PUBLIC CITIZEN LITIGATION GROUP

1600 20TH STREET, N,W.
WASHINGTON. D.C. 20009-1001

(202) 588-1000

BY EMAIL TOst
August 22,2016
Stuart 1. Oberman, Esquire
Oberman Law Firm
Walton Place
147 Lee Byrd Road
Loganville, Georgia 30052
Dear Mr. Oberman:
Thanks for your letter today. The gist is that you agree that the lawsuit against Matthew
Chan was a fraud, but you contend that not only Chan but Mitul Patel as well is a victim of the fraud.
In effect, you are contending that I was tricked by this fraud into wrongly portraying your client,
Mitul Patel, as being responsible for the suit.
I am glad to post your letter on our blog, as you request. I'll also put you in touch with
Matthew Chan's lawyer so that you can stipulate to having the injunction vacated and the lawsuit
dismissed.
I was not persuaded, however, by your suggestion that I should "retract" the blog post or
apologize for it. After all, you acknowledge that much of what I had to say on the blog was true.
But I also have qualms about your assertion that, before my blog post was published, Patel had no
knowledge ofthe lawsuit in Baltimore, for two reasons. First, in the course of investigating before
I published my article, I obtained from Yelp copies of emails from Mitul Patel to Yelp, attaching the
Baltimore court order and asking that Chan's Yelp comments be deleted. I attach the copies of these
emails. Yelp has told me that Patel used
the same email address that
Unless the
email addresses were spoofed, those emails suggest that your client knew about the court order and
was trying to take advantage of it.
Moreover, before I posted my article on the blog, I placed two telephone calls to Patel's
dental clinic to try to speak with him about the lawsuit; I told his receptionist why I was calling. In
addition, on Wednesday, August 17, I sent your client an email message mentioning his lawsuit
against Chan and spelling out my concerns. Although he did not call me back and did not reply to
the email, I trust he saw the messages before I published my article on Friday.
Finally, I am glad to hear that your client disavows the fraudulent lawsuit that was filed on

EXHIBIT A
~1

®

Printed on Recycled Paper

Stuart Oberman, Esquire
August 22, 2016
page 2
his behalf, but I am struggling to figure out who, or what company, would have an incentive to sue
on your client's behalf, to pay a filing fee of $165, and then to send copies of the court order to Yelp
as well as to the various other companies where Chan's criticisms were posted with a request that
reviews criticizing your client be deleted. It occurs to me that your client might have hired some
reputation management or search engine optimization outfit which committed this fraud on your
client's behalf without ever sharing the dirty details with him. I'd appreciate your finding out from
your client whether he ever retained a reputation-management or search engine optimization
company. If so, which one?

EXHIBIT C

2016 FLORIDA LIMITED LIABILITY COMPANY ANNUAL REPORT

FILED
Mar 26, 2016
Secretary of State
CC6990640692

DOCUMENT# L11000037309
Entity Name: SEO PROFILE DEFENDER NETWORK LLC
Current Principal Place of Business:
12 SE 10TH AVENUE
UNIT 1
FORT LAUDERDALE, FL 33301

Current Mailing Address:
12 SE 10TH AVENUE
UNIT 1
FORT LAUDERDALE, FL 33301 US
FEI Number: 90-0676891

Certificate of Status Desired: No

Name and Address of Current Registered Agent:
RUDDIE, RICHART
12 SE 10TH AVENUE
UNIT 1
FORT LAUDERDALE, FL 33301 US
The above named entity submits this statement for the purpose of changing its registered office or registered agent, or both, in the State of Florida.

SIGNATURE:
Date

Electronic Signature of Registered Agent

Authorized Person(s) Detail :
Title

MGR

Title

MGRM

Name

LYNN, DAVID

Name

RUDDIE, RICHART

Address

2278 FAIRFIELD DRIVE

Address

12 SE 10TH AVENUE UNIT 1

City-State-Zip:

BOCA RATON FL 33486

City-State-Zip:

FORT LAUDERDALE FL 33301

I hereby certify that the information indicated on this report or supplemental report is true and accurate and that my electronic signature shall have the same legal effect as if made under
oath; that I am a managing member or manager of the limited liability company or the receiver or trustee empowered to execute this report as required by Chapter 605, Florida Statutes; and
that my name appears above, or on an attachment with all other like empowered.

