DOCSLIB.ORG

Larry Klayman Larry Klayman, Esq

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Larry Klayman Larry Klayman, Esq No. 21 - _________ IN THE SUPREME COURT OF THE UNITED STATES Freedom Watch, Inc. and Laura Loomer Petitioners v. Google, Inc., Facebook, Inc., Apple, Inc., and Twitter, Inc. Respondents On Petition for a Writ of Certiorari to the United States Court of Appeals for the District of Columbia Circuit PETITION FOR WRIT OF CERTIORARI /s/ Larry Klayman Larry Klayman, Esq. Klayman Law Group, P.A 2020 Pennsylvania Avenue N.W. Suite 800 Washington, D.C. 20006 (561)558-5336 [email protected] i QUESTIONS PRESENTED 1. Did the U.S. Court of Appeals for the D.C. Circuit err by failing to find that the District of Columbia Human Rights Act’s prohibition on political discrimination does not require a physical location? 2. Did the U.S. Court of Appeals for the D.C. Circuit err by failing to find that Respondents are subject to the First Amendment to the Constitution? 3. Did the U.S. Court of Appeals for the D.C. Circuit err by failing to find that Respondents had violated the Sherman Act? ii TABLE OF CONTENTS Petition for Writ of Certiorari ................................................................... 1 Opinions Below ......................................................................................... 1 Jurisdiction ............................................................................................... 1 Constitutional Provisions Involved .......................................................... 2 Statement of the Case ............................................................................... 2 Reasons for Granting the Writ ................................................................. 7 This Case Raises Crucial Constitutional Issues That Must Be Addressed, Especially Considering the Current COVID-19 Pandemic ......................................................................................... 7 The D.C. Circuit’s Ruling on Petitioners’ First Amendment Claims Does Not Comport With this Court’s Recent Ruling in Packingham v. North Carolina, 137 S. Ct. 1730 (2017) ..................................... 12 The D.C. Circuit’s Rulings on Petitioners’ Antitrust Claims Are Erroneous and Do Not Consider Recent Lawsuits Brought by the United States of America Against Respondents ..................... 15 Section 1 Claims ................................................................... 16 Section 2 Claims ................................................................... 24 Conclusion ............................................................................................... 27 iii TABLE OF AUTHORITIES Cases Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009) ................................................ 21 Aspen Skiing Co. v. Aspen Highlands Skiing Corp, 472 U.S. 585 (1985) ........................................................................... 24, 25 Atl. Coast Airlines Holdings, Inc. v. Mesa Air Grp., Inc., 295 F. Supp. 2d 75 (D.D.C. 2003) ...................................................................................... 16 Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) ................. 20, 22, 27 Carparts Distribution Ctr. v. Auto. Wholesaler's Ass'n, 37 F.3d 12 (1st Cir. 1994) ................................................................................... 10, 11 City of Moundridge v. Exxon Mobil Corp., 471 F. Supp. 2d 20 (D.D.C. 2007) ........................................................................................................ 24 Del-Orden v. Bonobos, Inc., 2017 U.S. Dist. LEXIS 209251 (S.D.N.Y. Dec. 20, 2017) .......................................................................................... 10 Fed. Trade Com. v. Lukens Steel Co., 454 F. Supp. 1182 (D.D.C. 1978) ...................................................... 17, 20 National Federation of the Blind v. Scribd Inc., 97 F. Supp. 3d 565 (D. Vt. 2015) ............................................................................................ 10 Packingham v. North Carolina, 137 S. Ct. 1730 (2017) ............. 12, 13, 27 Statutes District of Columbia Human Rights Act ................................. 8, 9, 11, 12 iv PETITION FOR WRIT OF CERTIORARI Freedom Watch, Inc. (“Freedom Watch”) and Laura Loomer (“Ms. Loomer”) (collectively “Petitioners”), by and through Larry Klayman, Esq., respectfully petition this Court for a writ of certiorari to review the order of the order of the U.S. Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) OPINIONS BELOW On August 5, 2020, the D.C. Circuit issued a per curiam order denying Petitioners’ Petition for Rehearing En Banc. App. 121. On May 27,2020, the D.C. Circuit issued a per curiam judgment affirming the ruling of the U.S. District Court for the District of Columbia. App. 117 - 120. JURISDICTION The D. C. Circuit issued a per curiam order denying Petitioners’ Petition for Rehearing En Banc. App. 121. Pursuant to the Court’s March 19, 2020 order regarding filing deadlines due to the ongoing COVID-19 pandemic, Petitioners ‘s Petition for Writ of Certiorari must 1 be filed within 150 days from the date of the order denying petition for rehearing, which is January 4, 2021.1 CONSTITUTIONAL PROVISIONS INVOLVED United States Constitution, Amendment I: Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances. STATEMENT OF THE CASE Petitioners brought this suit against Respondents, all of whom are major technology and social media corporations, in response to their well-documented and publicized anti-competitive pattern and practice of suppressing and censoring conservative content. The Amended Complaint sets forth in extreme detail news publications which include admissions from employees employed by Respondents that such targeted suppression and censorship was, indeed, occurring. For example, this includes admissions, inter alia, from employees of 1 The exact date is January 2, 2021, which is a Saturday. 2 Respondent Facebook that their conduct had a chilling anti-competitive effect on conservative news.” App. 008. As set forth below, Respondents’ conduct violates not only the Constitution, but also numerous federal and state statutes. Respondents’ status as large and influential technology corporations, who can pay for and employ well-funded lobbyists to do their bidding, simply cannot shield them from liability in this regard. They must be held to the same level playing field as everyone else. This Amended Complaint is centered upon Respondents’ “conspiracy to intentionally and willfully suppress politically conservative content,” App. 004, and the resulting severe damages that this conspiracy has had on Freedom Watch and Ms. Loomer, both of whom are prominent conservative organizations/figures who rely on social media platforms to “to inform the public about [their] conservative advocacy and to raise the funds through donations to further its public advocacy and mission.” App. 011. The aim of this conspiracy to use anti-competitive means to suppress politically conservative content was to “take down President Donald Trump and 3 his administration with the intent and purpose to have installed leftist government in the nation’s capital and the 50 states.” App. 017. The Amended Complaint sets forth in detail how Respondents have acted anticompetitively to suppress and censor conservative content. For instance, YouTube, which is owned and operated by its parent company, Respondent Google, demonetized the channels of the conservative Prager University and Western Journal and also targeted conservative pundit Alex Jones of InfoWars due to their conservative political viewpoints. App. 006 - 007. Furthermore, the Amended Complaint details how Google has censored conservative content via its search engine, with “an incredible 96% of Google search results for ‘Trump’ news came from liberal media outlets, using the widely accepted Sharyl Attkisson media bias chart.” App. 007. Indeed, only recently, whistleblowers and former employees revealed how Google was trying to “influence the 2020 election process against Trump.” One stated, “[t]hey have very biased people running every level of the company…. They have quite a bit of control over the political process. That's something we should really worry about. They really want 4 Trump to lose in 2020. That's their agenda."2 And, after this case was filed the Antitrust Division of the U.S. Department of Justice, as well as tens of attorneys general throughout the states, sued these unbridled social media companies in a manner similar to Petitioners – who were ahead of the pro-competitive curve. The Amended Complaint thus sets forth in detail how Facebook has in concert with other social media giants anticompetitively censored and suppressed conservative content, including through the admissions of it former employees who admitted that they “routinely suppressed news stories of interest to conservative readers from [its] influential ‘trending’ news section” App. 008. In 2018, Facebook instituted an algorithm change that further suppressed conservative content. App 009. According to a study by Western Journal, “Liberal publishers have gained about 2 percent more web traffic from Facebook than they were getting prior to the algorithm changes implemented in early February. On the other hand, conservative [and thus Republican] publishers have lost an average of nearly 14 percent of their traffic from Facebook.” App 2 https://www.newsweek.com/google-engineer-anti-trump-conservative-
Load more

Recommended publications
  • In United States District Court for the District of Columbia
