COMPLAINT against Samuel Altman, Justin Bassett, DiggDejected, Alexis Ohanian, Reddit Corporation Service Company,

Part
1
2

Multiple Documents

Description
13 pages
Civil Cover Sheet

© 2019 The Bureau of National Affairs, Inc. All Rights Reserved. Terms of Service
// PAGE 1

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MAUSKOPF,
j.

ORENSTOIN: M..T.

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
Doim Albano

Plaintiff,

Heather Miller

Acti

(Judge's Initials)
V.

Complaint

DiggDejected(John Doe,Reddit Moderator)
Reddit.com

Reddit Corporation Service Company
Alexis Ohanian
Justin Bassett

MAY 20

Samuel Altman

Defendant(s)

i! I Vii— \

1. This document shall describe the case being brought by Heather Miller and Donn Albano, against
Defendants listed in the header. The Federal Court has jurisdiction over all ofthe specified violations
offederal law, including: Harassment, Defamation, Trade Disparagement, Loss ofProfits, Interference
With Free Trade, Brand Dilution,"RICO" Laws,and Discrimination Against Women. All ofthese
violations are within the jurisdiction ofthe federal court, as they are violations ofspecific federal laws,
as detailed in this document.

2. The Eastern District is the correct venue for this action, as both Plaintiffs, and at least one(or more)
ofthe Defendants, has offices in the Eastern District ofNew York, which is centered in Brooklyn, but
also includes the other boroughs ofNew York City.

3. Defendant DiggDejected (John Doe: name and address as of yet unknown,to be obtained by
subpoena) has posted defamatory content on Reddit.com,in violation ofthat website's terms of service,
and as an approved moderator,thereof. This Defendant has also committed harassment against
PlaintiflFs personally via this defamatory post, as well as trade disparagement,causing lost profits and
interference with free trade, as well as brand dilution, violation of RICO laws(in racketeering
conspiracy with Reddit and Reddit's attorney to maintain the defamatory post's visibility to the 'net and
world at large), and has violated the right ofa woman to conduct and profit fi*om a legitimate business.
4. Defendant Reddit.com, located at 520 Third Street, Suite 305, San Francisco, CA 94107, has

maintained the defamatory content, thus committing libel against the Plaintiffs. They have ignored our
cease and desist request, issued upon discovery ofthe defamatory content less than one year ago,and
have committed harassment,trade disparagement,caused lost profits, interference with fi-ee trade,
brand dilution, and violation ofthe RICO laws in maintaining the defamatory post. Reddit has also, as a
third party maintaining and hosting this post, violated the rights ofa woman to conduct and profit fi*om
a legitimate business.

5. Defendant Reddit Corporation Service Company, at 2710 Gateway Oaks Drive, Suite 150N,
Sacramento, CA,95833 has violated our rights imder the RICO act, as part of a racketeering conspiracy
to allow and possibly encourage, Reddit to maintain the defamatory, disparaging posts on the website at

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Reddit.com.

6. Defendants Alexis Ohanian, at 420 Taylor Street, San Francisco, CA 94102, Mr. Justin Bassett, at
520 Third Street, Suite 305, San Francisco, California 94107,and Mr. Samuel Altman,at 335 Pioneer

Way, Mountain View, California 94041,have all three committed violations ofthe RICO act, which
shall be detailed below,for their own financial benefit, in maintaining the posts online at Reddit, when

it was brought to the attention of Reddit, and before, when it was initially posted. It shall be shown in
this complaint,that there was a significant financial benefit to these three members ofthe"Y
Combinator" fimding company, whose startup and similar company "Unwind Me", was sold to Soothe,
Inc., a direct competitor to the two Plaintiffs in this action. These tliree also allowed the posts to remain
on their platform, in its unlawfulness, and have also committed harassment,trade disparagement,
caused lots profits, interference with fi*ee trade, and brand dilution, the same violations against
Plaintiffs as their company, Reddit.com, above.

7. On May 28,2018,Plaintiff, Donn Albano, partner of Mountainside Diversified, drafted a per se
Cease and Desist Notice to Newhouse News Agency, on behalfofPlaintiff, and Plaintiffs business
partner, Co-Plaintiff Heather Miller, notifying Defendant of numerous posts on their Internet property,
Reddit.Com,that are clearly textbook examples ofindisputable defamation per-se, statements
indicating that Plaintiffs,(and. Your Honor,I quote), "...give kids diseases," received by Defendant's
attorney. Corporate Service Company,sent as directed by Reddit's website instructions regarding legal
matters, provable by USPS Registered Mail receipts, as well as Delivery Confirmation, delivered on
June 5th, 2018, mailed out on May 30,2018.

8. To date, absolutely no effort has been made by Reddit, its attorneys, or any representatives of
Newhouse News,to comply with our lawful request. The libelous, harassing posts remain, and are
viewable to the world, at large, and both Plaintiffs are experiencing this as ongoing harassment and
dilution of our carefully maintained brands built over time, and Plaintiffs reason that these posts might
reasonably be assumed to keep Plaintiffs' business fi-om fairly competing in the marketplace, due to the
posts' high visibility, which shall be detailed below.

9. While the original statute of limitations may have expired for the two initially posted defamatory
comments,those comments being first electronically published in 2016,Plaintiff respectfully requests
Your Honor to allow this motion to proceed,in that various other, far more significant, state and
federal laws are still being violated. (And,although, ofcourse,the relevant State Laws regarding
defamation in New York State are outside the jurisdiction ofYour Honor's Court,these other offenses
mentioned are relevant. Plaintiffs argue, and so this State law is therefore included, nevertheless.)
10. In addition,the "Discovery" exception should apply in this instance, as the defamatory statement
was only discovered last year. Herein, Plaintiffs shall, as pro se litigants, do their very best to clarify
and explicate the details ofthese alleged transgressions, libel only being one ofa great many:
11.1. HARASSMENT.(NY State Law,cited for completeness ofrecord)
11. DEFAMATIONrLIBEL.
III. TRADE DISPARAGEMENT.
IV. LOSS OF PROFITS
V.INTERFERENCE WITH FREE TRADE.
VI. BRAND DILUTION.
VI. VIOLATION OF FEDERAL RICO LAWS.

VII. DISCRIMINATION AGAINST WOMAN/A WOMANAVOMEN.

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DC: NO BLANKET IMMUNITY FOR WEB COMPANIES.

