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COMES NOW, Matthew Chan, as Respondent, declares to the Court the as follows:
1. I am the Respondent in this case. In the original hearing, I chose to represent myself "pro se"
in this Court and I continue to represent myself now.
2. This Declaration may come as a "surprise" because it comes at a relatively late date.
However, I wanted to take the time to think and reflect carefully before I submitted this
Declaration. I have no desire to burden this court with any more pleadings, communications,
or submissions unless absolutely necessary.
3. The purpose of this Declaration is to serve the "greater good" by including it as part of the
court record. I take no joy in filing this Declaration but feel it is necessary. Over the last few
months, I have gone back and forth in my mind whether I should file this Declaration.
Ultimately, I have done so because I have learned that no one will ever advocate or represent
me as passionately or determinedly as I would for myself. If I do not speak for myself on the
matters herein then no one else will. Given the two-plus years that my supporters and I have

devoted in time, energy, money, publicity, and other resources on my behalf, I want to
address residual issues and matters of concern that have arisen during the "aftermath" period.
4. Because I continue to live and work in the jurisdiction of this Court, I have a strong vested
interest in ensuring that every court views me fairly and credibly in any possible hearings in
the future (related or unrelated to this case) and not let any possible bias, animosity, or ill will
from this case negatively affect me or unfairly taint my reputation in any possible court
matters in the future. I don't expect favoritism but I strongly desire and request that any court
be fair and respectful to me in the future whether I choose to represent myself "pro se" or
through counsel I may retain.
5. I was vigorous and passionate in my own defense at the evidentiary hearing (as well as
through two appellate courts and the court of public opinion) and I continue to hold high
respect and regard for all courts. Despite my strong disagreement with the Court's original
ruling and the subsequent protective order that was issued against me, I believe that the Court
was well-intentioned. I believe that because I was not a trained lawyer and chose to represent
myself "pro se," that it contributed to the ruling against me. To what degree, I may never
know. Certainly, in reviewing the court record many times, I feel strongly that I made errors
and did an inadequate job in presenting my case in certain parts. Indisputably, I was less
educated with legal procedure than opposing counsel but I believe the Court knows I did my
best while being respectful to the Court. I have had considerable time to relive, reflect, study,
and analyze the circumstances up to the hearing of my case.
6. One of my larger concerns I want to express in this Declaration is the fact that opposing
counsel, Elizabeth W. McBride is married to Judge Gil McBride, a Superior Court Judge. I
want to be clear that I have never met Judge McBride and have no feelings or impressions of

him one way or another. I did not know at the time of the original 2013 evidentiary hearing
that Ms. McBride was related to, much less married to Judge McBride. I never made the
connection although I had heard of Judge McBride's name prior. This was a point of surprise
and speculative discussion amongst my supporters when we later discovered this
relationship. Some of us were concerned that Ms. McBride's spousal connection to Judge
McBride might have had a subtle influence on the Court in this case. Let me be clear, there
is no evidence that the Court was ever influenced by this. I make no accusations of
anyone that Judge McBride or his spousal relationship to Ms. McBride had any
influence whatsoever on the Court in my case. However, I think it is reasonable that
outside observers might speculate and wonder if cases Ms. McBride represents and wins in
this Court will be entirely based on the merits and not her spousal relationship to Judge
McBride especially given the relatively small number of Superior Court judges that serve the
Columbus/Muscogee County area.
7. Prior to this case, I was already an avid supporter, advocate, and well-informed in matters of
free speech and the First Amendment especially as it relates to the Internet. In particular, it is
one reason that I chose to represent myself without a lawyer. I did not have the belief or
confidence that I could easily find a sufficiently qualified lawyer locally that would
passionately assert or argue my First Amendment rights or my rights as a website owner and
discussion forum provider under Section 230 of the Communications Decency Act. Further, I
did not have the confidence that any local lawyer would take the time to truly understand or
sufficiently explain the intricacies, operations, context, style, and culture of my website, (ELI) and its online community.

I want to recap the pertinent facts, events, and circumstances leading to this Declaration:
1. On February 13, 2013, Petitioner Linda Ellis, sought and was granted by the Court a
Stalking Ex Parte Temporary Protective Order against me, Respondent Matthew Chan. A
hearing was then scheduled for February 28, 2013.
2. The hearing did occur on February 28, 2013 as scheduled. Ms. Ellis was represented by
opposing counsel, Elizabeth W. McBride, and I represented myself "pro se."
3. Ms. Ellis, through her counsel, sought a Stalking Protective Order against me. I, as "pro se"
Respondent, vigorously and passionately defended my position by asserting that I never
contacted or stalked Ms. Ellis under O.C.G.A. 16-5-90. But even if the Court concluded that
I had contacted Ms. Ellis under said statute, I argued that my speech fell well within the
scope of the First Amendment and did not constitute stalking. Ms. Ellis, through her
counsel, attempted to place responsibility of forum posts I had not written upon me based on
the flawed and incorrect argument that because I was able to delete the forum posts and
chose not to do so, as equivalent to me endorsing or authoring the content of said forum
posts. I asserted 47 U.S.C. 230 (Section 230 of the Communications Decency Act of 1996):
"No provider or user of an interactive computer service shall be treated as the
publisher or speaker of any information provided by another information content
provider." This federal law preempts any state laws to the contrary: "[n]o cause of action
may be brought and no liability may be imposed under any State or local law that is
inconsistent with this section."