    Case 1:13-cv-00851-RJL Document 13-1 Filed 10/29/13 Page 1 of 31 IN UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA LARRY KLAYMAN, et. al Plaintiffs, v. BARACK HUSSEIN OBAMA II, et. al Defendants. Civil Action No. 13-CV-851 PLAINTIFFS' MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF THEIR MOTION FOR PRELIMINARY INJUNCTION I. INTRODUCTION On June 9, 2013, Plaintiffs filed suit challenging the legality of Defendants’ secret and illicit government scheme to systematically gather, intercept and analyze vast quantities of domestic telephonic communications and “metadata” wholly within the United States by implementing a highly classified, unlawful mass call tracking surveillance program. Compl. ¶2. On April 25, 2013, Defendant Honorable Roger Vinson, a judge of the U.S. Foreign Intelligence Surveillance Court (“FISC”), issued a top-secret order compelling the disclosure of all call detail records in possession of Verizon Telecommunication for analysis by the National Security Agency (“NSA”) on an ongoing daily basis.1 On June 5, 2013, based on the disclosures of whistleblower, Edward Snowden, who fled the United States for fear of government reprisal, The Guardian publicly revealed this previously classified order in an article entitled “NSA collecting phone records of millions of Verizon customers daily. Exclusive: Top secret order 1 Compl. ¶26; See, In re Application of the FBI for an Order Requiring the Production of Tangible Things from Verizon Bus. Network Servs., Inc. on Behalf of MCI Commc’n Servs., Inc. d/b/a Verizon Bus. Servs., No. BR 13-80 (FISA Ct. Apr. 25, 2013) (“Verizon Order”).
    [Show full text]
  • Spencer Sunshine*
    Journal of Social Justice, Vol. 9, 2019 (© 2019) ISSN: 2164-7100 Looking Left at Antisemitism Spencer Sunshine* The question of antisemitism inside of the Left—referred to as “left antisemitism”—is a stubborn and persistent problem. And while the Right exaggerates both its depth and scope, the Left has repeatedly refused to face the issue. It is entangled in scandals about antisemitism at an increasing rate. On the Western Left, some antisemitism manifests in the form of conspiracy theories, but there is also a hegemonic refusal to acknowledge antisemitism’s existence and presence. This, in turn, is part of a larger refusal to deal with Jewish issues in general, or to engage with the Jewish community as a real entity. Debates around left antisemitism have risen in tandem with the spread of anti-Zionism inside of the Left, especially since the Second Intifada. Anti-Zionism is not, by itself, antisemitism. One can call for the Right of Return, as well as dissolving Israel as a Jewish state, without being antisemitic. But there is a Venn diagram between anti- Zionism and antisemitism, and the overlap is both significant and has many shades of grey to it. One of the main reasons the Left can’t acknowledge problems with antisemitism is that Jews persistently trouble categories, and the Left would have to rethink many things—including how it approaches anti- imperialism, nationalism of the oppressed, anti-Zionism, identity politics, populism, conspiracy theories, and critiques of finance capital—if it was to truly struggle with the question. The Left understands that white supremacy isn’t just the Ku Klux Klan and neo-Nazis, but that it is part of the fabric of society, and there is no shortcut to unstitching it.
    [Show full text]
  • Laura Loomer Exceeds Pre-Ban Twitter Following on Parler with 300K Followers
    This publication is not affiliated with Laura Loomer for Congress. For more information visit LauraLoomerforCongress.com HOME TIP LINE CONTENT BY CATEGORY GET MY EMAILS DONATE SHOP ADVERTISE WITH US CONTACT ME SEE LAURA LOOMER ON DRUDGE REPORT Laura Loomer Exceeds Pre-Ban Twitter Following on Parler With 300k Followers Haley Kennington P O S T E D O N J U N E 2 4 , 2 0 2 0 SUPPORT LAURA’S WORK Share On Facebook Tweet It GET LAURA’S NEWSLET T ER This week marks a special milestone for investigative journalist and now Republican Congressional candidate in Florida District 21, Laura Loomer. After having been permanently banned from Twitter, Loomer moved over to free speech social media platform Parler, and not only brought her followers with her, but has now exceeded the amount of followers she had “pre-ban” on Twitter in 2018. Join Our Newsletter Enter your email Subscribe Privacy - Terms FOLLOW ME ON PARLER! FOLLOW ME ON T ELEGRAM! Loomer announced the landmark achievement Wednesday in a post on Parler: “I just became the first deplatformed person to exceed my Pre-Ban Twitter following here on @parler. When I was banned, people on the Left and Right cheered on the digital extermination of my persona. They said my career was over. FOREVER. Yet, here I am. SUBSCRIBE T O MY YOUT UBE CHANNEL Through my historic and unprecedented Congressional race in Florida’s 21st Congressional District, I am proving everyone wrong while making history. I’m on a mission to CANCEL CANCEL CULTURE and get elected to the United States Congress to ensure that no other American citizen is ever silenced the way I’ve been silenced.
