UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

t\MQ "6 Q..d 

~ COMPLAINT 

(Write the full name of each Plctintiff 

who is filing this complaint. If the 

names of all the plaintiffs cannot fit 

in the space above, please write 

"see attached" in the space and 

attach an additional page with ·the 

full list of names.) 

v. 

~ ~e. , rite the full name of each Defendant 

who is being sued If the names-of all 

the Defendants cannot fit in the space 

above, please write "see attached" in 

the space and attach an additional 

page with the full list of names.) 

I --------------

NDFL Pro Se I (Rev. 12/16) Civil Complai nt 

ClerlcAdmin/OfficiaVForms 

FILED lJSDC FLND GV 

AUG 20 '20 Ptd2:32 

Case No.: \ .J 1CJ - cv- l so· Aw ,J~ \2- ~ 

(To be filled in by the Clerk's Office) 

Jury Trialft.equested? 

• YES i!f"NO 

Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 1 of 12
I. PARTIES TO THIS COMPLAINT 

A. Plaintiff( s) 

1. Plaintiff's Name: ClA6o~QC S:n 1?u~ro$S;, 

Address: 1,ot; Se- I !c-tla b,y-~ A.~t 24:A. 

City, State, and Zip Code: C-io,CX:?SV1\\Q,. 1 fk 3'2.-bO l 

Telephone: 35""1..--:-33?1-: 61...-4 b (Home) ?£2. -339 -b'll\ b (Cell) 

2. Plaintiff's Name: ------------------

Address: ---------------------

City, State, and Zip Code: ______________ _ 

Telephone: _______ (Home) ________ (Cell) 

(Provide this information for any additional Plaintiffs in this case by 

attaching an additional page as needed) 

B. Defendant(s) 

1. Defendant's Name: __.,.. ~=-""""'"=-+'\..., e.,.'""'"-------------

N rune of Employer (if relevant): 

-------------

City, State, and Zip Code: t':bu~:\:rua Vt e,L\ t ChlttcxC\ ~ o.. 0i404 3 

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ClcrkAdmin/OfficiaL/Forms 2 

Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 2 of 12
2. Defendant's Name: _ h~. "¥" fRT""\~e _ _,, ___________ _ 

Name of Employer (if relevant): ___________ _ 

Address: Ch<i - {\~~e,, 'ihck W0-.~ 

City, State, and Zip Code: C.upe.c1'1C\O \ c~ l\So \Y 

3. Defendant's Name: -------------------

Nmne of Employer (if relevant): ____________ _ 

Address: -----------------------

City, State, and Zip Code: _______________ _ .. . 

(P~o,~ide this information for any additional Defendants in this case by 

attaching additional pages as needed.) 

II. BASIS FOR JURISDICTION 

Federal courts have limited jurisdiction. Generally, only two types of cases 

may be heard in federal court: (I) a case involving a federal question or (2) 

case involving diversity of citizenship of the parties. A "federal question" 

case arises under the United States Constitution or federal laws or treaties. 28 

U.S.C. § 1331. A ''diversity" case means a citizen of one State sues a citizen 

of another State or nation. No defendant may be a citizen of the smne State as 

any Plaintiff in a diversity case, and the amount in controversy must be more 

NDFL Pro Se I (Rev. 12/16) Civil Complaint 

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Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 3 of 12
than $75,000. 28 U.S.C. § 1332. 

What is the basis for federal court jurisdiction? (check all that apply) 

q~ ,£ Federal Question ...#biversity of Citizenship 

fudual £tuaSf,c~ ~ ,.\-,?~~~~~Gour\-. 

Fill out the paragraphs in this section that apply to this case. 

A. If the Basis for Jurisdiction Is a Federal Question: 

List the specific federal statutes, federal treaties, and/or provisions of the 

United States Constitution that are at issue in this case: ------

\5 \). ~, C..- 9czc. i. l £e..c • "'2..., 6 Q.C. k> 1 Sec..-9 

B. If the Basis for Jurisdiction is Diversity of Citizenship: 

1. Plaintiff( s) 

a. Plaintiff is an individual and a citizen of: - . ---------

b. If any Plaintiff is a business or corporation, list the State where the 

business is incorporated _______ or has its principal 

place ofbusiness: --- ---------------

(Note: Businesses/Corporations must be represented by counsel. 

