Deny knowledge or information sufficient to form a belief. 24. Admitted that Plaintiff markets SpyHunter, otherwise deny knowledge or information sufficient to form a belief as to the remaining allegations. 25. Admitted that Plaintiff markets and sells SpyHunter over the Internet, through various websites, otherwise deny knowledge or information sufficient to form a belief as to the remaining allegations. 26. Deny knowledge or information sufficient to form a belief. 27. Deny knowledge or information sufficient to form a belief. 28. Deny knowledge or information sufficient to form a belief. 29. Denied. 30. Deny knowledge or information sufficient to form a belief. 31. Deny knowledge or information sufficient to form a belief. 32. Admitted that Bleeping has stated that its owner and certain volunteers are adept at certain computer security technical and operational matters, otherwise denied. 33. Denied. 34. Admitted that Bleeping owns the domain name referenced and operates certain functions on the associated website while other functions are performed by volunteers, and that 3 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 4 of 29 the website contains the sections referenced, otherwise denied. 35. Admitted that Bleeping has generated revenue through hyperlinks on its website, including revenue paid by Plaintiff. 36. Admitted that Bleeping has participated in the program offered and utilized by SkimLinks. 37. Admitted that Bleeping has participated in the program offered and utilized by SkimLinks, and that commissions have been paid for purchases made on Bleeping’s website through said program, including commissions paid by Plaintiff. 38. Denied. 39. Admitted that Bleeping’s website contains the quoted language, but deny Plaintiff’s characterization of same, otherwise denied. 40. Admitted that Bleeping’s website contains the quoted language, but deny Plaintiff’s characterization of same, otherwise denied. 41. Admitted that the Bleeping website utilizes the Skimlinks program in the forums section of the Bleeping website, otherwise denied. 42. Admitted that Bleeping’s website contains the quoted language, but deny Plaintiff’s characterization of same, otherwise denied. 43. Admitted that Bleeping’s website generates revenues through advertising and commissions from affiliates and other advertisers, including Plaintiff, otherwise denied. 44. Denied. 45. Admitted that various member groups associated with the Bleeping website have been formed and evolved over time, otherwise denied. 46. Admitted that Bleeping identifies individuals in member groups and information 4 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 5 of 29 about them, otherwise denied. 47. Admitted that Admin & Site Admins are the highest level member groups, that Lawrence Abrams is the overall Admin of the Bleeping website, otherwise denied. 48. Admitted that the second-highest level member group is Global Moderator & Moderators, otherwise denied. 49. Admitted that the quoted language appears on Bleeping’s website but deny Plaintiff’s characterization of same, otherwise denied. 50. Admitted that the third-highest member group is Advisors, otherwise denied. 51. Admitted. 52. Denied 53. Admitted that when a Global Moderator, Moderator, or Advisor makes a post, the software for the site automatically identifies the poster as a Global Moderator, Moderator, or Advisor; otherwise denied. 54. Admitted that Bleeping runs a free training program referred to as the Malware Study Hall; otherwise denied. 55. Denied. 56. Admitted that volunteers work with Bleeping in running the referenced training program, otherwise denied. 57. Admitted. 58. Denied. 59. Denied. 60. Admitted that Bleeping has referred to the volunteers in the referenced positions as staff members, otherwise denied. 5 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 6 of 29 61. Admitted that Bleeping does not require the referenced disclosures that the vast majority of its volunteer “staff members” voluntarily make. 62. Denied. 63. Admitted that the quoted language appears on Bleeping’s site; otherwise denied. 64. Admitted. 65. Admitted that the individual identified by the pseudonym Quietman7 has been identified as a staff member and Global Moderator on the Bleeping website; otherwise denied. 66. Admitted that the referenced announcement was made on the Bleeping website in March, 2006; otherwise denied. 67. Admitted that the referenced announcement was made on the Bleeping website in March, 2006; otherwise denied. 68. Admitted. 69. Admitted. 70. Admitted. 71. Admitted. 72. Denied. 73. Admitted that Quietman7 performs some of the referenced functions for other volunteers associated with the Bleeping website; otherwise denied. 74. Denied. 75. Admitted that Quietman7 and other volunteers who have been referenced as staff members have recommended Malwarebytes’ products; otherwise denied. 76. Denied. 77. The information alleged in the first sentence of Paragraph 77 relates to 6 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 7 of 29 information that is or may be privileged and thus no response is required. The remaining allegations are denied. 78. Denied. 79. Deny knowledge or information sufficient to form a belief as to understandings held by consumers and users as referenced. 80. Denied. 81. Denied. 82. Denied. 83. Denied. 84. Denied. 85. Denied. 86. Denied. 87. Admit the quoted language appeared in the post referenced, otherwise denied. 88. Admitted. 89. Denied. 90. Deny knowledge or information sufficient to form a belief as to understandings held by consumers and users as referenced. 91. Denied. 92. Admitted that Bleeping has removed spam posts in accordance with the policies posted on its site, otherwise denied. 93. Denied. 94. Denied. 95. Denied. 7 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 8 of 29 96. Admitted that Bleeping has received cease and desist demands from Plaintiff; otherwise denied. 97. Denied. 98. Denied. 99. Denied. 100. Denied. FIRST CAUSE OF ACTION (Violations of Lanham Act § 43(a)) 101. Prior averments incorporated. 102. Denied. 103. Denied. 104. Denied. 105. Denied. 106. Denied. 107. Denied. SECOND CAUSE OF ACTION (Trade Libel/Commercial Disparagement) 108. Dismissed. No response required. 109. Dismissed. No response required 110. Dismissed. No response required. 111. Dismissed. No response required 112. Dismissed. No response required. 113. Dismissed. No response required 114. Dismissed. No response required. 115. Dismissed. No response required. 8 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 9 of 29 THIRD CAUSE OF ACTION (Libel) 116. Prior averments incorporated. 117. Denied. 118. Denied. 119. Denied. 120. Denied. 121. Denied. 122. Denied. 123. Denied. FOURTH CAUSE OF ACTION (Libel per se) 124. Prior averments incorporated. 125. Denied. 126. Denied. 127. Denied. As To All Counts The remaining allegations are prayers for relief that do not require an admission or denial. To the extent a response is required, the allegations are denied. Unless specifically admitted herein, all allegations are denied. Defendants further deny that Plaintiff is entitled to any relief, including the relief requested in the Second Amended Complaint. AFFIRMATIVE DEFENSES First Affirmative Defense Plaintiff fails to state a cause of action upon which relief can be granted. Second Affirmative Defense Plaintiff’s claims are barred, in whole or in part, by applicable statutes of limitation. 9 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 10 of 29 Third Affirmative Defense Plaintiff’s claims are barred, in whole or in part, by Section 230 of the Communications Decency Act, 47 U.S.C. §230. Fourth Affirmative Defense Plaintiff’s claims are barred, in whole or in part, because the statements at issue were not published by the Defendant, Bleeping Computer, LLC. Fifth Affirmative Defense Plaintiff’s claims are barred, in whole or in part, because the statements at issue are true or substantially true. Sixth Affirmative Defense Plaintiff’s claims are barred, in whole or in part, because the statements at issue consist of opinion and/or rhetorical hyperbole, protected under the Constitution of the State of New York, the U.S. Constitution, and applicable common law. Seventh Affirmative Defense Plaintiff’s claims are barred, in whole or in part, because the statements at issue are privileged under one or more of the following privileges: common/corresponding interest privilege, judicial proceedings privilege, fair report privilege, matter of public concern. Eighth Affirmative Defense Plaintiff’s claims are barred, in whole or in part, because the statements at issue are privileged under one or more of the foregoing privileges and Plaintiff cannot demonstrate malice. Ninth Affirmative Defense Plaintiff’s claims are barred, in whole or in part, because Plaintiff is a public figure and cannot demonstrate actual malice with clear and convincing evidence or otherwise. 