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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
DR. SPRING CHENOA COOPER,
Plaintiff,
COMPLAINT
-againstIndex No.:
RYAN BROEMS, CALIDADDY26, INRISKWETRUST,
and JOHN DOES 1-100,
Defendant(s).
Plaintiff DR. SPRING CHENOA COOPER (“Plaintiff” or “Dr. Cooper”), by her
attorneys DANIEL SZALKIEWICZ & ASSOCIATES, P.C., as and for her Complaint hereby
alleges, upon information and belief, as follows:
PRELIMINARY STATEMENT
1.

Defendants RYAN BROEMS, CALIDADDY26, INRISKWETRUST, and John

Does 1-100 (collectively “Defendants”) use the internet to sexually assault and exploit victims
from the comfort of their couches and behind a cloak of anonymity. Defendants have selected
Tumblr, which once marketed itself as a website for unique blogs, as the forum of choice to
effectuate their depraved goals. This is not unsurprising, since Tumblr has become a revenge
porn haven, with thousands of pages filled with nude photographs of females who have not
provided permission or consent for their images to be shared online.
2.

Using the platform to attempt to cause both severe emotional distress and

economic harm to unexpecting victims, Defendants have engaged in a relentless campaign to
destroy a distinguished professor, author, and activist’s reputation by disseminating private videos
and images naming Dr. Cooper and her employer and showing her engaging in sexual acts.

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Defendants’ exploits were undertaken specifically to humiliate and terrorize

Plaintiff, who has devoted her life to sexual health and sexual assault prevention.
4.

Defendants’ actions have compelled Dr. Cooper to file criminal charges and an

order of protection, have forced her to devote several hours each day to scouring the internet for
her images and videos, and require her to regularly deal with harassing strangers who contact her
after seeing the non-consensually posted content. Once Plaintiff locates the content, she then
must communicate with Tumblr to effectuate its removal, a process which can take days or
weeks.
5.

Undeterred by the Defendants’ onslaught of online harassment and history of

retaliating for her reporting of the same, Dr. Cooper now brings this action under the New York
City revenge porn statute seeking compensatory and punitive damages for the Defendants’ gross
wrongdoing and the immense harm it has caused.

THE PARTIES
6.

Plaintiff Dr. Cooper is a resident of the County of New York, State of New York.

7.

Dr. Cooper is an associate professor at the City University of New York, teaching

in the School of Public Health.
8.

Defendant Ryan Broems (“Broems”) currently resides at 100 Caton Avenue, 2N

Brooklyn, New York 11218.
9.

Defendant Broems is a resident of the City of New York and State of New York.

10.

Defendant INRISKWETRUST is an anonymous defendant who created, authored,

and published the intimate images and videos of Plaintiff on the Tumblr page located at
inriskwetrust.tumblr.com.

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Upon information and belief, Defendant Broems shared Plaintiff’s images and

videos with Defendant INRISKWETRUST, or is Defendant INRISKWETRUST.
12.

Upon

information

and

belief,

Defendant

Broems

requested

Defendant

INRISKWETRUST disseminate Plaintiff’s images on his or her Tumblr account.
13.

Despite due diligence, as detailed below, Plaintiff is ignorant of said Defendant

INRISKWETRUST’s true name and pleads, pursuant to CPLR §1024, by designating so much of
said Defendant INRISKWETRUST’s name as is known to Plaintiff.
14.

Defendant CALIDADDY26 is an anonymous defendant who created, authored,

and published the intimate images and videos of Plaintiff on the Tumblr page located at
inriskwetrust.tumblr.com.
15.

Upon information and belief, Defendant Broems shared Plaintiff’s images and

videos with Defendant CALIDADDY26 or is Defendant CALIDADDY26.
16.

Upon

information

and

belief,

Defendant

Broems

requested

Defendant

CALIDADDY26 disseminate Plaintiff’s images on his or her Tumblr account.
17.

Despite due diligence, as detailed below, Plaintiff is ignorant of said Defendant

CALIDADDY26’s true name and pleads, pursuant to CPLR §1024, by designating so much of
said Defendant CALIDADDY26’s name as is known to Plaintiff.
18.

Defendants John Does 1-100 are the unknown defendants who have shared and

disseminated Plaintiff’s images and videos on Tumblr accounts.