In simpler terms, the author of any forum post is only responsible for what he writes and no
one else. This has been and continues to be well supported in state and federal cases
throughout the U.S.
4. Although I acknowledge that the Court has no responsibility of what other lawyers have said
to me or about me in the past or might say to me in the future, I want to inform the Court of a

particularly shocking and appalling incident that occurred during an afternoon break of the
2013 hearing. The Court might recall that I openly complained that I, as an untrained nonlawyer, knew sufficiently enough to produce three sets of exhibits (one for myself, one for
the Court, and one for opposing counsel) yet Ms. McBride, a trained, professional lawyer in
good standing, did not have the respect or professional courtesy to provide me (a "pro se"
defendant), not one extra copy of ANY exhibit during the hearing. Not one. During one of
the afternoon breaks, a female lawyer whom I did not know or ever met before openly
said to me That is what you get for not hiring a lawyer. This unsolicited and open
statement directed at me was shocking, appalling, and entitled. Every citizen has the right to
represent themselves "pro se" and expect to be treated fairly, respectfully, and professionally
by opposing counsel and any court. What this says to me is that there is at least one
practicing lawyer (perhaps many others) in Columbus/Muscogee County that has a general
disdain and disrespect towards pro se litigants such as myself. On behalf of myself and all
future "pro se" litigants, I respectfully request this court to consider that in any future
hearings that the simple professional courtesy of additional copies of exhibits for opposing
"pro se" litigants be enforced. This is not a controversial or unreasonable request especially
since most opposing counsel themselves would insist that they receive the same.
5. Coming into any hearing before the Court, practicing lawyers in good standing already have
a substantial "natural advantage" over any untrained non-lawyer pro se litigants such as
myself. Given this substantial natural advantage, I assert that opposing counsel, Ms.
McBride, was unprofessional and took unfair advantage of me and my "pro se" status during
the February 28, 2013 hearing by not providing me ANY copies of ANY exhibits even when
requested. In fact, because of her "natural advantage" as a lawyer in good standing, she had a

duty to exercise extra caution and act fairly towards me as a "pro se" defendant. Taking
unfair advantage of a "pro se" litigant can result in unintended consequences. In my view, she
wasn't "doing her job". She cheated and deprived my rightful ability to easily reference those
exhibits used against me. And yet, she sat with copies of all my exhibits conveniently in her
possession that she could refer to anytime during and after the hearing. I was forced to rely
on my memory and brief notes I made during one of the breaks.
6. While Ms. McBride can make the argument that she could not immediately leave the
courtroom to provide me copies of any court exhibits, the Court amply provided her at least
two substantial breaks for her to correct this alleged "oversight". Despite my open complaints
in court (which are in the transcript), she chose not to do so. For this, I do not blame her
client, Ms. Ellis, for this. I place full responsibility and blame upon Ms. McBride. She is a
lawyer in good standing and has practiced law for many years. She is not a newcomer to
courtroom procedure. She knows better and she deliberately cheated to gain unfair
advantage against me.
7. Further, there is no good argument that she can make for not providing copies of the exhibits
to me AFTER the hearing. I reached out to her several times by phone and email (Exhibits A
& B). She was nonresponsive and completely ignored me. Her actions (or lack thereof) were
willful, irresponsible, unprofessional, and unfair. It greatly delayed and hurt my (and my
lawyers') efforts to properly evaluate my appellate position for many months. My grievance
and complaints against Ms. McBride might be beyond this Court's jurisdiction but
nonetheless I state this here and document it for the record.
8. During the days and weeks following the hearing, I sought and received legal advice of
whether I should appeal my case or not. I felt that most appellate cases are generally costly,

uphill battles where lower court decisions are often upheld. I was fully aware of this and it
was told to me by my appellate lawyers. For any appellate lawyer to fairly evaluate my case,
he would need to see the evidence (exhibits) that was used against me. However, I did not
have them due to Ms. McBride's disregard, disrespect, and professional misconduct towards
me as "pro se" defendant.
9. Shortly after the original hearing, I (still acting in pro se capacity) attempted to contact Ms.
McBride four times. Twice by telephone (when I left voice messages with her assistant) and
twice by email (Exhibits A & B) I tried to retrieve a draft copy of the final protective order
and copies of Ms. Ellis' court exhibits. I also inquired as to whether or not she wanted to
jointly order the court transcript. She was nonresponsive and ignored me every time.
10. Although the Court announced a general ruling at the conclusion of the 2013 hearing, I had
no specific instructions and the order had not been immediately written. As such, I, as pro
se defendant, appropriately sought to inform and advise Ms. McBride to write an
appropriate and reasonable order that was not overbroad and one that would not likely result
in an appeal filed against her client. I clearly did not want a protective order issued against
me but, if necessary, I was prepared to accept a minimal protective order as a compromise. I
wanted to make sure that any court order against me was fair, reasonable, lawful, and
constitutional. Unfortunately, the final order as written by Ms. McBride and issued by the
Court on March 6, 2013 was not. This was not only my opinion. It was the opinion of many
lawyers (including First Amendment legal scholars) which greatly influenced me to initiate
the appellate process against Ms. Ellis.
11. As I stated, Ms. McBride had the responsibility to ensure that a reasonable and fair court
order was written as to not compel me to appeal the case against Ms. Ellis. That would result