10 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 11 of 29 Tenth Affirmative Defense Plaintiff’s claims are barred, in whole or in part, because the statements at issue are not defamatory or reasonably susceptible of a defamatory meaning. Eleventh Affirmative Defense Plaintiff’s claims are barred, in whole or in part, because the relief Plaintiff seeks would amount to a prior restraint in violation of the Constitution of the State of New York, the U.S. Constitution, applicable common law and principles of equity. Twelfth Affirmative Defense Plaintiff’s claims are barred, in whole or in part, because the Plaintiff is libel proof, in that its reputation in the computer security community has been so low and so badly tarnished for so long that it is incapable of being further damaged. Thirteenth Affirmative Defense Plaintiff’s claims are barred, in whole or in part, by the doctrine of unclean hands. Fourteenth Affirmative Defense Plaintiff’s claims are barred, in whole or in part, by the doctrine of laches, waiver or estoppel. Further Affirmative Defenses Defendant reserves the right to amend or supplement this statement of affirmative defenses. BLEEPING COMPUTER’S COUNTERCLAIMS Defendant and Counterclaimant Bleeping Computer, LLC hereby sues Plaintiff Enigma Software Group USA, LLC (“Enigma”). This action is for violation of the Anti-Cybersquatting Consumer Protection Act, the Lanham Act, the Florida Deceptive and Unfair Trade Practices, 11 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 12 of 29 and Defamation. As set forth below, Enigma has been engaged in a pattern and practice of misusing and infringing upon Bleeping’s name and trademark in various formats and through various means, defaming and disparaging Bleeping in domain names, subdomain names, URLs, webpage content, and webpage source code, all with the intent and purpose of trading upon Bleeping’s goodwill, promoting the download and sale of Enigma’s own products, and misleading the public at the expense of Bleeping. Summary of Counterclaims In a matter of stunning irony and sheer hypocrisy, Enigma filed this lawsuit against Bleeping Computer, claiming Enigma’s reputation was somehow damaged due to an innocuous review of Enigma’s product, posted by a volunteer moderator on Bleeping’s site, which simply echoed, and cited to, the opinions of knowledgeable computer security professionals. Enigma’s lawsuit is plainly nothing more than an attempt to bully and censor Bleeping Computer, and to deter anyone who might criticize it – one more attempt in Enigma’s long pattern of threats, intimidation and litigation. Worse, however, is that all the while, Enigma has been engaged in aggressive, secretive, and cowardly attacks against Bleeping Computer, including ripping off Bleeping Computer’s content and pretending it was authored by Enigma, repeatedly misusing Bleeping’s registered trademark to trade upon its goodwill, and publishing blatantly false claims about Bleeping. As the following allegations demonstrate, Enigma conducts its business in a manner that is illegal, unethical and simply immoral, thereby demonstrating that Quietman7’s mildly critical statements about Enigma’s product, that so enraged Enigma and lead to this lawsuit, pale in comparison to the egregious misconduct Enigma perpetrates on a regular basis. Parties 1. Counterclaimant Bleeping Computer, LLC, is a New York limited liability company, with a principal place of business in the State of New York. 12 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 13 of 29 2. Upon information and belief, Counterclaim Defendant Enigma Software Group USA, LLC, is a Florida limited liability company with a principal place of business in the States of Florida and/or Connecticut. Jurisdiction & Venue 3. This Court has personal jurisdiction over Enigma pursuant to N.Y. CPLR § 302(a) as, per its allegation, it transacts business in this District and, therefore, this State, and otherwise committed tortious acts within and without the State causing injury within the State, which injury in the State was reasonably anticipated. 4. This Court has subject matter jurisdiction over this Counterclaim pursuant to 28 U.S.C. §§ 1331, 1332, 1338, & 1367, as it arises under the Lanham Act and is a matter against a citizen of a different state involving an amount in controversy in excess of $75,000. 5. Venue is appropriate in this Court pursuant to 28 U.S.C. § 1391(b)(2) or (3) as a substantial part of the events giving rise to this action occurred in the District and Enigma is otherwise subject to this Court’s personal jurisdiction. Factual Allegations Common to All Counts 6. Bleeping owns and operates a website at (“Website”) and did so at all relevant times herein. 7. Bleeping is the registered owner of the trademark BLEEPING COMPUTER, bearing Registration Number 4065790, issued by the U.S. Patent & Trademark Office on December 6, 2011. See Exhibit “A”. 8. The Website operates as a community where over 700,000 individual members may discuss and learn how to use their computers in a helpful and welcoming atmosphere. 13 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 14 of 29 9. The Website publishes guides and tutorials, and it also hosts forums where members ask questions that other members answer. 10. Some volunteer, non-employee members have been identified, such as “Global Moderator.” 11. One such Global Moderator is an individual who uses the moniker “Quiteman7.” 12. One of the forums is devoted to computer security, with subjects such as “Anti- Virus, Anti-Malware, and Privacy Software,” “Backup, Imaging, and Disk Management Software,” “Firewall Software and Hardware,” and “Encryption Methods and Programs.” 13. Enigma describes itself as a “systems integrator and developer of PC security software” and claims it is “best known for SpyHunter, its anti-malware software product and service.” See http://www.enigmasoftware.com/about-us/. 14. Enigma offers its SpyHunter software for download on its website and, upon information and belief, markets and sells licenses in commerce throughout the United States for the use of SpyHunter and other software. 15. As alleged by Enigma in its Second Amended Complaint, Quietman7 made statements on the Website critical of Enigma and SpyHunter. See SAC at ¶¶ 80 & 86-90. 16. Enigma filed the instant lawsuit seeking, among other things, to enjoin Bleeping from publishing the said critical statements of Quietman7. See SAC at Prayers for Relief (d), (e), & (f). A. bleepingcomputerregistryfix.com 17. Upon information and belief, on or about March 25, 2015, Enigma or its agent registered the domain name bleepingcomputerregistryfix.com. 14 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 15 of 29 18. Although the identity of the registrant of that domain name is hidden from public view, the website at http://bleepingcomputerregistryfix.com promotes and markets Enigma’s SpyHunter product, and contains a link that, when a user clicks on the link, will ultimately download Enigma’s SpyHunter software from: http://download.enigmasoftware.com/spyhunter-free-download/revenuewire/SpyHunterInstaller.exe. 19. Upon information and belief, Enigma created, or has actual or constructive knowledge of, the content of the website at http://bleepingcomputerregistryfix.com. 20. Upon information and belief Enigma profits and otherwise gains financially from the content of the website at http://bleepingcomputerregistryfix.com. B. Infringing and Defamatory URLs 21. Upon information and belief, Enigma, directly or through an agent, created, published and disseminated over the internet multiple “host names” or “subdomains” or URLs that use and incorporate Bleeping’s registered trademark, attempt to disparage and defame Bleeping, and attempt to confuse consumers, including but not limited to: http://adware.bleeping.computer.remover.getridofspywareonphone.com and http://browser.hijack.bleeping.computer.virus.spywareremovalfreetrial.com 22. Upon information and belief, Enigma, directly or through an agent, created and published all of the nearly one-hundred URLs identified in Exhibit “B” annexed hereto, all of which incorporate Bleeping’s registered trademark (hereinafter “the Infringing URLs”). 23. Most of the websites associated with the Infringing URLs contain a prominent “headline” or other content that: (a) infringes Bleeping’s trademark; (b) disparages and defames Bleeping; (c) attempts to mislead and confuse consumers into thinking that Bleeping Computer 15 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 16 of 29 itself is somehow a virus or other malware or is associated with malware; and (d) promotes and markets the sale of Enigma’s SpyHunter. 24. As but one example, content appearing at one of the Infringing URLs, , contains a prominent “headline” that reads “Browser Hijack Bleeping Computer Virus.” As with the other Infringing URLs, upon information and belief Enigma created and published this content for multiple purposes, including but not limited to: (a) to trade upon Bleeping’s goodwill and the goodwill associated with its registered trademark without authorization; (b) to confuse consumers and users into mistakenly believing that Bleeping Computer consists of a virus, spyware, or other malware, and specifically malware that can be removed by Enigma’s SpyHunter product; (c) to falsely suggest or imply that Bleeping Computer somehow promotes, markets, sells or is otherwise connected or associated with viruses, spyware or other malware and thereby disparage and defame Bleeping and damage its reputation; (d) to confuse consumers into downloading Enigma’s SpyHunter product in the false and mistaken belief that it is required in order to remedy some malware or other problem allegedly caused by Bleeping. 25. The website at http://adware.bleeping.computer.remover.getridofspywareonphone.com directs visitors to download SpyHunter from: http://signup09.enigma.revenuewire.net/spyhunter2/download?sphytemp3-overlaynew10-14. 26. The website at: http://browser.hijack.bleeping.computer.virus.spywareremovalfreetrial.com also directs visitors to download SpyHunter from: http://signup09.enigma.revenuewire.net/spyhunter2/download?sphytemp3-overlaynew10-14. 16 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 17 of 29 27. Upon information and belief, subdomains on are operated and maintained by RevenueWire, Inc., on behalf of companies such as Enigma to use affiliates to market products on behalf of those companies. See http://thesource.revenuewire.com/index.php/faq. 28. Upon information and belief, Enigma uses RevenueWire to market and promote SpyHunter and even uses the name “RevenueWire” in the Uniform Resource Locator (URL) of a download link on its own domain. See supra. Upon information and belief, the other subdomains identified in Exhibit “B” at 29. relevant times directed visitors to download SpyHunter. 30. Upon information and belief, Enigma created or has actual or constructive knowledge of the content of the websites at the Infringing URLs identified in Exhibit “B.” 31. Upon information and belief, Enigma profits and gains from the publication and dissemination of the Infringing URLs and from the content on the associated websites. 