X.PROTECTION UNDER SECTIOMN 230 FOR »PLANTIFFS*,RATHER THAN DEFENDANTS,

12.1. HARASSMENT.In Reddit's own words(on Linkedin), it's the "front page ofthe Internet," a true

descriptor, considering its Alexa traffic position of54, higher than CNN,the BBC,and eBay. To be
unfairly characterized in such harassing terms, by Reddit Moderator DiggDejected, and by Reddit, as a
disease-spreader, especially now,in this era of Measles Outbreaks and non-vaccination among some
Americans, especially while we both have had all our vaccines, and keep up-to-date with our required
First Aid Training.(In fact Plaintiffs both have Rescuer status First Aid, above and beyond what is
required by law), CPR,and Massage Insurance, is an experience that harasses and causes both
Plaintiffs to lose sleep, lose weight. Have stomach aches, and feel generally upset for being wrongly
accused, and quite likely has caused a loss of past, present, and future revenues and income.
13. While such harassing untrue statements remain on Reddit, we,the Plaintiffs, find these posts
alarming, stress-inducing, and beyond annoying, and so should legally constitute Harassment in the
Second Degree, as clearly per-se derogatory statements about persons and businesses cause imdeniable
harm. Also,these Reddit posts are "closed", and so Plaintiffs cannot even defend themselves and
counter lies with provable fact!

14. When an Internet user searches for Mountainside Diversified's service, called Mountainside On-Site

Massage Therapy(tm), by looking up our main website URL at Plaintiffs mobile massage service
website,"njmassage.info", a rule-abiding partnership,formed in the state ofNew York, doing business
and paying taxes in New York and New Jersey, these disparaging Reddit posts show on Google's first
and second pages ofresults(depending on the day, as many websites do shift around as per Google's
changing algorithms, and more importantly, the ever-changing popularity ofa web page).
15. Therefore, it is reasonable to consider that Internet users, and prospective customers, have found
these libelous and hateftil comments either by searching for Kids Spa parties on Reddit, where the posts
are located, or far more significantly, for Plaintiffs' service name. Mountainside On-Site Massage
Therapy(sm), or perhaps website, NJmassage.info, on Google, and other popular search engines, while
researching the background of Mountainside On-Site Massage Therapy. It is not unreasonable to
assert, therefore, that such comments have had a deleterious effect on our brand, as well an effect on

profits over time, but also specifically in the last year, the time fi-ame that Plaintiffs have had
knowledge of said crimes.
16. II. DEFAMATION:LIBEL.Plaintiffs assert that the CONTINUED daily publication ofthe posts,
coupled with knowledge ofsaid posts being libelous harassment,(having been notified with package
delivery confirmation via USPS)using the very channels ofcommunication that Reddit itself provides
to the public, constitutes a fresh reset ofthe one year libel limitation placed by New York State Law on
bringing forth a suit.(Ofcourse. Your Honor,this is included only for completeness.)Publication of
defamatory statements, including defamation per se, is also in violation ofFederal Laws.
17. Reddit is, unquestionably, a publisher. In fact, Reddit's Copyright Date on these libelous pages, and
all pages,is 2019("© 2019 Reddit,Inc. All rights reserved").
18. Each day that the post remains, it is re-published, unlike a paper newspaper which may,
inadvertently or otherwise, print a libelous statement in an advertisement, editorial, or article, in its

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daily or weekly periodical, fading from memory,and sight, with time.(If such paper news periodical
publisher(re)printed the identical defamation again, on a new day, it would constitute a new instance
of publication, and therefore a new offense under the law(s).)

19. Once Defendant(s) were notified ofthe illegal and unlawful statements published on their web
platform, the Defendant, Reddit, was bound by Law,as well as its own Code ofEthics, to remove such
statements, whether Plaintiffs are entitled to monetary damages or not, whether the statute of
limitations for damages in NYS or Federal law has expired, or not. The statements are untrue. The
statements harass.

20. In support ofour request for the Court to consider the daily publication ofthe defamatory
statements as re-publication, and therefore illegal under Federal as well as State law, we offer the
following statement. Wikipedia,long held to be the definite, accepted, science-based,"Correct" answer
for almost everything known,has this to say about Online Advertising. The following text is excerpted
from its Onlme_Advertising page:
21. "Fixed cost

22. Fixed cost compensation means advertisers pay a fixed cost for delivery of ads online, usually over
a specified time period, irrespective ofthe ad's visibility or users' response to it. One examples is CPD
(cost per day) where advertisers pay a fixed cost for publishing an ad for a day irrespective of
impressions served or clicks."

23. As your Honor can see, presently, in our online culture, advertising space, even on Reddit.com,is
considered freshly published each new day(12:00 AM)that the Advertisement remains visible for a set
duration oftime. To state that such is true for ads, but not for other content, would be arbitrary and
without logical sense. Plaintiffs respectfully request that the changing nature of web publication be
considered in its bearing on the Law,and what it really means to these publishers, like Defendant(s),
making their money from revenues from "published" online ads, principally.
24. Internet Defamation Law, Section 230, will possibly be one ofthe Defendants'response to the
charge oflibel, we are quite sure. However, DiggDejected, creator ofthis content, is not a user, but
rather a Reddit moderator, with clear approval to operate as Moderator, by Reddit, in conformance
with Reddit rules, by Reddit, itself. As Moderator, he is enacting the Mil ofReddit, in the spirit ofthenvery own Rules of Conduct. A Moderator stands in a unique position to NOT be protected by this
Internet Defamation law. Moderators' actions represent Reddit, as they are based on Reddit's guidelines
and rules. To continue to allow DiggDejected to maintain Moderator status is implicit approval of his
"job".
25. Under Internet Defamation Law, Section 230, Commimications Decency Act ofthe Federal Law,
liability is limited. However,the comments were posted and promoted by a well-known, active, and
longtime Reddit Moderator, DiggDejected. This was an instance ofa first publication, and not a
republication, so specific third-party protections for online intermediaries that re-publish content, stand
null and void.

