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PUBLIC CITIZEN LITIGATION GROUP

1600 20TH STREET, N,W.

WASHINGTON. D.C.

20009-1001

(202) 588-1000

BY EMAIL TOst

WASHINGTON. D.C. 20009-1001 (202) 588-1000 BY EMAIL TOst Stuart 1. Oberman, Esquire Oberman Law Firm Walton

Stuart 1. Oberman, Esquire Oberman Law Firm Walton Place 147 Lee Byrd Road Loganville, Georgia 30052

Dear Mr. Oberman:

August 22,2016

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.

Thanks for your letter today.

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 ofthese

emails. Yelp has told me that Patel used

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.

the court order and was trying to take advantage of it. the same email address that

the same email address that

trying to take advantage of it. the same email address that Moreover, before I posted my
trying to take advantage of it. the same email address that Moreover, before I posted my

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

~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?

2016 FLORIDA LIMITED LIABILITY COMPANY ANNUAL REPORT

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

Name and Address of Current Registered Agent:

RUDDIE, RICHART

12 SE 10TH AVENUE

UNIT 1 FORT LAUDERDALE, FL 33301 US

FILED Mar 26, 2016 Secretary of State

CC6990640692

Certificate of Status Desired:

No

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:

Electronic Signature of Registered Agent

Authorized Person(s) Detail :

Date

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

03/26/2016

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

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Reputation Saviors « Reputation Management Companies « ProfileDefe

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

Management Companies « ProfileDefe http://profiledefenders.com/blog/reputation-saviors/ 1 of 4 9/29/2016 7:01 PM
Management Companies « ProfileDefe http://profiledefenders.com/blog/reputation-saviors/ 1 of 4 9/29/2016 7:01 PM
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Yelp.com Cracked - Profile Defenders: A Company That Can Actually G

https://www.yahoo.com/news/yelp-com-cracked-profile-defenders-1530

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Yelp.com Cracked - Profile Defenders:

A Company That Can Actually Get Rid of Your Negative Listings and Reviews

May 31, 2012Actually Get Rid of Your Negative Listings and Reviews WASHINGTON, DC--(Marketwire -05/31/12)- The implausible

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 Ye lp's recent press which stated t hat 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

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.

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 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.

search results can quickly become a thing of the past. What to Read Next Teacher Invited
search results can quickly become a thing of the past. What to Read Next Teacher Invited

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Profile Defenders Lawsuit Removal Service Takes Down Defamatory W

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

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

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Profile Defenders Launches New Site Offering Complex Reputation Ma

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.

false and costly to a business or individuals reputation. tell your twitter followers . ShareThis URL:

tell your twitter followers.

ShareThis

reputation. tell your twitter followers . ShareThis URL: http://www.ProfileDefenders.com Defamatory material

URL: http://www.ProfileDefenders.com

followers . ShareThis URL: http://www.ProfileDefenders.com Defamatory material such as fictitious and negati ve

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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9/28/2016

CaseInformation

CaseInformation

CircuitCourtofMaryland

CourtSystem: CircuitCourtforBaltimoreCity­CivilSystem CaseNumber: 24C15005620

Title:

R.DerekRuddievsJakeKirschner

CaseType:

OtherTort FilingDate:11/10/2015

CaseStatus:

Closed/Inactive

CaseDisposition:DismissedbyCourt DispositionDate:12/14/2015

DismissedbyCourt DispositionDate: 12/14/2015 Plaintiff/PetitionerInformation

Plaintiff/PetitionerInformation

(EachPlaintiff/Petitionerisdisplayedbelow)

PartyType:Plaintiff PartyNo.:1

Name:Ruddie,R.Derek

Address:12DorsetHillCourt

City:

OwingsMills State:MD ZipCode:21117

City: OwingsMills State: MD ZipCode: 21117 Defendant/RespondentInformation

Defendant/RespondentInformation

(EachDefendant/Respondentisdisplayedbelow)

PartyType:Defendant PartyNo.:1

Name:Kirschner,Jake

Address:556thAvenue

City:

NewYork State:NY ZipCode:

Address: 556thAvenue City: NewYork State: NY ZipCode: DocumentTracking

DocumentTracking

(EachDocumentlisted.DocumentsarelistedinDocumentNo./SequenceNo.order)