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Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 4 of 12
Attach additional page to provide this information for additional 

Plaintiffs.) 

2. Defendant(s) 

a. If the Defendant is an individual, identify their citizenship below. 

1. Defendant (name) 

is a citizen of (State) 

2. Defendant (name) 

is a citizen of (State) 

3. Defendant (name) 

is a citizen of (State) 

b. If the Defendant is a corporation or business, list the state of 

incorporation or principal place of business below. 

1. Defendant (name) ______________ _ 

State of Incorporation is _____________ _ 

or Principal Place of Business is ___________ _ 

2. Defendant (name) ________________ _ 

State of Incorporation is 

-----,------------

or Principal Plcice of Business is ___________ _ 

(Attach additional page £{ necessary to list all Defendants.) 

3. Have you previously been involved in litigation with one or more 

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Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 5 of 12
of the named Defendants? 

o Yes o No 

If yes, identify prior case #: _______ Date: ____ _ 

Court: ----------------------

Defendant: 

---------,-------------

Judge: ------~--------------

Result: ---------------------

III. STATEMENT OF CLAIM 

Write a short an_d plain statement of your claim. Do not make legal 

arguments or quote from cases. State the facts which show what happened, 

as well as where and when it happened. State how each Defendant was 

involved and explain what a Defendant did or did not do; identify how each 

Defendant caused yo_u hanp or violated federal law. Write each statement in 

numbered paragraphs, limited as far as practicable to a single event or 

incident. If more than one claim is asserted, number each claim, and ensure 

that a short and plain statement of facts supporting each claim is included in 

the facts.alleged·. Attach no more than two (2) additional pages to state your 

claim. 

NDFL Pro Se l (Rev. 12/16) Civil Comp!aint 

ClerlcAdmin/OffieiaVForms 6 

Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 6 of 12
(continued from page 6) 

In response to Judge specific "Plaintiff confusingly names "Epic Games" as the 

Defendant in this case". When I filed this case I had no defendant listed but the Clerk of the 

Court at the U.S. District Court in Gainesville, FL told Me to place "Epic Games" as the 

Defendant, which I understand now is incorrect. Please consider Epic Games as the Plaintiff 

that I am assisting selflessly and without personal benefit to sue the Defendants Google and 

Apple. 

In response to Judge specific "When screening, the Court must dismiss any claim if it is 

... (ii) fails to state a claim upon which relief may be granted". I am not seeking any personal 

claim and I have no financial or other obligation to any party involved. I am selflessly acting to 

provide relief because I saw lawlessness occurring and I will not stand for it. I will provide an 

argument for My tactic in the law: 

e. Following the course of the Constitution the law is in effect in the United States. 

f. All laws in the United States must act in the same direction or the United States is falling 

out of the law. 

g. This is seen because the law will always win in court. 

h. I can conclude as all judges will conclude by simply denying falling out of the law. 

i. If I were a normal individual without the resources available to Me I would find the federal 

bench unapproachable. The law is serious but not so serious it may be held away from 

the public. 

In response to Judge specific "Plaintiff fails, however, to identify which antitrust laws are 

being violated and how he has standing to seek redress against any party under federal 

antitrust law". I find such laws now, 

j. The Sherman Act outlaws "every contract, combination, or conspiracy in restraint of 

trade" 15 U.S. Code§ 1. The conspiracy in restraint of trade is to remove the Plaintiff 

from all opportunities in these markets where the Plaintiff has property that is being sold 

and used because the Plaintiff did not pay a tax to the Defendants who are not involved 

in the work of the Plaintiff at all. 

k. The Sherman Act outlaws "Every person who shall monopolize, or attempt to 

monopolize, or combine or conspire with any other person or persons, to monopolize 

any part of the trade or commerce" 15 U.S. Code§ 2. The Plaintiff has been ejected 

from the market to the disadvantage of the Plaintiff when a competing method to earn 

revenue was created that avoided paying the price fixed by the Defendants Apple and 

Google despite the participation of the Defendants Apple and Google in the work is zero. 

