Without prejudice May 24, 2010 To: Nadav Haetzni, Adv. Puris Heatzni Rosenberg & Co.

15 Kanfei Nesharim St., Jerusalem By fax no. 02-653-7773 (tel: 02-653-7777) By registered mail and fax Re: My client, Mr. David Remez Publication of defamation your client, the Im Tirzu association Re: Your letter to my client, Mr. David Remez, from April 1, 2010 Dear Sir, 1. I hereby reply to your letter to my client, Mr. David Remez (who in your letter was called familiarly "Didi Remez"), pursuant to the contents of your referenced letter from April 1, 2010 (provided, of course, that your letter was sent in earnest, and was not sent as an April Fools' Day prank, a common practice in the world on that date). 2. In your letter you claim that my client, together with others, is a participant in a grave publication, in your words, on the Internet, as part of the Facebook site, which includes the logo "Im Tirzu a fascist movement." Subsequently in your letter you claim that the goal of this group is to promote a campaign of slander, defamation and vilification of your client. 3. Inasmuch as my client is indeed a participant in administering this group on the Internet and/or was a participant in the publications appearing therein, we completely reject the contents of your letter, in all its sections and arguments, for the reasons that will appear as follows. My client, inasmuch as he is a participant in administering the group "Im Tirzu a fascist movement," maintains his claims in this matter and his right to freedom of expression in a democratic state, as shall be explained as follows. Definitions 4. Before we present our arguments and address, in a nutshell, the arguments and complaints raised in your letter, we would like to define a number of terms to ensure our use of them is understood. Clearly these definitions are not comprehensive and cannot contain the complete extent of academic research concerning them: "Democracy" -- government of the people, a political regime where government is by elected representatives of the people. "Democratic" (from the Greek, demos people, kratos rule or power). 1.

An advocate of a regime of the rule of the people, a government of elected representatives of the people. 2. A person who sees other members of society as having equal rights to himself and does not aspire to elevate himself above others and lord over them. These terms were taken from The New Dictionary by Abraham EvenShoshan. "Freedom of speech" -- a regime of liberty, where every person is allowed to express their views publicly, even if they contradict the official view or the views of others, without being subjected to sanction because of said expression. "Fascism" - a system of ideologies and practices that wish to place the nation, defined in biological, cultural and/or historic terms, above all other foci of identification, and create a motivated national community (Kevin Passmore Fascism, a Very Short Introduction, Oxford University Press, 2002). 5. We also wish to comment that we tried as much as possible to avoid relying on the definitions that appear on the website "Wikipedia -- the free encyclopedia," considering the recent press reports ("Haaretz," May 14, 2010), that you take exception to some of the definitions appearing therein, at least when it comes to definitions related to your movement. It was also reported in that article that even your unequivocal demand to change the definitions of the movement so that they accord with the definitions your client wishes to appropriate for itself was accompanied by a threat, albeit implicit, of a legal suit in the matter. We will return to this later in our response. On the freedom to express opinions in a democratic state 6. I hereby inform you that our client completely rejects your demands in your letter. 7. The involvement you ascribe to our client in the Facebook group, inasmuch as it exists, constitutes a legitimate and legal use of his right to the freedom of expression afforded to him in a country whose regime is democratic. The attempt by your client, through you, to intimidate anyone who criticizes it is an anti-democratic act that gravely violates the right to freedom of expression. 8. The public discourse in Israel is sharp and stems from the gravity of the issues at hand. The use of the phrase "fascism" in its various conjugations and of even harsher terms attributed to individuals and movements perceived by their critics as undemocratic is not rare. The attempt to silence that criticism only reinforces the critic's justification for using such phrases. 9. Therefore, while sending libel threats to the whole world and trying to eliminate criticism, it is advisable that your client contend with the tools and funds at its disposal (and they are plentiful) with the content and substance

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of the criticism of it. Your client has proved it has the necessary ties to expose its positions and studies to the point that any nonsense it issues turns into an "investigative report" and "exposure." It is hard to claim your client suffers from the inability to voice its views and response to the criticism of it to the public. Actually, the contrary is true. I would like to add that my client is not deterred by the threats made in your letter as to moving the discussion to court. Not at all. It is possible that in light of your client's exception to the external definition of the Im Tirzu association, whether as part of Wikipedia or as part of the Facebook group "Im Tirzu a fascist movement," the courts of the state of Israel may have to decide on the issue, including hearing experts on fascism and fascist movements in Israel and the world, including a demand to review your client's internal documents. My client, along with substantial parts of the Israeli public, will be the first to welcome that, while continuing the public discourse, which my client has no intention of stopping. Finally, my client rejects, with due respect, your baseless and shameless demand to make any apology, as detailed in your letter. My client also rejects every claim presented in your letter, as if your client suffered any damage, whether monetary or not monetary, because of my client's freedom of speech and freedom of thought, as expressed, inasmuch as it was expressed at all, as part of the Facebook group "Im Tirzu a fascist movement." I would like to take this opportunity to express my regret for the delay in sending this reply on behalf of my client, caused by a heavy workload for organizations, some of which are subsidized by the New Israel Fund. Naturally, it goes without saying, that the contents of this letter or anything that does not appear therein do not constitute confirmation and/or agreement, explicit or implicit, with anything claimed or implied in your letter, and my client reserves the right to argue against those claims in any legal procedure and/or any other forum he sees fit.

Sincerely, Michael Sfard, Adv. Shlomi Zachary, Adv.