"The Court of Appeal’s ruling overturned the District Court’s ruling and declared that Cox was a journalist and therefore protected by the freedom of speech laws and the First Amendment."

NOW as a Matter of Law and Case Precedence, Due to the Crystal Cox Case ALL Bloggers are Legally Protected to Break the News and Report the News just as any main stream, institutional press Journalist, no matter who they work for.

"JOURNALIST OR BLOGGER: PROTECTED UNDER THE FIRST AMENDMENT OR NOT"

by Thomas Halek

"The opinions of the courts decide whether a blogger is a journalist and afforded the rights provided under the First Amendment.

DEFINITION OF A JOURNALIST

Dr. Anthony Curtis, Mass Communication Dept., University of North Carolina at Pembroke, in an article titled What is Journalism said, “Journalism is the practice of investigating and reporting events, issues and trends to the mass audiences of print, broadcast and online media such as newspapers, magazines and books, radio and television stations and networks, and blogs and social and mobile media.”

"IN THE EYES OF THE COURTS

How the courts have ruled on whether a blogger is a journalist and protected by the First Amendment has varied. In a paper titled, The Future of Online Legal Journalism, written by Christopher J. Davey, the Director of Public Information for the Supreme Court of Ohio, said, “The court speaks only through their opinions.” In the paper, Davey describes how the legal system’s view of on-line journalism has grown and changed since 1964 and the consequences because of it.

OBSIDIAN FINANCE GROUP v. CRYSTAL COX

On Mashable.com a headline reads, “Judge Hits Blogger With $2.5 Million Charge for Not Being a Journalist.” The case is OBSIDIAN FINANCE GROUP v. CRYSTAL COX. In The Atlantic, Robinson Meyer published an article U.S. Court: Bloggers Are Journalists. In the article, Meyer describes the case and the United States Court of Appeals For the Ninth Circuit ruling.

The Court of Appeal’s ruling overturned the District Court’s ruling and declared that Cox was a journalist and therefore protected by the freedom of speech laws and the First Amendment.

EMERITUS PROFESSOR JAMES PIELEMEIER INTERVIEW

Emeritus Professor James Pielemeier, a retired law professor from Hamline University, in an interview said, “It did seem to me that there was a trend towards treating bloggers like journalists in some areas, such as statutory Reporter’s Privileges (e.g. about confidential sources), at least if the statutory language arguably permitted such a result.” Pielemeier also said, “In general, there seemed to be a trend towards treating bloggers like journalists in other areas of first amendment law.”

Source and Full Article; Check it Out.
http://www.thomashalek.com/?page_id=419

A MAJOR Federal Victory by Blogger Crystal Cox paves the way for ALL Bloggers to Be Protected in a Court of Law to REPORT the "NEWS".

"In contrast, media resides in a legal framework that is deeply valued and protected. Since before theFirst Amendment of the Constitution was ratified as part of the Bill of Rights in 1791, America stood out for its high tolerance of free speech and legal protection of the press. 

"Our liberty depends on the freedom of the press, and that cannot be limited without being lost," wrote Thomas Jefferson to Dr. James Currie in 1786. 

Liberty was to be more valued than the dangers of defamation, a lesson that President Jefferson would learn for himself when mud began to be slung his way.

James Madison, 1st Amendment advocate/Wikipedia

That freedom and its supporting structures have become the air we breathe, ingrained institutionally and psychologically with the public and legally within our country's basic body of law.

Bloggers and website hosts can be thankful for their extensive protection from defamation lawsuits, like the attempts by former franchisor Mark Golob and personal injury attorney Nikolaus Reed, to two seismic events that have moved America farther down the road and further away from other countries in what it means to have a free press—New York Times Co. v. Sullivan andSection 230 of the Communications Decency Act of 1996.

Newspapers had been weighed down by libel lawsuits from southern states that had a chilling effect on journalists reporting about civil rights violators. 

They acted as a news deterrent because the press feared that they would incur a defamation lawsuit by those cast in an unflattering light. The 1964 U.S. Supreme Court ruling changed all that. According to Justice William Brennan in the landmark U.S. Supreme Court ruling ofNew York Times Co. v. Sullivan, the First Amendment to the U.S. Constitution was to provide that "debate on public issues ... [should be] … uninhibited, robust, and wide-open." It created a "malice standard." It didn't matter if a journalist made errors in reporting. 

What mattered was if a report was reckless in its disregard of truth because of malice, which is difficult to prove.

