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Manchanda Law Offices, PLLC Et Al v. Xcentric Ventures, LLC Et Al - Document No. 6
Manchanda Law Offices, PLLC Et Al v. Xcentric Ventures, LLC Et Al - Document No. 6
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Case 1:07-cv-06708-LLS Document 6 Filed 10/10/2007 Page 1 of 35
Introduction
Dockets.Justia.com
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legitimate businesses.
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other companies.
Jurisdiction
U.S.C. §1367.
Arm Statute, N.Y. Civ. Prac. L.&R. §302, all claims for relief in
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acts.
Long Arm Statute, N.Y. Civ. Prac. L.&R. §302, all claims for relief
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acts.
Venue
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the District.
District;
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existing under the laws of New York, with its principal place of
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the Websites.
residing for years in the city of Tupper Lake, New York. Magedson
has operated businesses in the state of New York and has owned
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DOE Defendants
through discovery.
its service marks, MANCHANDA LAW OFFICES and RAHUL MANCHANDA (the
under the Marks in interstate commerce since March 2002, and has
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like CNN, Fox News, MSNBC, the Today Show and other nationally
Manchanda’s services.
the Websites.
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targeted businesses.
each day.
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the consumer.
Websites.
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reports are left up, we think that removal of any reports would
ultimately make this site less credible and thus less effective as
a tool for educating consumers. That's why we have made this strict
policy decision.”
The Ripoff Report Defendants encourage such postings and urge users
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Marks, to cause search engines like Google to index pages for the
search for the Marks in Google’s search engine, Google lists the
Websites as one of the top search results. Consumers then view the
results.
1
Search engine indexing, also known as web indexing, involves the
collection, parsing and storage of data for fast and accurate retrieval.
Retrieval of data in an index is reflected, in Internet search engines, as
a list of links on a web page in response to a query for a word or phrase.
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meaning that within just a few days or weeks, your report may be
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individual.”
47. Under the CAP program, the Ripoff Report Defendants claim
they will verify every consumer complaint by two emails and a phone
are conspicuously not involved in, nor copied on, the supposed
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do anything once a business has signed up and paid for the CAP
program, other than take the businesses’ money. The Ripoff Report
Defendants know that their Websites are replete with defamatory and
that they can easily conclude that most if not all of the relevant
have used and invested the income they have derived through the CAP
Websites.
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nature of the complaints posted on the Websites, and are aware that
for millions of users to see; and statements that the Ripoff report
protection.
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Websites
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· Please stay away from this law firm, they are cons!
· They do not know the basic law and rules when it comes
to i20 student and h1b visas.
· ...that gives them the power to charge you whatever
· I was told verbally that I would only pay one fee for
what I needed to get done, until I got another bill in
the mail.
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false.
· Please stay away from this law firm, they are cons!
false.
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false.
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Plaintiffs’ Damages
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Count I
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Count II
should have known they were false when he published them on the
Websites.
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Count III
U.S.C. §1962(c).
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including Plaintiffs.
fear that, if the money is not turned over, they would cause damage
81. Under New York Penal Law, Grand Larceny in the Second
interstate commerce.
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Count IV
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Count V
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carrier and informs them that an purchase was made on his or her
the company and refunds the individual the money that was charged.
companies that his readers and users are unhappy with. Shortly
after his own posting on the Website, Rana informed his credit card
company that Plaintiffs had unlawfully charged his credit card the
Tortious Interference with a Contract under New York Common Law and
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follows:
92. That the Court enter judgment against Defendant Rana that
and Madgeson that they have violated the Racketeer Influenced and
1962(c).
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service marks.
according to proof;
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to 15 U.S.C. §1117(a).
foregoing sums.
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Respectfully submitted,
By: /S/
Rahul D. Manchanda, Esq.
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