DocNo./SeqNo.:1/0

FileDate:

11/10/2015 EnteredDate:11/12/2015 Decision:

PartyType:

Plaintiff PartyNo.:1

DocumentName:Complaint

PartyType: Plaintiff PartyNo.: 1 DocumentName: Complaint DocNo./SeqNo.: 2/0 FileDate: 11/18/2015 EnteredDate:

DocNo./SeqNo.:2/0

FileDate:

11/18/2015 EnteredDate:11/19/2015 Decision:Approved

PartyType:

Plaintiff PartyNo.:1

DocumentName:ConsentMotionforInjunctionandFinalJudgment

FiledbyPLT001­Ruddie,DEF001­Kirschner

DocNo./SeqNo.:2/1

FileDate:

DocumentName:OrderofCourt

12/18/2015 EnteredDate:12/18/2015 Decision:

APPROVEDASTOFORMANDCONSENT12­14­15.(J.GELLER)

DocNo./SeqNo.:2/2

FileDate:

DocumentName:CopiesMailed

12/18/2015 EnteredDate:12/18/2015 Decision:

CopiesMailed 12/18/2015 EnteredDate: 12/18/2015 Decision:

Thisisanelectroniccaserecord.Fullcaseinformationcannotbemadeavailableeitherbecauseoflegalrestrictions

onaccesstocaserecordsfoundinMarylandrules16­1001through16­1011,orbecauseofthepractical

difficultiesinherentinreducingacaserecordintoanelectronicformat.

Case Information

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

Case Information

Circuit Court of Maryland

Go Back Now

Court System:

Circuit Court for Baltimore City - Civil System

Case Number:

24C15006945

Title:

Brian Jones vs William Conti

Case Type:

Other Tort

Filing Date: 12/17/2015

Case Status:

Closed/Inactive

Case Disposition: 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.: 1/0

File Date:

12/17/2015

Entered Date: 12/18/2015

Decision:

Party Type:

Plaintiff

Party No.: 1

Document Name: 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

 

Name:

Order of Court

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-California-

91367/Vantage-Acceptance-Be-care-full-of 19900-per-month-charge-that-they-will-not- tell-you-989943, https://getoutofdebt.org/62563/vantage-acceptance-consumer- complaint-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:

Document Name: Copies Mailed

12/23/2015

Entered Date: 12/23/2015

Decision:

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

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

court cases, with missing defendants, aim at gettin
court cases, with missing defendants, aim at gettin

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

ThereThere areare aboutabout 2525 courtcourt casescases
ThereThere areare aboutabout 2525 courtcourt casescases
ThereThere areare aboutabout 2525 courtcourt casescases
ThereThere areare aboutabout 2525 courtcourt casescases
ThereThere areare aboutabout 2525 courtcourt casescases
ThereThere areare aboutabout 2525 courtcourt casescases

ThereThere areare aboutabout 2525 courtcourt casescases throughoutthroughout ththee countrycountry thatthat havehave aa suspicioussuspicious profile:profile:

AllAll involveinvolve allegedlyallegedly self-representself-representeded plaintiffs,plaintiffs, yetyet theythey havehave sisi milarmilar snippetssnippets ofof legaleselegalese thatthat eded plaintiffs,plaintiffs, yetyet theythey havehave sisimilarmilar snippetssnippets ofof legaleselegalese thatthat suggestsuggest aa commoncommon organizationorganization behindbehind them.them. (A(A fewfew othersothers,, havinghaving aa slightlyslightly differentdifferent

profile,profile, involveinvolve actualactual lawyers.)lawyers.)

AllAll thethe ostensibleostensible defendantsdefendants ostensiblyostensibly agragreedeed toto injunctionsinjunctions beinbein gg issuedissued againstagainst them,them, whichwhich oftenoften leadsleads eedeed toto injunctionsinjunctions beinbeingg issuedissued againstagainst them,them, whichwhich oftenoften leadsleads toto aa veryvery quickquick courtcourt orderorder (in(in somesome cases,cases, lessless thanthan aa week).week).

