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www.brownattorneys.com

Apr 22, 2022

VIA EMAIL AND US MAIL

Attn: Cynthia Brill, General Counsel
Attn: Steven Brill, Co-CEO
Attn: Gordon Crovitz, Co-CEO
NewsGuard Technologies, Inc.
25 W. 52nd Street, 15th Floor
New York, NY 10019
Email: cynthia.brill@newsguardtech.com
Email: gordon.crovitz@newsguardtech.com
Email: steven.brill@newsguardtech.com

Re: The Sons of Liberty - Sons of Liberty Media: Defamatory Statements Published by
Your Organization, Reckless Disregard of the Truth

Dear Mr. Brill, Ms. Brill, and Mr. Crovitz:

Please be advised that we represent Sons of Liberty Media in connection with the
above-referenced matter.

I'm writing to you about an eleven-page document published through your website,
https://www.newsguardtech.com/ in January 2022, a copy of which is attached hereto
as Exhibit A.

While I do not have the time or inclination to get involved in a full-fledged tit-for-tat of
each inaccuracy spread throughout the published document and falsely attacking my
client, allow me to briefly touch upon several prominent examples of falsehood and
deceptive innuendo spewed forth by your publication.
NewsGuard Technologies, Inc.
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April 22, 2022
Page 2

At the bottom of the page, beginning with a section entitled “Credibility,” you start by
claiming that” SonsOfLibertyMedia.com has repeatedly published false information,
including about the COVID-19 Pandemic and the 2020 U.S. Presidential election. Yet,
you fail to show what, specifically, is false.

On your false claim about Sons of Liberty’s election-fraud reporting, you try to beef up
your attack against my client with ambiguous conclusions such as unnamed “top
election officials in all 50 states,” or unspecified “numerous federal officials” and
“independent observers” -- whoever they are -- have “affirmed the integrity of the 2020
election” all to point to your opinion that certain unidentified claims made by
SonsOfLibertyMedia.com are allegedly “false.”

Your libelous attack is wholly void of legitimate issues concerning the election that
thousands of Americans have raised, only to have their voices suppressed. For
example, you fail to address massive vote switches shown on television on election
night, right in front of the eyes of millions of Americans, such as the infamous “30,000
vote switch” in Pennsylvania that has yet to be meaningfully addressed, a screenshot
which is pasted below.

Your attack against SonsOfLiberty also fails to address data, directly from the New York
Times showing votes which appear to be systematically siphoned from Trump. Please
see below:
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You fail to cite real, significant issues such as the federal case of Curling v.
Raffslesberger, brought against the Georgia Secretary of State, involving the
vulnerabilities of the Dominion Voting system, in which Obama appointee, Hon. Amy
Totenberg, found, among other things, that “These risks are neither hypothetical nor
remote under the current circumstances. The insularity of the Defendants’ and
Dominion's stance here in the evaluation and management of the security and
vulnerability of the BMD system does not benefit the public or citizens’ confident
exercise of the franchise. https://casetext.com/case/curling-v-raffensperger-3

Certainly you must be aware that not only did Rachel Maddow of MSNBC initially
support this lawsuit, raising concerns over the security of the Dominion Systems, but so
did the Atlanta Journal-Constitution, and concerns were raised by liberal members of
the Congress such as Elizabeth Warren, Amy Klobuchar, and others.

I’m sure you also know that Judge Totenberg subsequently SEALED this case without
credible explanation, which only raises more questions in the eyes of many Americans
about the reliability and susceptibility of computerized voting. And you would falsely
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attack and continue to lampoon good Americans like my client, who continue to raise a
plethora of legitimate, unanswered questions?

You fail to address the issue of unverified dropboxes scattered in major metropolitan
areas like Atlanta and other cities, or well over a thousand affidavits raised by witnesses
in places like the TGF Center in Detroit and the State Farm Center in Atlanta.

While citing several vague, unidentified sources expressing their opinions on the
so-called integrity of the election, you conveniently fail to point out that one court in the
United States has addressed many of these election fraud issues on the merits.
Dismissals based upon either “standing” or mootness do not address the substance of
any of these underlying claims.

You ignore and ultimately fail to address video evidence of unaccounted for ballots
being brought into the TFG center in Detroit in the middle of the night, or video of Fulton
County election workers pulling crates of ballots hidden under long tables in the middle
of the night, and begin counting after Republican election workers have been sent
home.

You ignore ballot evidence and unsupported mathematical impossibilities concerning

several districts and states where more people voted than are in those areas, or where
a ninety-plus percent Biden vote over multiple precincts becomes a statistical
impossibility. See, e.g., Fulton County, Georgia, and large swaths of precincts in
Philadelphia and Detroit.

Your failure to acknowledge the other side, full of legitimate factual concerns about
election integrity, goes on and on. And yet, with a dense, sweeping, anti-intellectualism,
you cast lazy, overly generalized, and unsubstantiated claims of “false stories about
COVID-19 and the 2020 Presidential Election.”

Likewise, your attempted swipe against Sons of Liberty for alleging false stories about
COVID-19 is a weak, lightweight, and largely unsupported ruse of an excuse to engage
in false smearing. For example, you attack an October 2021 article entitled, “Yep, The
entire China Joe Biden booster shot with Staged (Video).” You go on to say that “The
NewsGuard Technologies, Inc.
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Sons of Liberty Article said Biden’s booster appointment was held on what appeared to
be a “Hollywood movie set.”