SIGNATURE: RICHART RUDDIE

MGR

Electronic Signature of Signing Authorized Person(s) Detail

EXHIBIT D

03/26/2016
Date

EXHIBIT E-1

Profile Defenders Lawsuit Removal Service Is a HIT! « Company News ...

1 of 4

http://profiledefenders.com/blog/profile-defenders-lawsuit-removal-servi...

EXHIBIT E-2

9/29/2016 7:04 PM

Reputation Saviors « Reputation Management Companies « ProfileDefe...

1 of 4

http://profiledefenders.com/blog/reputation-saviors/

EXHIBIT F
9/29/2016 7:01 PM

Yelp.com Cracked - Profile Defenders: A Company That Can Actually G...

1 of 3

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Yelp.com Cracked Profile Defenders:
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WASHINGTON, DC--(Marketwire -05/31/12)- The implausible becomes possible when
the brightest minds are behind it. Jeremy Stoppelman, Max Levchin, and the rest of the
Yelp.com staff would be baffled if they knew that there was a company sophisticated
enough to actually save the lives and reputations of business owners who have
unjustly received unflattering, negative reviews.
Fortunately for business owners, high profile Doctors, Accountants, and Lawyers there
is one company, Profile Defenders, who 100% guarantees to get rid of unwanted Yelp
results. This is contrary to Yelp's recent press which stated that it could not be done.
In early March, Yelp.com made a statement via email to all yelpers and business
owners listed on their site that if an Online Reputation Management firm contacted
them about being able to remove or boost ratings on their site that it could not be done.
While that may very well be true, they have not accounted for other tactics that Profile

What to Read Next

Defenders has cracked. These sophisticated techniques allow our clients to get rid of
their unwanted listings which feature negative reviews that are either outwardly false or
misleading.
Can any other Reputation Management Companies Beat out Yelp?
No. Companies like Reputation.com who advertise about protecting one's reputation
are in fact unable to get rid of and suppress negative Yelp online search results.
Profiledefenders.com, on the other hand, is out there working tirelessly to clean up the
mess made by slanderous competitors and disgruntled ex-employees on Yelp pages.

Teacher Invited 2 Students to Her Home for Sex:
Cops
Inside Edition

So how is it done and how much does it cost?
We cannot let the secret sauce out of the bottle, and never will. In the end it's results
that matter and that's exactly what Profiledefenders.com delivers. Our services start at
only $5,000, and will help you get rid of unwanted listings permanently.
Is it Illegal and can Yelp Stop it?
Best of all, our services are 100% legal and cannot be stopped by Yelp -- this is
because Profile Defenders methodology is completely ethical. "There is nothing more

Investigation underway at New Jersey crash site
Reuters Videos

heart-warming than receiving dozens of letters each year from clients." These clients
thank us for saving their businesses, their lives, and most importantly the lives of their
families. Thanks to Profiledefenders.com, hurtful search results can quickly become a
thing of the past.

Utah Man Allegedly Held Teen in Shed For Six
Weeks, Forcing Her to Perform Sex Acts for
Food and Water
People

Photos of the day - September 29, 2016
Yahoo News Photo Staff

EXHIBIT G-1

Aftermath of 9/11, Congress allows lawsuits
against Saudi Arabia.
Reuters Videos

9/29/2016 7:45 PM

Profile Defenders Lawsuit Removal Service Takes Down Defamatory W...

1 of 3

https://pressreleasejet.com/newsreleases/2015/profile-defenders-lawsuit...

EXHIBIT G-2
9/29/2016 5:44 AM

Profile Defenders Launches New Site Offering Complex Reputation Ma...

2 of 3

http://www.urlwire.com/news/092115.html

Announce Date:09/21/15

..

Profile Defenders Launches New Site Offering Complex Reputation
Management Services
One of the leading reputation management companies has launched a new service to help remove
defamatory content from appearing in searches. The company, Profile Defenders, aims to help
those whose images are affected by slanderous or defamatory messages that are often false and
costly to a business or individuals reputation.
tell your twitter followers

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Defamatory material such as fictitious and negative reviews, slanderous content, and poor ratings
or complaints are just some examples of what Profile Defenders can protect against. This type of
content is usually aimed to hurt a company’s business or a person’s career and the general public
doesn’t know what is real. With Profile Defenders new service offering, these unwanted messages
can be removed and your reputation can be restored. While the service has been around for years,
Profile Defenders recently upgraded their website and tools to better assist their customers to
meet current demand. Their new solution in addition to removing unwanted content is utilizing
the courts in order to remove content permanently when certain criteria is met. 
The legal team at Profile Defenders provides a de-indexing service that removes the unwanted
content and utilizes the court system to remove the content permanently through their Profile
Defenders Lawsuit Removal Service. While online reputation management is growing in popularly
and needs are increasing for these services, Profile Defenders’ new services are one of a kind.
There are very few other companies that work to remove false content and most utilize
techniques that are frowned upon by the industry as a whole. Profile Defenders was persistent on
finding a way to remove false content using white hat methods such as negotiating with
webmasters on their clients behalf to remove unwanted sites appearing in Google search results.
 