26. Plaintiffs are proactively stating their response for their anticipated motion of non-liability in
regards to Section 230 ofthe CDA by Defendant(s). The text of Section 230, which is applicable to
this matter, states,"No provider or user ofan interactive computer service shall be treated as the
publisher or speaker ofany information provided by another information content provider..." We are

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not herein stating that Reddit(a company with a platform that is passive, receptive, waiting for content
to be posted, whether paid ads, or user-generated posts) has itself posted this material, however, when
Reddit became aware of material that violated their very own website's terms of use, posted by one of
its very own approved Moderators,tasked with removing illegal content, (defined as being illegal
banned activity, according to their terms ofservice, as defamation per se *is* illegal), Defendant(s)
were then obligated to remove said illegal content once informed. Defendant(s)have failed to do so.
In this, they(Defendants Reddit.com, et.al.) have then become co-conspirators with DiggDejected,thus
subject to die Federal RICO act, see subsection below.
27. In this same CDA act, subsection(3)State Law,the following statement is made: "No cause of
action may be brought and no liability may be imposed under any State or local law that is inconsistent
with this section." It should, however, be noted, that there is no area ofthis Act that states, whether
outright or by implication,that a service provider does not have to remove illegal content, once it has

been brought to their attention. As a consequence, and on the basis ofthe additional laws stated below.
Defendants reason that Reddit had, and continues to have, a responsibility to remove illegal content
from their website, once such content has been brought to Defendants' attention.
28. The question ofliability notwithstanding, our request to have the content removed should have
been respected, and could easily have been attended to by the management, DiggDejected (its author),
another moderator, or pretty much anyone with higher access at Reddit.com. Doing so would have
reduced, or even eliminated any, and all, ofthe below-detailed ramifications to Defendants, both
individually and as a business partnership, by the presence of unprotected(by the First Amendment),
illegal, libelous speech on Defendants' web site. What any of us may write online, in public, does
have its limitations, and any reasonable person might consider this task of Moderation a weighty, but
necessary task, but certainly part ofthe responsibilities ofoperating such a web news or contentsharing platform,in the year 2019.
29. In addition,the main portion ofthe CDA states quite plainly that publishers have the absolute right
to remove any content that they wish to remove,for any reason whatsoever, especially in regard to
parental controls, and that a user who posts such content has no recourse against the publisher for
removal of their post. According to the section in the Communications Decency Act entitled,
"PROTECTION FOR'GOOD SAMARITAN'BLOCKING AND SCREENING OF OFFENSIVE

MATERIAL," Civil Liability Subsection,"No provider or user ofan interactive computer service shall
be held liable on accoimt of(A)any action voluntarily taken in good faith to restrict access to or
availability of material that the provider or user considers to be obscene,lewd,lascivious, filthy,
excessively violent, harassing, or otherwise objectionable, whether or not such material is
constitutionally protected;"
30. In other words,Defendant(s)removal ofthe Illegal posts, as requested, would have been
completely consistent with the Communications Decency Act, and would have subjected Defendants to
no liability caused by DiggDejected, or any other Defendant,and would have prevented this lawsuit
fi'om needing to be commenced,in the first. At any time, Reddit could have chosen to comply with the
Cease and Desist notice, and acted to remove the comment left by their own approved moderator, a
comment which is a clear case ofdefamation per se.
31. The statement that was made is completely false, and highly damaging,and, Defendant(s)choice to
not remove the defamatory statement, has necessitated this lawsuit as Plaintiffs' sole means ofremedy
to this situation ofcontinued damage to Plaintiffs' personal reputation ofLicensed Massage Therapists,
Business Owners, and people in Society, as well as Plaintiffs' business's reputation, a reputation that

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was carefully cultivated, through education, degrees, work experience, and finally, superior customer
service, and diligent work, provided to many clients throughout the states ofNew Jersey and New
York, over the years.

32. It should be noted that since this defamatory statement came to Plaintiflfs' attention, and began

appearing in search results when an intemet user searched for Plaintiffs' Mobile Massage Service name
or URL,Plaintiffs' did experience a dropping offofinterest in booking our spa party services, even
though our company's page comes up at the top of Google's search results for some relevant results,
and previously diere were many more calls and much greater interest by consumers in our services.
33. III. TRADE DISPARAGEMENT,IV. LOSS OF PROFITS, V.INTERFERENCE WITH FREE
TRADE. VI. BRAND DILUTION.Interference with our ability to tum prospective interested Intemet

users into people wishing to purchase Plaintiffs' Services, has caused damage,and shall reasonably be
considered to continue to cause irreparable damage to Plaintiffs' brands. These statements then, are no
less than a form of harassment and bullying by computer,and are provably false.
34. Plaintiffs have never had a health code violation, and Plaintiffs' personal and business history,
demonstrates that Plaintiffs' do everything according to law and statute. The Federal Law,the

Communications Decency Act, plainly states that continuing to publish illegal content, whether
intentionally or by failure to act, is not permissible (section 230). Under Common law concepts, a
person or entity publishing libelous,damaging, and harassing, statements by another bears the same
liability as the author,(http://www.dmlp.org/legal-guide/immunity-online-publishers-undercommunications-decency-act)

35. Because Reddit Moderators are unpaid and volunteers, and exercise editorial control in line with
Reddit's rules, according to its own content guidelines, Reddit may be co-responsible.(Stratton
oakmont v. Prodigy 1995 NY Supreme Court) Reddit's policies state that,"...content is prohibited ifit
is illegal" and libelous, defamatory, harassing, brand-diluting, free-market interfering, statements are
illegal in all fifty states, and certainly a per se libelous statement calling people disease-mongers,
qualifies. Liability is increased for providers choosing to moderate their posted content, according to
precedent Whether DiggDejected is paid or unpaid, matters little then.
36. This Moderator, DiggDejected, author ofthe posts, has a checkered history, and many complaints
for arbitrarily removing content that is not in violation of Reddit policy, or law, but rather, against
Moderator's own personal political ideas, and views. There are various posts on the Intemet detailing
this.

(https://www.reddit.eom/r/ReportTheBadModerator/comments/8vbzbw/i_was_banned_from_like_5_su
breddits_most_i_havent/)In the case before this Court,Reddit Moderator,"DiggDejected", had
apparent malicious intent. Defendant DiggDejected knew Reddit's rules and was there to enforce them,
but then chose to break them himself,in the worst possible maimer. Twice,in our case, as there are two

separate posts.(Three times, if he, personally, was requested to remove the content he had posted, by
Reddit, and did not.)

37. VI. VIOLATION OF FEDERAL RICO LAWS.This post also constitutes a violation ofRICO
Laws,in that Reddit moderator, DiggDejected,author ofthese statements, Reddit attomey, and Reddit
itself, are all aware ofthe ongoing crimes ofcontinued daily publication, and possibly are working in
concert,to protect illegal posts from removal,a practice explicitly prohibited by various State and
Federal laws, detailed herein. However,this is not the only violation ofthe RICO laws,and this

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paragraph describes the least egregious violation first.