    [Show full text]
  • View Complaint
    SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Vincent Forras, on behalf of ) himself and all others of and in ) the City of New York, County ) of New York, similarly ) COMPLAINT situated, ) ) Index No. Plaintiff, ) v., ) ) Feisal Abdul Rauf, and ) Cordoba House/Park51, ) Cordoba Initiative, Soho ) Properties, and all other aliases ) known and unknown Defendants. FACTS COMMON TO ALLEGATIONS The Lead Plaintiff, Vincent Forras, and other members of the class similarly situated as set forth below, complain of the Defendants on behalf of himself and these other members of the class of the City of New York, County of New York, similarly situated, and alleges as follows: 1. Defendant Feisel Abdul Rauf (hereafter ―Feisel‖) is an individual and on information and belief, at all times mentioned herein resides in the City of New York, State of New York. 2. Defendant Cordoba House/Park51 is an entity whose true and correct form is unknown to the Lead Plaintiff at this time. On information and belief, at all times mentioned herein Cordoba House/Park51’s principal place of business is and was located at 51 Park Place, in the city of New York, State of New York. 3. Defendant Cordoba Initiative is an entity whose true and correct form is not fully known to the Lead Plaintiff and other members of the class at this time. On information and belief, at all times mentioned herein Cordoba Initiative’s principal place of business is and was located at 475 Riverside Drive, Suite 248 in the City of New York, State of New York.
    [Show full text]
  • The Early History of the Black Lives Matter Movement, and the Implications Thereof
    18 NEV. L.J. 1091, CHASE - FINAL 5/30/18 2:29 PM THE EARLY HISTORY OF THE BLACK LIVES MATTER MOVEMENT, AND THE IMPLICATIONS THEREOF Garrett Chase* INTRODUCTION From quarterbacks to hashtags, from mall demonstrations to community vigils, and from the streets of New York to the courts of Texas, the Black Lives Matter movement undisputedly has made its mark on America’s consciousness. But what is this “movement”? Where did it come from? Does Black Lives Mat- ter stand for civil rights, or human rights? What are the movement’s goals? What are its motivations? With the onslaught of media attention given to Black Lives Matter, I found the magnitude of these questions troubling. Black Lives Matter has garnered widespread awareness; yet, many know almost nothing about its origins. Black Lives Matter’s ultimate place in the historical narrative of our time is uncertain. Part viral social phenomenon, part civil rights move- ment, Black Lives Matter draws on common themes from previous civil rights movements, but is a marked departure from previous chapters of the centuries- long struggle for Black freedom and equality in America. As a matter of clarification, and with all due respect to those who were re- sponsible for the inception of the Black Lives Matter (“BLM”) movement, this Note addresses Black Lives Matter in the context of America’s history of civil rights movements. In an article for Time Magazine, one of the originators of the movement, Opal Tometi, specified that the aspirations of the movement go be- yond civil rights and that the movement characterizes itself as a human rights movement for “the full recognition of [Blacks’] rights as citizens; and it is a battle for full civil, social, political, legal, economic and cultural rights as en- * Associate Attorney at Shumway Van and William S.