 Profile Defenders is a reputation repair company that was established in 2010. They focus on
online reputation management and provide solutions to everyday problems that businesses or
individuals incur negative press on the internet. Profile Defenders monitors and improves the
clients online reputation and also works on PR campaigns to promote their clients in a positive
light. Profile Defenders has been featured in prestigious publications, praising their efforts for
online reputation management, such as Forbes, Bloomberg, and the Wall Street Journal. For more
information about how to defend your name and business on the internet, visit
ProfileDefenders.com

Posted by Eric Ward on 09/21/15
Archived URLwire page: http://www.urlwire.com/news/092115.html

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EXHIBIT G-3

9/29/2016 7:34 PM

ProfileDefenders.com Announces That They Can Remove Almost Any...

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EXHIBIT G-4
9/29/2016 5:57 AM

9/28/2016

Case Information

Circuit Court of Maryland
Go Back Now

Case Information

Court System:
Case Number:
Title:
Case Type:
Case Status:
Case Disposition:

Circuit Court for Baltimore City ­ Civil System
24C15005620
R. Derek Ruddie vs Jake Kirschner
Other Tort Filing Date: 11/10/2015
Closed/Inactive
Dismissed by Court Disposition Date: 12/14/2015

Plaintiff/Petitioner Information

(Each Plaintiff/Petitioner is displayed below)
Party Type: Plaintiff Party No.: 1
Name: Ruddie, R. Derek
Address: 12 Dorset Hill Court
City:
Owings Mills State: MD Zip Code: 21117
Defendant/Respondent Information

(Each Defendant/Respondent is displayed below)
Party Type: Defendant Party No.: 1
Name: Kirschner, Jake
Address: 55 6th Avenue
City:
New York State: NY Zip Code:
Document Tracking

(Each Document listed. Documents are listed in Document No./Sequence No. order)
Doc No./Seq No.:
File Date:
Party Type:
Document Name:

1/0
11/10/2015 Entered Date: 11/12/2015 Decision:
Plaintiff Party No.: 1
Complaint

Doc No./Seq No.:
File Date:
Party Type:
Document Name:

2/0
11/18/2015 Entered Date: 11/19/2015 Decision: Approved
Plaintiff Party No.: 1
Consent Motion for Injunction and Final Judgment
Filed by PLT001­Ruddie, DEF001­Kirschner

Doc No./Seq No.: 2/1
File Date:
12/18/2015 Entered Date: 12/18/2015 Decision:
Document Name: Order of Court
APPROVED AS TO FORM AND CONSENT 12­14­15. (J. GELLER)
Doc No./Seq No.: 2/2
File Date:
12/18/2015 Entered Date: 12/18/2015 Decision:
Document Name: Copies Mailed

This is an electronic case record. Full case information cannot be made available either because of legal restrictions
on access to case records found in Maryland rules 16­1001 through 16­1011, or because of the practical
difficulties inherent in reducing a case record into an electronic format.

EXHIBIT H
http://casesearch.courts.state.md.us/casesearch/inquiryDetail.jis?caseId=24C15005620&loc=69&detailLoc=CC

1/1

Case Information

1 of 2

http://casesearch.courts.state.md.us/casesearch/inquiryDetail.jis?caseId...