38. The continued and commiserate publication by three entities(the moderator, the attorney, and the
management ofReddit),together which constitute an enterprise, as defined by the RICO act, which
may or may not be legal associations(i.e. in acting together,they do not have to be a legally formed
corporation or other legal entity, ifthey are acting together) are a violation ofthe RICO law. As per
section 4 ofthe Definitions section ofthe RICO act, an "'enterprise' includes any individual,
partnership, corporation, association, or other legal entity, and any union or group ofindividuals
associated in fact although not a legal entity;" The publication by this enterprise ofthe defamatory
statements is a violation, under the RICO act, ofTitle 18, sections 1951 (relating to interference with
commerce,robbery, or extortion), and section 1952(relating to racketeering), (citation: 18 U.S. Code
§71961. Definitions found at https://www.law.comell.edu/uscode/text/18/1961).
39. However,there is an even more compelling enterprise within this organization, described in the
following paragraphs. This enterprise consists ofthe three defendants listed in this case, Mr. Altman,

Mr. Bassett, and

Ohanian. A\^le the enterprise involving Reddit, its moderator, and its attomey,is

an enterprise in conspiratorial violation ofPlaintiffs' rights by continuing to publish the illegal and
damaging post, after it was brought to their attention, the association ofthree individuals in positions of
power at Reddit, and in a position to directly profit from the damage to our company's name and
reputation, is a serious legal issue according to the RICO laws.
40. According to Bloomberg, https://www.bloomberg.com/research/stocks/private/people.asp?
privcapld=29927936, Justin Bassett,the head ofRounding-Up at Reddit, became president ofa startup
accelerator, Y Combinator,in 2014. From the same Bloomberg information, it was found that in
addition to Mr. Bassett, Mr.Alexis Ohanian was also involved in Y Combinator,as a Partner ofY
Combinator. Mr. Ohanian is also one ofthe Co-Founders and Executive Chairman for Reddit,Inc.,

establishing his part in the RICO conspiracy that has been unfolding against our small company. Yet
another board member of Reddit,Inc., is Samuel H.Altman, who is also involved in Y Combinator,as
a Member ofthe Board of Overseers. Thus it is established that an enterprise ofno less than three
people, involved directly with a major competitor ofour company(see below), in addition to
DiggDejected and the attorneys for Reddit, who ignored Plaintiffs' Cease and Desist request, was
involved, in this case ofRICO violations.

41. According to Y Combinator's Companies page, https://www.ycombinator.com/companies/, Y
Combinator funded "UnwindMe",a mobile massage on-demand company. This establishes the true
association ofthese three individuals as an enterprise, according to the definitions in the RICO act, and
a financial motive for their association and continued publication ofthe defamatory statements against
our company is carefully detailed below.

42. While the website for "Unwind Me" is now defunct, it was easily found, via the Facebook page for
Unwind.Me(https://www.facebook.com/Unwind.Me),that Unwind.me was acquired by Soothe,Inc.,
one ofPlaintiffs' major competing companies in the mobile massage therapy market. The prior
Facebook page for UnwindMe shows a graphic oftheir acquisition by Soothe. A Techcrunch article
describes fte acquisition for an "undisclosed sum": https://techcrunch.eom/2015/09/15/sootheacquires-unwind-me/

43. This acquisition occurred around the time that the defamatory post appeared on Reddit, and in light
ofthis new information, it is very likely that it was informally (i.e., not in writing but verbally) agreed
by the parties at Reddit that the post be left up,instead of moderated as illegal content, as their User

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Agreement and the various State and Federal laws relating to defamation, concur.

44. Its appearance and remaining on the site could have also had a positive impact on the size ofthe
monetary compensation provided for their acquisition by Soothe,Inc., as it might have been perceived
by the purchasing company as being a defamation directed against one oftheir main competitors that,
at the time, came up very high in the Google search results for relevant search terms(mobile massage,
massage at home,couples massage, etc.), in the New Jersey and New York City on-demand mobile
massage markets, which various co-Defendants entered into in about 2015,just after this defamatory
post appeared and began to have an impact, although unknown to Plaintiffs, on public perception ofour
company, and its reputation. This very real possibility establishes a financial benefit aspect for the
RICO violations, as there must be some gain by the violators ofthe RICO act,in order for the Laws to
apply.

45. Defendants may have had, and continue to have, financial interest in Soothe,if Defendants were
compensated for their Unwind.Me sale in Soothe private stock, or some other continuing benefit.
SooAe directly competes with Plaintiflfs' company in the New Jersey and New York On-demand
Mobile Massage markets, as, both then and now,our company comes up quite high in search results for
the very same search terms. Whenever someone would have searched for "mobile massage" or "mobile
massage nj" or "in home massage," there was our company,on the first page of Google.
46. When the Court considers that the webpage directly defamed (kids-spa-party-nj.njmassage.info) is
the same website as our main mobile massage service (njmassage.info), a well-known New Jersey and
New York mobile massage competitor, the violations ofthe RICO act begin to make sense, and two
separate but related enterprises(the first ofDigg Dejected, Reddit corporate staff, and,later, their
attorney; the second of Mr. Bassett, Mr. Ghanian, and Mr. Altman)are well established herein.
47. Mountainside On-Site Massage Therapy provides in-home kids spa parties. The header details this,
that it's Mountainside On-Site Massage Therapy presenting the Mobile Kids Spa Parties, therefore, it's
Mountainside On-Site Massage Therapy being disparaged, as well as the Plaintiffs personally, and the
Kids Spa Service. Plaintiffs' various massage and mobile spa services are listed on the page linked to
on the Reddit posts, with links to the mobile in-home,event, and corporate, massage pages, both in the
side menu,and on the top ofthe linked-to page at NJMassage.Info, where it states "Mountainside OnSite Massage Therapy presents Mobile Kids Spa Parties." There is no difference between the two
services, except in the colors used on the kids page, which are pink and purple, instead ofthe green
used on our main webpage. Anyone visiting the kids spa party page would understand it to be the same
brand and company as the Mobile Massage service,just another of our Mobile Mas sage sub-services,
on a different page.

48. It often happens that when a company is bought out by a competing company,that the previous
owners then become shareholders in the acquiring company. Regardless of whether this is the case,
various Defendants still would have a positive outlook towards the company that they just made a
handsome sum firom (it would have very likely been substantial if Unwind Me was a real competitor
with a large clientele in California, as the TechCruch article suggests, and as Soothe also purchased the
client information when they bought the company, which has great value, also according to the
Techcrunch article mentioned above). And,as stated above,this enterprise benefiting fi'om the sale of
Unwind.Me would have had a vested financial interest in leaving the defamatory post up in collusion
with one another and with their moderator.

49. It should be noted that Plaintiff(s), as experienced web marketers, have completed an exhaustive

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search for the term "gives people diseases" with the term "Reddit" and "spa parties" on Google, and
have found no similar posts on the Reddit forum, besides the two about Plaintififs that still comes up in
Google search results. A search of Gives people diseases" on Reddit returns no similar defamatory
statements besides the two against Plaintififs.