Despite due diligence, as

detailed below, Plaintiff is ignorant of said Defendants John Does 1-100 true name and pleads,
pursuant to CPLR §1024.
19.

Upon information and belief, Defendant Broems requested Defendants John Does

1-100 disseminate Plaintiff’s images on their Tumblr accounts.

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If Defendants INRISKWETRUST, CALIDADDY26, and John Does 1-100 are not

residents of the State of New York, jurisdiction is proper because Defendants transacted business
in the State of New York through the dissemination of the images of a person they knew was a
resident of the County of New York, State of New York. More so, the Defendants originally
obtained the images and videos from a New York resident and acted in concert with the New
York resident to harass the Plaintiff and violate the law.
21.

More so, Defendants INRISKWETRUST, CALIDADDY26, and John Does 1-100

regularly do business in the state through their Tumblr blogs and the transaction of business is the
subject of the current litigation.

STATEMENT OF FACTS PERTAINING TO ALL CAUSES OF ACTION
Dr. Cooper’s Relationship with Defendant Broems
22.

Dr. Cooper and Defendant Broems dated from December 2016 until November 18,

2017. While they had a tumultuous relationship, often arguing over Defendant Broems’ invasion
of Plaintiff’s privacy and proclivity for masturbating to online revenge pornography, Dr. Cooper
finally cut ties with Defendant Broems when she discovered that he had secretly engaged in
sexual activity with five other females the week prior.
23.

Unable to cope with Plaintiff’s decision to end their relationship and against Dr.

Cooper’s request that he not contact her, Defendant Broems sent Dr. Cooper messages that ranged
from loving and thoughtful to viciously angry. After six weeks of manic messaging, Defendant
Broems’ communications became less aggressive and more depressive; fearing for Defendant
Broems’ safety, Dr. Cooper agreed to continue conversations with him as long as their
relationship remained cordial and platonic.

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Before long, Defendant Broems’ messages once again became harassing and

angry. Defendant Broems would demand that Plaintiff tell him who she was dating, whether he
was sleeping with other men, and whether she was using condoms. When Plaintiff refused to
answer his invasive questions, Defendant Broems would grow angrier, assuming that her refusal
to answer meant that she had found someone new. Despite this, Defendant Broems continued to
initiate conversations with Plaintiff, even asking that she send him intimate photos; if Plaintiff did
not respond immediately, Defendant Broems would become hostile and would send & texts
demanding to know why she was ignoring him.
25.

In mid-January, 2018, Defendant Broems was sending masturbation Snapchats

each morning. On January 15, after sending Plaintiff another barrage of Snapchat messages in
which he was masturbating, Defendant Broems once again became aggressive with Plaintiff when
she did not respond.

Attempting to antagonize Plaintiff, Defendant Broems wrote that he

assumed she was “fucking someone else” at that very moment.
26.

Unwilling to continue dealing with Defendant Broems’ relentless hostility,

Plaintiff blocked Defendant Broems’ Snapchat account on January 15, 2018.
27.

That same day, Defendant Broems continued his harassment by text message,

sending Dr. Cooper a message stating “hope he was worth it.” Disinterested in continuing their
destructive relationship, Dr. Cooper blocked his text messages as well.

Defendant Broems’ Retaliation
28.

Over the course of their relationship, Defendant Broems and Dr. Cooper had

engaged in numerous heated discussions about her disdain for revenge pornography and her

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desire for Defendant Broems to recognize the inherent immorality of re-posting, watching, and
sexual gratification from nonconsensual images and videos.
29.

With this in mind and freshly enraged by Plaintiff’s rejection, Defendant Broems

sought to harm Plaintiff in a manner that he knew would be deeply humiliating, painful, and
damaging to her personal life and career – by broadcasting Plaintiff’s most intimate photos and
videos on the internet for the world to see.
30.

On the evening of January 15, 2018, Dr. Cooper received a message from

Defendant CALIDADDY26 in which he or she wrote “I know who you are, be my personal
webslut, or I’ll post you on my slut exposing blog.”

When Plaintiff declined to respond,

Defendant CALIDADDY26, who was either acting on behalf of Defendant Broems’ or was
Defendant Broems himself, echoed her ex-boyfriend’s questions from the day earlier, demanding
to know whether Plaintiff had a new boyfriend and asking what specific sexual activities she was
doing with him.
31.