    [Show full text]
  • Luhn-V-Scott.Pdf
    UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA LAURA WILLIS LUHN, Plaintiff, v. No. 19-cv-1180 (DLF) SUZANNE GUNDERSON SCOTT, et al., Defendants. MEMORANDUM OPINION Laura Luhn brings this suit against Fox News Network, LLC and its CEO, Suzanne Gunderson Scott. Compl., Dkt. 1. Luhn’s amended complaint asserts four causes of action against Fox News and Scott: (1) defamation; (2) defamation by implication; (3) false light invasion of privacy; and (4) intentional infliction of emotional distress. Am. Compl., Dkt. 15. Before the Court is the defendants’ motion to dismiss the amended complaint for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). Mot. to Dismiss, Dkt. 16. For the reasons that follow, the Court will grant the defendants’ motion and dismiss the case. I. BACKGROUND1 A. Luhn’s History at Fox News Luhn began working for Fox News in 1996. Am. Compl. ¶ 31. She spent the next decade and a half enduring extensive and traumatic sexual abuse at the hands of Roger Ailes, the 1 The factual allegations below are drawn from Luhn’s amended complaint. See Banneker Ventures, LLC v. Graham, 798 F.3d 1119, 1129 (D.C. Cir. 2015) (court considering motion to dismiss must “accept all the well-pleaded factual allegations of the complaint as true and draw all reasonable inferences from those allegations in the plaintiff’s favor”). The Court has granted and considered Luhn’s Motion for Leave to File Surreply, Dkt. 19. former CEO of Fox News. See id. ¶ 33. According to Luhn’s complaint, Ailes “demanded, coerced, extorted, blackmailed and forced sexual favors from her.” Id.
    [Show full text]
  • Foreign Surveillance and the Future of Standing to Sue Post-Clapper
    . Foreign Surveillance and the Future of Standing to Sue Post-Clapper Andrew Nolan Legislative Attorney June 14, 2013 Congressional Research Service 7-5700 www.crs.gov R43107 CRS Report for Congress Prepared for Members and Committees of Congress c11173008 . Foreign Surveillance and the Future of Standing to Sue Post-Clapper Summary Recent news accounts (and government responses to those news accounts) have indicated that the government is reportedly engaged in a surveillance program that gathers vast amounts of data, including records regarding the phone calls, emails, and Internet usage of millions of individuals. The disclosures to the media reportedly suggest that specific telecommunication companies have been required to disclose certain data to the government as part of the intelligence community’s surveillance efforts. The recent controversy over the reports of government targeting efforts comes months after the Supreme Court ruled in a case called Clapper v. Amnesty International. In Clapper, the Court dismissed a facial constitutional challenge to section 702 of the Foreign Intelligence Surveillance Act on constitutional standing grounds. Specifically, the Clapper court found that the litigants, a group of attorneys and human rights activists who argued that their communications with clients could be the target of foreign intelligence surveillance, could not demonstrate they would suffer a future injury that was “certainly impending,” the requirement the majority of the Court found to be necessary to establish constitutional standing when asking a court to prevent a future injury. Notwithstanding the Clapper decision, in light of the recent revelations about the government’s intelligence gathering methods, several lawsuits have been filed by individuals who are customers of the companies allegedly subject to court orders requiring the disclosure of data to the government.