50. This fact makes this a unique case ofdisparagement, and even more likely to have been a case of
criminal conspiracy to defame a competitor of Soothe,in light ofthe financial incentive and benefit
that their management did receive,fi*om said company. Plaintiffs encourage Your Honor to undertake a
search in similar manner.

51. This would need to be pursued further in Discovery, as to whether or not the co-founders of Reddit,
as well as the head of Rounding-Up and the Board Members, are or were directly invested in Soothe,
Inc., as "angel investors," private stock holders in their pre-IPO stock, or were,or are, otherwise
invested. Due to the high position of Mr. Barrett, Mr.Altman,and Mr. Ohanian,outside independent
investors also employed in high positions at Reddit, it is likely that information on Soothe was shared
between them,and they may all, in fact, be investors in Soothe. On Financial Content,
http://markets.fmancialcontent.com/stocks/news/category?Category=Soothe, Soothe is shown as a
privately traded stock, with the option to buy and sell private shares ofstock or to invest in the
company.

52. The above statements establish that there was a financial and racketeering motive for the

maintenance ofthis post. This could have easily been at the request ofJustin Bassett,Alexis Ohanian,
or Samuel Altman,or anyone else who was invested in Soothe, in order to prevent our success as a
major competing brand to Soothe,Inc. It is quite possible and,in fact, likely, that the other founders of
Reddit are also invested in Soothe,Inc., with the potential for racketeering profits hanging in the
balance ofthe success or failure ofour competing company.

53. As a result ofthis startup company and sale thereof,they are very likely in violation ofthe Criminal
section ofthe Racketeering Act, mentioned above, under Section 1963, Criminal Penalties: "(a)(3)any
property constituting, or derived fi*om,any proceeds which the person obtained, directly or indirectly,
fi*om racketeering activity or unlawful debt collection in violation ofsection 1962." According to
subsection(b)ofthe same section,"(b)Property subject to criminal forfeiture under this section
includes—...(2)tangible and intangible personal property, including rights, privileges, interests,
claims, and securities."

54. These areas are quoted to support the statement that there was a criminal conspiracy occurring in
connection with this defamatory statement, as these three individuals, and possibly others, received
property (in the form of money and possibly stocks, bonds, or board positions) derived indirectly jfrom
these RJCO violations, and that this property could be seized by the government ifan investigation
were to be commenced against these three individuals. This issue ofdefamation, which could have
been easily resolved in the beginning, may actually now reveal illegal and illicit activities that are in
violation ofFederal Law,and likely State Laws as well, and may warrant investigation by the Court.
55. The discovery ofthe Unwind Me app that various Defendant(s)sold to Soothe,Inc.,for an
undisclosed sum,and potential stock options, changes this case fi:om a simple case ofdefamation,to a
clearer case ofracketeering and collusion. This has been sufficiently proven as a distinct possibility and
passes the test for a valid motion,in accordance with the RICO act, in the preceding paragraphs, to the
greatest extent that a non-law enforcement individual would be able to prove on their own, with
extremely limited investigative resources.

 Case 1:19-cv-03048-RRM-JO Document 1 Filed 05/20/19 Page 10 of 13 PageID #: 10

56. As part ofthe background of Soothe,Inc., from whom various Defendant(s)publicly, and provably,
profited. Plaintiffs offer the following information for the consideration ofthe Court. Some startups,
such as Uber and Lyft(which took over the thriving taxi-cab business, which had aheady existed in
every city, state, and rural area around the country), as well as Soothe, as relevant to this case, has been
to move into existing markets(in this case,the mobile massage market), while stating in their
interviews and website documentation,that they had originated the brand new concept of mobile
massage. Documentation ofthis fact can be provided, at the request ofthe court, including interviews,
competitors in existence, etc., but is beyond the scope ofthis complaint.
57. Mobile massage, however, was not the original idea ofthe founder of Soothe,Inc., as claimed in
interviews and on its website, whereas even Mobile Massage with On-Demand Same-Hour booking,
has been extant for over six years before the founding of Soothe,Inc. Several companies in New
Jersey, and other states, were highly visible on Google and elsewhere on the web,as well as Zeel and a
number ofcompanies already providing a similar service in California and New York City. This is to
demonstrate that Soothe,Inc., and thus the Defendants named above from Y Combinator, would have

had knowledge ofour company as a competitor to the company involved in their racketeering business
transaction.

58. In the section ofthe RICO act which regards damages, titled Civil Remedies,subsection(3)states
"Any person injured in his business or property by reason ofa violation of section 1962 ofthis chapter
may sue therefor in any appropriate United States district court and shall recover threefold the damages
he sustains and the cost ofthe suit, including a reasonable attorney's fee..."
(https://www.law.comell.edu/uscode/text/l8/1964)
59. Vll. DISCRIMINATION AGAINST WOMAN/A WOMAN/WOMEN.Federal laws are designed

to protect women against harassment, as a group. Being that Mountainside On-Site Massage Therapy,
Mobile kids Spa Parties, and Mountainside Diversified, have as their President, a woman,in a market
dominated by women,doing what is largely considered "women's work'(painting nails, doing hair.,
massage, etc.) this is clearly bias against Ms. Miller, and women,at large, in that an ancient meme of
"women as defiled" continues to blast forth from DiggDejected, and other Reddit users' keyboards, and
Reddit,in knowing this for the last eleven months, since our verified delivery of written notification, is
committing a crime of bias against a woman, personally, by relying on a wom canard regarding
women,taken as a group.

60. A clear case of Civil Rights Discrimination against the right ofa woman,who owns a business,to
be free of harassment in conducting her business matters, and ability to earn a living by working as a
Massage Therapist, and Massage Uierapy Service operator. These misogynistic comments,about
"giving diseases" are aimed at a website that is owned by a woman, with some services specificedly
geared toward women and girls, in a field where all competing Kids Spa businesses are generally
owned by women. This is a publicly made discriminatory remark by a Moderator, a respected member
ofthe "largest online community on Earth," as Reddit bills itself.
61. As an example ofthe trope referenced above, is the paragraph in Translation In Modem Japan,
edited by Indra Levy. On page 176,from the Chapter entitled "Monstrous Language" we find the
following statement: "The female figure in Koya represents the new trope ofthe sexually alluring yet
diseased female. She is a blend ofthe traditional animal-female trope and the new diseased female
trope. It is not her body that turns into an animal, but her diseased power that can tum men into hybrid
creatures, a feat she accomplishes by seducing men."