OfOf thesethese 25-odd25-odd cases,cases, 1515 givegive thethe addressesaddresses ofof thethe defendandefendan tsts —— butbut aa privateprivate investigatorinvestigator thethe addressesaddresses ofof thethe defendandefendantsts —— butbut aa privateprivate investigatorinvestigator (Giles(Giles MillerMiller ofof LynxLynx InsightsInsights && InvestigationsInvestigations)) couldn’tcouldn’t findfind aa singlesingle oneone ofof thethe ostensibleostensible defendantsdefendants atat thethe ostensibleostensible address.address.

Now,Now, youyou mightmight ask,ask, what’swhat’s thethe pointpoint ofof susuinging aa fakefake defendantdefendant (to(to thethe extentextent thatthat somesome ofof thesethese defendantsdefendants areare indeedindeed fake)?fake)? HowHow cancan anyoneanyone getget anyany realreal moneymoney fromfrom aa fakefake defendant?defendant? HowHow cancan anyoanyonene orderorder aa fakefake defendantdefendant toto obeyobey aa realreal injunction?injunction?

TheThe answeranswer isis thatthat GoogleGoogle andand variousvarious otheotherr InternetInternet platformsplatforms havehave aa policy:policy: TheyThey wowon’tn’t taketake downdown materialmaterial (or,(or, inin GooglesGoogles

case,case, removeremove itit fromfrom GoogleGoogle indexes)indexes) justjust becausebecause someonesomeone sayssays it’sit’s defamatory.defamatory. UnderstandableUnderstandable —— whywhy wouldwould thesethese companiescompanies wantwant toto adjudicateadjudicate suchsuch factualfactual disputes?disputes? ButBut ifif theythey seesee aa courtcourt orderorder thatthat declaresdeclares thatthat somesome materialmaterial isis defamatory,defamatory, theythey tendtend toto taketake downdown oror deindexdeindex thethe materialmaterial,, relyingrelying onon thethe court’scourt’s decision.decision.

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

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

YYetet thethe troubletrouble isis thatthat thesethese InternetInternet platfoplatformsrms can’tcan’t reallyreally knowknow ifif thethe injunctioninjunction wawass issuedissued againstagainst thethe actualactual authorauthor ofof thethe supposedsupposed defamationdefamation —— oror againstagainst aa realreal personperson atat all.all. That’sThat’s whywhy wewe havehave incidentsincidents likelike this:this:

1.1. MatthewMatthew Chan,Chan, aa GeorgiaGeorgia resident,resident, postsposts aa negativenegative reviewreview ofof MitulMitul Patel,Patel, aa GeorgiGeorgiaa dentist,dentist, onon YelpYelp andand aa fewfew otherother sites.sites. (Readers(Readers maymay rememberremember thisthis storystory,, whichwhich wewe bloggedblogged aboutabout inin August;August; that’sthat’s thethe inincidentcident thatthat gotgot usus inveinvestigatingstigating thisthis issue.)issue.)

SeveralSeveral monthsmonths afterafter ChanChan putsputs upup hishis post,post, YelpYelp emailsemails him,him, sayingsaying thatthat it’sit’s aboutabout toto taketake hishis commentcomment downdown becausebecause itit receivedreceived aa courtcourt orderorder thatthat waswas issuedissued againstagainst him,him, anandd thethe courtcourt concludedconcluded thatthat hishis commentcomment waswas defamatory.defamatory.

ButBut wait!,wait!, sayssays ChanChan —— he’she’s nevernever beenbeen sued.sued. AndAnd suresure enoughenough,, thethe orderorder isis againstagainst aa supposedsupposed MathewMathew ChanChan ofof Baltimore.Baltimore. AsAs bbestest wewe cancan tell,tell, nono suchsuch MathewMathew ChanChan exisexiststs inin Baltimore,Baltimore, butbut inin anyany eventevent nono BaltimoreanBaltimorean isis thethe authorauthor ofof thethe post.post. YetYet thethe orderorder isis supposedlysupposedly basedbased onon thatthat MathewMathew ChanChan agreeingagreeing withwith MitulMitul PatelPatel thatthat thethe reviewreview waswas defamatory,defamatory, andand shouldshould bebe removed.removed. (As(As we’llwe’ll seesee below,below, MitulMitul PatelPatel anandd somesome ofof thethe otherother plaintiffsplaintiffs statestate thatthat theythey diddid notnot authorizeauthorize thethe lawsuitlawsuit oror sigsignn thethe pleadings,pleadings, thoughthough theythey diddid hirehire aa “reput“reputationation managementmanagement compancompanyy toto dodo something.)something.)