in unnecessary legal cost and expense for both me and her client. It would not surprise me if
Ms. Ellis has since become unhappy with Ms. McBride. Ms. McBrides poor and
unprofessional choice to ignore my requests to see her draft of the protective order and deny
me copies of the exhibits unnecessarily harmed not only me but also Ms. Ellis, her client. Ms.
Ellis did not have the legal education, background, or experience to understand the negative
ramifications of Ms. McBride's poor choices and actions. Unlike Ms. Ellis, I am far more
informed on such matters. I understand the consequences of Ms. McBride's poor choices. I
assert and make the complaint that Ms. McBride forced both her client and me into an
unnecessary and costly appellate case which cost both sides several thousands of dollars in
legal fees, costs, and expenses in addition to lost time and energy. Although I ultimately
prevailed in appellate court, it was all so unnecessary and could have entirely been avoided
had Ms. McBride simply handled her client's case more responsibly. I cannot place blame
upon Ms. Ellis in this instance. I blame Ms. McBride.
12. An interesting anecdote I want to share is that on October 7, 2014, in the Supreme Court
building where I was represented by three lawyers, Ms. McBride twice approached and
attempted to communicate with me directly. It seemed to be an unusual action to take.
Once, she called out to me when I was walking from the sidewalk to the entrance of the
Supreme Court building. I briefly glanced at her and then ignored her. The second time, I
was standing and conversing with my five out-of-state friends/supporters (who traveled to
Atlanta to meet me and watch oral argument) in a waiting area. She approached me (us) and
asked, "Are you with the Chan v. Ellis case?" I was clearly standing there and she
recognized me earlier. She also asked if one of us was Oscar Michelen. This was a
disingenuous question as Mr. Michelen's photo has been and continues to be prominently

displayed on the ELI website for seven years. It is ironic that when I wasn't represented by
any counsel that she would not respond to or communicate with me in any fashion. But
somehow at the Supreme Court, she felt the strange inclination to try to communicate with
me twice despite the fact that I made efforts to physically avoid both her and Ms. Ellis. The
time for Ms. McBride to speak with me was during March 2013, not when we finally arrived
in the highest court in the state for oral argument a year and a half later.
13. Ms. McBride also had the responsibility to vet her clients exhibits to ensure they were true,
authentic, and representative of the actual forum posts and not let her client submit altered,
modified, or obscured exhibits mislead or deceive the Court. I have since discovered that
several exhibits shown to the Court were not true, authentic, or representative of the
actual forum posts.
14. The point of my presenting "new" exhibits now is not meant as a "retrial". It is meant to
inform the Court and place into the record that the original exhibits presented in the original
hearing were not true, accurate, or representative. I had always been bothered by the poor
quality of Ms. Ellis' original exhibits. I never understood why Ms. Ellis presented such
extremely poor, distorted, cropped, and marked up exhibits. Conversely, I presented to the
Court very "clean", organized, and easily readable exhibits. It was only after the Supreme
Court reversed the order on March 27, 2015 and Ms. Ellis' continued to make defamatory
public statements about me in the media and press as a "stalker" and "cyberstalker"
did I finally feel compelled to go into the forum archives (hidden from public view) and
personally review every single exhibit she submitted against me at its original online source.
I was informed very early on by my appellate lawyers that no new evidence could be
submitted during the appellate process. Thus, no matter how poor quality or cropped the

original exhibits were, they were the only ones allowed to be discussed and referenced in
appellate briefs. I did not like that but I respected the rules. It would be two years later in
April 2015 (after Ms. Ellis' public defamatory statements against me would not cease) that I
finally decided to compare and analyze Ms. Ellis' poor-quality exhibits with the original
source material online.
15. Although I prevailed in the Supreme Court, there were still matters of public perception and
my online reputation I wanted to rectify. Ms. Ellis seemed determined to defame me and my
reputation even after the Supreme Court decision. There is no denying that my own writings
in prior forum posts and one video don't paint me in a flattering light. I (along with my
supporters) became very unhappy with Ms. Ellis' continued online antics of taking my words
entirely out-of-context and distorting the actual meanings. Because Ms. Ellis used such
tactics publicly as her primary weapon against me to damage my online reputation, I had to
discover for myself how far she took it with the original court exhibits. What I discovered in
the forum archives when compared to her court exhibits was upsetting to me.
16. In Exhibit C, my comment about Ms. Ellis being "dead right" seems to stand alone.
However, my comment is actually an open response to April Brown's comment from June
23, 2012 which was cropped out of the court exhibit and not at all directed to Ms. Ellis. The
cropping and omission was not an accident.
17. In Exhibit D, the court exhibit implies that April Brown embedded the "death" lyrics of the
"Hearse Song" in the forum post. And yet the actual forum post (below the court exhibit
version), never had any "death lyrics" whatsoever. It was simply a lone posting of a "Hearse
Song" YouTube video. I included the follow-up post to the YouTube video which clearly


shows April Brown's comments that have NOTHING to do with death or violence. The
addition of the "death lyrics" was intentional.
18. In Exhibit E, I provide the first three never-before-shown posts of "Ellis Get Ready We
Are Coming After You!" as the originating context for that thread of discussion. Ms. Ellis
emphasized (through an oval mark) that boisterous topic title. And yet, if the Court reads the
first three posts, it has to do with April Brown's moral outrage over Kalka & Baer's (Ms.
Ellis' attorneys) $100,000 demand letter issued on behalf of Ms. Ellis to a book author over
an unknowing sharing of her poem. Part of the argument for my position in my appeal was
that the Court was unable to fully view the true and full context of the exhibits because what
Ms. Ellis presented was cropped, modified, obscured, or out-of-context.
19. In Exhibit F, Ms. Ellis presented her exhibit as if it were "current" as of the February 28,
2013 hearing that ELI user, Robert Krausankas, posted a photo of her home and Ms.
McBride implied that it was still online. And yet in the forum archives, the full post shows
that as of January 17, 2013, Mr. Krausankas modified the post to display only the
hyperlink, not the photo. In other words, on February 13, 2013 when Ms. Ellis applied for
the Ex-Parte Temporary Protective Order, she made the false statement in her petition that
the photo of her home was still being posted online, when in fact, as of January 17, 2013,
Mr. Krausankas had already removed the Google Street View photo of her home of his
own accord! At the February 28, 2013 hearing, Ms. Ellis and Ms. McBride again made the
false assertion that the photo of her home was still being shown online for the purpose of
threatening Ms. Ellis. It was not. The Court was mislead. The full, uncropped forum post
clearly shows that Mr. Krausankas was illustrating what Ms. Ellis publicly reported to the
State of Georgia as the address of her daycare center business (Kindercare Learning