Circuit Court of Maryland
Go Back Now

Case Information

Court System:
Case Number:
Title:
Case Type:
Case Status:
Case Disposition:

Circuit Court for Baltimore City - Civil System
24C15006945
Brian Jones vs William Conti
Other Tort Filing Date: 12/17/2015
Closed/Inactive
Judgment/Verdict Disposition Date: 12/21/2015

Plaintiff/Petitioner Information

(Each Plaintiff/Petitioner is displayed below)
Party Type: Plaintiff Party No.: 1
Name: Jones, Brian
Address: P.O. Box 1349
City:
Owings Mills State: MD Zip Code: 21117
Defendant/Respondent Information

(Each Defendant/Respondent is displayed below)
Party Type: Defendant Party No.: 1
Name: Conti, William
Address: P.O. Box 335
City:
Owings Mills State: MD Zip Code: 21117
Document Tracking

(Each Document listed. Documents are listed in Document No./Sequence No. order)
Doc No./Seq No.:
File Date:
Party Type:
Document Name:

1/0
12/17/2015 Entered Date: 12/18/2015 Decision:
Plaintiff Party No.: 1
Complaint

Doc No./Seq No.: 2/0
File Date:
12/17/2015 Entered Date: 12/18/2015 Decision: Granted
Document Name: Consent Motion For Injunction And Final Judgment

Doc
No./Seq
2/1
No.:
File Date: 12/23/2015 Entered Date: 12/23/2015 Decision:
Document
Order of Court
Name:
It is hereby Ordered, Adjudged and Decreed as follows:1. The Court finds that Defendant
William conti ("Defendant') posted false and defamatory statements about Plaintiff Brian
Jones on the following webpage(s): http://800notes.com/Phone.aspx/1-800-829-7700,
http://www.ripoffreport.com/r/Vantage-Acceptance/Woodland-Hills-California91367/Vantage-Acceptance-Be-care-full-of 19900-per-month-charge-that-they-will-nottell-you-989943, https://getoutofdebt.org/62563/vantage-acceptance-consumercomplaint-june-25-2014 (the "Defamation").2. The Defamation is not otherwise protected
by the First Amendment. 3. Defendant shall remove the Defamation.4. If the Defendant
cannot remove the Defamation from the Internet, the Plaintiff shall submit this Order to
Google, Yahoo, bing, or any other Internet search engine so that the link can be removed
from their search results pursuant to their existing policies conerning de-indexing of
defamatory material.5. Upon entry of this Order, this matter shall be closed. Geller, J
Doc No./Seq No.: 2/2
File Date:
12/23/2015 Entered Date: 12/23/2015 Decision:
Document Name: Copies Mailed

This is an electronic case record. Full case information cannot be made available either because of legal restrictions

EXHIBIT I

10/8/2016 1:32 AM

EXHIBIT J

Dozens of suspicious court cases, with missing defendants, aim at gettin...

https://www.washingtonpost.com/news/volokh-conspiracy/wp/2016/10/1...

There are about 25 court cases throughout the country that have a suspicious profile:

All involve allegedly self-represented plaintiffs, yet they have similar snippets of legalese that
suggest a common organization behind them. (A few others, having a slightly different
profile, involve actual lawyers.)
All the ostensible defendants ostensibly agreed to injunctions being issued against them,
which often leads to a very quick court order (in some cases, less than a week).
Of these 25-odd cases, 15 give the addresses of the defendants — but a private investigator
(Giles Miller of Lynx Insights & Investigations) couldn’t find a single one of the ostensible
defendants at the ostensible address.
Now, you might ask, what’s the point of suing a fake defendant (to the extent that some of these defendants are indeed fake)?
How can anyone get any real money from a fake defendant? How can anyone order a fake defendant to obey a real injunction?
The answer is that Google and various other Internet platforms have a policy: They won’t take down material (or, in Google’s
case, remove it from Google indexes) just because someone says it’s defamatory. Understandable — why would these
companies want to adjudicate such factual disputes? But if they see a court order that declares that some material is
defamatory, they tend to take down or deindex the material, relying on the court’s decision.

1 of 5

EXHIBIT K

10/11/2016 12:54 AM

Dozens of suspicious court cases, with missing defendants, aim at gettin...

https://www.washingtonpost.com/news/volokh-conspiracy/wp/2016/10/1...