2.2. SteveSteve Rhode,Rhode, whowho liveslives inin NorthNorth CarolinaCarolina,, runsruns getoutofdebt.orggetoutofdebt.org,, wherewhere hehe writeswrites aboutabout (among(among otherother things)things) whatwhat hehe seessees

asas abusiveabusive practicespractices byby debtdebt reliefrelief firms.firms. OverOver thethe pastpast fewfew yeyears,ars, hehe hashas criticizedcriticized suchsuch companies,companies, includingincluding twotwo CaliforniaCalifornia

companiescompanies calledcalled FinancialFinancial RescRescueue andand RescueRescue OneOne Financial.Financial.

OverOver thethe pastpast yearyear andand aa month,month, threethree suitsuitss havehave beenbeen filed,filed, inin RhodeRhode IslandIsland federafederall court,court, inin MarylandMaryland statestate court,court, andand inin

FloridaFlorida statestate court,court, claimingclaiming thatthat variousvarious commentscomments onon severalseveral separateseparate postsposts defameddefamed thesethese debtdebt reliefrelief companies.companies. TheThe RhodeRhode IslandIsland casecase isis partpart ofof thethe patternpattern wewe dedescribescribe above;above; thethe otherother twotwo casescases areare slightslightlyly different,different, inin thatthat theythey involveinvolve lawsuitslawsuits bbroughtrought byby lawyerslawyers ratherrather thanthan byby osostensiblytensibly self-representedself-represented plaintiffs.plaintiffs.

Let’sLet’s focusfocus forfor nownow onon thethe suitsuit inin RhodeRhode Island.Island. TheThe complaincomplaintt objectsobjects toto anan allegedlyallegedly defamatorydefamatory commentcomment thatthat discusseddiscussed RescueRescue OneOne Financial,Financial, citingciting twotwo blogblog poposts,sts, oneone ofof whichwhich isis aboutabout FinancialFinancial Rescue.Rescue. ButBut neitheneitherr companycompany suessues Rhode,Rhode, whowho mightmight wellwell havehave foughtfought back.back.

Instead,Instead, aa lawsuitlawsuit isis filedfiled ostensiblyostensibly onon behalfbehalf ofof BradleyBradley SmithSmith —— thethe chiefchief executiveexecutive ofof RescueRescue OneOne FinancialFinancial —— againstagainst oneone DeborahDeborah Garcia,Garcia, whowho supposedlysupposedly liveslives inin RhodeRhode Island.Island. AsAs bestbest wewe cancan tell,tell, no-oneno-one byby thatthat namename liveslives atat thethe addressaddress givengiven forfor

her.her.

“Deborah“Deborah Garcia”Garcia” stipulatesstipulates toto aa libellibel jujudgment,dgment, whichwhich thethe courtcourt promptlypromptly enters.enters. TheThe orderorder isis submittedsubmitted toto GoogleGoogle withwith aa requestrequest toto removeremove thatthat pagepage fromfrom GoGoogleogle indexes,indexes, soso thatthat no-oneno-one cancan fifindnd itit usingusing GoogleGoogle;; GoogleGoogle complies.complies.

3.3. AA CaliforniaCalifornia newspapernewspaper writeswrites aa storystory inin 20132013 aboutabout anan elementaryelementary schoolschool parentparent whowho hadhad putput fakefake signaturessignatures andand falselyfalsely

attributedattributed quotesquotes onon aa petition.petition. (The(The petitionpetition waswas urgingurging thethe schoolschool notnot toto changechange itsits giftedgifted educationeducation program.)program.) TheThe newspapernewspaper quotesquotes thethe parentparent asas apologizingapologizing forfor herher actions.actions.

TwoTwo andand aa halfhalf yearsyears later,later, aa cocommentmment appearsappears onon thethe story:story: TheThe comment,comment, signedsigned “Robert“Robert Castle,”Castle,” accusesaccuses thethe parentparent ofof beingbeing prejudicedprejudiced andand takingtaking bribes,bribes, thoughthough itit alsoalso sayssays thethe commencommenterter isis drunkdrunk andand isn’tisn’t suresure he’she’s talkingtalking aboutabout thethe samesame personperson

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

thatthat thethe storystory describes.describes.

