Date: Tue, 26 Mar 1996 14:53:54 -0800 To: rnewman@cybercom.net (Ron Newman) From: Grady Ward Ron, Here is the gist of the Complaint that accompanied the TRO: B. Defendant's Violation of Plaintiff's Rights 14. Defendent has been infringing RTC's copyright in each of the Works listed in Exhibit A by reproducing portions of each of these Works and by electronically displaying or distributing them on the Internet, or by loading those works into his computer, all without any authorization from the plaintiff. 15. Plaintiff is informed and believes, and on that basis alleges that, during the past approximately year or more, Ward has, without authorization, anonymous reproduced and/or caused others to reproduce portions of each of the Works listed in Exhibit B, identified on Internet as "SCAMIZDAT" and has, without authorization, electronically displayed or distributed these Works on the Internet and/or caused others to do so, all in violation of plaintiff's rights. 16. Plaintiff is informed and believes, and on that basis alleges that, Ward has copied and/or induced others to copy and has wrongfully acquired and now threatens to and intends imminently to post to the Internet the Works listed in Exhibit C hereto, in whole or in part hereto to the Internet, thereby causing serious, irreparable harm to RTC's copyright and trade secret rights, if not immediately restrained from doing so. The prayer for interlocutory relief below relates to the Works in Exhibit C only. (There are 12 more sections here but they pretty much are redundent or included to logically lead to the paragraphs above. Exhibit A is OTIII and NOTS Series 1. Exhibit B is essentially all issues of SCAMIZDAT extant, Exhibit C are the NOTS not previously displayed in SCAMIZDAT) As far as the sections on Claims for Relief: (1) a permanent injunction on me and "everyone acting in concert or participation" from publishing, reproducing, distributing, performing, or creating derivative works based upon in whole or in part any of the works of L. Ron Hubbard in any media now known or herinafter developed. (2) Impounding of all means by which those infringing copies might be reproduced. (3) For statutory damages in the amount of $100,000 per violation (>$10,000,000) A few more punishments, but you get the idea... :-)