Centers)! Mr. Krausankas did not post the photo to "threaten" Ms. Ellis in any way. Ms.
McBride irresponsibly echoed Ms. Ellis false assertions and helped perpetrate a lie without
checking online for herself her client's "exhibits" prior to the hearing.
20. The four exhibits (Exhibits C through F), are more than sufficient to illustrate my points. I
was both foolish and nave to assume that any forum posts Ms. Ellis would show to the Court
would be complete and in its full context. I never suspected that she would submit such
extremely altered, modified, and obscured forum posts. Nor did I suspect that Ms. McBride
would not vet her client to ensure that the exhibits provided were in fact true, authentic, and
representative of the actual posts. As an inexperienced non-lawyer, I did not request from the
Court that Ms. Ellis show and display the full forum discussions in its proper context and that
it be printed out for all parties to review and scrutinize. Nor did I ask the Court to instruct
Ms. Ellis to go online while in court to confirm the accuracy of their exhibits. Ironically
enough, the "affidavit" submitted by Seattle lawyer, Timothy B. McCormack (which I fought
to have put aside), provided the "cleanest", most readable, and unaltered versions of forum
posts (although they were still isolated from the fuller context of online discussion.)
21. Another significant factor that influenced my decision to submit this Declaration is that my
appellate lawyer, Oscar Michelen, felt compelled (with my authorization) to send Ms. Ellis a
Cease-and-Desist Letter (Exhibit G) on my behalf on April 13, 2015. This letter speaks for
itself. It was written to clearly inform and put Ms. Ellis on notice that we would not stand
idly by while she continued to publicly and defamatorily refer to me as a "stalker" and
"cyberstalker" when the legal matter of whether I "stalked" her was ruled and settled
unanimously in my favor by all seven Justices of the Supreme Court.


22. During the trial, through my own oversight, I never presented the 18 testimonial letters
(Exhibit H) written on my behalf. These testimonials letters come from supporters
throughout the U.S. and even internationally such as Israel, Canada, and Australia. You will
find that these letters are from intelligent, well-informed individuals who were witness to me,
ELI, and online discussions about Ms. Ellis. I present them now as part of the overall record.

IN CONCLUSION, barring any unexpected developments or follow-up responses by Ms.

Ellis or Ms. McBride, I consider this Declaration my capstone statement on the matter with this
Court. After everything I have seen and experienced, Ms. McBride and Ms. Ellis have proven
to be dishonorable and untrustworthy. I (along with my supporters) remain vigilant and keep
a watchful eye of signs they might falsely attack me or my reputation again. If that happens, I
will once again be compelled to vigorously defend myself as I did before.
At this juncture, I do not request anything from this Court except to respectfully consider
and take into account everything I have written in this Declaration. No one can change or undo
the past but perhaps others can learn and benefit from this case by being informed and cognizant
that things are not always what they appear to be. I have learned much from the last 2.5 years.
This case has been an educational and life-changing experience I will never forget and hope to
never repeat.
This 14th day of August, 2015.
Respectfully submitted,

Matthew Chan, PRO SE

P.O. BOX 6391
Phone: (762) 359-0425


This is to certify that I have this day served RESPONDENTS DECLARATION

PROFESSIONAL MISCONDUCT by filing the same through U.S. Postal Service First Class
Mail to the following attorneys of record:
Elizabeth W. McBride
P.O. BOX 1199

This the 14th day of August, 2015.

Respectfully Submitted,

Matthew Chan, PRO SE

P.O. Box 6391
Columbus, GA 31917
Phone: (762) 359-0425


Exhibit A
Subject:PPO: Ellis v. Chan
Date:Fri, 08 Mar 2013 15:17:21 -0500
From:* Matthew Chan * <>
To:Elizabeth McBride <>
Ms. McBride,
I have been in touch with Sally at Judge Jordan's office today to find
out when the order was signed and to follow-up on the court transcript
matter. The last I heard was in the courtroom when Judge Jordan proposed
you wrote the language of the PPO for him to sign off on.
As the defendant, I'm not fond of having this PPO served upon me but I
am respectful of the court and have proactively taken steps to comply in
the absence of an actual PPO. I trust if you speak to your client, Ms.
Ellis, she can attest to this. In fact, I believe I am going way beyond
what the PPO might call for regarding Ms. Ellis but I'm not really sure
without seeing the actual signed PPO.
As a lawyer for myself (PRO SE), if you have drafted the PPO or already
received the judge's signed PPO, I respectfully request that you email
me, fax me, or mail it to me within the next 2 business days so I can
review it. I respect that you have a busy schedule serving multiple
clients. Given that, I trust that is NOT an unreasonable request on my
part. If I am incorrect, please don't hesitate to let me know. It is my
intention to have a cordial relationship with you.
Even if I were not the defendant, if I were a lawyer, I would make that
reasonable request to get the PPO to prepare any client so that he
complied properly and NOT inadvertently violate the terms of the court's
PPO. After all, everyone is best served if everyone is in compliance and
following the rules, right?
I'm not sure what the proper communication protocol is but perhaps I
should NOT be using email and communicate via letterhead using snail
mail or faxing a letter to you.
I called your office earlier to confirm that I am using the correct
email address: I have copied your assistant, Ms. Lunford,
in case you are out of office or otherwise unavailable.
Thank you.
Matthew Chan, PRO SE

Exhibit B

Subject:Shared Transcript Expense: Ellis v. Chan

Date:Thu, 07 Mar 2013 16:00:08 -0500
From:* Matthew Chan * <>
To:Elizabeth McBride <>

Hello Ms. McBride,

I've called Judge Jordan's office twice and left a couple of messages for Kathy Bostic (our court reporter) to let
me know how much a copy of our court transcript might be for the Ellis v. Chan case. I understand Ms. Bostic
stays pretty busy and it might take a little while to get a copy of a court transcript.
At our hearing, the court mentioned that it was a shared expense if we both wanted a copy. As you know, when
asked if I was interested in my half of the court transcript, I did answer in open court that I was interested in
sharing expenses with you on the court transcript. I am guessing because our hearing went for so long, it is
going to be an expensive court transcript.
If you happen to be in communication with Ms. Bostic, maybe you can find out her timeline for when you and I
can get a transcript.
In the meantime, can you please provide me with copies of the exhibits you used at the hearing?