Yet the trouble is that these Internet platforms can’t really know if the injunction was issued against the actual author of the
supposed defamation — or against a real person at all. That’s why we have incidents like this:
1. Matthew Chan, a Georgia resident, posts a negative review of Mitul Patel, a Georgia dentist, on Yelp and a few other sites.
(Readers may remember this story, which we blogged about in August; that’s the incident that got us investigating this issue.)
Several months after Chan puts up his post, Yelp emails him, saying that it’s about to take his comment down because it
received a court order that was issued against him, and the court concluded that his comment was defamatory.
But wait!, says Chan — he’s never been sued. And sure enough, the order is against a supposed Mathew Chan of Baltimore. As
best we can tell, no such Mathew Chan exists in Baltimore, but in any event no Baltimorean is the author of the post. Yet the
order is supposedly based on that Mathew Chan agreeing with Mitul Patel that the review was defamatory, and should be
removed. (As we’ll see below, Mitul Patel and some of the other plaintiffs state that they did not authorize the lawsuit or sign
the pleadings, though they did hire a “reputation management company” to do something.)
2. Steve Rhode, who lives in North Carolina, runs getoutofdebt.org, where he writes about (among other things) what he sees
as abusive practices by debt relief firms. Over the past few years, he has criticized such companies, including two California
companies called Financial Rescue and Rescue One Financial.
Over the past year and a month, three suits have been filed, in Rhode Island federal court, in Maryland state court, and in
Florida state court, claiming that various comments on several separate posts defamed these debt relief companies. The Rhode
Island case is part of the pattern we describe above; the other two cases are slightly different, in that they involve lawsuits
brought by lawyers rather than by ostensibly self-represented plaintiffs.
Let’s focus for now on the suit in Rhode Island. The complaint objects to an allegedly defamatory comment that discussed
Rescue One Financial, citing two blog posts, one of which is about Financial Rescue. But neither company sues Rhode, who
might well have fought back.
Instead, a lawsuit is filed ostensibly on behalf of Bradley Smith — the chief executive of Rescue One Financial — against one
Deborah Garcia, who supposedly lives in Rhode Island. As best we can tell, no-one by that name lives at the address given for
her.
“Deborah Garcia” stipulates to a libel judgment, which the court promptly enters. The order is submitted to Google with a
request to remove that page from Google indexes, so that no-one can find it using Google; Google complies.
3. A California newspaper writes a story in 2013 about an elementary school parent who had put fake signatures and falsely
attributed quotes on a petition. (The petition was urging the school not to change its gifted education program.) The
newspaper quotes the parent as apologizing for her actions.
Two and a half years later, a comment appears on the story: The comment, signed “Robert Castle,” accuses the parent of being
prejudiced and taking bribes, though it also says the commenter is drunk and isn’t sure he’s talking about the same person

2 of 5

10/11/2016 12:54 AM

Dozens of suspicious court cases, with missing defendants, aim at gettin...

https://www.washingtonpost.com/news/volokh-conspiracy/wp/2016/10/1...

that the story describes.
Then, within a few months, a lawsuit is filed in Shasta County — not where the incident happened — against supposed Shasta
County resident “Robert Castle,” claiming the comment is defamatory, and alleging that Castle agrees to an injunction. (The
Baltimore, Rhode Island, and California lawsuits share a good deal of legal boilerplate.) Instead of just granting the injunction,
the judge demands that the parties come in for a hearing, noting, among other things, that “there is a purported signature of
Defendant Robert Castle” but no proof that such a defendant was served.
The docket does not report that the hearing was ever held; instead, a similar case is then filed in Los Angeles County, also far
from the scene of the underlying incident, with the same plaintiff and the same defendant. An injunction is indeed issued. Yet
as best we can tell no Robert Castle lives in Shasta County.
No lawsuit against the newspaper based on its initial story would have succeeded, partly because the newspaper’s report may
well have been accurate, and partly because the statute of limitations had expired. But because the theory of the case was that
the “Robert Castle” comment had defamed the parent, that tail was used to wag the dog: The ostensibly libelous comment was
used as a justification for an order apparently aimed at deindexing the whole newspaper article. (The order has apparently not
yet been submitted to Google, though there has been an attempt to use a bogus copyright takedown request to get Google to
deindex the newspaper article.)
4. Other lawsuits have apparently aimed at deindexing

1. An article in the Charleston Post & Courier that discussed the indictment of a local
businessman,
2. A federal court opinion posted on Leagle.com that dealt with a criminal forfeiture in a child
pornography case,
3. A Web page critical of a rich Indonesian businessman,
4. A Web page critical of so-called “cremation diamonds” that are supposedly made from the
ashes of loved ones,
5. Posts on Dharmawheel.com critical of a California Buddhist leader,
6. A wide variety of RipOffReport.com complaint pages,
7. And many more.
We have seen such lawsuits in California, Florida, Illinois, Maryland, Nevada, Pennsylvania and Texas. About half of them
have been in the Baltimore area and in Philadelphia.