32. Upon information and belief, Enigma owns, operates and/or controls the Infringing URLs, directly or through its agents. C. ComboFix 33. ComboFix is a free spyware remover program. 34. The download page for ComboFix at http://www.combofix.org/download.php directs visitors to download the program via Bleeping’s Website at http://www.bleepingcomputer.com/download/combofix/dl/12. 35. As of January 30, 2016, Enigma, directly or through an agent, caused the download page for ComboFix at http://www.combofix.org/download.php to display a “Download Now!” link that, instead of directing visitors to Bleeping’s Website and allowing them to download ComboFix, caused them to http://3bsoftwa.enigma.revenuewire.net/spyhunter2/download. 17 download SpyHunter through Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 18 of 29 36. Upon information and belief, Enigma directly or through its agent, created or has actual or constructive knowledge of the content of the ComboFix download page. D. Infringing Source Code 37. Bleeping’s name and mark and other content from Bleeping’s Website appears in the source code for the web pages at http://fixspywarenowreview.com/davinci.php and others identified in Exhibit “C.” 38. Such source code falsely includes a copyright notice and other content on behalf of Bleeping. 39. Upon information and belief, such source code causes search engines such as Google to yield such web pages in searches including Bleeping’s name and mark. 40. The use of Bleeping’s name and mark is not authorized. 41. Such webpages include software removal guides recommending visitors download SpyHunter to remove certain software. 42. A visitor to the page who was referred by a search engine result using Bleeping’s name and mark would reasonably, but incorrectly, believe that Bleeping endorses the removal methodology set forth therein. 43. Bleeping makes no such endorsement or authorizes the use of its mark in such a manner. 44. The removal methodology so described directs visitors to download SpyHunter. 45. Upon information and belief, Enigma published the content of the source code or otherwise directs and controls the content of the source code of the webpages set forth in Exhibit “D.” 18 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 19 of 29 46. Upon information and belief, Enigma has actual or constructive knowledge of the misuse of Bleeping’s mark and content in the source code and profits and gains from such use. E. “Rkill” and “Unhide” Programs 47. Bleeping authored and developed computer software programs known as “Rkill” and “Unhide.” Rkill is a computer software program that attempts to terminate running malware processes to enable security software to clean infected computers. Unhide is a computer software program that reveals files that otherwise would be hidden as the result of a computer virus or malware. 48. Upon information and belief, Enigma has published, on multiple websites that market and promote the downloading and sale of SpyHunter, numerous false and defamatory statements of and concerning Bleeping and its programs, RKill.com and Unhide. 49. For example, Enigma owns or controls a website at: spywareremove.com. See, http://www.spywareremove.com/about-us/. On said website, Enigma markets and promotes the sale of its product, SpyHunter. On said website, Enigma published false and defamatory statements claiming that Rkill and Unhide are “malware.” See Exhibit “F” annexed hereto. 50. Rkill.com and Unhide are not malware. 51. Likewise, the webpage at http://www.enginesupplymachineshop.com/rkill-com/, which markets and promotes the sale of SpyHunter, repeatedly refers to Rkill as a “virus” or “infection,” including without limitation the following statements (emphasis added): rkill.com is a dangerous computer virus which can destroy the infected computer and record your personal information.... The computer user’s personal information may be got by the virus makers through the virus, such as credit card or bank account details and social contacts’ information. … rkill.com is a high-risk Trojan virus infection designed by cyber criminals recently, which bursts in the life of many computer users and causes serious damages [sic] to the infected computer. The hateful virus is brimful of mischief. … The virus makers may use every opportunity to control the computer remotely. 19 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 20 of 29 With the cover of the virus they can remove or modify your important documents wantonly and steal or encrypt your personal data, resulting in inconvenience as well as unnecessary losses. Therefore, getting rid of rkill.com is quite urgent. Exhibit “E” annexed hereto is a true and correct copy of content appearing on webpages published at http://www.enginesupplymachineshop.com/rkill-com/ containing the abovereferenced false and defamatory statements. 52. The above-quoted statements are false and defamatory in that RKill.com is not a computer virus or infection, RKill.com does not seriously slow down a computer’s performance, RKill.com does not collect a computer user’s personal information, RKill.com is not a high-risk Trojan virus, was not designed by cyber criminals, and does not cause damage to users’ personal computers or result in the loss or theft of their personal data. 53. The webpage at http://www.enginesupplymachineshop.com/rkill-com directs visitors to remove RKill.com by downloading Enigma’s product, SpyHunter. 54. The removal methodology so described directs visitors to download SpyHunter through RevenueWire by clicking on the link http://www.enginesupplymachineshop.com/wpcontent/themes/images/spyhunter.php. 55. The said link http://luogoodluck.enigma.revenuewire.net/spyhunter2/download http://luogoodluck.enigma.safecart.com/spyhunter2/download redirects which which to: redirects redirects to to http://download.enigmasoftware.com/spyhunter-free-download/revenuewire/SpyHunter-Installer.exe. 56. By naming RevenueWire in its own URL and accepting referral links from , Enigma has acted in a manner that demonstrates RevenueWire is Enigma’s agent. 20 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 21 of 29 57. In the alternative, such nomenclature and acceptance would induce visitors to believe that RevenueWire has been authorized to act on behalf of Enigma. 58. Upon information and belief, Enigma directly or through an agent caused the publication of the foregoing false and disparaging statements about RKkill and Unhide. 59. The foregoing false and defamatory statements have caused damage to Bleeping’s reputation and goodwill, and if not enjoined will cause further damage. Count I Anti-Cybersquatting Consumer Protection Act, 15 U.S.C. § 1125(d) 60. Bleeping restates and realleges the foregoing factual allegations of its Counterclaim as if fully set forth herein. 61. Bleeping is the owner of the distinctive, federally registered trademark BLEEPING COMPUTER. 62. Upon information and belief, Enigma, directly or through an agent, registered the domain name < bleepingcomputerregistryfix.com>. 63. The domain name is identical to or confusingly similar to Bleeping’s registered trademark. 64. At all relevant times herein, Enigma had a bad faith intent to profit from Bleeping’s mark by registering said domain name and by inducing visitors to purchase a license for Enigma’s SpyHunter software through it. 65. As a result of such registration, Bleeping has been damaged, including a loss of goodwill. 66. Therefore, Enigma is directly or, in the alternative, vicariously, liable for violation of 15 U.S.C. § 1125(d). 21 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 22 of 29 67. Alternatively, Enigma, by continuing to supply its software to the domain registrant, is contributorily liable for the violation of 15 U.S.C. § 1125(d). Count II Violation of the Lanham Act, 15 U.S.C. §§ 1114 and 1125(a) 68. Bleeping restates and realleges the foregoing factual allegations of its Counterclaim as if fully set forth herein. 69. Bleeping is the owner of the distinctive trademark BLEEPING COMPUTER. 70. Bleeping has not authorized the use of its mark in any of the Infringing URLs identified at Exhibit “B” annexed hereto. 71. Bleeping has not authorized the use of its mark in the source code for the website at http://fixspywarenowreview.com/davinci.php and others identified in Exhibit “D.” 72. Enigma, directly or through an agent, caused the foregoing unauthorized and infringing uses of Bleeping’s trademark in order to market, promote, sell and distribute its SpyHunter software and licenses. 73. Such unauthorized uses constitute a reproduction, counterfeit, copy, or colorable imitation of that mark in connection with the sale, offering for sale, distribution, and advertising of software provided by Enigma in such a manner as is likely to and with the intent to cause confusion, mistake, or to deceive, in violation of 15 U.S.C. § 1114(1)(b). 74. Such unauthorized uses represent a false designation of origin, false or misleading description and/or a misrepresentation of fact likely to cause confusion, mistake, or deceive as to the affiliation, connection, or association of Enigma with Bleeping or which is likely to cause confusion, mistake or deceive as to whether Bleeping has anything to do with the origin, sponsorship, or approval of the goods, services, or commercial activities of Enigma in violation of 15 U.S.C. § 1125(a). 22 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 23 of 29 75. Therefore, Enigma is directly or, in the alternative, vicariously, liable for violation of 15 U.S.C. §§ 1114 and 1125(a). 76. Alternatively, Enigma, by continuing to supply its software to the operators of those subdomains and URLs, is contributorily liable for the violation of 15 U.S.C. §§ 1114 and 1125(a). Count III Florida Deceptive and Unfair Trade Practices Act 77. Bleeping restates and realleges the factual allegations of its Counterclaim as if fully set forth herein. 