Rosenberg Puris Haetzni & Co. law offices April 1, 2010 To: Mr. Roi Yellin Mr. Yuval Yellin Mr. Dror Mizrahi Mr.

Idan Ring Mr. Didi Remez Mr. Noam Livneh Mr. Noam Winner Ms. Tal Niv Sent by e-mail and registered mail Dear Madame and Messrs., Re: Libelous publication On behalf of my client, Im Tirzu, registered association (henceforth: "Im Tirzu"), I hereby address you as follows: Publication of defamation 1. Representatives of my client recently learned that you publish a grave publication on the Internet, on the page of a group with many participants, on a network called Facebook. In the publications of this group you appear and express yourselves, manage the publication and identify yourselves officially as its "administrators" (this platform of publication will henceforth be called: "the page"). 2. On this page, which serves as a platform for many surfers, grave statements have regularly been made recently regarding my client (henceforth: "the publication"). These statements, besides being groundless and baseless, are grave defamation, in its meaning in the Anti-Defamation Act, 1965. 3. Firstly, the following logo has recently appeared on the page regularly: "Im Tirzu – a fascist movement." 4. Also appearing on the page, in its different parts and at different times of publication, are systematic, recurring statements, blaming my client of being a body/movement with "fascist" ideas, characteristics and activities. 5. Furthermore, as far as my client knows, the aforementioned group and page were established a priori on Facebook to lead and promote a campaign of defamation, libel and smearing of my client. All with the purpose of giving my client a bad image, reputation and name as a "fascist movement."

The severity of the defamation 6. The contents of the publications about my client constitute, both in and of themselves and in their overall context and of course inasmuch as can be understood and implied by them, malicious and grave defamation. That defamation has already hurt and could cause my client serious damages in the future, including monetary and reputation damages. 7. The significance of the serious defamation you published about my client cannot be overstated. As you know well, the fascist movement, which grew in the 1920s in Italy, was characterized by a dictatorial, violent, offensive and oppressive nature. As part of the rise of fascism to power personal liberties were canceled, democracy was abolished and the exclusive leader, "the Duce," was elevated to the supreme status. Likewise, the will of the leader was sanctified and democratic conduct was canceled, as were liberty, freedom of expression, parliamentary rule, the rest of the principles of democracy and the good of the individual. 8. More serious yet, the fascist regime in Italy allied with the Nazi regime in Germany and together they persecuted the Jews, sent them to concentration and death camps and perpetrated the Holocaust of European Jewry. So much that in the awareness of any reasonable person, fascism is related inextricably to Nazism, with everything that implies. The distortion and wrong 9. Im Tirzu is a moderate Zionist movement, which started on campuses in Israel and whose goal is to strengthen the values of classic Zionism. 10. Im Tirzu maintains legitimate national activity on the campuses and outside them, investigates various developments and makes its findings public, all in the spirit of the founder of Zionism Binyamin Ze'ev Herzl. 11. There is no connection between Im Tirzu and manifestations and expressions of fascism, to the contrary. Therefore, anyone who insults Im Tirzu, its activists and its activities with charges connected to fascism or its manifestation does so knowingly, maliciously and deliberately. 12. It is also clear that the grave accusations against my client are intended to achieve alien, unfit and grave objectives. Namely, to hurt Im Tirzu, its activity and the reputation it has gained. All in order to blunt the effects of its Zionist activity. 13. The provocation of my client and the deliberate and malicious defamation are clear and obvious from various publications that appear on the aforementioned group's page. 14. Furthermore, it is no accident that you did not bother to address my client and/or its main activists to learn the facts from them and whether there is any connection between its ideas and/or activity and the fascist movement.

15. Therefore the publication you publish constitutes a violation of the provisions of the Anti-Defamation Act, 1965. The wrong entailed by the publication is especially grave in the light of the malice embodied by the publication, as well as the essence and nature of Im Tirzu. The grave harm to Im Tirzu 16. The grave defamation you committed and continue to commit all the time is already having its pernicious effect. This is evident first of all from the group page you publish, which carries more and more defamatory publications in various ways related to my client. But this defamation began to appear following you, in a series of other publications in various media, outside of the aforesaid group page. It appears that the defamation you spread against my client has taken hold and is spreading like seeds in the wind. Demand of correction and apology 17. Therefore, you are hereby required to retract immediately and publish a full correction of the facts along with an apology towards Im Tirzu and its activists because of the publication. You must do so in wording, manner, place and extent approved by me as a representative of my client. 18. My client is examining the question of the compensation it deserves because of the publication of the defamation by you, and will make a decision to that effect according to your response to this letter. 19. In the event you do not meet my client's aforementioned demand, my client will seek appropriate remedy in the competent court, including adequate monetary compensation for the damage caused and that will be caused to it by the publication. Sincerely, Nadav Haetzni, Adv. Puris Heatzni Rosenberg & Co.

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