 Case 1:19-cv-03048-RRM-JO Document 1 Filed 05/20/19 Page 11 of 13 PageID #: 11

62. There are many other examples ofthese types of gender-biased tropes against women in popular
culture, American and British Victorian culture, and other cultures around the world. As a meme,the
"diseased female" is nothing new,and is being perpetuated by a whole new generation of men and their
counterparts online,in the media,and in real life situations. A more modem example can be found on
Twitter, at https://twitter.eom/Maggie_McNeill/status/1006341830097567744, where a user states,"He
spreads 'sex trafficking' hysteria, the 'diseased whore' myth and the'women can't be trusted to manage
our own sexuality' trope as much as any other prohibitionist."

63. The continued publication by Reddit and their assignees ofthe defamatory and derogatory
statements have presented a barrier to commerce and trade, undertaken by a women-owned business,
with most ofthe services provided by women. With regard to US Title 42, Subchapter 21,Subchapter
VI,definitions(referenced here: http://uscode.house.gov/view.xhtml?

path=/prelim@title42/chapter21&edition=prelim),(a)"The term 'person' includes one or more
individuals, governments, governmental agencies, political subdivisions, labor unions, partnerships,
associations, corporations, legal representatives, mutual companies,joint-stock companies,trusts,
unincorporated organizations, trustees, trustees in cases under title 11,or receivers."
64. In the same section, definitions,(g)"The term 'commerce' means trade, traffic, commerce,
transportation, transmission, or communication among the several States; or between a State and any
place outside thereof; or within the District of Columbia,or a possession ofthe United States; or
between points in the same State but through a point outside thereof." By publication and continued
maintenance ofthis statement on their website, Reddit, and the other parties named above, have
affected our ability to compete and succeed in commerce, with regard to our business' reputation,
standing, and long-term capability for success.
65. As a discriminatory statement directed against women as a group or class, and the individual
partner, as a women-owned business, this statement has had a direct impact on our ability to
successfully compete in the marketplace, and has had a negative affect on the commerce that our
company has been engaged in since publication ofthis detrimental and discriminatory statement. This
has a direct effect on Plaintiffs' money-making capacities in our employment, and as such is a violation
ofthe aforementioned Title, with regard to discrimination on the basis ofsex in the workplace. It has
had a definite effect on the earning capacity ofthe business owner,as a woman,as a result ofthis wellknown gender biased trope of women as diseased.

66. IX. NO BLANKET IMMUNITY FOR WEB COMPANIES.In regards to the shielding of
companies from ALL manner ofliability for violation ofany and all laws that they wish to violate,the
following should be noted in addition to statements made in this document prior to the enumeration of
laws violated and redresses requested:

67. The purpose ofour court system is providing a lawful forum for the redress of grievances. Section
230 ofthe Communications Decency Act should not,then, be read, in such a manner,that a libeled, or
otherwise illegally and unlawfully violated, person, persons, business, or service provided by a
business, cannot find suitable legal remedy for provable crimes oflibel, and others, with no means of
having such harmful statements deleted, retracted, or have anyone whatsoever, held liable for various
damages arising firom violations of various rules and laws.
68. Such a broad interpretation is flawed; as this statute was intended to protect Children from

 Case 1:19-cv-03048-RRM-JO Document 1 Filed 05/20/19 Page 12 of 13 PageID #: 12

indecent content, and for the prevention ofthe proliferation of pornography on the internet. In regard
to this particular case,the violations made by the aforementioned Defendants were much more
grievous than simple republication ofan isolated statement by an isolated individual, and the RICO
statutes, as well as other violations oflaw, are not protected from prosecution by a simple reference to
Section 230 ofthe CDA. The violations ofFederal Law that have been committed by the parties

named as Defendants in this lawsuit go far beyond any protections that were intended by Congress in
creating the Communications Decency Act,and should not be so broadly interpreted as to give

Defend^ts free license to collude,conspire, and violate any laws they so choose, while hiding behind a
law that was not meant to protect them,and should not protect them.

69. In addition, a more recent law has removed many ofthe protections afforded by Section 230,in
giving specific redresses to persons who have been violated by certain forum type websites. In fact,
BackPage.com was literally shut down (actually seized by the federal government "as part ofan
enforcement action by the [FBI],the [USPIS],and the [IRS] Criminal Investigation Division", without
warning, upon passage ofthe FOSTA act)over third party posting ofcontent to their site on the basis of
the newly enacted FOSTA Bill. This bill removes the legal shield for websites that post content created
by others, and enables states and victims to obtain redress and recover damages.
70. This law,specifically, caused the shutdown and seizure ofthe website backpage.com, which was a
known advertising forum for prostitution, human trafficking, and sex slavery, while hiding behind the
shield ofSection 230. Just as in that instance,the laws should be interpreted as they were designed to

be interpreted, and, as stated before, should not allow perpetrators ofreal crimes to hide behind laws
that were never meant to protect them from prosecution for true criminal acts.
71. The Communications Decency Act,including Section 230, was written to allow parental control of
contents, but has been broadly over-interpreted to provide immunity to a variety oftypes of websites in
all cases, when they should be held liable for certain actions, when such actions involve their officers
and board members. The FOSTA bill was written and passed specifically to limit the immunity of
websites who were using the shield of Section 230 to allow sex trafficking and other clearly
Victimizing' crimes to occur on their forums without any legal remedy or recourse for said victims.

72. It is my hope that this court will understand that there is a lot more going on in this particular case
than simply a case ofa third party posting a random statement on Reddit,and that this particular case
actually seems to involve collusion and conspiracy, in violation of multiple federal laws and statutes,
and that even smaller businesses should be protected from predatory companies, whether they are
social media sites or other types ofsites. Section 230 should not be broadly interpreted in this instance,
as it does not apply when conspiracy, as demonstrated herein, has occurred. The CDA was not drafted
to serve as a blanket immunity against redress, or a nullification of legal due process.
73. X.PROTECTION UNDER SECTION 230 FOR PLANTIFFS,RATHER THAN DEFENDANTS.

A Child who has gone to our parties, or a classmate, or friend, ofa kid who has attended our parties,
may see the post and(wrongly)believe they,themselves, or their fnend who attended, has contracted a
disease. Such is not beyond reasonable,as we host Kids Galleries that the children visit, and we've had
thousands ofattendees. Such would clearly be traumatic and stress-producing, possibly causing social
stigma, and is clearly within purview ofthe main intent of Section 230. So rather than Defendants
being protected. Plaintiffs assert that we,Donn Albano, Heather Miller, Mountainside Diversified,and
our brands. Mobile kids Spa Parties and Mountainside Diversified, and websites NJmassages.com,and
NJmassage.info, are in fact, the protected parties in this instance.