    [Show full text]
  • IN the UNITED STATES DISTRICT COURT for the CENTRAL DISTRICT of CALIFORNIA LARRY KLAYMAN, a Natural Person C/O 7050 W. Palmetto
    Case 2:17-cv-00836-JAK-JEM Document 1 Filed 02/02/17 Page 1 of 21 Page ID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA LARRY KLAYMAN, a Natural Person c/o 7050 W. Palmetto Park Rd, #15-287 Boca Raton, FL, 33433 Case No: _______________ Plaintiff, v. BARACK HUSSEIN OBAMA, A Natural Person Washington, D.C. Defendant COMPLAINT I. ! INTRODUCTION AND NATURE OF THE ACTION 1.! This is a civil action for damages against Defendant Barack Obama (“Defendant Obama”) for Assault and Intentional Infliction of Emotional Distress based on Defendant Obama’s and his surrogates, agents and co-conspirators overt actions to incite violence and/or serious bodily harm stemming from President Donald Trump’s January 27, 2017 Executive Order titled Protecting the Nation From Foreign Terrorist Entry into the United States (the “Executive Order”).1 The actions and/or omissions giving rise to Plaintiff Larry Klayman’s causes of action occurred within this judicial district, as set forth below, and were made by Defendant Obama as a private citizen. He thus has no possible claim of immunity from suit. II. ! STANDING AND THE INDIVIDUAL PLAINTIFF PARTIES 2.! Plaintiff Larry Klayman (“Plaintiff”) is a citizen of Florida. Plaintiff is a prominent public-interest attorney and advocate who has been vocal about his pro-Israel and 1 Donald J. Trump, Protecting the Nation From Foreign Terrorist Entry into the United States, The White House, Jan. 27, 2017, available at: https://www.whitehouse.gov/the-press-office/2017/01/27/executive-order-protecting-
    [Show full text]
  • Islamophobia in Reactionary News: Radicalizing Christianity in the United States’ (2019) 5(1): 61 Open Library of Humanities
    Muslims in the Media How to Cite: Montalbano, K 2019 Islamophobia in Reactionary News: Radicalizing Christianity in the United States. Open Library of Humanities, 5(1): 61, pp. 1–49. DOI: https://doi.org/10.16995/olh.473 Published: 16 September 2019 Peer Review: This article has been peer reviewed through the double-blind process of Open Library of Humanities, which is a journal published by the Open Library of Humanities. Copyright: © 2019 The Author(s). This is an open-access article distributed under the terms of the Creative Commons Attribution 4.0 International License (CC-BY 4.0), which permits unrestricted use, distribution, and reproduction in any medium, provided the original author and source are credited. See http://creativecommons.org/licenses/by/4.0/. Open Access: Open Library of Humanities is a peer-reviewed open access journal. Digital Preservation: The Open Library of Humanities and all its journals are digitally preserved in the CLOCKSS scholarly archive service. Kathryn Montalbano, ‘Islamophobia in Reactionary News: Radicalizing Christianity in the United States’ (2019) 5(1): 61 Open Library of Humanities. DOI: https://doi. org/10.16995/olh.473 MUSLIMS IN THE MEDIA Islamophobia in Reactionary News: Radicalizing Christianity in the United States Kathryn Montalbano Young Harris College, US [email protected] The accuracy and relevance of United States print news media has been called into question at increasing rates in the post-truth era. Conservatives, in particular, have long expressed concerns that mass and digital media censor conservative as well as Christian viewpoints while promoting a progressive and, more recently, pro-Muslim, platform.
    [Show full text]
  • Klayman V. Obama
    Case 1:13-cv-00881-RJL Document 30 Filed 11/23/13 Page 1 of 35 IN UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA LARRY KLAYMAN, on behalf of himself and all others similarly situated, 2020 Pennsylvania Ave. NW Suite 800 Washington, DC 20006 and MICHAEL FERRARI, on behalf of himself Civil Action No.: 13-CV-881 and all others similarly situated, Santa Clara, CA and CHARLES STRANGE, on behalf of himself and all others similarly situated, Philadelphia, Pennsylvania and MATT GARRISON, on behalf of himself and all others similarly situated, Long Beach, CA Plaintiffs, v. BARACK HUSSEIN OBAMA II, President of the United States 1600 Pennsylvania Ave. NW Washington, DC 20500 and ERIC HIMPTON HOLDER, JR., Attorney General of the United States 555 Fourth St. NW Washington, DC 20530 and 1 Case 1:13-cv-00881-RJL Document 30 Filed 11/23/13 Page 2 of 35 KEITH B. ALEXANDER Director of the National Security Agency, 9800 Savage Rd. Fort Meade, MD 20755 and NATIONAL SECURITY AGENCY, Director of the National Security Agency, 9800 Savage Rd. Fort Meade, MD 20755 and THE U.S. DEPARTMENT OF JUSTICE, 950 Pennsylvania Ave. NW Washington, DC 20530 and FACEBOOK, INC., 156 University Avenue Palo Alto, CA 94301 and MARK ZUCKERBERG, Founder and CEO of Facebook 156 University Avenue Palo Alto, CA 94301 and GOOGLE, 1600 Amphitheatre Parkway Mountain View, CA 94043 and LARRY PAGE CEO of Google 1600 Amphitheatre Parkway Mountain View, CA 94043 and 2 Case 1:13-cv-00881-RJL Document 30 Filed 11/23/13 Page 3 of 35 YOUTUBE INC./LLC, San Bruno, CA and SALAR KAMANGAR CEO of YouTube San Bruno, CA and APPLE, INC., 1 Infinite Loop Cupertino, CA 95014 and TIMOTHY D.