The Civil Rights movement, Vietnam and then Watergate all eroded the public's faith in government and eventually corporate institutions. Enron, Arthur Anderson, AIG and Lehman Brothers only accelerated that distrust. 

For the sake of more open discussion and transparency, the public and the laws have greatly increased in toleration of attacks on reputations.

Then came Section 230 of the Communications Decency Act. Online host intermediaries like social media's Blue MauMau, Twitter, Facebook, Blogspot, UnhappyFranchisee or Yelp are not held liable for the writings and speech posted by others on their sites.

"I think Section 230 is the Internet equivalent of New York Times v Sullivan," says attorney Paul Steinberg. In essence, host providers of public forums are not liable for what people post on their site. "That fundamentally changed the game." Steinberg argues that social media couldn't exist without the legal protections of Section 230.

The win in the Superior Court of Mendocino County, California, by Sean Kelly comes just a few months after a major federal victory by another blogger."

Source and Full Article

http://www.bluemaumau.org/13936/freedom_press_includes_bloggers

For More

http://ninthcircuitcrystalcoxappeal.blogspot.com/

Bloggers all over the US are Rejoicing at the Ground Breaking Decision in the Crystal Cox Case. Now ALL Bloggers have Equal rights to REPORT the News and Break the NEWS. Equal to any mainstream Journalist or Reporter.

"On January 17, 2013 the Ninth Circuit Court issued its decision giving Cox the same protection as a journalist. Interestingly enough, the decision was based in part on the Citizens United v. Federal Election Commission.

The Court wrote, in part:

The protections of the First Amendment do not turn on whether the defendant was a trained journalist, formally affiliated with traditional news entities, engaged in conflict-of-interest disclosure, went beyond just assembling others’ writings, or tried to get both sides of a story.

As the Supreme Court has accurately warned, a First Amendment distinction between the institutional press and other speakers is unworkable: “With the advent of the Internet and the decline of print and broadcast media … the line between the media and others who wish to comment on political and social issues becomes far more blurred.”

Citizens United, 558 U.S. at 352. In defamation cases, the public-figure status of a plaintiff and the public importance of the statement at issue — not the identity of the speaker — provide the First Amendment touchstones.

Bloggers all over the US are rejoicing as are we.

The decision is short, so we are including it below the fold."

Source and Full Document

http://raisedonhoecakes.com/ROH/2014/01/19/bloggers-and-first-amendment-fans-rejoice/

For More
http://ninthcircuitcrystalcoxappeal.blogspot.com/

"The city's police department, charges the legal advocacy group, has given itself 'unbridled, unreviewable discretion to suppress protected speech and conduct.'"

"National Lawyers Guild Challenges NYPD on Use of Sound Cannons Against Peaceful Protesters"

"The New York Police Department is being challenged by legal advocates for what they say was the department's use of untested, unregulated military-grade sound cannons during civil rights marches in Manhattan earlier this month.

In a letter (pdf) sent to the office of Police Commissioner Bill Bratton on Friday, the National Lawyers Guild said the department's use of long range acoustic devices (LRADs) against peaceful street protesters violated numerous constitutional amendments. The group demanded a safety review of the device and public release of guidelines over how and under what circumstances they could be deployed.

Videos of officers using the LRADs surfaced on December 4 and 5 during marches that came after a grand jury's failure to indict NYPD officer Daniel Pantaleo for the chokehold death of Eric Garner. Crowds can be seen dispersing quickly as loud, shrill, repetitive beeps ring out in short blasts over and over."

"The city's police department, charges the legal advocacy group, has given itself 'unbridled, unreviewable discretion to suppress protected speech and conduct.'"

"Watch:

The police department claimed it had used the device as a loudspeaker to make announcements to the crowd. However, as the New York City chapter of the NLG pointed out in its letter to the Commissioner's office, LRADs are designed to "modify behavior, and force compliance, by hurting people... technology that is designed to induce individual compliance through human discomfort and pain cannot be defined solely as a communication tool."

Initially developed as a sound weapon for the military, the LRAD's so-called "deterrent tone" is meant to hit human hearing at its most sensitive levels. As Amnesty International explains, "LRADs can pose serious health risks which range from temporary pain, loss of balance and eardrum rupture, to permanent hearing damage."

Further, as NLG notes in its letter, even by the standards of the police department's own Disorder Control Unit, the smallest LRADs are in the "dangerous range" for hearing damage and pain.