My mailing address is:

Matthew Chan
1639 Bradley Park Dr. #500
PMB 110
Columbus, GA 31904
Thank you.
Matthew Chan, PRO SE

Exhibit C

Exhibit submitted in court.

The actual forum post included context of my remark. Note that my comment on Ms. Ellis being "dead" right was
actually an open response to April Brown's comment from June 23, 2012.

Exhibit D

Court exhibit contained superimposed "death" lyrics

The actual post only had "Hearse Song" YouTube video & no "death" lyrics. Read follow-up comment for true context.

Exhibit E

The first three posts of "Ellis Get Ready WE are Coming After You" discussion thread was part of the lead up to the
"Hearse Song" YouTube video that Ms. Ellis considered a "death threat". The originating discussion thread clearly
shows no physical or death threat, nor did I originate the discussion.

Exhibit F

Exhibit submitted on February 28, 2013 as being "current" now discovered as untrue.

Actual Screenshot from May 2015 (since January 17, 2013 had no photo of her house, only a link to Google Maps). The
purpose of showing the home was to illustrate what Ms. Ellis reported as a daycare center, not to "threaten" her.



Hi Matthew,
I've been asked why, as a poet, I would be active in ELI forums which deal
with copyright trolling and in particular the effort to expose Linda Ellis, a
fellow poet.
Here's my answer:
Just as the activities of some used car dealers have damaged the
reputation of all used car dealers, Linda Ellis' inhuman activities of trolling
innocent non-profit users of her poem, "The Dash", is affecting the
reputation of today's poets.
I specialize in bereavement poetry, and as I visit funeral homes and attend
their trade conventions, I have come to realize the damage she is doing to
poetry as well as to other poets, Because of her many letters to funeral
directors asking for huge sums of money for putting her poem (at the
request of a family) on a funeral program, many are very cautious of using
poetry on their programs. At a recent C.A.N.A. Symposium I had one
funeral director tell me that because of the letter received by a fellow
funeral director friend, demanding money for using The Dash poem, they
no longer use poetry on their programs for the fear of being sued.
I can certainly understand one's desire and efforts to protect their
literary works from those who would use it for profit or gain, but to go after
the innocent who merely use it because it gives them comfort is so wrong.
It's that very kind of use that will give that work greater popularity, and
increase the chances of it being picked up for commercial use, bringing
royalties to the author. I encourage people to use my writings for their own
personal use.
Poetry has a way of bringing comfort and hope to those who have lost one
dear to them. I have received hundreds of emails from people who have
written to tell me how much they appreciated one of my poems at their
time of loss.

If Ms. Ellis feels so strongly about what she considers illegal use of one of
her poems, she should send a letter asking them to refrain from further use
without permission. Instead she sends letters demanding huge amounts of
money from these good people who have posted one of her poems on
their website, or ask for it to be printed in a funeral program, or who have
simply shared it in an email to a grieving friend because they think it is
beautifully written and will comfort them.
It is obvious to me that her poem, "The Dash" was not written from her
heart because her actions so contradict the beautiful writing in the poem.
Her interest in her works appears to be strictly money.
Linda Ellis has damaged her reputation, and is damaging the reputation
and livelihood of other poets by her outrageous activities against good
people, and I am doing what I can to protect the integrity of poetry and
Your ELI site has helped so many of the innocent who have received
letters from Linda, and other copyright extortionists. They need to be
exposed, and good people need to be protected from them.
Thanks for all you do.
Best Regards,

Ron Tranmer
Ron Tranmer Poetry




In 2012, I connected with Matthew Chan, moderator of the website, Extortion Letter
Info. Com, after being targeted by Lindas Lyrics for copyright extortion.
I run a funeral event planning and support service in Sydney, Australia. At the time, I
had a list of suitable poems that could be read at funerals, one of these was the
Linda Ellis poem The Dash. At no time was I aware there was a strict copyright
issue with this poem. I first received my copyright extortion letter in July 2012 from
Lindas Lyrics, citing breach of copyright for showing this poem on my website. The
letter said in words to the effect that removal of the poem is not enough, there is
also damages to consider with a fee of $7500 payable. Understandably I was
upset to receive such a letter, but common sense also prompted me to check the
validity of the letter, because it was received by email and not post. This is when I
first became aware of the Linda Ellis copyright extortion scam through the Extortion
Letter Info website.
Whilst I have full respect for copyright and agree that Linda Lyrics has the right to
protect that copyright, I absolutely do not believe that The Dash is worth $7500.
Particularly when it is a clear cut case of innocent infringement. A cease and
desist letter would have been the right, and ethical, approach. It would appear
that I am not alone in this deliberation as thousands of other letter recipients seem to
have the same viewpoint. Linda Ellis shows no remorse in her targets, relentlessly
attempting to extort money from funeral homes, schools, charities, religious entities
and even members of the general public. I firmly believe this makes Linda Ellis and
her associates objects for scrutiny & criticism in the public domain.
In my opinion, Matthew is extremely knowledgeable on the subject of copyright
extortion. He does a worthy job of promoting awareness to prevent more victims of
extortion - clearly showing dedication, integrity and a strong sense of empathy. His
website, and the discussion forums therein, are informative and well researched.
Matthews expertise enabled me to make decisions on how to handle my dealings
with Lindas Lyrics.
It is with great confidence that I commend his character, both personally and
Kind Regards,