The next day, on January 16, 2018, following through on his or her threat,

Defendant CALIDADDY26 uploaded on his or her Tumblr page three intimate images of
Plaintiff.

The first two images depicted Dr. Cooper’s face and nude body while she was

masturbating and the third image was a screenshot of Dr. Cooper’s OKCupid profile (the
“profile”).
32.

Prior to Defendant CALIDADDY26 uploading the photos, Defendant Broems was

the only individual in possession of the images as he had taken one photo himself and the other
she had sent to only him.
33.

Tellingly, Defendant Broems had sent Dr. Cooper the same screenshot of her

profile only nine days prior begging her to consider reconciling with him.

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In fear for her safety, Dr. Cooper sought legal intervention the day her photos were

posted; unsurprisingly, the New York County Family Court granted a Temporary Order of
Protection against Defendant Broems.
35.

Despite this, Defendant Broems continued to harass Dr. Cooper online on a regular

basis. When Dr. Cooper blocked one Twitter account he was using to contact her, he would
simply create another; each time, Dr. Cooper would block the account.
36.

On or around February 1, 2018, Plaintiff received a Facebook message containing

a threat nearly identical to CALIDADDY26’s – send new photos or have new images shared
publicly online. In response, Plaintiff filed a police report.
37.

On February 22, 2018, Defendant Broems, because of his actions, was arrested and

charged with six misdemeanors.
38.

On February 23, 2018, the day after Defendant Broems’ arrest, Dr. Cooper’s social

media accounts became inundated with messages from strangers; some called her a “slut[,]” or
“stupid cunt[,]” and others told her how they had “gotten off” to her photos and demanded more
images.
39.

Dr. Cooper immediately searched Tumblr and found that, in retaliation for having

the courage to go to the police, Defendant Broems’ or someone acting on his behalf, had uploaded
eight (8) additional nude photographs on a Tumblr account that had previously solely been within
Defendant Broems’ possession.
40.

The February 23, 2018 Tumblr also contained a direct link to Dr. Cooper’s

Facebook profile and a screenshot of her Facebook page.
41.

On March 1, 2018, Dr. Cooper filed another complaint with the police because of

Defendant Broems’ actions.

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Following her report, on March 6, 2018, Plaintiff once again woke to sexually

explicit messages from strangers.

Searching Tumblr, she found that Defendant Broems or

someone acting on his behalf had shared and disseminated photographs of Dr. Cooper engaged in
sexual activity. Posting from the Tumblr account “Exposednamedsluts7[,]” Defendant Broems or
someone acting on his behalf had either distributed or made available for the account holder to
share, images of Dr. Cooper engaged in sex with Defendant Broems and performing fellatio.
43.

Another police report was filed on March 8, 2018 and, as had become Defendant

Broems’ modus operandus, additional nonconsensual images of Dr. Cooper that were only in his
possession were uploaded to Tumblr.
44.

Incapable of allowing another week to pass without attempting to cause mental

anguish to the Plaintiff, on March 17, 2018, yet another Tumblr page appeared with Defendant
Broems’ images of Plaintiff. The page contained the same images that had been posted in the
past as well as a new image of Dr. Cooper performing oral sex.
45.

This time, the images were shared by accounts entitled “filthyfuckslutstoexpose”

and “exposer1886[.]”
46.

On March 21, 2018, Defendant Broems was arrested once again by the New York

City Police Department for his actions.
47.

In response, on March 26 and March 29, 2018, two new Tumblr sites were created

with new intimate photographs of the Plaintiff.
48.

Seeking a release from the emotional stresses associated having her images shared

with unknown numbers of people online, Dr. Cooper left the country for a week hoping to
“unplug[.]”

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With Plaintiff briefly unable to perform her routine scouring of the internet,

Defendant Broems again uploaded, or caused to be uploaded, multiple images and three videos of
Dr. Cooper engaged in sexual acts. The Tumblr page also contained a screenshot of Dr. Cooper’s
faculty page.
50.

Because the Defendants chose to involve Dr. Cooper’s employer, she had no

choice but to report Defendants’ harassment to her employer.
51.

Dr. Cooper is at an unenviable impasse; each time she attempts to put an end to the

online harassment, Defendants retaliate by posting more images and videos.
52.

To date, the Defendant has uploaded no fewer than 11 intimate images and 6

intimate videos of the Plaintiff.