3 of 5

10/11/2016 12:54 AM

Dozens of suspicious court cases, with missing defendants, aim at gettin...

https://www.washingtonpost.com/news/volokh-conspiracy/wp/2016/10/1...

And the possibility of such shenanigans bears on the Hassell v. Bird litigation that is now before the California Supreme
Court: The issue there (see here and here) is whether takedown injunctions can actually be made legally binding on Internet
platforms, rather than just being something that platforms choose whether to follow. The questionable nature of many such
injunctions is reason to further insist that platforms not be legally bound by them.
***
Who is behind these cases? For many of these, we don’t know. As we mentioned, many of the plaintiffs might well not have
known what was happening. They might have hired a reputation management company, expecting it to get the negative posts
removed legitimately (e.g., through a legitimate libel lawsuit, or through negotiation with the actual authors).
But in four of these situations, the lawyers for the ostensible plaintiffs report that they, or the companies that they lead, dealt
with one particular reputation management company; and another case seems to be connected to that company as well.
A. The lawyer for the real Bradley Smith alleges that Smith’s signature on the Rhode Island complaint was forged. He also
states that Smith “does not recall authorizing” the suit filed in his name on a similar complaint against an apparently fictitious
defendant in state court in Baltimore.
Smith’s lawyer passed along a contract that Smith’s company, Rescue One Financial, signed with a company called “RIR 1984
LLC,” headed by one Richart Ruddie. RIR was to be paid $6,000 per month to apply its “proprietary de-indexing program” so
that “negative posts from Steve Rhodes [sic]” “will be de-indexed using our proprietary methods.” The contract was aimed in
part at “insulating against negative Google search results,” specifically by “remov[ing]” “Steve Rhodes [sic] articles.”
B. After Matthew Chan filed a motion to vacate the Maryland state court “consent order,” the ostensible plaintiff (Mitul Patel)
filed his own motion to vacate, stating to the court that Patel “has been caused to suffer negative publicity via internet news
blogs as a result of the attempt by the party purporting to be Plaintiff MITUL R. PATEL’s attempts to have negative reviews of
[Patel’s] Dental practice removed from internet review websites.”
Patel’s motion states that Patel did not actually file the lawsuit, and it attaches a letter from Patel’s lawyer to Richart Ruddie.
The letter alleges that Patel had signed an SEO contract with a Ruddie-led entity called “SEO Profile Defense Network LLC,”
and alleges that this entity “apparently forged Dr. Patel’s signature to a Complaint and Consent Motion.” (Patel’s lawyer has
steadfastly refused to produce the contract in question.)
C. We likewise have confirmation that Profile Defenders, a Richart Ruddie company, was hired by two of the plaintiffs in the
other cases that fit the pattern we described in the opening paragraphs.
D. The earliest case that we could find fitting this general pattern was filed in November 2015 — and it had as the plaintiff R.
Derek Ruddie in Owings Mills, Md. Richart Ruddie was apparently born in Owings Mills, and Derrek (though with two r’s)
appears to be his middle name; the address given in court documents has been associated with Richart Ruddie in various
records. And the monthly payments under the reputation management contract signed by Rescue One Financial are to be

4 of 5

10/11/2016 12:54 AM

Dozens of suspicious court cases, with missing defendants, aim at gettin...

https://www.washingtonpost.com/news/volokh-conspiracy/wp/2016/10/1...

made to Ruddie’s company at a bank located in Owings Mills.
The defendant in this November 2015 case, true to form, could not be found at the address listed in the court documents. The
lawsuit itself succeeded in using a comment, ostensibly derogatory of Ruddie — though it didn’t use Ruddie’s last name — to
get a whole RipOffReport.com post deindexed. (The comment was, “Hey Rich whats the deal with this guy you recommended?
Does he give you a kick back or something?”) That RipOffReport post was critical of a lawyer, who we assume was the main
beneficiary of the November 2015 lawsuit. The lawyer has declined to say whether he had any reputation management
agreement with Ruddie.
Indeed, a few days after this lawsuit was filed, a Profile Defenders press release announced,
Profile Defenders Lawsuit Removal service honors a guarantee to take down and [sic] defamatory or
unwanted webpages from search results as long as they meet specific criteria…. The future of online
reputation management is moving into permanent removals…. The Profile Defenders lawsuit removal
service is now available and pricing starts at $6,000…. Legal services provided by the profile defenders
team and in house council [sic] have proven to be successful….
We asked Ruddie and SEO Profile Defenders several times to comment, but their only response, to our initial inquiry about
Patel, was, “We deny these allegations and we have no further comment. When and if we do we will contact you.” But, to give
them the last word, here is something from Richart Ruddie Entrepreneurial Blog, dated Sept. 8, 2016:
Just be a good person – Richart Ruddie
Had one of the nicest compliments this past weekend. A new friend said “Chart do you know why I like
you?”
“At the end of the day you’re just a genuine person Richart Ruddie” ….
***
Eugene Volokh is a law professor at UCLA School of Law. Paul Alan Levy is an attorney at Public Citizen Litigation Group.