    [Show full text]
  • Opposition to Joint Motion to Dismiss the Complaint
    Case 1:18-cv-02030-TNM Document 34 Filed 02/11/19 Page 1 of 24 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA FREEDOM WATCH, INC, et al Plaintiffs, v. 1:18-cv-02030 GOOGLE, INC, et al ORAL ARGUMENT REQUESTED Defendants. OPPOSITION TO JOINT MOTION TO DISMISS AMENDED COMPLAINT Plaintiffs Freedom Watch, Inc. and Laura Loomer (collectively “Plaintiffs”) submit the following in opposition to Defendants’ Google, Inc. (“Google”), Facebook, Inc. (“Facebook”), Twitter, Inc. (“Twitter”), and Apple, Inc.’s (“Apple”) (collectively “Defendants”) Joint Motion to Dismiss Amended Complaint. ECF No. 29. Dated: February 11, 2019 Respectfully submitted, /s/ Larry Klayman Larry Klayman, Esq. Chairman and General Counsel FREEDOM WATCH, INC. D.C. Bar No. 334581 2020 Pennsylvania Ave. NW, Suite 345 Washington, DC 20006 Tel: (310) 595-0800 Email: [email protected] Attorney for Freedom Watch, Laura Loomer, and the Class i Case 1:18-cv-02030-TNM Document 34 Filed 02/11/19 Page 2 of 24 TABLE OF CONTENTS INTRODUCTION ...........................................................................................................................1 STATEMENT OF RELEVANT FACTS ........................................................................................1 LEGAL STANDARD ......................................................................................................................5 Fed. R. Civ. P 12(b)(1) Standing .................................................................................................5 Fed. R. Civ. P 12(b)(6).................................................................................................................6
    [Show full text]
  • Backlash, Conspiracies & Confrontation
    STATE OF HATE 2021 BACKLASH, CONSPIRACIES & CONFRONTATION HOPE ACTION FUND We take on and defeat nazis. Will you step up with a donation to ensure we can keep fighting the far right? Setting up a Direct Debit to support our work is a quick, easy, and secure pro- cess – and it will mean you’re directly impacting our success. You just need your bank account number and sort code to get started. donate.hopenothate.org.uk/hope-action-fund STATE OF HATE 2021 Editor: Nick Lowles Deputy Editor: Nick Ryan Contributors: Rosie Carter Afrida Chowdhury Matthew Collins Gregory Davis Patrik Hermansson Roxana Khan-Williams David Lawrence Jemma Levene Nick Lowles Matthew McGregor Joe Mulhall Nick Ryan Liron Velleman HOPE not hate Ltd PO Box 61382 London N19 9EQ Registered office: Suite 1, 3rd Floor, 11-12 St. James’s Square, London SW1Y 4LB United Kingdom Tel.: +44 (207) 9521181 www.hopenothate.org.uk @hope.n.hate @hopenothate HOPE not hate @hopenothate HOPE not hate | 3 STATE OF HATE 2021 CONTENTS SECTION 1 – OVERVIEW P6 SECTION 3 – COVID AND CONSPIRACIES P36 38 COVID-19, Conspiracy Theories And The Far Right 44 Conspiracy Theory Scene 48 Life After Q? 6 Editorial 52 UNMASKED: The QAnon ‘Messiah’ 7 Executive Summary 54 The Qanon Scene 8 Overview: Backlash, Conspiracies & Confrontation 56 From Climate Denial To Blood and Soil SECTION 2 – RACISM P14 16 Hate Crimes Summary: 2020 20 The Hostile Environment That Never Went Away 22 How BLM Changed The Conversation On Race 28 Whitelash: Reaction To BLM And Statue Protests 31 Livestream Against The Mainstream
    [Show full text]