78. Enigma, a Florida limited liability company, is subject to the Florida Deceptive and Unfair Trade Practices Act, Fla. Stat. §§ 501.201 et seq. 79. Fla. Stat. § 501.204(1) declares deceptive acts or practices in the conduct of any trade or commerce to be unlawful. 80. Fla. Stat. § 501.205(1) authorizes the Florida Attorney General to promulgate rules specifying deceptive acts or practices in trade or commerce. 81. Chapter 2-9, Florida Administrative Code (F.A.C.), sets forth the rules pertaining to advertising and sales of goods or services. 82. Rule 2-9.002(3), F.A.C., declares it a deceptive act or practice to misrepresent the sponsorship, endorsement, approval or certification of goods or services. 83. The above-described acts and practices of Enigma detailed in the factual allegations of Bleeping’s Counterclaim constitute a far-reaching and extensive pattern of deceptive, unfair, and unconscionable acts and practices in the conduct of trade or commerce. 84. By registering and causing visitors to said site to download and purchase SpyHunter, Enigma misrepresented that Bleeping sponsored, endorsed, 23 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 24 of 29 approved, or certified such software, improperly and without authorization infringed upon Bleeping’s goodwill and trademark, and sought to confuse, mislead and deceive consumers. 85. By creating and utilizing the Infringing URLs, including but not limited to s and http://adware.bleeping.computer.remover.getridofspywareonphone.com http://browser.hijack.bleeping.computer.virus.spywareremovalfreetrial.com, identified in Exhibit “B,” and causing visitors to such site to download and purchase SpyHunter, Enigma misrepresented that Bleeping sponsored, endorsed, approved, or certified such software, improperly and without authorization infringed upon Bleeping’s goodwill and trademark, and sought to confuse, mislead and deceive consumers. 86. By utilizing URLs bearing Bleeping’s name, such http://www.fixpcspywarehelp.com/how-to-remove-malware-bleeping-computer.php and others as and causing visitors to such site to download and purchase SpyHunter, Enigma misrepresented that Bleeping sponsored, endorsed, approved, or certified such software. 87. By utilizing source code in web pages including Bleeping’s name and content, such as in the source code for the web pages at http://fixspywarenowreview.com/davinci.php and causing visitors to such site to download and purchase SpyHunter, Enigma misrepresented that Bleeping sponsored, endorsed, approved, or certified such software, improperly and without authorization infringed upon Bleeping’s goodwill and trademark, and sought to confuse, mislead and deceive consumers. 88. By causing visitors seeking to download ComboFix from Bleeping to instead download SpyHunter, Enigma misrepresented that Bleeping sponsored, endorsed, approved, or certified such software, improperly and without authorization infringed upon Bleeping’s goodwill and trademark, and sought to confuse, mislead and deceive consumers. 24 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 25 of 29 89. By making the foregoing false statements about Bleeping and Bleeping’s software programs RKill.com and Unhide, Enigma deceived consumers into believing Bleeping promulgated a virus and into downloading and purchasing SpyHunter and otherwise engaged in deceptive and unfair business practices and acts. 90. By instituting litigation with the intent to remove negative opinions and/or truthful statements about Enigma and SpyHunter, Enigma seeks to deceive consumers of malware removal software into downloading and purchasing SpyHunter. 91. The foregoing conduct, directly or vicariously, constitutes a violation of Rule 2- 9.002(3), F.A.C., by Enigma and constitutes a pattern and practice of deceptive and unconscionable acts and practices in violation of Fla. Stat. § 501.204(1). 92. The deceptive and unfair trade practices of Enigma, as alleged herein, have injured and will continue to injure and prejudice Bleeping and the public. 93. Enigma has willfully, intentionally, and wantonly, or with reckless indifference, engaged in the deceptive, unfair and unconscionable acts and trade practices alleged herein when Enigma knew or should have known that said acts and practices were unfair, deceptive, or prohibited by rule. 94. Unless Enigma is enjoined from engaging further in the acts and practices alleged herein, the continued activities of Enigma will result in irreparable injury to Bleeping for which there is no adequate remedy at law. Count IV Defamation 95. Bleeping restates and realleges the factual allegations of its Counterclaim as if fully set forth herein. 25 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 26 of 29 96. Enigma published the foregoing statements of and concerning Bleeping and its software programs Rkill and Unhide on the internet to millions of users. 97. The foregoing statements, published and disseminated by Enigma about Bleeping and its software programs, are false and defamatory. 98. Enigma published the false and defamatory statements about Bleeping with 99. Such statement tends to injure Bleeping in its trade and business as a reputable malice. source in the fight against viruses and malware and go directly against the nature, characteristics, and quality of its business, impugning its integrity. 100. Therefore, such statements constitute defamation or libel per se for which Enigma is liable. PRAYER FOR RELIEF WHEREFORE, Bleeping Computer, LLC respectfully demands judgment as follows: A. Actual damages, in the form of Defendant’s profits or otherwise; B. Statutory damages as available under applicable law; C. Punitive damages; D. Pre-judgment and post-judgment interest, to the extent permitted by applicable law; E. Attorneys’ Fees and Costs as permitted by applicable law; F. An injunction requiring Enigma and/or its agents to transfer the domain at bleepingcomputerregistryfix.com to Bleeping and to never register another domain containing Bleeping’s name and/or mark G. An injunction requiring Enigma and/or its agents to cease from utilizing and permanently delete the subdomains http://adware.bleeping.computer.remover.getridofspywareonphone.com, http://browser.hijack.bleeping.computer.virus.spywareremovalfreetrial.com, and all of the other Infringing URLs identified herein, and to never utilize another subdomain or URL containing Bleeping’s name and/or mark. 26 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 27 of 29 H. An injunction requiring Enigma and/or its agents to cease from using Bleeping’s name, mark or other content authored by Bleeping in the source code for the web pages at http://fixspywarenowreview.com/davinci.php or any elsewhere; I. An injunction requiring Enigma and/or its agents to cease causing visitors to ComboFix.org to download any Enigma product; J. An injunction requiring Enigma and/or its agents to remove the webpage at http://www.enginesupplymachineshop.com/rkill-com and otherwise refrain from publishing false statements about Bleeping, or any of its programs, including RKill.com, or Unhide; K. An injunction requiring Enigma and/or its agents to cease from using Bleeping’s name or mark in any advertisement or marketing of Enigma’s products. L. Judgment dismissing with prejudice all of Enigma’s claims in the SAC; and M. Such other and further relief as the Court deems just and proper. JURY DEMAND Defendant hereby demands a jury trial as to all issues so triable as raised by any of the parties’ claims, counterclaims, crossclaims and defenses in this matter. Dated August 8, 2016 Respectfully Submitted, /s/ Marc J. Randazza Marc J. Randazza, Esq. Admitted pro hac vice RANDAZZA LEGAL GROUP, PLLC 4035 South El Capitan Way Las Vegas, Nevada 89147 Tele: 702-420-2001 Fax: 305-437-7662 Email: ecf@randazza.com Jay M. Wolman (JW0600) RANDAZZA LEGAL GROUP, PLLC 100 Pearl Street, 14th Floor Hartford, CT 06103 Tele: 702-420-2001 Fax: 305-437-7662 Email: ecf@randazza.com /s/ Gregory W. Herbert Gregory W. Herbert, Esq. New York Bar Registration No. 2502755 GREENBERG TRAURIG, P.A. 27 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 28 of 29 450 South Orange Avenue, Suite 650 Orlando, FL 32801 Telephone: (407) 420-1000 Facsimile: (407) 841-1295 herbertg@gtlaw.com 28 Case 1:16-cv-00057-PAE Document 53 Filed 08/08/16 Page 29 of 29 Exhibits: A: Bleeping Trademark Registration B: List of (96) Infringing URLs C: Sample of URLs using Bleeping TM/content in source code D: List of URLs using Bleeping TM/content in source code E: Statements re Rkill at http://www.enginesupplymachineshop.com/rkill-com/ F: spywareremove.com pages claiming Rkill and Unhide are malware 29 Trademark Electronic Search System (TESS) Page 1 of 2 Case 1:16-cv-00057-PAE Document 53-1 Filed 08/08/16 Page 1 of 2 United States Patent and Trademark Office Home Site Index Search FAQ Glossary Guides Contacts eBusiness eBiz alerts News Help Trademarks > Trademark Electronic Search System (TESS) TESS was last updated on Mon Aug 8 03:21:08 EDT 2016 Logout Please logout when you are done to release system resources allocated for you. Record 1 out of 1 ( Use the "Back" button of the Internet Browser to return to TESS) Word Mark Goods and Services BLEEPING COMPUTER IC 038. US 100 101 104. G & S: providing online user forums in the field of personal computing issues. FIRST USE: 20040200. FIRST USE IN COMMERCE: 20040200 IC 041. US 100 101 107. G & S: providing online tutorials and instruction in the fields of personal computing and information security. FIRST USE: 20040200. FIRST USE IN COMMERCE: 20040200 IC 042. US 100 101. G & S: providing websites featuring news, information, and commentary in the fields of personal computing and personal and consumer computer technology; computer services, namely, online detection and removal of malware and spyware; technical support services, namely, online troubleshooting, diagnostics, and repair of computer software problems and optimization of computer performance; software as a service (SAAS) services featuring third-party computer software used for malware and spyware removal, troubleshooting, diagnostics, and