The presence of "zero participation" in the creation of the item that was sold, which is 

purely made by the Plaintiff in Their product "Fortnite", means Defendants Apple and 

Google were acting to extend Their business over that of the Plaintiff without good 

cause. Without any restraint on why Defendants Apple and Google may charge a fee to 

Plaintiff Epic Games then Epic Games is a subsidiary of Defendants Apple and Google 

and this isn't the case. 

"Monopoly" is a control or advantage obtained by one entity over the commercial 

market in a specific area. Monopolization is an offense under federal anti trust law. The 

Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 7 of 12
two elements of monopolization are (1) the power to fix prices and exclude competitors 

within the relevant market. 1 

In response to Judge specific "In order to proceed in federal court, Plaintiff must 

establish as a threshold matter that he has "standing" to sue", and in response to Judge specific 

"for relief, he seeks to "break up" the companies and create a "future-trust" to "defend future 

similar victims of monopoly" as "a real way to prevent this fraud from happening again". The 

Sherman Act provides remedy against monopolies and restraint of trade or commerce, "the 

several district courts of the United States are invested with jurisdiction to prevent and restrain 

violations of sections 1 to 7 of this title". 15 U.S. Code§ 9. I ask the Court to pursue the 

limitation on Defendants Apple and Google from monopolizing access to these customers. 

I am always harmed by any monopoly in the United States or abroad, as are all people. 

In standing I am a consumer and I am a business owner and all monopolies seek explicitly to 

remove the law from all normal business. It is similar to a common criminal - anyone may call 

9-1-1 to report them. I am not seeking a personal fine on Defendants Apple and Google, and 

only the restoration of the law. 

In response to Judge specific "Mere vague and conclusional assertions that Google and 

Apple have violated antitrust laws are insufficient to proceed with an antitrust case". If I may I 

would like to improve the entire standing of law in the United States. I will prove using logic how 

a business is or is not a monopoly and I will support it with fact from the Sherman Act. Then I 

will show how this can be applied to Google and to Apple and how the Plaintiff Epic Games can 

be shown to be a victim. 

a. The Sherman Act states: "Every person who shall monopolize, or attempt to monopolize, 

or combine or conspire with any other persons, to monopolize any part of the trade or 

commerce .. . shall be deemed guilty of a felony." 15 U.S. Code§ 2. 

b. The entire principle of the Sherman Act may be restated: allow no business that seeks to 

place one or more other businesses underneath it in ability to flourish. This follows from 

to monopolize is a felony, a monopoly is an unfair advantage or control over the ability to 

compete or to have fair pricing, and the U.S. Code will intervene to stop this felonious 

conduct. 

c. This is exactly the general principle: allow none to do unto others what they would not 

allow done unto them. 

d. There are very, very specific ideas in the Sherman Act and all of these create a huge 

body of law that is tough to navigate! 

e. I will restate how the Plaintiff and the Defendants are engaged in business to reach 

customers. 

i. The Plaintiff has. built a_ property that is valuable and not unethical in fact, called 

"Fortnite". 

ii. The Plaintiff allows digital property inside this property to be sold and does so to 

earn revenue. 