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

Then,Then, withinwithin aa fewfew months,months, aa lawsuitlawsuit isis filedfiled inin ShastaShasta CounCountyty —— notnot wherewhere thethe incidentincident hahappenedppened —— againstagainst supposedsupposed ShastaShasta

CountyCounty residentresident “Robert“Robert Castle,”Castle,” claimingclaiming thethe commentcomment isis defamatory,defamatory, andand allegingalleging ththatat CastleCastle agreesagrees toto anan injunction.injunction. (The(The Baltimore,Baltimore, RhodeRhode Island,Island, andand CaliforniaCalifornia lawslawsuitsuits shareshare aa goodgood dealdeal ofof legallegal boilerplatboilerplate.)e.) InsteadInstead ofof justjust grantinggranting thethe injunctiinjunction,on, thethe judgejudge demandsdemands thatthat thethe partiesparties comecome inin forfor aa hearing,hearing, noting,noting, amongamong otherother thingsthings,, thatthat “there“there isis aa purportedpurported signaturesignature ofof DefendantDefendant RobertRobert Castle”Castle” butbut nono proofproof thatthat suchsuch aa defendantdefendant waswas served.served.

TheThe docketdocket doesdoes notnot reportreport thatthat thethe hearinghearing waswas everever held;held; insteainstead,d, aa similarsimilar casecase isis thenthen filedfiled inin LosLos AngelesAngeles County,County, alsoalso fafarr fromfrom thethe scenescene ofof thethe underlyingunderlying incident,incident, withwith thethe samesame plaintiffplaintiff andand thethe samesame defenddefendant.ant. AnAn injunctioninjunction isis indeedindeed issued.issued. YetYet

asas bestbest wewe cancan telltell nono RobertRobert CastleCastle liveslives inin ShastaShasta County.County.

NoNo lawsuitlawsuit againstagainst thethe newspapernewspaper basedbased onon itsits initialinitial storystory woulwouldd havehave succeeded,succeeded, partlypartly becabecauseuse thethe newspaper’snewspaper’s reportreport maymay

wellwell havehave beenbeen accurate,accurate, andand partlypartly becausebecause thethe statutestatute ofof limitationslimitations hadhad expired.expired. ButBut becausebecause thethe theorytheory ofof thethe casecase waswas thatthat thethe “Robert“Robert Castle”Castle” commentcomment hadhad defameddefamed thethe parent,parent, thatthat tailtail waswas usedused toto wagwag thethe dog:dog: TheThe ostensiblyostensibly libelouslibelous commentcomment waswas usedused asas aa justificationjustification forfor anan orderorder appareapparentlyntly aimedaimed atat deindexingdeindexing thethe wholewhole newspapenewspaperr article.article. (The(The orderorder hashas apparentlyapparently notnot yyetet beenbeen submittedsubmitted toto Google,Google, thoughthough therethere hashas beenbeen anan attempattemptt toto useuse aa bogusbogus copyrightcopyright takedowntakedown requestrequest toto getget GoogleGoogle toto deindexdeindex thethe newspapernewspaper article.)article.)

4.4. OtherOther lawsuitslawsuits havehave appaapparentlyrently aimedaimed atat deindexingdeindexing

1. AnAn articlearticle inin thethe CharlestonCharleston PostPost && CourierCourier thatthat discusseddiscussed thethe indictmentindictment ofof aa locallocal businessman,businessman,

2. AA federalfederal courtcourt opinionopinion postedposted onon Leagle.comLeagle.com ththatat dealtdealt withwith aa criminalcriminal forfeitureforfeiture inin aa childchild pornographypornography case,case,

3. AA WebWeb pagepage criticalcritical ofof aa ririchch IndonesianIndonesian businessman,businessman,

4. AA WebWeb pagepage criticalcritical ofof so-calledso-called “cremation“cremation didiamonds”amonds” thatthat areare supposedlysupposedly mademade fromfrom thethe ashesashes ofof lovedloved ones,ones,