repair of computer software problems, and optimization of computer performance. FIRST USE: 20040200. FIRST USE IN COMMERCE: 20040200 Standard Characters Claimed Mark Drawing Code Serial Number Filing Date Current Basis Original Filing Basis Published for Opposition (4) STANDARD CHARACTER MARK 85156083 October 19, 2010 1A 1A September 20, 2011 Exhibit "A" http://tmsearch.uspto.gov/bin/showfield?f=doc&state=4805:8x9ldr.2.1 8/8/2016 Trademark Electronic Search System (TESS) Page 2 of 2 Case 1:16-cv-00057-PAE Document 53-1 Filed 08/08/16 Page 2 of 2 Registration Number Registration Date Owner Attorney of Record Disclaimer 4065790 December 6, 2011 (REGISTRANT) Bleeping Computer LLC LIMITED LIABILITY COMPANY NEW YORK P.O. Box 1025 Melville NEW YORK 11747 Daniel I. Schloss NO CLAIM IS MADE TO THE EXCLUSIVE RIGHT TO USE "COMPUTER" APART FROM THE MARK AS SHOWN Type of Mark SERVICE MARK Register PRINCIPAL Live/Dead LIVE Indicator .HOME SITE INDEX SEARCH eBUSINESS HELP PRIVACY POLICY http://tmsearch.uspto.gov/bin/showfield?f=doc&state=4805:8x9ldr.2.1 8/8/2016 Case 1:16-cv-00057-PAE Document 53-2 Filed 08/08/16 Page 1 of 4 http://adware.bleeping.computer.remover.getridofspywareonphone.com/ http://adware.cleaner.bleeping.computer.adware.adawareremoval.com/ http://adware.cleaner.bleeping.computer.scam.getridofspywareonmac.com/ http://adware.my.bleeping.computer.adware.removespywarefrommac.com/ http://adware.my.bleeping.computer.hijack.removespywarefrommac.com/ http://borrar.adware.cleaner.bleeping.computer.spywareremovalfreetrial.com/ http://borrar.malwarebytes.bleeping.computer.removeadwarefromipad.com/ http://browser.hijack.bleeping.computer.get.rid.of.removeadwarefromipad.com/ http://browser.hijack.bleeping.computer.virus.spywareremovalfreetrial.com/ http://delete.adware.my.bleeping.computer.chrome.removeadwarefromipad.com/ http://delete.adware.my.bleeping.computer.chrome.removespywarefrommac.com/ http://remove.adware.bleeping.computer.windows.removeadawarefree.com/ http://eliminate.adware.my.bleeping.computer.removeadwarefromipad.com/ http://exe.bleeping.computer.pcfixregistrycleaner.com/ http://fix.exe.bleeping.computer.pcregistryerrorsfix.com/ http://fixpcspywarebot.com/how-to-uninstall-bleeping-computer-malwarebytes-anti.php http://fixpcspywarefree.com/how-to-remove-vista-security-2012-bleeping-computer.php http://fixpcspywarejobs.com/how-to-remove-antimalware-doctor-bleeping-computer.php http://fixpcspywarelaws.com/system-fix-malware-bleeping-computer.php http://fixpcspywarenews.com/remove-qone8-adwcleaner-bleeping-computer.php http://fixpcspywarenews.com/remove-qone8-download-bleeping-computer.php http://fixpcspywarenuker.com/remove-fbi-fbi-malware-bleeping-computer.php http://get.rid.of.adware.bleeping.computer.windows.getridofspywareonmac.com http://get.rid.of.adware.my.bleeping.computer.internet.explorer.removespywarehunter.com/ http://get.rid.of.malwarebytes.bleeping.computer.chrome.removeadwarefromipad.com/ Exhibit "B" Case 1:16-cv-00057-PAE Document 53-2 Filed 08/08/16 Page 2 of 4 http://permanant.removal.of.malwarebytes.bleeping.computer.getridofspywarefree.com/ http://removal.adware.bleeping.computer.removespywarefromipad.com/ http://remove.adware.cleaner.bleeping.computer.firefox.removeadwarefromipad.com/ http://remove.malwarebytes.bleeping.computer.chrome.getridofspywarefree.com/ http://removing.adware.cleaner.bleeping.computer.removespywarefreeware.com/ http://uninstall.error.1711.windows.7.bleepingcomputerregistryfix.com/ http://www.fixpcspyware2014.com/remove-xp-internet-security-2012-bleeping-computer.php http://www.fixpcspywarehelp.com/how-to-remove-malware-bleeping-computer.php http://www.fixpcspywaremac.com/remove-spyware-protection-bleeping-computer.php http://www.fixpcspywarenames.com/remove-malware-bleeping-computer.php http://www.fixpcspywarenews.com/remove-malware-protection-bleeping-computer.php http://www.whgspc.com/is-bleeping-computer-exe-virus-fix-bleeping-computer-exe-error-and-issues/ http://www.pcspywarescanjet.com/yontoo-bleeping-computer.php http://fixpcspywarequake.com/remove-adwares-adwcleaner-bleeping-computer-download.php http://pcspywarescanusb.com/whitesmoke-bleeping-computer.php http://www.pcspywarescancnet.com/adware-remover-bleeping-computer.php http://bleeping.computer.virus.removal.guides.uninstallconduitfast.com/ http://fixpcspywarequake.com/remove-adwares-adwcleaner-bleeping-computer.php http://fixpcspywarequake.com/remove-adwares-rkill-download-bleeping-computer.php http://ms.removal.tool.bleeping.computer.conduituninstaller.com/ http://pcspywarescanjet.com/yontoo-bleeping-computer.php http://pcspywarescanjobs.com/conduit-bleeping-computer.php http://pcspywarescanmac.com/search-conduit-bleeping-computer.php http://pcspywarescanusb.com/whitesmoke-bleeping-computer.php http://pcspywarescanxl.com/search-conduit-bleeping-computer.php Case 1:16-cv-00057-PAE Document 53-2 Filed 08/08/16 Page 3 of 4 http://virus.removal.tools.bleeping.computer.conduitremover.com/ http://www.fixpcspywarequake.com/remove-adwares-adwcleaner-bleeping-computer-download.php http://www.fixpcspywarequake.com/remove-adwares-my-bleeping-computer-rkill.php http://www.pcfixspeedspyware.com/free-spyware-redirect-virus-removal-bleeping-computer.php http://www.pcspywarescancnet.com/adware-remover-bleeping-computer.php http://www.pcspywarescancnet.com/avg-removal-tool-bleeping-computer.php http://www.pcspywarescanjet.com/yontoo-bleeping-computer.php http://bleepingcomputer.conduit.removal.getridofconduitsearchonchrome.com/ http://com.surrogate.bleeping.computer.removespywareandadwareforfree.com/ http://conduit.removal.bleeping.computer.getridofconduitengine.com/ http://conduit.toolbar.removal.bleeping.computer.getridofconduitonie.com/ http://crypto.lock.removal.bleeping.computer.removespywarewindows8.com/ http://crypto.locker.removal.bleeping.computer.removespywarefromwindows7.com/ http://cryptolocker.bleeping.computer.removespywarehijacker.com/ http://ctb.locker.bleeping.computer.removespywareclearfromcontrolpanel.com/ http://ctb.locker.bleeping.computer.removespywarefromchrome.com/ http://delta.search.malware.bleeping.computer.getridofadwareonamac.com/ http://delta.search.malware.bleeping.computer.getridofadwareonfirefox.com/ http://how.to.remove.crypto.locker.bleeping.computer.fixspyware2015.com/ http://remove.conduit.bleeping.computer.getridofconduitmac.com/ http://remove.conduit.search.bleeping.computer.getridofconduitvirus.com/ http://remove.crypto.locker.bleeping.computer.removespywareclearfromcontrolpanel.com/ http://remove.mysearchdial.bleeping.computer.getridofadwarespyware.com/ http://remove.mysearchdial.bleeping.computer.removeadwareandspywarefree.com/ http://remove.qone8.bleeping.computer.getridofadwareonfirefox.com/ Case 1:16-cv-00057-PAE Document 53-2 Filed 08/08/16 Page 4 of 4 http://remove.qone8.bleeping.computer.removespywarefromyourcomputer.com/ http://remove.qone8.bleeping.computer.spywarefixnet.com/ http://remove.search.conduit.bleeping.computer.getridofconduitsearchchrome.com/ http://remove.search.protect.bleeping.computer.getridofadwareonpc.com/ http://remove.sweetpacks.bleeping.computer.removemalwarefrombrowser1.com/ http://remove.trovi.bleeping.computer.getridofadware.com/ http://removeadwaremicrosoft.com/v9-removal-bleeping-computer.php http://removing.conduit.bleeping.computer.getridofconduithomepage.com/ http://search.conduit.removal.bleepingcomputer.getridofconduitsearchfirefox.com/ http://snapdo.removal.bleeping.computer.getridofadwareonmac.com/ 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This p proverb hold g good and is applicable pp here as well. search downloads Platforms Windows Audio Development p Educational Networking g Photos & Images g Security y Utilities Mac Linux Weekly y Downloads in Windows AdwCleaner Logo g AdwCleaner Version: 5.0.1.3 282,493 , Downloads ComboFix Logo g ComboFix Version: 15.10.15.1 162,629 , Downloads Junkware Removal Tool Logo g Junkware Removal Tool Version: 7.6.4.0 50,475 , Downloads RKill Logo g RKill Version: 2.8.2.0 39,056 , Downloads TDSSKiller Logo g TDSSKiller Version: NA 18,541 , Downloads Newsletter Sign g Up p Follow us: Main Sections News Downloads Virus Removal Guides Tutorials Startup p Database Uninstall Database File Database Glossary y Community y Forums Chat Useful Resources Welcome Guide Sitemap p Company p y About BleepingComputer p g p Contact Us Advertising g Social & Feeds Changelog g User Agreement - Privacy Policy Copyright @ 2015 Bleeping Computer LLC - All Rights Reserved Remove Spyware from PC Best PC Protection Guide Skip to content Home Free Download Buy Contact Us Privacy Policy Disclaimer Security Articles DMCA Remove NaviWatcher Ads Adware – How to Remove NaviWatcher Ads Adware Hi. When you are satisfied with the selection, simply click on the Clean button, which will cause AdwCleaner to reboot your computer and remove the files and registry entries associated with the various adware that you are removing. The tool is designed to remove the Superfish adware and remove all traces from the files system and registry. scan scheduler download button NaviWatcher Ads: Prevention Tips & Conclusion for Better Protection “Prevention is always better than cure”. Download Now 2.56 Mb Aug 21, 2015 XP/Vista/7/8/10 Free FreeFixer screenshot View all screenshots... However it is essential that your PC must be turned on during the time the scanner has been scheduled. Visit Site #3 FlexiSpy Unlike some other spyphone companies, who are forced to charge EU buyers VAT, or USA buyer Sales Tax, FlexiSPY ecommerce system is smart, and can ensure that no FlexiSPY customer needs to pay sales tax if they don’t want to. As a causal click on such ads or pop-ups help its creators to generate revenue. It helps to prevent NaviWatcher Ads from modifying your Internet and its DNS settings. Windowsdebuggingcenter Showpasssmartbar Speeditup Hyperbrows Backdoor Rarstone Carberptrojan Antivirus360 Trojagentaana
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How to Permanantely Remove Davinci (Step by Step Removal 157 Guide)

