September 21, 2023

Re: Cease and Desist Demand

To Owner of Account @OwenShroyers:

I write on behalf of J. Owen Shroyer, my client, to demand that you, the owner of the
account operating under the name “Owen Shroyer” (username “@OwenShroyers”) on the
platform X Corp. (“X”), immediately cease the misappropriation of Mr. Shroyer’s identity and
defamation of his character in violation of Texas state law.

Over the course of nearly a year, you have engaged in crude, derogatory, and
inappropriate commentary on X while using Mr. Shroyer’s name and image. On several
occasions, you have impersonated Mr. Shroyer and misled other X users, many of whom know
Mr. Shroyer personally and/or professionally, to believe that you represent his identity and
opinions. In doing so, you are actively damaging Mr. Shroyer’s reputation and professional
credibility as a reporter, journalist, and media personality.

Texas law recognizes a right of publicity that protects the name or likeness of living
persons. See Henley v. Dillard Dep’t Stores, 46 F.Supp.2d 587 (N.D. Tex. 1999); see also Brown
v. Ames, 201 F.3d 654 (5th Cir. 2000). By impersonating Mr. Shroyer and using his name,
images, and other uniquely identifiable characteristics in your bio, and benefitting from that
impersonation by garnering followers and representing your opinions as his, you have engaged in
illegal activity by misappropriating Mr. Shroyer’s identity without permission and falsely
representing your profile as Mr. Shroyer’s official account.

This letter serves as a formal legal demand that you immediately cease publishing content
under Mr. Shroyer’s name, remove Mr. Shroyer’s name from your account and X handle,
remove all images of Mr. Shroyer from your profile, erase all elements used to impersonate Mr.
Shroyer’s identity from your bio, and clearly signify that you are not and have never been
affiliated with Mr. Shroyer by indicating that you are a “parody” or “fake” account in both your
name and bio.

Failure to timely comply will result in further legal proceedings, including filing a civil
action and seeking the disclosure of your identity from X.

Regards,

/s/ Lexis Anderson

Lexis Anderson, Esq.