Then, after trying to make it appear that the whole movie set claim was somehow false,
you go on to contradict yourself by saying, “The event did occur on a set in the
Eisenhower Executive Building’s South Court Auditorium, which is located next to the
White House’s West Wing.”

So, on the one hand, you attempt to lampoon the notion that Biden actually received his
shot on a set, as Sons of Liberty reported, but on the other hand, buried within your own
article, you concede that the shot was in fact given on a set, essentially admitting that
the allegation was truthful, after implying that it was somehow untruthful.

You have openly contradicted yourself in coming to a conclusion that is internally

illogical. Surely you can do better than this.

Indeed, it appears that most of what NewsGuard claims as inaccurate comes from
cherry-picking and choosing out-of-context mockingbird media attributions, mixing and
matching whatever you need to construct a false and/or deceptive claim, such as the
voting numbers from Wisconsin.

And then, you attack my client on the topic of January 6, claiming that “there is no
evidence that Antifa led the mob on January 6.”

No evidence?

Perhaps you would have us believe that these black-uniformed, black-hooded

vigilantes, ostensibly among the first to break into the United States Capitol, as shown
below, are Trump supporters?
NewsGuard Technologies, Inc.
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Perhaps I’m missing something. But I see no red MAGA hats among this, ostensibly the
vanguard among the infiltrators. These infiltrators are wearing the garb of Antifa and/or
Black Lives Matter, who have been known to reap real destruction. And yet, you
recklessly excoriate my client and sloppily claim there is “no evidence” to support their
claim about Antifa's involvement.

No evidence?

Please.

You act as if the former U.S. Capitol Police Chief, Steven Sund, never testified before
Senator Ron Johnson’s committee that, "The assessment indicated that members of the
Proud Boys, white supremacist groups, Antifa, and other extremist groups were
expected to participate on January 6, and that it may be inclined to become violent."

Instead, you again opt for an intellectually lazy, sloppily-inaccurate “there is no

evidence” meme, all in an effort, solely, to falsely discredit my clients.

You also claim, recklessly, that Sons of Liberty’s reporting on vaccines and autism is
inaccurate despite verifiable evidence and testimony in several articles by those who
have witnessed the studies confirm. In that effort, you cite both the WHO and the CDC,
organizations whose ever-moving and changing stories on masks, social distancing,
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lockdown, etc., have significantly damaged their reputations and credibility in a post
COVID world.

I also note that you totally ignore the affidavit of Dr. Andrew Zimmerman. This pediatric
neurologist originally served as the expert medical witness for the government, which
defended vaccines in the federal Vaccine Court. Dr. Zimmerman initially concluded that
there was no link between the covid vaccines and autism.

However, upon further research, he signed a sworn affidavit that he had discovered
“exceptions in which vaccinations could cause autism.” He says he told a group of DOJ
lawyers that “in a subset of children, vaccine-induced fever and immune stimulation did
cause regressive brain disease with features of autism spectrum disorder.”

The publication, The Hill, reports that “The U.S. vaccine court has paid $4 billion to date,
including for injuries in which children ended up with autism but when the plaintiff’s
alleged the brain injury using the term “encephalopathy” rather than “autism.”
https://bityl.co/Bkoe

While you might not like or approve of the evidence on this point, to claim that “no
evidence exists,” and thus to impugn my client, is beyond disingenuous. Moreover, the
misrepresentation of the Soros-funded lab story is also quite telling. You acknowledge
that Mr. Soros funded the lab laboratory, or at least, as you say, “Soros was a
shareholder in WuXi, a pharmaceutical company that does have a branch in Wuhan.”

From that acknowledgment, you go on with a strawman argument insinuating that Sons
of Liberty claimed that Soros was directly responsible for COVID viral manipulation.
That claim was not made. So, once again, you are not being honest about what the
article actually states.

You say that my client’s claim that the alleged "virus" was engineered is false. And yet,
a plethora of evidence exists supporting the notion that it was engineered.

See, e.g., “‘Damning’ science shows COVID-19 likely engineered in lab: experts, the
New York Post, June 6, 2021;” “Fauci was warned that COVID-19 may have been
‘engineered,’ emails show,” the New York Post, June 2, 2021; SMOKING GUN Covid
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was ‘engineered by scientists for carnage’ and may have infected Patient Zero after
MONKEY BITE, book claims,” The Sun, September 29, 2021; “Ex-MI6 boss says
coronavirus likely engineered in Wuhan lab.” Fox News, June 4, 2020.

And the list goes on and on, with multiple outlets reporting on the virus having been
engineered. Yet, despite these numerous reports, your publication isolated Sons of
Liberty as if it is the only outlet ever to report on the “virus” having been engineered.

Clearly, your eleven-page missive is nothing more than a cherry-picked hit-piece full of
defamatory allegations demonstrating a reckless disregard for the truth, meaning that
you don’t have vicarious First Amendment Protection against a libel suit for much of
what you wrote.

It is evident that your philosophical bent is not the same as my clients. That is fine, and
that is your right, but that doesn’t give you a right to employ defamation.

You are certainly welcome and free to take up debate on issues for which you disagree.
But when you claim that “Sons of Liberty has repeatedly published false information,”
that is an alleged statement of fact, not opinion, and goes far beyond the line by
stepping into the quicksand of defamation and quickly tossing journalistic integrity in the
trash can.

We expect a prompt retraction and will be looking forward to your response.

Kind regards,

Donald M. Brown, Jr., Esq.

Attorney for Sons of Liberty Media

DMB/tg
Enclosure
Cc: Mr. Bradlee Dean