5. PostsPosts onon Dharmawheel.comDharmawheel.com criticalcritical ofof aa CaliforniaCalifornia BuddhistBuddhist leader,leader,

6. AA widewide varietyvariety ofof RipOffRRipOffReport.comeport.com complaintcomplaint pages,pages,

7. AndAnd manymany more.more.

WeWe havehave seenseen suchsuch lawsuitslawsuits inin CalifornCalifornia,ia, Florida,Florida, Illinois,Illinois, Maryland,Maryland, Nevada,Nevada, PennPennsylvaniasylvania andand Texas.Texas. AboutAbout halfhalf ofof themthem havehave beenbeen inin thethe BaltimoreBaltimore areaarea andand inin Philadelphia.Philadelphia.

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

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

AAndnd thethe possibilitypossibility ofof suchsuch shenanigansshenanigans bearsbears onon thethe HassellHassell v.v. BirdBird litigationlitigation thatthat isis nownow beforebefore thethe CaliforniaCalifornia SupremeSupreme Court:Court: TheThe issueissue therethere (see(see herehere andand herehere)) isis whetherwhether takedowntakedown injuncinjunctionstions cancan actuallyactually bebe mademade legallylegally bindingbinding onon InternetInternet platforms,platforms, ratherrather thanthan justjust beingbeing somethsomethinging thatthat platformsplatforms choosechoose whwhetherether toto follow.follow. TheThe questionablequestionable naturenature ofof manymany suchsuch

injunctionsinjunctions isis reasonreason toto furtherfurther insistinsist ththatat platformsplatforms notnot bebe legallylegally boundbound byby them.them.

** ** **

WhoWho isis behindbehind thesethese cases?cases? ForFor manymany ofof these,these, wewe don’tdon’t know.know. AsAs wewe mentioned,mentioned, manymany ofof thethe plaintiffsplaintiffs mightmight wellwell notnot havehave knownknown whatwhat waswas happening.happening. TheyThey mightmight havehave hiredhired aa reputationreputation managementmanagement company,company, expectingexpecting itit toto getget thethe negativenegative postsposts removedremoved legitimatelylegitimately (e.g.,(e.g., throughthrough aa lelegitimategitimate libellibel lawsuit,lawsuit, oror throughthrough negotiationnegotiation withwith thethe actualactual authors).authors).

ButBut inin fourfour ofof thesethese situations,situations, thethe lawyerslawyers forfor thethe ostensibleostensible plaintiffsplaintiffs reportreport thatthat they,they, oror thethe companiescompanies thatthat theythey lead,lead, ddealtealt withwith oneone particularparticular reputationreputation managememanagementnt company;company; andand anotheranother cacasese seemsseems toto bebe connectedconnected toto thatthat companycompany asas well.well.

AA TheThe lawyerlawyer forfor thethe realreal BradleyBradley SmithSmith allegesalleges thatthat Smith’sSmith’s signaturesignature onon thethe RhodeRhode IslandIsland complaintcomplaint waswas forged.forged. HeHe alsoalso statesstates thatthat SmithSmith “does“does notnot recarecallll authorizing”authorizing” thethe suitsuit filedfiled inin hishis namename onon aa similarsimilar complaintcomplaint againstagainst anan apparentlyapparently fictitifictitiousous defendantdefendant inin statestate courtcourt inin Baltimore.Baltimore.

Smith’sSmith’s lawyerlawyer passedpassed alongalong aa contractcontract thatthat Smith’sSmith’s company,company, RescRescueue OneOne Financial,Financial, signedsigned withwith aa companycompany calledcalled “RIR“RIR 19841984 LLC,”LLC,” headedheaded byby oneone RichartRichart Ruddie.Ruddie. RIRRIR wawass toto bebe paidpaid $6,000$6,000 perper monthmonth toto applyapply itsits proprietaryproprietary de-indexingde-indexing programprogram soso thatthat “negative“negative postsposts fromfrom SteveSteve RhodesRhodes [s[sic]”ic]” “will“will bebe de-indexedde-indexed usingusing ourour propriproprietaryetary methods.”methods.” TheThe contractcontract waswas aimedaimed inin

partpart atat “insulating“insulating againstagainst negativenegative GoogGooglele searchsearch results,”results,” specificallyspecifically byby “rem“remov[ing]”ov[ing]” “Steve“Steve RhodesRhodes [sic][sic] articles.”articles.”