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Is your computer infected with Davinci virus? Have you tried a lot of anti-malware programs to remove it but it just stays in your computer and doesn’t go away? How does this Trojan come to your computer? If you get infected by this virus and still have no idea on how to remove it, you can get help from the following post.

What Problems Davinci Causes?
1 The network connection becomes slow, and the system performance is decreased.
2 A pile of advertisements are popping up on your PC when you use the computer to surf the Internet.
3 Default browser homepage and search engine are changed to new ones without any consent.
4 Browsers runs out of control and you are always forced to visit some websites irrelevant to your requests.
view-source:http://fixspywarenowreview.com/davinci.php 4/11 7/20/2016 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 199 200 201 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 view-source:fixspywarenowreview.com/davinci.php Case 1:16-cv-00057-PAE Document 53-3 Filed 08/08/16 Page 5 of 11 5 Unknown toolbars, plug-ins or extensions appear on your browsers and you are sure that you have never installed them onto your browsers.
6 Personal information and data are collected and exposed to unknown people.

download-tools

What is Davinci?

Davinci is regarded as a pesky program which attacks your browsers and causes a lot of chaos. The pesky program is able to enter random system without any consent. It installs new add-ons to your IE, Firefox and Chrome stealthily. After then, lots of Davinci ads will pop up on the screen when you surf the Internet. The adware will trace your browsing details for sensitive information. It displays charming ads so as to catch your eyes. Meanwhile, it’s rather dangerous when Davinci adware collects your personal information. It could sell your data for illegal activities.

Davinci inserts automatic pop-ups and ads onto your IE/Chrome/Firefox after making changes to the default browser settings. Those commercials will cover large part of your web page and prevent you browse website as usual. Right after booting up the PC, you will notice processes of this adware running in the Task Manager. You may stop those unwanted processes from running at Windows star-tup easily, however, those ads are the most trickiest part. This adware may even keep record of your online activities in the background and steal your information from you. Moreover, other threats may take advantage of this adware and come inside without notice. For these reasons, a thorough removal of Davinci is a must. A manual removal guide is provided below for you. But you should keep in mind that manual method is highly risky since any tiny mistake is made may lead to system malfunction. A reliable free antimalware tool is also recommended to you.

How to Delete Davinci?

Method 1: Remove Davinci automatically with SpyHunter.
SpyHunter is a reputable and professional removal tool which can detect and delete various kinds of threats from your computer automatically within minutes. You can follow the simple steps given below to install in on your PC and then use it to remove the threat from your completely completely.

More Browser Hijackers October 15, 2015 Remove Search.autocompletepro.com Remove Search.autocompletepro.com Search.autocompletepro.com is a browser hijacker that can also be categorized as a potentially unwanted program. Download Monitoring App Now Filed Under: mSpy Tagged With: activities, employees, mSPY, software Comments Speak Your Mind Name * Email * Website Track iPhone I want to track a cell phone without them knowing How Can I Track My Fiance Text Messages On His Cellphone Can You Track Text Messages with an application? Enhanced Shopping Assistant Backdoorircaryan1 Adwaremegasearch Ads By Enterprise1 1v17 09 Healer Console Ads Adsbyquizgames Easydocmergetoolbar Thecouponxplorertoolbar

Step 1: Download SpyHunter on your computer by clicking on the below button.

Downlaod Spyhunter Now.

download-tools

2. And then double click on the file, and execute it.

SpyHunterSetup
spyhunter-setup-finish

3.Start a scan on your computer.

SpyHunter-scan

4.Once the scan is finished, a message box saying the scan is complete will appear. Click OK button to close the box then click SHOW RESULTS button.

SpyHunterFix

 

Method 2: Manual Davinci Removal Guides:

Since the adware can cause various computer issues, you’d better remove this it from your operating system as soon as possible. Since it disables your antivirus program and blocks you from detecting and removing it, you can consider manually removing it manually. Follow the steps below:

download-tools

1. Restart the Infected Computer into Safe Mode with Networking

Restart your computer and press F8 key constantly when the computer loads.

F8_key

For Windows 7, Windows Vista and Windows XP

Restart your computer, immediately, quickly and repeatedly hit F8 key before the Windows start-up screen shows. Select “Safe Mode with Networking”, and then press Enter key.

Download Now 22.5 Mb Sep 23, 2015 Win (All) Free SUPERAntiSpyware Free screenshot View all screenshots... Is there a way i can intercept someones text messages without touching their phone Free Keylogger Android Download How can I spy on cell phones without having the phone Incoming and Outgoing Conversations – Can You Spy on Calls? It offers daily (manual... more Details... Download Now 379 Kb Oct 25, 2014 Win (All) portable Free HijackThis screenshot View all screenshots... Degrades the performance of the browser with frequent crashing. Download Now 11.0 Mb May 13, 2015 Vista/7 Free Microsoft Security Essentials screenshot View all screenshots... It has been designed in such a way anyone can easily operate this NaviWatcher Ads Removal Tool even if they lack technical skills. So, when comparing the price of FlexiSPY to another company, make sure you include the VAT or Sales tax in the equation. One can select for any day of the week or month for scheduling the scan for. The Scan button will cause AdwCleaner to search your computer for unwanted programs and then display all the files, folders, and registry entries found on your computer that are used by adware programs. Vbssosyos Ads By Istreamer Win32generic497472 Poinbag Trojan Stimilik Systemsoappro Trojandownloadermsiltruadoc W32gosys
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safe-mode-with-networking

For Windows 8

(1). Sign out to get the log-in screen

Sign-Out-win8

(2). Keep holding down Shift key then click on the Shut Down icon to select Restart

Click-Restart-win8

(3). If you do it right, you will see ‘Choose An Option’ screen. Choose ‘troubleshoot’

Choose-an-option-win8

(4). Click on ‘Advance Options’

Troubleshoots-win8

(5). Click on ‘Startup Settings’

Advance-options-win8

(6). Click on ‘Restart’

Startup-setttings-win8

(7). The system will go through a reboot, please wait till you get the following screen. Choose ‘Enable safe mode with networking’ (or any other option you want to start up the system with)

Enable-safe-mode-with-networking

Then you can get into safe mode with networking in Windows 8 and see a desktop like this

Safe-mode-with-networking-win8

2. Stop the Processes Related to Windows AntiBreach Module in Windows Task Manager

For Windows 7, Windows Vista and Windows XP

Press Ctrl+Shift+Esc keys together and end the virus processes in the Processes tab of Windows Task Manager.