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Monday, October 10, 2016

Profile Defenders and Richart Ruddie: The Common Link Between Two Phony Defamation Suits
by Paul Alan Levy
I had previously suggested that similarities in the wording of consent orders in Patel v. Chan, filed in state court in Baltimore, and
Smith v. Garcia, filed in federal court in Rhode Island, implied that some black-hat SEO outfit might be responsible for frauds on both
courts. Since then, lawyers for both plaintiffs have identified a single individual, Richart Ruddie, as being involved. A joint blog post
that I wrote with Eugene Volokh, published today, points to more than two dozen cases around the country that follow this pattern, and
we cite evidence pointing to the central involvement of a single reputation management operation run by Richart Ruddie under a
variety of company names. The facts that Richart Ruddie is a native of Owings Mills, a suburb of Baltimore, and that his contract calls
for payments into a bank in Owings Mills, could explain why so many of the phony cases have been filed there.
What We Have Learned from the Motions to Vacate in Baltimore
Since I blogged about these cases, Matthew Chan has moved to vacate the order that was entered against his reviews of Mitul Patel, and
Patel, rather than consenting to Chan's motion, has filed his own motion to vacate the decision, claiming that he never signed the papers
and never authorized papers to be filed on his behalf in that court. Patel's moving papers attach a letter from Stuart Oberman, his
Georgia counsel, who asserts that Richart Ruddie was Patel's reputation management operative. Oberman accuses Ruddie of filing the
Baltimore state court lawsuit, and blames Ruddie for the fact that the Streisand Effect has besmirched Patel's reputation.
I am ready to assume that Patel is telling the truth when he says that he did not sign the papers, but based on what I have been able to
glean from available evidence I am not so sure about the veracity of his claim that he did not authorize the filing of a lawsuit as a means
of cleaning up his reputation by getting Chan's online criticisms taken down. Patel's counsel has not been willing to disclose to
reputation management contract that he signed, but I was also contacted by the attorney for Bradley Smith, who not only confirmed for
me that Smith’s signature was forged on the Rhode Island papers, but also provided me with the reputation management agreement
that Smith's company Rescue One Financial (but not Smith himself) had signed with another of Ruddie's companies. That contract
called for Ruddie's company to apply its "proprietary de-indexing program" so that "negative posts from Steve Rhodes [sic] . . . will be
de-indexed using our proprietary methods," thus "insulating against negative Google search results," specifically directed to "remove. . .
Steve Rhodes [sic] articles" from search engine results.
Patel's counsel, although claiming to be outraged by Ruddie's conduct, has steadfastly refused to produce the contract in question. He
cannot be concealing this document to protect Ruddie, so I have to wonder what it is in the contract that Patel feels he has to hide. Does
the wording of the contract suggest that Ruddie's phony lawsuit, despite Oberman's letter complaining about the impact on Patel's
reputation, is exactly what Patel was paying him for? If its contents are comparable, they could show that Patel gave Ruddie blanket
approval to file lawsuits in his name.
Moreover, Ruddie's web site makes clear that he is providing a "lawsuit service" whose methods cannot be safely discussed in public:
“We have to be vague on the details legally until we speak with you." So at the very least we need to know what "details" were revealed
to Patel once he contacted Ruddie and made clear that he was prepared to pay a pretty penny to have negative material about him taken
offline.
Finally, after Ruddie's firm obtained the "consent" order from the Maryland court (assuming as Oberman asserts that it was Ruddie's
firm that did the dirty work), documents provided by Yelp show that it was Patel himself who emailed that order to Yelp, asking that the
Chan review be taken down - this request used an email address which Patel has used for several other purposes. And the consent order
that Patel provided to Yelp contained the signature that Patel now says was forged, and it also contained the signature of "Mathew