B.B. AfterAfter MatthewMatthew ChanChan filedfiled aa motionmotion toto vacatevacate thethe MarylandMaryland statestate courtcourt “consent“consent order,”order,” thethe ostensibleostensible plaintiffplaintiff (Mitul(Mitul Patel)Patel) filedfiled hishis ownown motionmotion toto vacatevacate,, statingstating toto thethe courtcourt thatthat PatelPatel “has“has beenbeen causcauseded toto suffersuffer negativenegative publicitypublicity viavia internetinternet newsnews bblogslogs asas aa resultresult ofof thethe attemptattempt byby thethe papartyrty purportingpurporting toto bebe PlaintiffPlaintiff MITULMITUL R.R. PATEL’sPATEL’s attemptsattempts toto havehave negativenegative reviewsreviews ofof [Patel’s][Patel’s] DentalDental practicepractice removedremoved fromfrom internetinternet reviewreview websites.”websites.”

Patel’sPatel’s motionmotion statesstates thatthat PatelPatel diddid notnot acactuallytually filefile thethe lawsuit,lawsuit, andand itit attachesattaches aa letterletter fromfrom Patel’sPatel’s lalawyerwyer toto RichartRichart RuddieRuddie TheThe letterletter allegesalleges thatthat PatelPatel hahadd signedsigned anan SEOSEO contractcontract withwith aa Ruddie-ledRuddie-led entityentity calledcalled “SEO“SEO ProfileProfile DefenseDefense NetworkNetwork LLC,LLC,

andand allegesalleges thatthat thisthis entityentity “a“apparentlypparently forgedforged Dr.Dr. PatePatel’sl’s signaturesignature toto aa ComplaComplaintint andand ConsentConsent Motion.”Motion.” (Patel’s(Patel’s lawyerlawyer hashas steadfastlysteadfastly refusedrefused toto producproducee thethe contractcontract inin question.)question.)

C.C. WeWe likewiselikewise havehave confirmationconfirmation thatthat PrProfileofile Defenders,Defenders, aa RichartRichart RuddieRuddie company,company, waswas hiredhired byby twotwo ofof thethe plaintiffsplaintiffs inin thethe otherother casescases thatthat fitfit thethe patternpattern wewe describeddescribed inin thethe openingopening paragraphs.paragraphs.

D.D. TheThe earliestearliest casecase thatthat wewe couldcould findfind fittingfitting thisthis generalgeneral papatternttern waswas filedfiled inin NovemberNovember 20152015 —— andand itit hadhad asas thethe plaintiffplaintiff RR

DerekDerek RuddieRuddie inin OwingsOwings Mills,Mills, MdMd

appearsappears toto bebe hishis middlemiddle name;name; thethe addresaddresss givengiven inin courtcourt documentsdocuments hashas beenbeen assoassociatedciated withwith RichartRichart RuddieRuddie inin variousvarious

records.records. AndAnd thethe monthlymonthly paymentspayments underunder thethe reputationreputation managementmanagement contractcontract signedsigned byby RescueRescue OneOne FinancialFinancial areare toto bebe

RichartRichart RuddieRuddie waswas apparentlyapparently bornborn inin OwingsOwings MillsMills,, andand DerrekDerrek (though(though withwith twotwo r’s)r’s)

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

mademade toto Ruddie’sRuddie’s companycompany atat aa bankbank locatedlocated inin OwingsOwings Mills.Mills.

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

TheThe defendantdefendant inin thisthis NovemberNovember 20152015 case,case, truetrue toto form,form, couldcould notnot bebe foundfound atat thethe addressaddress listedlisted inin thethe courtcourt documents.documents. TheThe lawsuitlawsuit itselfitself succeededsucceeded inin usingusing aa comment,comment, ostensostensiblyibly derogatoryderogatory ofof RuddieRuddie —— thoughthough itit didn’tdidn’t useuse Ruddie’sRuddie’s lastlast namename —— toto getget aa wholewhole RipOffReport.comRipOffReport.com popostst deindexed.deindexed. (The(The commentcomment wawas,s, “Hey“Hey RichRich whatswhats thethe dealdeal withwith thisthis guyguy youyou recommended?recommended? DoesDoes hehe givegive youyou aa kickkick backback oror something?”)something?”) ThatThat RipOffReportRipOffReport postpost waswas critcriticalical ofof aa lawyer,lawyer, whowho wewe assumeassume waswas thethe mainmain