Nicole Olson
Emerald Creative Funeral Support Services

David Price
2460 Hover Drive
Castle Rock, CO 80104
February 21, 2013
Honorable Frank J. Jordan, Jr.
Judge of Superior Courts
Government Center
P.O. Box 1340
Columbus, GA 31902-1340
Re: Civil Action File No. SUI3DM409 Linda Ellis v. Matthew Chan
Your Honor:
The purpose of this letter is to express my support for Matthew Chan and to express my desire that you deny
Linda Elliss request for a Stalking Protective Order.
I first came in contact with Matthew Chan approximately a year ago when I was researching the actions Linda
Ellis was taking to extract settlements from those who had allegedly violated her copyright of The Dash
Poem. My research brought me to (ELI), a site founded by Mr. Chan. I found the
site to be a tremendous source of information for people dealing with corporations and individuals aggressively
(or over-aggressively, in my opinion) defending the rights associated with their copyrights.
I know the question on the table today between Mr. Chan and Mrs. Ellis is not about copyright law, so I will not
burden you with my opinion on the tactics used by Mrs. Ellis.
I do want to express my belief that Mr. Chan represents absolutely no threat to Mrs. Ellis (or anyone else) that
warrants a Protective Order. This is based on my multiple interactions with Mr. Chan via email and telephone
over the past year. In fact, I have observed Mr. Chan being the voice of calm and reason in emotionally charged
situations multiple times in the last year.
The internet is a disruptive technology. The history of disruptive technologies teaches us that regulations and
laws cannot change at the same space as technology. This results in periods of time when existing regulations
and laws do not adequately perform their function and need to be updated. While I have no doubt that our
copyright laws will eventually be modified, it is sites like ELI that provide an invaluable service to those that
find themselves inadequately protected by existing regulations and laws. Mr. Chan is doing society a service
with ELI and should be commended for the content and community and activism he has created.
While Mr. Chan is a vigorous advocate for his point of view and his advocacy of his beliefs is no doubt an
annoyance to those who disagree with him, my experience has been that his actions are thoughtful and legal, his
character is strong, and he has exceptionally high integrity.
Mrs. Elliss request for a Protective Order is, in my opinion, without merit, a waste of scarce judicial resources,
and should be denied. Thank you for taking time to read this.

David V. Price

To Whom It May Concern,

I am writing today in support of Matthew Chan. In 2009 when I was faced with a copyright "demand" letter from Getty Images, I discovered his site,
(ELI). It's a community and support group for people that have been hit with copyright
claims that are disproportionate to the damages. With his help and the help of others on
the site, I was able to formulate a response that got the legal representatives for Getty
Images to leave me alone. Over the last several years I have come to know him and
consider him a friend. I have also continued to participate in the ELI community. is a clearinghouse of useful and constructive information about
the practice of copyright trolling and how one might defend against an extortionate
claim. That is why people involved in copyright trolling go out of their way to find ways to
shut the site down.
I'm not going to spend too much time in this letter pointing out the ridiculous claims of
stalking. I trust the court will see through this. What I would hope the court would do is
find a way to penalize Ms Ellis for wasting both Matthew Chan's and the court's time.
I do not know Linda Ellis. However, over the course of the last few years her practice of
seeking outrageous fees for infringing on her sing-song poem, The Dash, have become
quite well known. Hundreds of people internationally have been hit with letters demanding thousands of dollars.
Here are some actions that I understand have been taken by Linda Ellis or her agents:
The extortionate nature of her business was originally exposed by a member of
Matthew's site, April Brown. Linda issued a bogus DMCA complaint and had Ms
Brown's entire YouTube account taken down.
I'm told Linda Ellis complained about April Brown to her husband's employer.
Linda Ellis issued a DMCA takedown notice to Matthew's Scribd account regarding a document shared for commentary. When Matthew disputed this
claim, Ms Ellis did not counter.

Motion City

1424 4th Street, #604, Santa Monica, CA 90401

T 310.434.1272

Linda Ellis complained to Matthew's previous ISP about the same issue she
presents to the court. His ISP did not want to get involved and this led to Matthew having to migrate the site to a new host.
She now is attempting to pursued the court that Matthew Chan is "stalking" her
when they have never met and Matthew has never threatened her.
It is my opinion that Linda Ellis is trying to use the court to attempt to stifle free speech. I
hope that Matthew will request reimbursement for his time, expenses, and fees for defending against this frivolous action. I hope the court will see fit to grant that. The only
way to curtail people from tying up the judicial system is to send a clear message that
such frivolity has a cost.
Thank you,