Elena L. Cohen, president of the NLG's New York City chapter and one of the lawyers who authored the letter, told Common Dreams that LRAD use against protesters not only threatens their physical health, but also violates their constitutional rights. 

"[A]ny regulation of First Amendment protected speech must be narrowly tailored and avoid burdening substantially more speech than is necessary to achieve the government’s legitimate interests," Cohen said. "The NYPD does not seem to have any trouble controlling protests and protesters, or communicating with protesters via bullhorns. 

Using a military sound cannon is clearly not the least restrictive way to get people to move onto a sidewalk or convey message."

One protester who attended the marches when the LRADs were used told Gothamist that he had residual pain from the sound cannon blast for the next six days. "It was like an earache," he said. "Any loud noises made it worse."

Another protester told the New York Times that the experience was not only physically painful, causing her migraines and disorientation, but "emotionally jarring" as well.

"The LRAD was used as a weapon without reasonable notice and without providing a meaningful opportunity to disperse," the NLG wrote in its letter to Bratton, adding that the device was deployed "in circumstances where there was no imminent threat to public safety or property and where its use was not necessary to protect public safety or property."

The letter continues, "the NYPD’s uses of the LRAD were unjustified and unreasonable."

The appearance of the LRADs follows recent criticism of police militarization, which came after protesters in Ferguson, Missouri were assaulted with tear gas and rubber bullets by officers perched atop armored tanks, wielding rifles and batons. 

As Cohen says, the NYPD's sound cannons are an extension of the militarization trend, "part of the now ubiquitous sight of police officers in the United States wearing riot gear and driving tanks."

Gideon Oliver, a lawyer and co-author of the letter, told Gothamist that a sound cannon is not "a precision tool. This is an area-of-effect weapon."

"When the police use it, it’s not as if they’re just targeting one person," Oliver continued. "It’s indiscriminate like teargas."

Moreover, the sound cannons can hurt those not actively protesting. "The LRAD can cause hearing damage, and possible neurological damage, to anyone in its path. Particularly in New York City, anyone walking on the street or out of a building might end up in its path, and suffer short or long term health effects," Cohen said. "This is especially troubling for groups that might be at higher risk to hearing damage, such as children in the street, or mobility-impaired persons who might not be able to get out of the path of the LRAD fast enough to escape hearing damage."

As discovered through a Freedom of Information Law request filed by the NLG in 2012, the NYPD has had two of the devices since 2004 and has admitted to deploying them on multiple occasions—but still has no policies for their use.

The NLG called on Bratton to cease the department's use of LRADs until the devices have been tested for safety and guidelines for their use have been made and publicized.

Without such guidelines, the NLG says, the NYPD hands free rein to officers to injure, confuse, and control protesters and bystanders alike, giving the department "unbridled, unreviewable discretion to suppress protected speech and conduct.""

Source and Full Story
http://www.commondreams.org/news/2014/12/15/national-lawyers-guild-challenges-nypd-use-sound-cannons-against-peaceful-protesters

Here is the Letter
https://s3.amazonaws.com/s3.documentcloud.org/documents/1379007/new-york-police-are-asked-to-stop-using-lrad.pdf

Marc Randazza AGAIN Admits to have BEEN Crystal Cox's attorney yet keeps whining that he was NOT my Attorney. Marc Randazza agrees to "bow out" as Crystal Cox's attorney then claims he was NEVER her attorney.

Attorney Marc Randazza continues to FLAT OUT LIE in Court Motions and Claim he was not Crystal Cox's attorney yet there is so much that points out that this is NOT TRUE.

"REQUEST NO. 3:

Anyway phone records, emails, faxes, mail, or records of documentation of any kind between
you and anyone, including and not limited to Judge Marco Hernandez, Michael Spreadbury, ...., Martin Cain, Lara Pearson, Alexandria Mayers, Sean Boushie, Peter L. Michaelson, Eric Turkewitz, Leo Mulville, Jordan Rushie, Kenneth P. White, Ari Bass aKa Michael Whiteacre, Sean Tompkins, Eugene Volokh, Liberty Media Company and all associates, any Porn company what so ever, Stephen Lamont, Pamela Simon, Ted Bernstein, Alan Rose or any other party, in which you made statement to about Crystal Cox in any way and especially whereby you accused Cox of criminal activity.


"RESPONSE TO REQUEST NO. 3:

Counterdefendant objects to Request No. 3 on the grounds that the request is unintelligible,
overly broad, unduly burdensome, vague, ambiguous, lacks specificity, and requests documents
which are neither relevant nor reasonably calculated to lead to the discovery of admissible
evidence.