FIRST CAUSE OF ACTION
(Violation of New York City Administrative Code §10-177 against Defendant Ryan
Broems)
53.

Plaintiff repeats and realleges the allegations stated above as if fully set forth

54.

Defendant Broems disclosed Dr. Cooper’s intimate images and videos without her

herein.

consent.
55.

Defendant Broems’ intention for disclosing the intimate images was to cause her

substantial emotional harm and to cause her to lose her salaried position, which would have
caused Dr. Cooper economic harm.
56.

Dr. Cooper was readily identifiable in the intimate images and videos which

display not only her face, but also contain images of her Facebook page and faculty page and

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contact information. Additionally, Defendant Broems created a new compilation of images,
entitling them “Fully exposed Slut Dr. Spring Chenoa Cooper CUNY Associate Professor.”
57.

Although a criminal statute, the code provides for civil remedies:
(a) Compensatory and punitive damages;
(b) Injunctive and declaratory relief;
(c) Attorneys' fees and costs; and
(d) Such other relief as a court may deem appropriate.

58.

As a result of Defendant Broems’ actions, the Plaintiff demands judgment for any

actual damages which exceed the jurisdictional limits of all lower courts which would have
otherwise have jurisdiction of this matter, together with damages for pain and suffering and
punitive damages, attorney’s fees, costs of this litigation, injunctive relief preventing Defendant
Broems from disseminating the images, and such other relief as the Court deems equitable and
just.

SECOND CAUSE OF ACTION
(Intentional Infliction of Emotional Distress against Defendant Ryan Broems)
59.

Plaintiff repeats and realleges the allegations stated above as if fully set forth

60.

Defendant Ryan Broems engaged in the intentional, extreme, and outrageous

herein.

conduct of possessing and disseminating Plaintiff’s nude photographs and videos.
61.

Defendant Ryan Broems’ conduct was so extreme in degree and so outrageous in

character that it goes beyond all possible bounds of decency.
62.

Defendant Ryan Broems’ sole purpose in sharing the images and videos was to

harass and/or embarrass Plaintiff and cause others to view Plaintiff in a sexual position.

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Defendant Ryan Broems intended to cause severe emotional distress or recklessly

disregarded the likelihood that such conduct would tend to cause severe emotional distress. Such
outrageous behavior is beyond the limits of decency and is intolerable in a civilized society.
64.

As a direct and proximate result of Defendant Ryan Broems’ conduct, Plaintiff

suffered severe emotional distress.
65.

Defendant Ryan Broems acted with the intent to cause severe emotional distress,

or alternatively, disregarded the substantial probability that his actions would cause severe
emotional distress.
66.

Here, the acts of Defendant Ryan Broems were so egregious and were done so

clearly with malice and/or reckless indifference in the face of a perceived risk that his actions
would harm Plaintiff’s reputation and mental wellbeing, that, in addition to all the damages
inflicted upon Plaintiff and in addition to all the measure of relief to which Plaintiff may properly
be entitled herein, Defendant Broems should also be required to pay punitive damages to punish
him for his reckless conduct in the further amount greater than the jurisdictional limit of all lower
courts to be determined by the trier of fact, in order to deter him and others similarly situated
from engaging in such conduct in the future.
67.

Plaintiff demands judgment against Defendant Broems in an amount to be

determined upon the trial of this action; said amount being sufficient to compensate Plaintiff for
her severe injuries as well as an amount sufficient to punish Defendant Broems for his willful,
wanton, reckless, and unlawful conduct constituting a complete and reckless disregard for
Plaintiff, together with interest, attorneys’ fees, costs, and disbursements in this action; and said
amount exceeding the jurisdictional limits of all lower courts which would otherwise have
jurisdiction.

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THIRD CAUSE OF ACTION
(Violation of New York City Administrative Code §10-177 against Defendants
CALIDADDY26, INRISKWETRUST, and JOHN DOES 1-100)
68.

Plaintiff repeats and realleges the allegations stated above as if fully set forth

69.

Defendants CALIDADDY26, INRISKWETRUST, and John Does 1-100, using

herein.

Tumblr’s platform, disclosed Dr. Cooper’s intimate images and videos without her consent.
70.