1 https://definitions.uslegal.com/m/monopoly/ 

Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 8 of 12
iii. The Defendants Apple and Google are independent, and only similarly act in this 

one way: They each have a product that they sell that is a way to reach phone 

users, called Their "app stores". 

iv. The Plaintiff was not allowed to sell Their own property, which is inside Their 

game "Fortnite", because Defendants Apple and Google restrict it to be taxed for 

Themselves. The app stores are not being used because the customer already 

has "Fortnite" and the transaction is between Plaintiff Epic Games and the 

customers. The participation of Apple and Google is zero. The app stores 

delivered the game to the customer, then Apple and Google did not stop. The 

Defendants inserted Themselves into the private exchange between the 

customers and Plaintiff Epic Games to monopolize this type of transaction and 

imposed a penalty when Epic Games went around this monopoly. The app stores 

have nothing to do with Epic Games and the customers yet they are how 

Defendants Apple and Google imposed a sanction on the Plaintiff. 

v. Defendants Apple and Google may have independent transactions with the 

customer, but Plaintiff Epic Games may not. This is Defendants Apple and 

Google both placing Epic Games beneath Them as an inferior business, and 

therefore it violates the Sherman Act. 

I. A second, additional way to know a crime was committed is to check if this event was 

ethical. All ethical events are not the worst kind of event. Therefore if I can find that this 

event was a "worst case scenario" then it wasn't ethical to occur. Here I do so: worse is, 

there is no way for a business to reach a customer without paying another business 

because this is extortion. Avoiding this worst case means there is always a way for a 

business to reach a customer without needing to pay another business. In this case it is 

clear Defendants Apple and Google are punishing Plaintiff Epic Games for reaching 

customers without paying the Defendants. Worse is, to pay a business for doing no 

work. This is a lack of good faith on the part of the business! Plaintiff Epic Games must 

pay Defendants Apple and Google to sell in-game property that is manufactured and 

distributed solely by Epic Games, is the argument made by Defendants Apple and 

Google. Apple and Google are acting in bad faith. 

In response to Judge specific "to have standing to bring an antitrust action a plaintiff 

must have suffered antitrust injury". Further "to have standing the plaintiff must establish that he 

is an efficient enforcer of the antitrust laws." 

a. I am an owner of an iPhone and so this monopoly by Apple extends to reach Me in fact. 

b. I was an owner and could be an owner of an Android phone within the day and so this 

part of the monopoly from Google extends to reach Me in fact. 

c. I am affected by the inability to reach "Fortnite" because of the actions of the Defendant 

Apple and I won't stand for an extortion of a business that is trying to reach Me by 

Defendants Apple or Google. 

d. This requirement is seeming to hide the lawlessness of criminals behind the inability to 

stand against them because I must prove that I should be allowed to stand against 

crime. It is clear that lawlessness is wrong in all courts and in all ways and I should be 

allowed to simply "see" lawlessness to be allowed to fight it. 

Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 9 of 12
IV. RELIEF REQUESTED . 

State briefly and precisely what damages or other relief the plaintiff asks the 

court to order. Do not make legal arguments. Include any basis for claiming 

. that the wrongs alleged are continuing at the present time. Include the 

amounts of any actual damages claimed for the acts alleged and the basis for 

these amounts. Include any punitive or exemplary damages claimed, the 

amounts, and the reasons you claim you are entitled to actual or punitive 

money damages. ___ (._s.....,e....,)_£-"'"'--'n:Hn .......... ..u..<',!o~C.-o1-cb=od........_----t~.......,,...e.'-I)-------

V. CERTIFICATION .. 

As required by Federal Rule of Civil Procedure 11, I certify by signing below 

that to the best of my knowledge, information, and belief, this complaint: ( 1) 

is not being presented for an improper purpose, such as to harass, cause 

W1D.ecessary delay, or needlessly increase the cost of litigation; (2) is 

supported by existing law or by a non-frivolous argument for extending, 

NDFt. Pro Se I (Rev. 12/16) Civil Compl&int 

ClerlcAdmin/OfficiaVFonns 7 

Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 10 of 12
(continued from page 7) 

The markets of Defendants Apple and Google must be removed from Their control to 

eject simple competitors who sell there which includes the Plaintiff or the ability to set the prices 

charged on the markets of Defendants Apple and Google must be removed from Them or both. 

These are the elements of a monopoly: the power to fix prices and the exclusion of competitors 

from the market. 2 Specific powers to the Court are to seize the property from Defendants Apple 

and Google if They are found to have conspired for "restraint of trade or commerce". 15 U.S. 