Counterdefendant further objects as the request seeks documents which are protected by
the attorney/client privilege and/or work product privilege. Furthermore, some of the documents
requested are, or should be, in Cox’s possession – for example, communications with Eugene
Volokh, her attorney. Such discovery requests should be directed at him. "

Source of Marc Randazza Response
https://docs.google.com/file/d/0Bzn2NurXrSkiUHBIcDltaWRKQ28/edit

Odd that Marc Randazza is claiming attorney client protection when he claims he was not my attorney. He STOLE my work product but seems to think his "work product" has value and worth but mine can just be STOLEN ???



INTERROGATORY NO. 21:

Did you have phone conversations with Eugene Volokh and state that you represented Cox and
discuss with him your strategy, or a deal you were trying to make with the opposition, Plaintiff’s
attorney David Aman?

RESPONSE TO INTERROGATORY NO. 21:

"Counterdefendant objects to Interrogatory No. 21 on the grounds that it is vague, ambiguous,
overly broad, not limited in time and scope, and seeks information which is neither relevant nor
reasonably calculated to lead to the discovery of admissible evidence.

Counterdefendant further objects because this interrogatory is in excess of the 25 allowable
interrogatories pursuant to Rule 33(a) of the Federal Rules of Civil Procedure. As a result,
Counterdefendant is not required to respond to the same. Subject to and without waiving the
foregoing objections, Counterdefendant responds as follows:

Counterdefendant spoke with Eugene Volokh in December 2011. 

Randazza informed Volkokh that if he was going to represent Cox, that Randazza would gladly bow out, and defer to Volokh to handle the case.

Volokh, however, said that he would prefer that Randazza co-counsel the case with him due to Volokh’s stated lack of litigation experience. Counterdefendant and Volokh discussed possible strategies that he and Volokh thought might be good ideas during that call.

Counterdefendant and Volokh both discussed the fact that Cox’s interests would be better served
through settlement."

Source ( Page 18 )
https://drive.google.com/file/d/0Bzn2NurXrSkiM0hkaW9IYVV2VGc/view?usp=sharing


Why in the world would you would you "bow out" Mr Randazza if you were NEVER My attorney in the first place? What gives you the right to choose for me, make decision for me and to bow out as my attorney if you are saying that you were not my attorney ??? Hmmm

How in the world does attorney Marc Randazza have the legal right to bow out and to "defer" me, the client to another attorney and then defer to that attorney on the case?

WOW, Marc Randazza world's biggest Hypocrite Attorney.

First Amendment Attorney Marc Randazza of Randazza Legal Group SAYS that Preliminary Injunctions are unconstitutional, they are unlawful prior restraint, they are "patently unconstitutional", they are clearly an "unconstitutional remedy". Especially if there was no prior First Amendment Adjudication.

Let's Look at the RULING and Marc Randazza's 

Big Preliminary Injunction VICTORY

A Bit from Marc Randazza's Victory APPEALING an alleged unconstitutional preliminary injunction against his client. Even though Marc Randazza himself used an unconstitutional preliminary injunction against me, Crystal Cox and stole my search engine ranking, my intellectual property, my blogs and then proceeded to violate my privacy rights, constitutional rights, civil rights and to harass and defame me for years.

""Irina Chevaldina appeals an order granting a preliminary injunction to “enjoin tortious interference, stalking, trespass and defamatory blogs” entered in favor of Raanan Katz and the other named appellees, plaintiffs in the circuit court. We vacate the order and injunction. "

Source
http://3dca.flcourts.org/Opinions/3D12-3189.op..pdf


" In this appeal, we review a temporary injunction in the circuit court action
which determined that “the Defendants have blogged extensively about the
Plaintiff and many of these blogs are arguably defamatory. Although ultimately a
defamation trial will be held, this Court ORDERS the Defendants not to enter
defamatory blogs in the future.”

The court determined that:

Plaintiffs have a substantial likelihood of ultimately prevailing on the
merits of their claims, and there is a substantial threat of irreparable
injury to the Plaintiffs if injunctive relief is not granted, that the
threatened injury to Plaintiffs outweighs whatever damage the
injunction would cause the Defendants, and that the injunction would
not be adverse to the public interest."

Source
3dca.flcourts.org/Opinions/3D12-3189.op..pdf

In Randazza v. Cox there was no "substantial likelihood of ultimately prevailing on the
merits of their claims" and there certainly was no First Amendment Adjudication BEFORE Plaintiff Marc Randazza seized Blogger Crystal Cox's intellectual property.