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Chan" over a signature block showing an address that Patel must have known was phony (because he knows where his former patient
lived). So I am not inclined to believe that Patel was as innocent of the methods being employed on his behalf as he and his team of
lawyers would now like us to believe. Whether Patel can be held personally liable for the actions taken on his behalf by the Ruddie
companies acting as his agent remains to be seen.
Implications for Future Cases
We know that phony lawsuits of this kind are a widespread problem throughout the country thanks to the exhaustive research to which
Professor Volokh and I refer in our joint article. I give full credit to my co-author because it was his painstaking research that identified
so many similar cases around the country. And it was the pro bono work of Giles Miller of Lynx Insights and Investigations that tracked
down the fact that so many of the supposed defendants who "agreed" to consent orders do not exist. Because both Steve Rhode and
Matthew Chan have good claims for sanctions, civil discovery may well allow us to uncover additional information about the full extent
of the fraud at work here.
On the other hand, I expect that Ruddie will prove a slippery character – the home page of his “Profile Defenders” web site provides a
New York City street address that appears to be phony (a letter I sent him at that address demanding that he preserve relevant
documents came back undeliverable), and both the Linked In and Google profiles of Profile Defenders show a Washington, D.C. address
that does not exist. Moreover, Florida’s records reveal that Ruddie maintains a stable of many different LLC’s. It may take the
investigative resources of a federal or state grand jury or of the Federal Trade Commission to track him and his assets down, and bring
him to justice.
At least two cases involving Steve Rhode’s blog were filed by lawyers rather than in pro se guise. One such Maryland state court case
was filed on behalf of Bradley Smith, and was aimed at the de-indexing several pages about Rescue One Financial, so I assume that this
is a case fomented by Richart Ruddie in furtherance of his agreement get pages de-indexed. Not only has the lawyer in that case has
never responded to me, but it appears that he has retained counsel to respond to inquiries about his representation (considering the
possible bar charges, this strikes me as a wise choice). The lawyer in a Florida case filed to secure de-indexing of a blog post about a
different debt relief company – filed against Bradley Smith as a defendant – told me that the case came to him in a package, although he
has refused to say from whom. In yet another another lawyer-filed case that Professor Volokh was able to identify in his investigations
(not involving a Rhode web page), the lawyer identified a Richart Ruddie company as the source of his information. The lawyer said
that he had no reason to discredit Ruddie’s representations.
Some, but not all, of the lawyers who are used in this scheme are relatively junior lawyers who are practicing by themselves and may
well have been quite anxious for new business. Certainly, they did not ask enough questions. Going forward, though, we can expect
even new lawyers to inform themselves about Ruddie and turn down the business lest they, too, be charged with filing forged papers.
At the same time, the breadth of the problem should give Google and other search engines greater reason to exercise caution in
"deindexing" web pages when consent orders are submitted as a basis for denying consumers access to web pages that criticize
individuals and businesses. And now that the California Supreme Court has granted discretionary review in Hassell v.Bird, we can hope
that courts will have second thoughts about subjecting interactive web sites to liability, or even to injunctive relief, based on defamation
judgments that do not represent determinations by a trier of fact based on an adversary proceeding. Here at Public Citizen, for
example, we have in the past refused to remove comments on this blog where the court orders about those comments had been obtained
by default. The widespread success that scammers have achieved without any real showing of a basis for liability is a good reason to
respect the discretion of hosting sites to decide whether to honor injunctions issued against their users.
Finally, this is an area in which judges need to do a better job of protecting the interests of absent parties. If two parties, whether pro se
or otherwise, want to settle their differences by agreeing that the defendant is going to pay the plaintiff money, or that the defendant is
going to subject himself to an injunction in favor of the plaintiff, that is the two individual parties' decision to make. Judges should
certainly take precautions, as the judge did in the Shasta County California case that we cited in our joint blog post, to be sure that the
defendant has been served before even a consensual order is entered. But when an injunction recites that a third party is to be obligated
to act, or even just expected to perform, judges should be on their guard. It is surely a disappointment that so many judges were
hoodwinked by the filing of pro se papers into entering injunctions that were so plainly intended to spur action by third parties that
were hosting reviews or including critical web pages in their search engine indexes, but without any notice to the third parties.
Posted by Paul Levy on Monday, October 10, 2016 at 07:10 PM | Permalink

10/11/2016 12:38 AM