 Case 1:19-cv-03048-RRM-JO Document 1 Filed 05/20/19 Page 13 of 13 PageID #: 13

REDRESS.Your Honor,Plaintiffs, Donn Albano,and heather Miller, are respectfully requesting, as
redress:

♦IMMEDIATE* Motion To Compel the Removal, permanent deletion, of untrue lies, the hateful and
harassing statements re-published daily on Reddit.Com by direct order of the Court upon Defendants,
DiggDejected and Reddit, with Prejudice.

We are also requesting *IMMEDIATE* Motion To Compel a Retraction and/or apology on Reddit, as
well as NJ.Com, by Reddit *and* DiggDejected, for permitting this garbage, outside of Reddit's own
rules, to remain for almost one full year after being notified of its presence, on their web site,
RedditCom.

OTHER DAMAGES. We are also respectfully requesting that Your Honor consider whether damages
are in order in respect to any/some/all of the legal boundary violations committed either by Reddit,
Digg Dejected, or Reddit's Attomey(s), or by the addition^ conspiratorial enterprise described herein
as Co-Defendants in this case.

Of course, this is fully within Your Honor's quite clearer imderstanding of the laws, however, we are
asking for $5 million donated to a womens' charity of our agreed choosing (Plaintiffs and any
Defendant(s) foimd guilty), as well as $500,000 For Assertive Kids Foundation that Plaintiffs' started
two years ago, as well as $1 million dollars to Plaintiffs, in reparation to our brand, for purposes to
redress loss of revenue, to offset issues of re-branding, paying for advertisements, and other ways of
proactively combating any damage that has been done.
Plaintiffs' business hires over 60 contractors as LMTs who need to eat. We need to keep our company

in a positive light to consumers, so all of them can continue to help be fed by our company's work that
we provide. We are more concerned with helping people than profits, however, we must be realistic.

As for the argument that immunity is provided by section 230 of the Communications Decency Act, if
Your Honor finds that this law protects single Defendant Reddit against damages, even in these
circumstances, we still respectMly request an immediate order for removal of content, as well as
retraction on Reddit, as well as in the daily newspaper, NJ.Com.

Plaintiffs request Your Honor to permit time for Plaintiffs, relatively inexperienced Pro Se litigants, to
subpoena and get information for the identity of DiggDejected.
/

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 Case 1:19-cv-03048-RRM-JO Document 1-1 Filed 05/20/19 Page 1 of 2 PageID #: 14
JS44 (Rev. 11/27/17

CIVIL COVER SHEET

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SHE INSTRUCTIONS ON NEXT RAGE OF THIS FORM.)

Wn?i /Sfa^oWleaSer Miller, P.O. Box 20521, Staten Island. NY 10302 DiggSejec^^'^^'i Doe, Reddit Moderator): Reddit.com; Reddit
Corporation Service Company; Alexis Ohanlan; Justin Bassett;
Samuel Altman

(b) County of Residence of First Listed Plaintiff

Countv of Residence of First Listed Defendant

(IN U.S. PLAINTIFF CASES ONLY)

(EXCEPTIN U.S. PUINTIFFCASES)
NOTE:

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

Attorneys (ifKnown)

(c) Attorneys (Firm Name. Address, and Telephone Number)
Pro Se: See Above

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Boxfor Plaintiff

11. BASIS OF JURISDICTION (Placean "X"in One Rox Only)

(For Diversity Cases Only)

□ 1

U.S. Government

^3

Plaintiff

Federal Question
Citizen of Tliis State

(U.S. Gorernmeni Nol a Parly)

and One Box for Defendant)

PTF

DEF

□ 1

□

PTF

1

Incorporated or Principal Place
of Business In This State

□ 2

U.S. Government
Defendant

□ 4

Diversity
(Indicale Citizenship of Parlies in hem III)

Citizen of AndjB^tlB Ir
 1a

oft

Citizen or Subject of a

□ 3

□ 4

DEF

□ 4

.

Incorpwawo aW l^ci^Wlac^lK □ 5 □ 5
of ^ums\^^otn^  gte^^
□

3

Foreign Nation

□ 6

□ 6

Foreiun Country

IV. NATURE OF SVlTfRiacc an "X" in One Btix Only)
CONTRACT

Click here for: Nature of Suit Code Descriptions.
FORFEITURE/PENALTY

TORTS

□ 110 Insurance

PERSONAL INJURY

□ 310 Airplane

□ 120 Marine
□ 130 Miller Act

□ 140 Negotiable Instrumeni
□ 150 Recovery of Overpayment
& Enforcement of Judgment

□ 315 Airplane Product
Liability
□ 320 Assaiil
Slani

□ 330 Federal Employers'
Liability

□ 151 Medicare Act

□ 152 Recovery of Defaulted

□ 340 Marine
□ 345 Marine Product

Student Loans

(Excludes Veterans)

□ 153 Recovery of Overpayment

Liability
□ 350 Motor Vehicle
□ 355 Motor Yehisl]

of Veteran's Benefits
□ 160 Stockholders'Suits

□ 190 Other Contract

PERSONAL INJURY

□ 365 Personal Injury Product Liability

□ 360 Other Personal

G 196 Franchise

Injury
□ 362 Personal Injury •

□ 690 Other

jjiaceutical
□ 368 Asbestos Personal

REAL PROPERTY

CIVIL RIGHTS

□ 240 Torts to Land

□
□
□
□

□ 245 Tort Product Liability
□ 290 All Other Real Property

□ 445 Amer. w/Disabilities ■

□ 220 Foreclosure

□ 230 Rent Lease & Ejectment

440
441
442
443

Other Civil Rights
Voting
Employment
Housing/
Accommodations

Employment

□ 376QuiTam(31 USC
3729(a))
□ 400 State Reapportionment
□ 410 Antitrust

□ 820 Copyrights

□ 430 Banks and Banking

□ 830 Patent

□ 450 Commerce

□ 835 Patent - Abbreviated

□ 460 Deportation
□ 470 Racketeer Influenced and

Corrupt Organizations

□ 840 Trademark

LABOR
PERSONAL PROPERTY
□ 710 Fair Labor Standards
□ 370 Other Fraud

71 Truth in Landing

Act

□ 720 Labor/Management

W.)