See the Link Below that shot down all of Plaintiff Randazza's unsupported causes of action
in a Denial of a Summary Judgement in Randazza v. Cox
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf

The Ruling Goes on to Say;

"A temporary injunction “should be granted only sparingly and only after the moving party has alleged and proved facts entitling it to relief.” Liberty Fin. Mortg. Corp. v. Clampitt, 667 So. 2d 880, 881 (Fla. 2d DCA 1996)."
3dca.flcourts.org/Opinions/3D12-3189.op..pdf

Yet attorney, Plaintiff Marc Randazza proved NO FACTS in Randazza v. Cox and Bernstein, yet he filed gag orders, injunctions, stole blogs, shut down sites, and even redirected my blogs to a post on his blog defaming and lying about me. Why do the courts protect Marc Randazza when he is clearly violating law and the constitutional rights of his victims?

"In order to establish the right to a temporary injunction the moving party must show: the likelihood of irreparable harm; the unavailability of an adequate remedy at law; the substantial likelihood of success on the merits;

the threatened injury to the petitioner outweighs the possible harm to the respondent; and the granting of the temporary injunction will not disserve the public interest. E.g., City of Miami Beach v. Kuoni Destination Mgmt., Inc., 81 So. 3d 530, 532 (Fla. 3d DCA 2012). 

We review the temporary injunction for an abuse of the trial court’s discretion. Angelino v. Santa Barbara Enters., 2 So. 3d 1100, 1103 (Fla. 3d DCA

A. Injunction Against Tortious Interference and Defamatory Blogs Injunctive relief is not available to prohibit the making of defamatory or libelous statements. See, e.g., Vrasic v. Leibel, 106 So. 3d 485, 486 (Fla. 4th DCA 2013).

A temporary injunction directed to speech is a classic example of prior restraint on speech triggering First Amendment concerns. Id.

There is, however, a limited exception to the general rule where the defamatory words are made in the furtherance of the commission of another intentional tort. E.g., Murtagh v. Hurley, 40 So. 3d 62 (Fla. 2d DCA 2010); Zimmerman v. D.C.A. at Welleby, Inc., 505 So. 2d 1371 (Fla. 4th DCA 1987). "

Source of Ruling

3dca.flcourts.org/Opinions/3D12-3189.op..pdf

Yet Plaintiff Marc Randazza was easily GRANTED an unconstitutional preliminary injunction against Blogger Crystal Cox and iViewit inventor Eliot Bernstein, why?

Well connected First Amendment Attorney Marc Randazza FLAT OUT lied about me, perjured himself over and over and Judge Gloria Navarro took him at his word and NO PROOF and stole my search engine ranking, my intellectual property, my work product and caused me irreparable harm to myself, my business and my relationships.

Here is the Unconstitutional TRO Filing  (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.2.0.pdf

Added Flat out Lies to TRO  (Randazza Filing)
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.6.0.pdf

REPLY with more Lies and Attacks regarding the TRO  (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.12.0.pdf

Another REPLY (Randazza Filing)
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.28.0.pdf

ORDER by Judge Gloria Navarro GRANTING Unconstitutional TRO / Motion for Preliminary Injunction against Defendant Blogger Crystal Cox in favor of Marc Randazza.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.14.0.pdf

Another ORDER by Judge Gloria Navarro GRANTING Unconstitutional TRO / Motion for Preliminary Injunction Just in case the FIRST ONE was not heard.
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.41.0.pdf

My, Defendant Crystal Cox's Response and Objection to Unconstitutional TRO / Motion for Preliminary Injunction

Defendant Crystal Cox's  Objection
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.29.0.pdf

Defendant Crystal Cox's  REPLY to Response
http://ia701205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.30.0.pdf

Randazza et al v. Cox et al

District of Nevada 2:12-cv-02040

Cause;  15:1125 Trademark Infringement (Lanham Act)

Nature Of Suit:  840 Trademark

1) VIOLATION OF INDIVIDUAL CYBERPIRACY PROTECTIONS

– 15 U.S.C. § 8131

2) CYBERSQUATTING - 15 U.S.C. §

1125(d)

3) RIGHT OF PUBLICITY – NRS

597.810

4) COMMON LAW RIGHT OF

PUBLICITY

5) COMMON LAW RIGHT OF

INTRUSION UPON SECLUSION

6) CIVIL CONSPIRACY

Other Preliminary Injunctions Judge Gloria Navarro Gave Randazza Legal Group

even though they are allegedly "Rare" and Unconstitutional 

"ViaView, Inc. v. Chanson et al"

"Court Description: ORDER Granting 6 EX PARTE MOTION for Temporary Restraining Order filed by ViaView, Inc. IT IS FURTHER ORDERED that Defendants shall have until 12/7/2012 to file Response to 6 Motion for Preliminary Injunction.