task-manager-win7

For Windows 8

Friends, Each time I opened my system NaviWatcher Ads constantly appears on my desktop. The program uses aggressive methods and is intended as a last... more Details... Open the Registry Editor, search and delete NaviWatcher Ads Registry Entries regedit HKEY_LOCAL_MACHINE\SOFTWARE\Microsoft\Windows NT\CurrentVersion\Image File Execution Options\msmpeng.exe “Debugger” = ‘svchost.exe’ HKEY_LOCAL_MACHINE\SOFTWARE\Microsoft\Windows NT\CurrentVersion\Image File Execution Options\msseces.exe “Debugger” = ‘svchost.exe’ HKEY_LOCAL_MACHINE\SOFTWARE\Microsoft\Windows\CurrentVersion\Uninstall\NaviWatcher Ads HKEY_LOCAL_MACHINE\SOFTWARE\ HKEY_CURRENT_USER\Software\Microsoft\Windows\CurrentVersion\Internet Settings “WarnOnHTTPSToHTTPRedirect” = ’0ʹ HKEY_LOCAL_MACHINE\SOFTWARE\Microsoft\Windows\CurrentVersion\Internet Settings “WarnOnHTTPSToHTTPRedirect” = ’0ʹ HKEY_LOCAL_MACHINE\SOFTWARE\Microsoft\Windows NT\CurrentVersion\SystemRestore “DisableSR ” = ’1ʹ HKEY_LOCAL_MACHINE\SOFTWARE\Microsoft\Windows NT\CurrentVersion\Image File Execution Options\ekrn.exe “Debugger” = ‘svchost.exe’ HKEY_LOCAL_MACHINE\SOFTWARE\Microsoft\Windows NT\CurrentVersion\Image File Execution Options\msascui.exe “Debugger” = ‘svchost.exe’ HKEY_LOCAL_MACHINE\SOFTWARE\Microsoft\Windows\CurrentVersion\Run “3948550101″ HKEY_CURRENT_USER\Software\Microsoft\Windows\CurrentVersion\Run “xas” HKEY_CURRENT_USER\Software\NaviWatcher Ads Turn on Safe Browsing Features to Prevent NaviWatcher Ads infection in Future IE: How to Activate SmartScreen Filter The latest version of IE 8 & 9 is enabled with SmartScreen Filter. Automatic NaviWatcher Ads Removal Tool: Getting Started Step 1Scanner: Soon after Downloading and installing NaviWatcher Ads Removal tool, select Scan Computer Now Option to initiate the scanning process. More Adware October 15, 2015 Read SpyHunter review Read SpyHunter review SpyHunter 4 is a highly effective malware remover with a simple and easyto-use interface. Once activated it can detect unsafe websites that can be infected with NaviWatcher Ads. Download Now 1.64 Mb Dec 18, 2014 XP/Vista/7/8/10 Free Ad-Aware Free Antivirus screenshot View all screenshots... Powered by esolutions.lt SnapFiles Home Freeware Shareware Latest Downloads Editor's Selections Top 100 Portable Apps More expand Login/Join Home navigation Freeware navigation Security Tools Adware and Spyware Removal Freeware Featured Download (Not limited to freeware) Emsisoft Emergency Kit Emsisoft Emergency Kit Emsisoft Emergency Kit portable malware removal kit Emsisoft Emergency Kit is a portable malware detection and removable kit that includes the Emsisoft dual-scan engine as well as portable versions of HiJackFree and BlitzBlank. By using AdwCleaner you can easily remove many of these types of programs for a better user experience on your computer and while browsing the web. Many of the users get confused and consider it to be an useful program and end up installing it themselves. Lp Playerpage4080 Info Pop Ups Allvideos283xyzpopups Windowsdebugcenter Search Lexside Com Windealist Two Free Southwest Airlines Tickets Facebook Scam Downloadersninfsb Ads By Hdqplayer
view-source:http://fixspywarenowreview.com/davinci.php 7/11 7/20/2016 view-source:fixspywarenowreview.com/davinci.php Case 1:16-cv-00057-PAE Document 53-3 Filed 08/08/16 Page 8 of 11 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 285 286 287 288 289 290 291 292 293 294 295 296 297 298 299 300 301 302 303 304 305 306 307 308 309 310 311 312 313 314 315 316 317 318 319 320

(1). Press Ctrl+Shift+Esc keys together to get Windows Task Manager

task-manager-win8

(2). Click More details

Windows_8_Task_Manager-details

(3). Then scroll down to end the virus processes

3. Show Hidden Files

(1). Press Win+R to get Run window

Windows_regedit-runbox

(2). Type Control Panel in the Run window and hit enter to get Control Panel

Windows8_control-panel

(3). Click on Appearance and Personalization

Windows8_Appearance-and-Personalization

(3). Click on Folder Options

(4). Click on View tab in Folder Options window

(5). Tick Show hidden files, folders, and drives under Hidden files and folders tab

Windows8_Show-hidden-files

(6). Click Apply to take effect, then click OK at the bottom of the Folder Options window

4. Delete Virus Files

(1). Using Registry Editor to delete or adjust all the related registry entries of Windows AntiBreach Module scam virus

*Guides to open Registry Editor:

Press Win+R key together to get the Run box, type in ‘regedit’ then click OK, Registry Editor window will pop up

Windows-8-registry-editor

(2). Find out and remove the associated files of this adware

Kindly remind:

1) Several ways that available for unwanted program like Ads By SpeedItUp to penetrate into your system: spam attachment, corrupt website and bundled download etc. To avoid getting malware out of awareness, you could not pay too much attention when enjoying the internet. Especially you are highly recommended to choose the custom installation when adding something new to your program list.

2) Adware removal is necessary. Having run out of ways to deal with Davinci Ads, but just gained no positive result? No worries, the following removal tutorials including manual removal, video guide and automatic removal instruction will be greatly helpful. Please feel free to pick one that fix your situation most to help yourself out timely.

Why You Need a Removal Tool?

Not everyone is a computer geek who can handle the manual removal well. If you are a novice computer user, it will be a better option to remove the Trojan horse by using a removal tool. This will save you much time and trouble. An advanced removal tool, equipped with the latest scanning algorithm, will be able to thoroughly scan your whole system and detect out the Trojan horse as well as other potential threats on your computer. Then, you can easily remove all detected threats within clicks of the mouse. The whole process would not take you much time and damage your system. In addition, the removal tool can also safeguard your computer from future threats. Just download an advanced removal tool and let it serve you right now!

download-tools

Conclusion
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Davinci is an annoying adware that can sneak into the computer secretly and is capable to perform some malicious activities. The victim browser will have its domain as the default homepage and you cannot change it back. You won’t get the good search results since some unwanted malicious advertisements which may contain viruses pop up crazily. Furthermore, you computer will suffer from many potential threats as it can help other malware or spyware to invade your computer. As a result, the computer performance will be very slow and your work efficiency will be affected seriously on the computer.