Property Damage
□ 385 Property Damage
Product Liability

SOCIAL SECURITY

□ 861 HlA(1395fl)
□ 862 Black Lung (923)
□ 863 DIWC/DIWW (405(g))
□ 864 SSID Title XVI

Relations

□ 740 Railway Labor Act
□ 751 Family and Medical

□ 865 RSI (405(g))

PRISONER PETITIONS

□ 790 Other Labor Litigation

□ 791 Employee Retirement

Habeas Corpus:

Income Security Act

□ 463 Alien Detainee
□ 510 Motions to Vacate

□ 530 General

□ 535 Deatli Penalty

Exchange

I5I( 890 Other Statutory Actions
□ 891 Agricultural Acts

Act

FEDERAL TAX SUITS

□ 870 Taxes (U.S. Plaintiff
or Defendant)
□ 871 IRS—Third Party
26 USC 7609

Sentence

□ 480 Consumer Credit
□ 490 Cable/Sat TV
□ 850 Securities/Commodities/

□ 893 Environmental Matters
□ 895 Freedom of Information

Leave Act

□ 896 Arbitration

□ 899 Administrative Procedure

Act/Review or Appeal of
Agency Decision
□ 950 Constitutionality of
State Statutes

IMMIGRATION

Other:

□ 446 Amer. w/Disabilities ■
Other
□ 448 Education

□ 423 Withdrawal
28 USC 157

New Drug Application

Injury Product
Liability

Mcdcal_Mal£tactice
□ 210 Land Condemnation

□ 375 False Claims Act

PROPERTY RIGHTS

rsonal Injury
Product Liability

OTHERSTATUTES

BANKRUPTCY

□ 422 Appeal 28 USC 158

□ 367 Health Care/

Produ

□ 195 Contract Product Liability

□ 625 Drug Related Seizure
ofProperty 21 USC 881

□ 540 Mandamus & Other

□ 462 Naturalization Application
□ 465 Other Immigration

□ 550 Civil Rights

Actions

O 555 Prison Condition
□ 560 Civil Detainee Conditions of
Confinement

V. ORIGIN (Placean "X" in One Box Only)
X1 Original
□ 2 Removed from
Proceeding
State Court

□ 3

Remanded from
Appellate Court

□ 4 Reinstated or
Reopened

OS Transferred from
Another District

^ 6 Multidistrict
Litigation -

(specify)
Transfer
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictionat statutes unless diversity):

VI. CAUSE OF ACTION

VII. REQUESTED IN

Direct File

Brief description of cause:
Civil Action Pursuant To "Harassment, et al"

□ CHECK IF THIS IS A CLASS ACTION

DEMANDS

CHECK YES only if demanded in complaint:

UNDER RULE 23, F.R.Cv.P.

COMPLAINT:

JURY DEMAND:

VIII. RELATED CASE(S)

IF ANY

(See instructions).

RANDOM/RANDOM

DOCKET NUMBER NONE

SIGNATURE OF ATTORNEY OF RECORD

DATE

05/20/2019
FOR OFFICE USE ONLY

RECEIPT#

□ 8 Multidistrict
Litigation -

AMOUNT

APPLYING IFP

JUDGE

mi

MAG. JUDGE

□ Yes

DNo

 Case 1:19-cv-03048-RRM-JO Document 1-1 Filed 05/20/19 Page 2 of 2 PageID #: 15
J *

CERTIFICATION OF ARBITRATION ELIGIBILITY
Local Arbitration Rule 83.10 provides that with certain exceptions, actions seeking money damages only in an amount not in excess of S150,000,
exclusive of interest and costs, are eligible for compulsory arbitration. The amount of damages is presumed to be below the threshold amount unless a
certification to the contrary is filed.

1,

,counsel for

,do hereby certify that the above captioned civil action

is ineligible for compulsory arbitration for the following reason(s):
monetary damages sought are In excess of $150,000, exclusive of interest and costs,

/

the compiaint seeks injunctive relief,
the matter is otherwise ineligible for the following reason

DISCLOSURE STATEMENT - FEDERAL RULES CIVIL PROCEDURE 7.1
Identify any parent corporation and any publicly held corporation that owns 10% or more or its stocks:

RELATED CASE STATEMENT (Section VIII on the Front of this FormI
Please list all cases that are arguably related pursuant to Division of Business Rule 50.3.1 in Section VIII on the front of this form. Rule 50.3.1 (a)provides that "A civil case is'related*
to another civil case for purposes of this guideline when, because of the similarity of facts and legal issues or because the cases arise from the same transactions or events, a
substantial saving of judicial resources is likely to result from assigning t)oth cases to the same judge and magistrate judge.* Rule 50.3.1 (b) provides that' A civil case shall not be
deemed 'related* to another dvil case merely because the dvil case:(A)involves identical legal issues, or(B)involves the same patties.* Rule 50.3.1 (c)further provides that

'Presumptively, and subject to the power of a judge to determine otherwise pursuant to paragraph (d), dvil cases shall not be deemed to be 'related* unless both cases are still
pending before the court."

NY-E DIVISION OF BUSINESS RULE 50.1fdH2)

1.)

Is the civil action being filed in the Eastern District removed from a New York State Court located in Nassau or Suffolk

County?
2.)

□

Yes

□

No

If you answered "no" above;

a) Did the events or omissions giving rise to the claim or claims, or a substantial part thereof, occur in Nassau or Suffolk

County?

Q

Yes

 2 

No

b) Did the events or omissions giving rise to the claim or claims, or a substantial part thereof, occur In the Eastern

District?

IZI

Yes

□

No

c) If this is a Fair Debt Collection Practice Act case, specify the County in which the offending communication was
received:

If your answer to question 2 (b) is "No," does the defendant (or a majority of the defendants, if there is more than one) reside in Nassau or

Suffolk County, or, in^ interpleader action, does the claimant (or a majority of the claimants, if there is more than one) reside in Nassau or
Suffolk Countv?
M
Yes
1 1
No
(A/ofe; A corporation shall be considered a resident of the County In which It has the most significant contacts).
BAR ADMISSION

1 am currently admitted in the Eastern District of New York and currently a member in good standing of the bar of this court.

n

Yes

Q

No

Are you currently the subject of any disciplinary action (s) in this or any other state or federal court?

m

Yes (If yes, please explain

O

No

I certify the accuracy of all information provided above.
Signature:
Last Modified: 11/27/2017

 COMPLAINT against Samuel Altman, Justin Bassett, DiggDejected, Alexis Ohanian, Reddit Corporation Service Company,

General Information

Court

United States District Court for the Eastern District of New York;
United States District Court for the Eastern District of New York

Federal Nature of Suit

Other Statutory Actions[890]

Docket Number

1:19-cv-03048

© 2019 The Bureau of National Affairs, Inc. All Rights Reserved. Terms of Service
// PAGE 17