Code§ 1. This follows from 15 U.S. Code§ 6. "any property owned under any contract or by 

any combination, or pursuant to any conspiracy (and being the subject thereof) mentioned in 

section 1 of this title, and being in the course of transportation from one State to another, or to a 

foreign country, shall be forfeited to the United States, and may be seized and condemned by 

like proceedings as those provided by law for the forfeiture, seizure, and condemnation of 

property imported into the United States_contrary to law." 

The markets the Defendants create and manage and which are the mechanism of Their 

monopoly over the Plaintiff Epic Games are Their property and therefore the Court should seize 

these markets and place them in a separate organization with a different control than 

Defendants Apple and Google.This i~ an explanation of the term "to break up" Apple and 

Google. 

Furthermore Defendants Apple and Google have collected billions of dollars in revenue3

· 

4 that is Their property. The Court must seize these illegal revenues from the profits of a 

monopoly and then hold them in a trust for the reason I specify in My original filing : the original 

owners of this money are not all proven to still exist. I sought to provide the Court with a real 

way to hold this property that will still hear the affected parties, all of them on the markets of 

Defendants Apple and Google, to return to them what was stolen from them. I believe always a 

"trust fund" needs a reason for money to arrive and a reason for money to be spent and so I 

provided these in My original filing. 

In response to Judge specific "a cursory review of Plaintiffs other complaints reflects that 

many of them are due to be dismissed as frivolous." I further mitigate this argument "a claim is 

frivolous if it is without arguable merit either in law or fact." Thank you, Honorable Judge Gary R. 

Jones, for the lovely order that was very carefully cited and I see an example now of how to 

proceed. These are My first lawsuits and I hope to be a fierce defender of the law. I have proven 

that this case is easily within the bounds of the law, and I was using a real technique though I 

will cite My logic from now on directly from the U.S. Code. Please consider that I was able to 

prove to satisfaction that the logic I used was meaningful and not intended to waste the Judge's 

or Court's time. Please allow all of My.suits to continue and I simply promise I will research 

exact citations of the law to follow My already submitted lawsuits, following the order dated 19 

August 2020. 

2 https://definitions.uslegal.com/m/monopoly/ 3 "Apple's App Store platform grossed around $50 billion in 2019" 

https://www. en be.com/2020/01 /07 /apple-a pp-store-had-estimated-gross-sales-of-SO-bi II ion-in-2019. html 4 "Once again, iOS App Store 2018 revenue, at $33.2 billion is significantly higher than Google Play 

revenue of $21 .5 billion" https://www.businessofapps.com/data/app-revenues/ 

Case 1:20-cv-00180-AW-GRJ Document 5 Filed 08/20/20 Page 11 of 12
modifying, or reversmg existing law; (3) the factual contentions have 

evidentiary support or, will likely have evidentiary support after a reasonable 

opportunity for further investigation or discovery; and ( 4) the complaint 

otherwise complies.with the requirements of Rule 11. 

I agree to timely notify the Clerk's Office if there is any change to my 

mailing address. I understand that my failure to keep a current address on file 

with the Clerk's Office may'result in the dismissal ofmy case. 

Date: P.,~ 'Lo1wu,Plaintiff ~ Signanrre: ~ 

Printed Name of Plaintiff: C,V\.0$~~\.-..Q..( ~QS\ ?<lC5c0es·r 

Address: we;- ss L<a±fu A;va... . f\>:h 42-4 ~ 

ll • ' v\Q,\ 00-'$\/\ \ \.e I r\._. 31..k,o\ 

E-Mail Address: S+eaccclr ~\.(QS) 'f:O @ 5~ \ -cp(Y\, 

Telephone Number: sS7....-3"39. - h'Z-L\ G:, 

(Additional signature pages must be attached if there is more than one 

Plaintiff.) 

NDFL Pro Se I (Rev. 12/1~) Civil Complain< 

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