Jerry Witt
Motion City Films
1424 4th Street #604
Santa Monica, CA 90401

Motion City

1424 4th Street, #604, Santa Monica, CA 90401

T 310.434.1272

Yeah, We Do That.
3023 Ash Court
Mason, Ohio 45040-1400
Gregory A. Troy

(513) 544-7069

To Matthew,
I want to extend my sincere thanks for all that you do through the
(ELI) website. I know when I received my extortion letter from Getty Images a year ago, I was
panicked and fearful of an imminent and impending lawsuit which is what these types of letters
are designed to do. I had absolutely no idea what to do and my first reaction was trying to figure
out how I was going to pay this within the 14-day deadline given to me by Getty. I went online
looking for anything that could assist me and I found your site. As I read it, I started to learn and
understand what was going on and what was happening to me. I ended up posting my story and a
possible plan of action and asked for assistance from the ELI forum members, You, among
others, responded offering support, guidance and help.
Without this site and all you do to educate, inform and assist extortion letter recipients, I truly
believe that so many of us would have simply given up and paid since it would have been
cheaper than trying to retain legal help, which is why unfortunately these letters are so often
successful. I also applaud the stance you have taken in fighting these copyright trolls by exposing
the facts, naming names, and calling it as you see it. While you and everyone on the ELI Forums
firmly believes in and respects the intellectual property rights of artists to protect their works,
you vigorously take to task those who are considered trolls and demand far more than their
product is worth or they could ever hope to be awarded in court.
While your site was set up as a result of receiving a Getty letter yourself and initially designed to
support Getty letter recipients, you realized that there were many other copyright trolls out there
such as Linda Ellis. You extended and offered your support and provided a place for us all to
gather, compare notes, educate ourselves and others. We learned how to defend ourselves from
unjust and inaccurate claims from copyright trolls.
I have seen and read the court documents that Linda Ellis filed against you. As an avid member
of ELI, I make it a point to read every post that is made so that I can stay current and up-to-date
in the fight against copyright trolls. Based on what is in the ELI Forums, I can say that some of
your responses are edgy and colorful. In my opinion, none of them have crossed the line and
there was never any time where you threatened to do physical harm to Linda Ellis, stalk her, her
family, or encourage others on the ELI Forums to do so.
Linda Ellis failed to disrupt the forum from discussing her copyright infringement business
model through complaints to your web hosting provider, which caused ELI to have to move to a
new web hosting provider. She is now grasping at straws trying to find a way to stop ELI from

sharing copies of her settlement demand letters, experiences from those who have received her
letters, and telling the world how she preys upon grieving families and church groups who share
her poem demanding $7,500 from them.
It must be pretty amazing to look back from ELI's humble beginnings to what it has grown into
with close to 1,000 current members and to realize how many people you have helped and
educated over the five-year history of your site. Thank you so much for everything you have
done for me and allowing me to be a part of your site and try to pay it forward by helping new
letter recipients through their initial dark period of fear and uncertainty after receiving a
settlement demand letter. I am so thankful that you and your site are there for us.
My sincere thanks,


Im writing this letter in support of the Extortion Letter Info forums and specifically
Matthew Chan.

In 2011 I briefly shared a poem entitled The Dash on a blog. The author of the poem,
Linda Ellis demanded that I pay her $7500 via an email. To make a long story short,
Linda Ellis has run havoc on my personal and professional life, and specifically my
online accounts. The list of acts and attacks is long. I consider Linda Ellis deceptive,
unethical, and irresponsible and a bully.

Matthew Chan and the Extortion Letter forums (ELI) are instrumental in exposing
the practice of copyright trolling and the people and companies that scour the
Internet looking for copyrighted content. ELI is vital to exposing this horrific abuse
of a loophole in the copyright law. As an example, once The Dash poem is discovered
in an unauthorized post (simply shared with friends, families and associates) Linda
Ellis and John W. Jolin begin a long and high pressure letter writing campaign that
may or may not include the unethical and unlawful practice of filing false DMCA
notices, multiple letters to an employer, letters to clients, and Google ads defaming
the offender. Ellis and Jolin use a variety of scare tactics and misrepresentations to
collect all devises outlawed by bill collectors. is the only resource that specifically supports victims of the
Linda Ellis scheme for extracting money with her aggressive and intimidating letter
writing campaign. Victims document these actions on the ELI forum. This
information is an essential resource for attorneys and individuals who wish to
prepare a defense. Members share satire, legal documents, analysis and first hand
accounts of the intimidating tactics John W. Jolin and Linda Ellis initiate. These
public disclosures monitor and memorialize the extortion activity and help
members prepare for and respond too the attacks to their online accounts and other

I applaud Matthew Chan and the members of ELI for their honesty, diligence and
professionalism. The Eli community is transparent, truthful and investigative and
shining a very bright light on this injustice.


April Brown, CEO Charity Auction World

michaels,rossand cole ltd.


lL 60148

I wantedto takea
in yourforum,hostedat,
Asan avidreaderandparticipant
few momentsto thankyoufor whatyou haveputtogether.
I havebeena followerof yoursitefor a littleovera yearnow, I foundELIthrougha googlesearchafter
a verylargesumof moneyfroma largedigitalimagefirm. Yoursite
a letterdemanding
dealof timeandmoneyin dealing
of highlytalentedindividuals
a community
Withyoursite,I havediscovered
the wrongs
- otherwise
knownon the internetascopyright

to dealwith copyright
A mechanism
to allowoneto gatherthemselves
to deal
boardandplaceto "vent"whennecessary.
A sounding
to dealwith varyingtrollthreats.
A forumto discuss
A creativeoutletthat letspeoplepooltheirthoughtsto developnewstrategies.
A mechanism
thatjustmightinitiatesomelegalreformsin thistroubling

youwill findthat it
Matt,I am certainthat if you lookbackat the evolutionof,
whenyou hasgrownbeyondthe U.S.
doesfar moretodaythanyoueverenvisioned
aroundthe world. Expertattorneys
with contributors
to thingslikeclassactionlawsuits,
geta lot of fulfillment
I knowyouprobably
is niceto knowthattheworkyoudo evenif it is notsomucha moneymaking
Thankyoufromthe bottomof my heart.Andthankyoufor allthoseyouhavehelped
is appreciated.
whatI knowtheyfeel. "Thanks!"
who haven'ttakenthe timeto express


555WatersEdge,suite 120 Lombard,rL 60148 Tet630.916.0662

Fax630.916.0663 www
UK office ArgyteHouse,1 Dee Road,Richmond,surrey,TW9
2JN Ter 070 B:l2z7720

3601 Suffolk Drive San Diego, California 92115 (619) 241-4230

To Whom It May Concern:

