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Herman & Russo, P.C. v. Xcentric Ventures, LLC - Complaint

Herman & Russo, P.C. v. Xcentric Ventures, LLC - Complaint

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Published by David S. Gingras
Complaint filed in Herman & Russo, P.C. v. Xcentric Ventures, LLC and Ed Magedson, U.S. District Court, Northern District of Georgia Case No. 10-CV-0398.
Complaint filed in Herman & Russo, P.C. v. Xcentric Ventures, LLC and Ed Magedson, U.S. District Court, Northern District of Georgia Case No. 10-CV-0398.

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Published by: David S. Gingras on Mar 23, 2010
Copyright:Attribution Non-commercial

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07/08/2013

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I
N
TH
E UNIT
E
D
STA
T
ES
DI
S
TRICT
C
O
UR
T
NORTH
ER
N
DI
S
TRI
C
T OF G
E
ORGI
A
Melissa A
. Herman, David A
. Russo
David A
. Russo and
Herman & Russo, P.C
. * PLAINTIFFS' ORIGINAL COMPLAINT
Plaintiffs, * AND JURY DEMAND
I
10-
rv-039
Defendants
.
and David A
. Russo ("Russo") file this Original Complaint and Jury Demand against Defendants
Xcentric Ventures, LLC ("Xcentric Ventures" or "Xcentric"), Edward Magedson ("Madgeson"),
and John or Jane Doe ("Doe") on personal knowledge as to all facts regarding themselves andon information and belief as to all other matters, as follows
:
H
e
rman & Ru
ss
o
,
P.C
.
225 Creekstone Ridge
Woodstock, GA 30188Telephone (678) 925-3510
Facsimile (678) 741-2697
Melissa A. Herman (Georgia Bar No
. 348378)
David A
. Russo (Georgia Bar No
. 621210)
F
EB 1
12010
JAMES tV
. T
E
,
C
L
E
RK
eRutv a
e
ri
c
V
.
XCENTRIC VENTURES, LLC, and
EDWARD MAGEDSON, and JOHN
OR JANE DOE
Plaintiffs Herman & Russo, P.C
. ("HR Law"), Melissa A
. Herman ("Herman"),
 
NORTHERN DISTRICT OF GEORGIA
Melissa A
. Herman, David A
. Russo
David A
. Russo and
Herman & Russo, P
.C
. * PLAINTIFFS' ORIGINAL COMPLAINT
Plaintiffs, * AND JURY DEMAND
V
and David A
. Russo ("Russo") file this Original Complaint and Jury Demand against Defendants
Xcentric Ventures, LLC ("Xcentric Ventures" or "Xcentric"), Edward Magedson ("Madgeson"),
and John or Jane Doe ("Doe") on personal knowledge as to all facts regarding themselves andon information and belief as to all other matters, as follows
:
IN THE UNITED STATES DISTRICT COURT
XCENTRIC VENTURES, LLC, and
EDWARD MAGEDSON, and JOHN
OR JANE DOE
Defendants
.
Plaintiffs Herman & Russo, P.C. ("HR Law"), Melissa A. Herman ("Herman"),
 
search for any business or individual unfortunate enough to be the victim of such a report
.
I
.
PRELIMINARY STATEMENT
Defendants Edward Magedson and Xcentric Ventures along with John or Jane Doe the
authors of defamatory statements are in a relationship that profits from defamation. DefendantsMagedson and Xcentric operate a website known as "Ripoff Report", which is located on the
Internet at http
: //www
.ripoffreport
.com (the "Website"). Magedson and Xcentric profit from theWebsite by selling advertisements, books written by Magedson, and their "Corporate Advocacy
Program", in which they offer to neutralize defamatory statements that appear on their ownwebsite for a fee
.
Third parties can post comments, statements, and allegations on this Website about
businesses and individuals who have allegedly "ripped them off'. Magedson and Xcentric
enhance these third party posts by adding their own original content to boost the defamatorynature of these posts. For example, for each post on their Website, third parties are prompted tocreate a title for their post that begins with the name of the post's targeted business or individual
.
Magedson and Xcentric add the words "Rip-off Report
:" to the beginning of this title to create
the hidden "title metatag" for the post. This "title metatag" is located in the HTML (hyper textmarkup language) script that underlies each webpage containing a post of the Website. Whileadding this defamatory content to this hidden title metatag may seem harmless, in actuality, thatdefamatory title metatag is what Internet search engines, such as Google, Yahoo, etc, display asresults for Internet searches. The highly charged words "Rip-Off Report:" followed by the name
of the defamed target have the intended effect of shocking any person who conducts an Internet

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