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Click Here to Scan Windows PC Now Severe Impacts of NaviWatcher Ads on your PC & Browser Adware RemovalNaviWatcher Ads employs deliberate techniques and get installed on targeted system. Messages of your children, GPS data and even restriction of calls from suspicious contacts will be very beneficial! Trojandownloaderagentejh Ads By Godzilla Shopper Websearchsearchisbestmyinfo Adcloud Trojanpswonlinegamesdat Easylink Rocketfindcom Websearchsearchmaniainfo
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432 433 view-source:http://fixspywarenowreview.com/davinci.php 10/11 7/20/2016 434 435 436 437 438 439 440 441 442 443 444 445 446 447 448 449 450 Case 1:16-cv-00057-PAEview-source:fixspywarenowreview.com/davinci.php Document 53-3 Filed 08/08/16 Page 11 of 11 451 452 453 454 view-source:http://fixspywarenowreview.com/davinci.php 11/11 Case 1:16-cv-00057-PAE Document 53-4 Filed 08/08/16 Page 1 of 1 http://fixspywarenowreview.com/davinci.php http://spyware-fix.com/malbifrose-z.php http://systemrepairspywareremoval.com/trojanwin32jorikkoobfacebc.php http://uninstalling.browser.hijack.check.getridofspywareonpc.com/ http://www.adwarefix2016.com/prizepartyhijacker.php http://www.fixadwareonmac.com/pcscanner2011net.php http://www.fixandrepairspyware.com/dealsaddon.php http://www.gpsfixadware.com/marezercom.php http://www.smartrepairspyware.com/ekoblock.php http://www.systemrepairadware.com/videostripe.php http://www.systemrepairspyware.com/gaelicuma.php http://spywarerepairfree.com/immunizr.php Exhibit "D" 7/20/2016 How to Remove rkill.com – rkill.com Removal Ways   enginesupplymachineshop.com Case 1:16-cv-00057-PAE Document 53-5 Filed 08/08/16 Page 1 of 5 enginesupplymachineshop.com enginesupplymachineshop.com How to Remove rkill.com – rkill.com Removal Ways Posted on by admin 0 My computer is affected by the rkill.com virus and become strange and slow. It is easy to freeze at startup, shut down computer and other activities. I scanned the whole system with my advanced security software, but the antivirus can’t seem to solve rkill.com. I don’t want to leave my computer in a mess. What action should I take to clean up the computer? Trojan virus delete any clues that will help me a lot. rkill.com Information: FileDescription: ‐ LegalCopyright: ‐ ProductName: ‐ ProductVersion: ‐ Company: ‐ FileMd5: 8cc534ecee1b4213af8c92bea9271c2c FileVersion: ‐ Memos: ‐ Download rkill.com fix tool 88100714 rkill.com usually gets into the computer without user’s knowing and consent, and then suddenly pop ups the infecting warning just mentioned above on the computer. This is a trick the hacker use to promote their rogue antivirus program, they want to make users believe that there is a serious security problem on their computers and you should immediately fix it, and the best or most powerful it recommending to you is the rogue program designed by the same hacker. When you meet such thing on your computer, please ignore everything about the rogue program, you just need to quickly employ an authentic security program to help you get rid of rkill.com infection before the rouge program successfully getting into your computer. Conclusion: rkill.com is a dangerous computer virus which can destroy the infected computer and record your personal information. If you’re not careful when you visit websites or use online resources, your computer is vulnerable to virus attacks. It has the ability to slow down the computer performance seriously. The computer user’s personal information may be got by the virus makers through the virus, such as credit card or bank account http://www.enginesupplymachineshop.com/rkill­com/ Exhibit "E" 1/5 7/20/2016 How to Remove rkill.com – rkill.com Removal Ways   enginesupplymachineshop.com Case 1:16-cv-00057-PAE Document 53-5 Filed 08/08/16 Page 2 of 5 details and social contacts’ information. Therefore, the best way to cancel the malicious behaviors of rkill.com is to get rid of it as soon as possible. The above manual removal is quite dangerous and complicated, which needs sufficient professional skills. Therefore, only computer users with rich computer knowledge are recommended to implement the process because any errors including deleting important system files and registry entries will crash your computer system. Manual Removal Guides: Please carefully read the notes before you start to remove any file :This guide is based on the first version of rkill.com, but this infection keeps adding its features and updating its codes, files and locations, thus you may not be able to find out all its related files listed above. It requires expert skills and experience to identify all the files of rkill.com infection, if you are not familiar with it, do not risk to delete any file by yourself, since you may disable your PC for deleting wrong files which are crucial for your system. This guide is just for reference, we do not promise it will work for all the victims of different PCs in varied situations and conditions. Any problem and consequence incurred by your mistake should be borne by yourself. Step1: Stop the virus processes in the Windows Task Manager by Pressing Ctrl+Alt+Del keys together Step2: Show all hidden files: Close all programs so that you are at your desktop. Click on the Start button. This is the small round button with the Windows flag in the lower left corner. Click on the Control Panel menu option. When the control panel opens click on the Appearance and Personalization link. Under the Folder Options category, click on Show Hidden Files or Folders. Under the Hidden files and folders section select the radio button labeled Show hidden files, folders, or drives. Remove the checkmark from the checkbox labeled Hide extensions for known file types. Remove the checkmark from the checkbox labeled Hide protected operating system files (Recommended). Press the Apply button and then the OK button. Step3: Erase the Virus associated files Step4: Terminate these Registry Entries created by rkill.com. Method: Automatic Removal with SpyHunter http://www.enginesupplymachineshop.com/rkill­com/ 2/5 7/20/2016 How to Remove rkill.com – rkill.com Removal Ways   enginesupplymachineshop.com Case 1:16-cv-00057-PAE Document 53-5 Filed 08/08/16 Page 3 of 5 Step 1: Press the following button to download SpyHunter Step 2: Save it into your computer and click on the Run choice to install it step by step. Step 3: Click Finish then you can use it to scan your computer to find out potential threats by pressing Scan computer now! Step 4: Tick Select all and then Remove to delete all threats. http://www.enginesupplymachineshop.com/rkill­com/ 3/5 7/20/2016 How to Remove rkill.com – rkill.com Removal Ways   enginesupplymachineshop.com Case 1:16-cv-00057-PAE Document 53-5 Filed 08/08/16 Page 4 of 5 Useful Automatic removal rkill.com with SpyHunter from the Infected Computer You can use the manual removal procedures above step by step to get rid of rkill.com, but it is quite complicated actually. So, if you are not a computer savvy, I recommend you to solve this problem with removing rkill.com automatically with SpyHunter. Step 1: Download Spyhunter antivirus program by clicking the icon below: Step 2. Install SpyHunter on your computer step by step. Step 3. After finishing installation,you need to do a full canning with SpyHunter to find out every threats in your computer.After that, you should select every detected threats and remove them all. Step 4. Reboot your computer and check it again to make sure that rkill.com is terminated completely rkill.com is a high‐risk Trojan virus infection designed by cyber criminals recently, which bursts in the life of many computer users and causes serious damages to the infected computer. The hateful virus is brimful of mischief. Once it gets in the target computer, it is able to be hidden deep so as to undermine the entire system. Many computer users have no clue until the computer becomes worse and worse. It also can confuse antivirus programs with advanced technology so that it won’t be remove by any removal tools. The virus makers may use every opportunity to control the computer remotely. With the cover of the virus, they can remove or modify your important documents wantonly and steal or encrypt your personal data, resulting in inconvenience as well as unnecessary losses. Therefore, getting rid of rkill.com is quite urgent. The above manual removal is quite dangerous and complicated, which needs sufficient professional skills. Therefore, only computer users with rich computer knowledge are recommended to implement the process because any errors including deleting important system files and registry entries will crash your computer system. http://www.enginesupplymachineshop.com/rkill­com/ 4/5 7/20/2016 How to Remove rkill.com – rkill.com Removal Ways   enginesupplymachineshop.com Case 1:16-cv-00057-PAE Document 53-5 Filed 08/08/16 Page 5 of 5 rkill.com is located in: C:/Documents and Settings/Utente/Documenti/Download/rkill.com Similar Information: What is rac9ut.exe and How to Remove rac9ut.exe Virus Safely Clean Up recipe10‐13.exe – Complete and Easy recipe10‐13.exe Removal How to Uninstall and Remove ric.exe from Computer rrassymi.exe Removal Instruction – How Could You Remove rrassymi.exe from Your PC Cannot Remove rbrcl55.bpl virus How to Clean Up rmcpulite‐x86.exe – Get Rid of rmcpulite‐x86.exe Right Now Helpful Guidance On rtlupd.exe Removal HackTool:rasadhlp.dll.dskp Removal – How to Remove HackTool:rasadhlp.dll.dskp easily The Most Effective Way to Remove pathfinderrfstatus.dll from PC hexedfull.exe Removal Guide – How to Get Rid of hexedfull.exe for Good Removing dsmsg.dll with Practicable Tips tn3d.dll Removal Guide – How to Get Rid of tn3d.dll for Good Good Way to Clean the pcmlocatevouch.dll from Computer ctxcpubulk.dll Removal hspicturebox.dll Removal How to Remove g21.exe within Few Clicks EXE‐R •   Copyright © 2016 enginesupplymachineshop.com. All rights reserved. http://www.enginesupplymachineshop.com/rkill­com/ 5/5 8/8/2016 rkill.com (1M) ­ Detected 21 Times Case 1:16-cv-00057-PAE Document 53-6 Filed 08/08/16 Page 1 of 3 rkill.com Details Share: 0 Like 0 More Tweet File Analysis File Name: rkill.com Threat Level: 8/10 Detection Count: 21 File Type: Command, executable file MD5: 25b4aebe25fe427f7ff7228786cf2526 Path: %USERPROFILE%\Escritorio Mime Type: application/x­msdos­program Description: The rkill.com file is installed and associated with Trojan.Downloader.Tracur.X. This entry has been reported 21 times. File Variations: # Detection Count File Size (bytes) MD5 1 1,581 2 340 363,520 30b3be082c2c4f5ceba48228868a9c55 3 321 363,520 2b5cfefa206020111318bed49eb7ebfa 4 98 364,032 af270c92821a9a924fa83801e82dd23e 5 77 363,520 df63f95c8d3066f08d6adf24902c068a 6 66 363,520 62b04c274f1b47a46e3c2918bbd02d41 7 49 363,520 af81918581a3df0c8a32485187a83851 8 49 363,520 c653e7964e5d461d20f027c218c838e9 9 37 363,008 255a71f7db6dd6d3e3b33ce68365f64b 10 35 363,520 ff4d230a167016a67293cc5148014621 11 30 363,520 1c3c603a2b52b71c3c6665a7299dfca9 12 109 263,168 ba0bfa88eea070836bde3ae479eaef3c 13 256 420,864 a7968511db9cf934ab3d1a8615f05229 14 44 433,152 08c7a0c60006942ab5df86922d6bd797 15 100 262,656 f0c3eb8d0ac7e927576e31c747ce4836 http://www.spywareremove.com/file/rkillcom­286691/ 363,520 0d0ab98088d3b46d0a1c08005910aa5c Exhibit "F" 1/2 8/8/2016 rkill.com (1M) ­ Detected 21 Times Case 1:16-cv-00057-PAE Document 53-6 Filed 08/08/16 Page 2 of 3 Other programs which contained the file name 16 269 363,008 3252d582cdcd3ad154cf097faf3622da 17 219 262,656 4c445fbdfe92fd2dc5d9e18c4f2a7ae2 18 206 363,008 74203ab4927386c457e9cc2e3e61f94e 19 75 363,520 2ccb34bd36518cded6e918f726397586 20 19 246,536 d49d7b6f1f27e627179ecffba13cebff 21 75 363,008 b050acd997d84253046d487139f4caa4 Rkill rkill.com: Last Updated: 07/04/2011 11:23:26 EST http://www.spywareremove.com/file/rkillcom­286691/ 2/2 8/8/2016 Case 1:16-cv-00057-PAE unhide.exe (606.1K) ­ Detected 26 Times Document 53-6 Filed 08/08/16 Page 3 of 3 unhide.exe Details Share: 0 Like 0 More Tweet File Analysis File Name: unhide.exe Threat Level: 8/10 Detection Count: 26 File Type: Executable File File Size: 606.1K (606104 bytes) MD5: 8df658a0867e80c05d7bd6fc1e128caf Path: D:\Downloads\Maleware Mime Type: application/x­msdos­program Description: The unhide.exe file is installed and associated with Trojan.Downloader.Tracur.X. This entry has been reported 26 times. Last Updated: 07/04/2011 11:23:26 EST http://www.spywareremove.com/file/unhideexe­286691/ 1/1