Plaintiff shall file reply by 12/21/2021. Motion Hearing set for 1/2/2013 02:30 PM in LV Courtroom 7D before Judge Gloria M. Navarro. Signed by Judge Gloria M. Navarro on 11/30/12. (Copies have been distributed pursuant to the NEF - EDS)"

Source

law.justia.com/cases/federal/district-courts/nevada/nvdce/2:2012cv01657/90093/10

In SOME Cases, a Preliminary Injunction is Unconstitutional and Marc Randazza DEFENDS that position. Yet he used an unconstitutional Injunction to steal my work product, my intellectual property, my search engine ranking and my online content.

Preliminary Injunction are Unconstitutional Depending on Which Side your Attorney is On.

Opening Brief in the Irina Chevaldina Appellate Case No. 3D12-3189, Attorney Marc Randazza. 

https://drive.google.com/file/d/0Bzn2NurXrSkiNS1DeFZVdWxJSkU/view?usp=sharing

In the District of Nevada, Judge Gloria Navarro's court, the Most Important thing is the Attorneys Pay Check, and the Law, the Constitutional Rights of Defendants, Due Process seems to be Irrelevant.

Judge Gloria Navarro seems to CLEARLY favors Randazza Legal Group as far as I see it.

These attorneys sue whoever they want, they get their attorney fees, intellectual property, fines paid to them and what ever they want in the MAGICAL Land La La Lawless Land of Judge Gloria Navarro of District of Nevada. 

More Research Links on that Topic

vegasinc.com/news/2011/jul/09/attorneys-seek-fee-injunction-against-righthaven/

vegasinc.com/news/2011/jul/06/righthaven-ordered-pay-defendants-legal-fees/

Liberty Media Holdings LLC v. FF Magnat Limited

aw.justia.com/cases/federal/district-courts/nevada/nvdce/2:2012cv01057/88374/38

"The Plaintiff has shown a substantial likelihood of success on the merits of its claims sufficient for the Court to issue a limited Temporary Restraining Order. Plaintiff alleges copyright infringement, contributory copyright infringement, vicarious copyright infringement and inducement of copyright infringement. (Compl., ECF No. 1.)

To show a substantial likelihood of prevailing on the merits of a copyright infringement claim, Plaintiff must show that: (1) it owns the copyright to which its infringement claims relate; and, (2) Defendants violated one of the Plaintiff's exclusive rights in the works. See Feist Publ'ns, Inc. v. Rural Tel. Serv. Co., Inc., 499 U.S. 340, 361 (1991);

Latimer v. Roaring Toyz, Inc., 601 F.3d 1224, 1232-33 (11th Cir. 2010); Sid & Marty Krofft Television Prods., Inc. v. McDonald's Corp., 562 F.2d 1157, 1162 (9th Cir 1977); Educational Testing Servs. v. Katzman, 793 F.2d 533, 538 (3d Cir. 1977). These two factors have been clearly established by the Plaintiff."

Source of Above Judge Gloria Navarro RULING Favoring the SAME Plaintiff

nv.findacase.com/research/wfrmDocViewer.aspx/xq/fac.20120621_0003126.DNV.htm/qx

Marc Randazza does not and did NOT have "substantial likelihood of success on the merits of its claim". Yet he was favored over his TARGET / his Victims.

Why is no FBI Agent, Dept. Of Justice Agent, the Nevada Attorney General, or the U.S. Attorney General Looking at all this?

It sure seems to VIOLATE the Rights of the Targets, the Defendants in some sort of pattern of "shakedown", in my Opinion

More Research on the Liberty Media Holdings LLC v. FF Magnat Limited and this Same  Attorney, who sure is GOOD at Showing Alleged "merits" of winning, Before a Defendant has any First Amendment Adjudication or Right to Due Process.

rfcexpress.com/lawsuits/copyright-lawsuits/nevada-district-court/98475/liberty-media-holdings-llc-v-ff-magnat-limited-et-al/summary/

Love this Part "Emergency MOTION for Temporary Restraining Order by Plaintiff Liberty Media Holdings LLC. Motion ripe 6/20/2012."