Matthew Chan deserves to be publicly commended for his leadership in exposing the
abuse of process that has become an epidemic after the Digital Millennium Copyright Act
left an unbalanced play field between copyright owners and copyright users.
Mr. Chan has spent countless hours creating a forum for the discussion of this growing problem. He has exposed numerous copyright abusers who resort to dirty tricks that
border on extortion in order to intimidate innocent infringers into paying disproportionate sums of money for the use of a copyrighted work. He has provided many people with
legitimate resources to defend themselves from legal thugs who pretend to be defending
copyrights but are in fact just trolling for cash settlements based on "strategic litigation."
It has always been clear that the forum is not against copyright owners defending
their rights, but rather against the thuggish intimidation tactics and dishonest claims
made by agents attempting to monetize any infringement and the ridiculous settlement
amounts that these people attempt to extract from innocent infringers.
With regard to Linda Ellis, Matthew Chan has been nothing but honest and upfront
about the ugliness of her business model. She has positioned herself as a World-Class
Copyright Troll and deserves the attention not only from Matthew Chan and ELI but
from anyone else who is concerned about frivolous strategic litigation.
As a very frequent visitor of the ELI forum, I find the notion that Matthew Chan or
anyone has made physical threats to anyone else to be risible. If anyone ever did, Iwould
be the first not to want anything to do with the group. In actuality, Matthew Chan has
played a very balanced role as moderator, sometimes correcting members posts for
accuracy and fair play. The claim that Matthew Chan is stalking anyone borders on the
delusional. Perhaps Ms. Linda Ellis should seek counseling if verbal criticism of her
unethical legal bullying makes her feel physically threatened.
Mr. Chan has worked very hard to provide a public service that helps balance the
play field by educating copyright users and keeping an eye on the unethical practices of
key industrial players. I am personally grateful to Matthew Chan for all of his efforts
putting together this forum and for creating this community, and specifically for shedding
light on the questionable practices of the likes of Ms. Linda Ellis and her copyright thugs.
We need more hard-working and dedicated industry watchdogs like Matthew Chan.

Alberto Zevallos
Owner, Art Zenith

Matthew Chan
1639 Bradley Park Drive
Suite 500, PMB 110
Columbus, GA37904

Dear Matt:
I said on the forum that I'd send you $100 to help you resolve the Linda Ellis


Unfortunately, upon digging deeper into this month's allocated money, things
are tighter around here than I thought so I'm only able to contribute $50 to
your defense fund. I wish we could afford more...
With that said, I appreciate very much everything you've done with ELI to
help me work through my case with Getty Images. Your dynamic personality
and obvious devotion to fighting copyright extortion on your website and
forum has helped people around the world fight the various copyright
extortion and speculative invoicing schernes now'so rampant on the Internet.
Your information on ELI represents one of the few tools individuals have at
their disposal to respond to the lies, threats, and misrepresentations being
sent out by various companies and individuals to twist and pervert copyright
laws and thus enrich themselves with outrageous payment "settlements" paid
by naive and fearful victims.
Because far too many people fall for threats from "fast buck" lawyers and
unscrupulous individuals like Linda Ellis who makes absurd payment
demands for what any judge would label as de minimus use of her lame poem,
The Dash, it's vitally important that you and ELI be allowed to continue your
work, work that I feel is fully protected by the First Amendment.

Sincerely yours,

Slw Mu11,r4a-a,

Submitted by email from on 2/19/2013, 9:02pm

To Whom It May Concern,

I was recently the victim of an attempted $2000 extortion over two small images I used on a free
blog for singers. Upon receiving the letter I immediately found Matthew Chan and his Extortion
Letter Info site.
As a small business owner I am indebted to Matthew Chan and the ELI community. They are
truly providing a service to business owners everywhere who are increasingly being targeted
over innocent infringement.
I know Matthew routinely suffers the wrath of companies and individuals, who have turned the
threats of lawsuits on small business owners into a lucrative profit center.
Linda Ellis in particular has gone after Matthew and the ELI forum. She is obviously not
interested in free speech and the sharing of information as this is damaging to her business model
of financially fleecing churches and bereaved families over innocent infringement of her short
A personal story to illustrate what Matthew is fighting for: A friend put the lyrics of Paul
McCartneys song The End on her mothers headstone. As fate would have it, she met Mr.
McCartney on a flight a few months later. When she told her story he was so touched he
grabbed her hand and asked her to sit with him and talk. This world famous musician was
genuinely moved by what his lyrics meant to my friend in her time of grief. Linda Ellis would
have presented a demand for $7500 to be followed by escalating threats and dollar amounts.
Widows, non-profits, churches, the list of Linda Ellis' victims continues to grow. This is what
Matthew Chan and ELI fight against every day. I, for one, am glad he is there.
John Henny
12722 Riverside Dr., Suite 201
Valley Village CA 91741

On Feb 18, 2013, at 7:46 PM, Vintage Logos <> wrote:

To Whom It May Concern:
Although I have never personally meet Matthew Chan, I can say that he has given me and other
members of the website a way to discuss, vent and learn about the
lawyers, companies and people involved in copyright extortion tactics.
Linda Ellis and her lawyer have contacted a large amount of people with letters written in a form
of extortion and demand payment upon receipt of the letter; For using her copyrighted
material. She is now being called out by the forum because what she is doing is morally wrong
and corrupt. She does not send a cease and desist notice, she DEMANDS payment! People need
to know that they do not need to pay someone just because they say so. It is my first amendment
right and duty to speak up and discuss these issues with everyone willing to listen because I and
others find her ways of using lawyers to extort people for money offensive!
We need more people like Matthew Chan to bring these types of people out into the open. Long
live Liberty.
Shawn P McNamara
Vintage Logos Inc - Custom Drumheads & More
2692 Madison Rd
Suite N1-304
Cincinnati OH 45208-1320
Toll Free USA & Canada

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