Defendants CALIDADDY26, INRISKWETRUST, and John Does 1-100’s

intention for disclosing the intimate images was to cause Plaintiff substantial emotional harm and
to cause her to lose her salaried position, which would have cased Dr. Cooper economic harm.
71.

Dr. Cooper was readily identifiable in the intimate images and videos which

display not only her face, but also contain images of her Facebook page and faculty page. More
so, Defendants CALIDADDY26, INRISKWETRUST, and John Does 1-100 combined images
and entitled the compilation “Fully exposed Slut Dr. Spring Chenoa Cooper CUNY Associate
Professor.”
72.

As a result of Defendants CALIDADDY26, INRISKWETRUST, and John Does

1-100’s actions, the Plaintiff demands judgment for any actual damages which exceed the
jurisdictional limits of all lower courts which would have otherwise have jurisdiction of this
matter, together with damages for pain and suffering and punitive damages, attorney’s fees, costs
of this litigation, injunctive relief preventing Defendants CALIDADDY26, INRISKWETRUST,
and John Does 1-100 from disseminating the images, and such other relief as the Court deems
equitable and just.

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FOURTH CAUSE OF ACTION
(Intentional Infliction of Emotional Distress against Defendants CALIDADDY26,
INRISKWETRUST, and JOHN DOES 1-100)
73.

Plaintiff repeats and realleges the allegations stated above as if fully set forth

74.

Defendants CALIDADDY26, INRISKWETRUST, and John Does 1-100 engaged

herein.

in the intentional, extreme, and outrageous conduct of possessing and disseminating Plaintiff’s
nude photographs and videos.
75.

Defendants CALIDADDY26, INRISKWETRUST, and John Does 1-100’s

conduct was so extreme in degree and so outrageous in character that it goes beyond all possible
bounds of decency.
76.

Defendants CALIDADDY26, INRISKWETRUST, and John Does 1-100’s sole

purpose in sharing the images and videos was to harass and/or embarrass Plaintiff and cause
others to view Plaintiff in a sexual position.
77.

Defendants CALIDADDY26, INRISKWETRUST, and John Does 1-100 intended

to cause severe emotional distress or recklessly disregarded the likelihood that such conduct
would tend to cause severe emotional distress. Such outrageous behavior is beyond the limits of
decency and is intolerable in a civilized society.
78.

As

a

direct

and

proximate

result

of

Defendants

CALIDADDY26,

INRISKWETRUST, and John Does 1-100’s conduct, Plaintiff suffered severe emotional
distress.
79.

Defendants CALIDADDY26, INRISKWETRUST, and John Does 1-100 acted

with the intent to cause severe emotional distress, or alternatively, disregarded the substantial
probability that his actions would cause severe emotional distress.

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Here, the acts of Defendants CALIDADDY26, INRISKWETRUST, and John

Does 1-100 were so egregious and were done so clearly with malice and/or reckless indifference
in the face of a perceived risk that his actions would harm Plaintiff’s reputation and mental
wellbeing, that, in addition to all the damages inflicted upon Plaintiff and in addition to all the
measure of relief to which Plaintiff may properly be entitled herein, Defendants
CALIDADDY26, INRISKWETRUST, and John Does 1-100 should also be required to pay
punitive damages to punish him for his reckless conduct in the further amount greater than the
jurisdictional limit of all lower courts to be determined by the trier of fact, in order to deter him
and others similarly situated from engaging in such conduct in the future.
81.

Plaintiff

demands

judgment

against

Defendants

CALIDADDY26,

INRISKWETRUST, and John Does 1-100 in an amount to be determined upon the trial of this
action; said amount being sufficient to compensate Plaintiff for her severe injuries as well as an
amount sufficient to punish Defendants CALIDADDY26, INRISKWETRUST, and John Does 1100 for their willful, wanton, reckless, and unlawful conduct constituting a complete and reckless
disregard for Plaintiff, together with interest, attorneys’ fees, costs, and disbursements in this
action; and said amount exceeding the jurisdictional limits of all lower courts which would
otherwise have jurisdiction.

WHEREFORE, Plaintiff demands judgment against Defendants Ryan Broems,
CALIDADDY26, INRISKWETRUST, and John Does 1-100 on all causes of action in the sum
of the amount greater than the jurisdictional limit of all lower courts to be determined by the trier
of fact, plus punitive damages, the costs of this action, pre-judgment interest and reasonable

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