I get threats of death, violence and Judge Gloria Navarro IGNORES my Real Emergency. Yet Gloria Navarro allows Randazza Legal Group to abuse the process and get emergency protective orders and Injunctions.

Frozen Accounts, Preliminary Injunctions, FORCED Attorney Fees and whatever Randazza Legal Group wants they get, WHY?

scribd.com/doc/105188141/Liberty-Media-Holdings-v-FF-Magnat

"Section 505 of the Copyright Act grants district courts discretion to award “

a reasonable attorney's fee to the prevailing party as part of the costs"

Randazza Legal Group sues their TARGET, and the Judge Forces their VICTIM to PAY the ATTORNEYS outrageous Fee's.  And if you Don't Judge Gloria Navarro will Freeze your Accounts. Pattern and History, I THINK SO.. in my NON-Attorney OPINION.

Don't Forget Liberty Media Holdings allegedly is infringing on the iViewit Technology and many companies owned, at least in part by Liberty Media Holdings are named in iViewit Technology. Randazza SUED Eliot Bernstein and got a Preliminary Injunction against him as well, with NO First Amendment Adjudication.

The Full Hypocritical Filing of Marc Randazza Regarding the 

Unconstitutional actions of Preliminary Injunctions.

docs.google.com/file/d/0Bzn2NurXrSkiT3M2c1FVbHZqX2c/edit

Page 8 of above;

"This appeal Seeks to cure an unlawful prior restraint on the Appellant’s First Amendment rights, improperly imposed by the lower court. On November 19, 2012, the circuit court enjoined Appellant from writing, “defamatory” blogs 'in the future, despite expressly making “no findings of facts as to actual ‘violations of law by the [Appellants], except that [Appellants] have blogged extensively about the Appellee] and many of these blogs are arguably defamatory.” (RÃ/14)

The circuit court made this decision Without following the mandates of Florida Rule of Civil Procedure 1.610. However, even if it had, the injunction is patently unconstitutional."

                      WOW, "the injunction is patently unconstitutional", it is "unlawful prior restraint", EXCEPT for when Marc Randazza uses it against a Blogger he wants to SUPPRESS the SPEECH of.

                

Page 10

"Months and months of litigation, thousands of dollars, and thousands of pages of documents later, RKA sought a clearly unconstitutional remedy - an injunction against alleged defamation prior to any court determination that the speech at issue was even legally capable of defamatory meaning, much less Whether it was actually defamatory, privileged, or otherwise protected by the First Amendment. (R Vl-6)

The resulting lnjunction Order was so over-broad and subject to abuse, that the RKA even sought an order for contempt based upon Chevaldina doing no more than reporting the existence of the Order itself."

All that money to seek a "clearly unconstitutional remedy"? And Marc Randazza defends the opposite position he took to constitutionally violate Crystal Cox an Eliot Bernstein?

Full Hypocritical Motion Linked Below

docs.google.com/file/d/0Bzn2NurXrSkiT3M2c1FVbHZqX2c/edit

Attorney Marc Randazza sought a "clearly unconstitutional remedy , "injunction ..prior to any court determination" from Crystal Cox and Eliot Bernstein, even though that "speech" was protected under the First Amendment and with NO First Amendment Adjudication. 

Randazza Legal Group, Marc Randazza stole massive online content, work product, intellectual property and used the lawsuit to violate my privacy rights, harass me, defame me, lie about me, harass me and to post private emails, get my bank account and wire records, harass and bully my church, threaten my ex's, get private proprietary business information from customers and clients and to put me and my sources under constant attack, threats, stalking, harassing, bullying and defaming for over 2 years now and counting. He did this as an "officer of the court". Clearly abusing his power.

Marc Randazza and Randazza Legal Group are

CLEARLY acting outside of the Law and are Violating

the rights of citizens every single day.

And they are using Judges, Attorneys, 

Investigators, Officers of the Court, and Thugs to do it,

in my Opinion.

EXPOSE Randazza Legal Group.

I say Indict Marc Randazza, J. Malcom DeVoy,

Michael Whiteacre, Ronald Green, Sean Thomas, 

and others I ALLEGE are acting in Civil and Criminal 

Conspiracy with them every single day.