bbeneficiaryeneficiary ofof thethe NovemberNovember 20152015 lawsuit.lawsuit. TheThe lawyerlawyer hashas declineddeclined toto saysay whetherwhether hehe hadhad anyany reputationreputation managementmanagement agreementagreement withwith Ruddie.Ruddie.

Indeed,Indeed, aa fewfew daysdays afterafter thisthis lawslawsuituit waswas filed,filed, aa ProfileProfile DefendersDefenders presspress releaserelease announced,announced,

ProfileProfile DefendersDefenders LawsuitLawsuit RemovalRemoval serviceservice honorshonors aa guaranteeguarantee toto taketake downdown andand [sic][sic] defamatorydefamatory oror unwantedunwanted webpageswebpages fromfrom searchsearch resuresultslts asas longlong asas theythey meetmeet specificspecific criteria….criteria…. TheThe futurefuture ofof onlineonline reputationreputation managementmanagement isis movingmoving intointo permanentpermanent removals….removals…. TheThe ProfileProfile DefendersDefenders lawsuitlawsuit removalremoval serviceservice isis nownow availableavailable andand pricingpricing startsstarts atat $6,000….$6,000…. LegalLegal servicesservices providedprovided byby thethe profileprofile defendersdefenders teamteam andand inin househouse councilcouncil [sic][sic] havehave provenproven toto bebe successful….successful….

WeWe askedasked RuddieRuddie andand SEOSEO ProfileProfile DefendersDefenders severalseveral timestimes toto comment,comment, butbut ththeireir onlyonly response,response, toto ourour initialinitial inquiryinquiry aboutabout PPatelatel,, was,was, “We“We denydeny thesethese allegationsallegations andand wewe havehave nono furtherfurther commcomment.ent. WhenWhen andand ifif wewe dodo wewe willwill contactcontact you.”you.” But,But, toto givegive themthem thethe lastlast word,word, herehere isis somethingsomething fromfrom RichartRichart RuddieRuddie EntrepreneurialEntrepreneurial BlogBlog,, dateddated Sept.Sept. 8,8, 2016:2016:

JustJust bebe aa goodgood perspersonon –– RichartRichart RuddieRuddie

HadHad oneone ofof thethe nicestnicest complimentscompliments thisthis pastpast weekend.weekend. AA newnew friendfriend saidsaid “Chart“Chart dodo youyou knowknow whywhy II likelike you?”you?”

“At“At thethe endend ofof thethe dayday you’reyou’re justjust aa genuinegenuine personperson RichartRichart Ruddie”Ruddie” ….….

** ** **

EugeneEugene VolokhVolokh isis aa lawlaw profesprofessorsor atat UCLAUCLA SchoolSchool ofof Law.Law. PaulPaul AlanAlan LevyLevy isis anan attorneyattorney atat PublicPublic CitizenCitizen LitigationLitigation Group.Group.

anan attorneyattorney atat PublicPublic CitizenCitizen LitigationLitigation Group.Group. 5 of 5 10/11/2016 12:54 AM

Profile Defenders and Richart Ruddie: The Common Link Between Two

http://pubcit.typepad.com/clpblog/2016/10/profile-defenders-and-richart

Monday, October 10, 2016 Profile Defenders and Richart

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.

for payments into a bank in Owings Mills, could explain why so many of the phony cases have been filed there.

The facts that Richart Ruddie is a native of Owings Mills, a suburb of Baltimore, and that his contract calls

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] de-indexed using our proprietary methods," thus "insulating against negative Google search results," specifically directed to Steve Rhodes [sic] articles" from search engine results.

will be

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

Profile Defenders and Richart Ruddie: The Common Link Between Two

http://pubcit.typepad.com/clpblog/2016/10/profile-defenders-and-richart

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.

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.

Because both Steve Rhode and

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).

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.

The lawyer in a Florida case filed to secure de-indexing of a blog post about a

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