Some More Fun on Preliminary Injunctions and Marc Randazza

http://crystalcoxmedia.blogspot.de/2013/03/pro-se-litigant-investigative-blogger.html

Marc Randazza of Randazza Legal Group had NO CASE against Crystal Cox or Eliot Bernstein, as is easily seen in the Denial of a Summary Judgement which CLEARLY shoots down every cause of action of the Plaintiff as a matter of LAW.


More on that at the Link Below
http://ethicscomplaint.blogspot.com/2014/12/randazza-v-cox-lanham-act-trademark.html


Here is the RULING that Denied the Summary Judgement
http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.200.0.pdf

"STALKERS SEAN MATTHEW TOMPKINS & ARI SCOTT BASS BULLY THE POOR TO PROMOTE RANDAZZA LEGAL GROUP"

"On the afternoon of November 26, 2014 (the day just before the Thanksgiving), two well documented stalkers by the names of Sean Matthew Tompkins andAri Scott Bass (each who have an extensive criminal history) decided to utilize their porn industry hate site to bully and harass Alexandra Melody Mayers fka Monica Foster in effort to promote Randazza Legal Group (a porn industry lawfirm known for defending pedophiles, donating funds in attempt to halt legislation meant to protect adult performer’s health and safety, and for being closely affiliated with the pornographic industry’s political face – The Free Speech Coalition).

While Alexandra fka Monica was webcamming the early afternoon of November 26, 2014 she conveyed to her viewers that she’d appreciate tips for her performance so that she could purchase herself a Thanksgiving meal.

As of current, Alexandra is experiencing extreme financial difficulty and works independently as an adult webcam model part time while maintaining a non-adult industry job part time simultaneously (she is not on well fare nor does she receive assistance from non-profit organizations). 

Either Sean Matthew Tompkins, Ari Scott Bass or one of their associates entered her chat room utilizing the screen name “Organ Shifter” to observe her webcam performance & log her dialogue.

click to enlarge – This blog post was created to bully, harass & intimidate Alexandra Mayers while simultaneously promoting porn industry lawfirm Randazza Legal Group

After Alexandra fka Monica completed her live webcam session the blog below was written and posted on Sean Matthew Tompkins & Ari Scott Bass’s hate site in effort to bully, harass, intimidate and make fun of Alexandra’s financial situation while simultaneously promoting Randazza Legal Group (who is currently being sued by Roca Labs for defamation, slander and libel).

Alexandra fka Monica is currently defending herself in a frivolous lawsuit filed in civil court by the owner of Randazza Legal Group’s wife for in excess of $50,000 (a lawsuit which is based on 3 tweets). 

Wouldn’t it be ironic if by this time next year it’s Randazza Legal Group who’s stuck in the poor house rather than Alexandra Melody Mayers…

After all, if Randazza Legal Group continues to donate $20,000 (twenty times more than the average pornographer and the equivalent amount to Larry Flynt Productions) to campaign efforts that consistently fail such as No On Measure B / No On Government Waste – eventually they WILL deplete themselves of resources.

click to enlarge – Randazza Legal Group donated as much as Larry Flynt of Hustler to No On Measure B / No On Government Waste

Roca Labs files a lawsuit against Randazza Legal Group for slander / libel / defamation."
Source and More
http://www.xxxorganizedcrime.com/?p=147

100% FACT BELOW

Roca Labs Says:

"Despite being an Officer of the Court and a practicing member of the Florida Bar,  RANDAZZA has waged his war against ROCA by intentionally and maliciously publishing many false  and defamatory statements in his pleadings, with the intent to share them to his contacts in the media,  and indeed by directly speaking to the media about ROCA with the intent to have them publish false,  misleading and defamatory articles about ROCA, and by harassing and making derogatory statements  about ROCA via his personal social media sites including his Twitter account"

Source and Full Legal Action against First Amendment PORN Attorney Marc Randazza aKa scumbag, hypocritical asshole, liar, and lawless.

https://s3.amazonaws.com/s3.documentcloud.org/documents/1357796/246279896-roca-labs-randazza-complaint.pdf"

NOW That is FACT whether a Court Agrees or NOT does not change that it is fact and the Randazza Legal Groupies do it over and over, year after year, case after case, target after target.

Randazza Legal Group acts in the same way, in deliberate action, willful intent, purposely and though he knows the law very well. Randazza Legal Group does this in conspiracy to silence, suppress, attack, harass, intimidate and shake down their targets. 

RICO ( Pattern and History ) is so easy to prove if any actual Law abiding Prosecutor would look into these cases or if the Judges I have told would actually care about the LAW.