DN,fW1( -Chk 

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IN THE UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA 

GORDON ROY PARKER, a.k.a. Ray Gordon, d/b/a 

Snodgrass Publishing Group, 

F U-c f-~'

.'....-., r;") li-~' ~)__ f 

Plaintiff, 

v. Iry( II ,. 1 2U06

Learn The Skills Corp., etM~'~i,Cler?~

By Dsp. Cler!( 

Defendants. 

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CASE NO.: 05-cv-2752 

Hon. Harvey Bartle, III 

CERTIFICATE OF SERVICE
 

I, Gordon Roy Parker, hereby certify that I have served the foregoing Supplement To
 

Plaintiff's Motion For Reconsideration on the following Defendants, by the following means:
 

Trustees of the Vniv. ofPA Mary Kay Brown Matthew S. Wolf, Esq. 

Dennis G. Young (Counsel) Buchanan Ingersoll, PC 241 Kings Highway East 

Montgomery, McCracken, 1835 Market Street, 14th Floor Haddonfield, NJ 08033 

Walker & Rhoads Philadelphia, PA 19103 Attorney For LTSC & 

123 South Broad Street, 28th FI. Attorney For Paul Ross Defendant 

Philadelphia PA 19109 Regular Mail Regular Mail 

Regular Mail 

Formhandle@fastseduction.com (Pro Se) 

Thorn E. Geiger (Pro Se) Learn The Skills Corp. 

817 North McCrary Road 955 Massachusetts Ave, #350 

Columbus, MS 39702-4320 Cambridge, MA 02139 

Regular Mail Regular Mail 

This the 10th day of April, 2006. 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 1 of 53
IN THE UNITED STATES DISTRICT COURT
 

EASTERN DISTRICT OF PENNSYLVANIA
 

GORDON ROY PARKER, a.k.a. Ray Gordon, d/b/a 

Snodgrass Publishing Group, 

F~ .. 

fjlaintiff, 

v. L'~J

t "") Learn The Skills Corp., et al. li~ i\ 1 , 2006

~~~~2-:;~D~~Utmts.

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CASE NO.: 05-cv-2752 

Hon. Harvey Bartle 

SUPPLEMENT TO PLAINTIFF'S MOTION FOR RECONSIDERATION 

Plaintiff Gordon Roy Parker, in the above-styled action, moved this court for 

reconsideration of its order dismissing this case. 

Plaintiff moved in that pleading to amend the Complaint, and stated that he would add 

the recently filed Parker v. LTSC (III) Complaint, which is now case #06-vc-229 in the District 

of Delaware. A full copy of that Complaint is attached hereto as Exhibit A and incorporated by 

reference as if fully set forth verbatim herein. 

The Delaware complaint is forty-eight (48) pages in length, with approximately a 

dozen pages devoted to the RICO claims. This is one-third shorter than the 72-page complaint 

this court deemed "too long," but as Plaintiff has already argued, the district courts do not set 

page limits on Complaints. Plaintiff intends to argue on appeal that this guideline is vague and 

overbroad, and that dismissing a case without greater specificity regarding lengthy constitutes a 

denial of his right to civil due process. Should the Court in this case set aside judgment against 

the four defendants named in the Delaware action as well as this action, then Plaintiff will 

"adapt" that complaint for this Court. Delaware's pleading rules are such that more specificity 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 2 of 53
regarding the defamation claims had to be included. The complaint could be further pared down 

should the court impose a stricter page limitation. 

Service of the Delaware action (and a related motion for expedited discovery of 

LTSC) is being made simultaneously with service ofthis pleading, as it relates to this case. In 

the mail, Plaintiff is including a copy of the summons and Delaware complaint, along with a 

waiver of service for each Defendant, and attaching the exhibit as normal for the two 

nondefendants in that case who are in this case.. 

This the 10th day of April, 2006. 

Gordon Roy Parker 

Plaintiff, Pro Se 

4247 Locust Street, #806 

Philadelphia, PA 19104 

(215) 386-7366 

SnodgrassPublish@aol.com 

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Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 3 of 53
IN THE UNITED STATES DISTRICT COURT
 

DISTRICT OF DELAWARE
 

GORDON ROY PARKER, a.k.a. Ray Gordon, d/b/a · · Snodgrass Publishing Group, · · 4247 Locust Street, #806 . : 

Philadelphia, PA 19104 : 

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Plaintiff, : CASE NO.: Ol-cv~)Jli v. : 

· · Hon. 

Learn The Skills Corp., c/o Business Filings, Inc., 108 

West 13th Street, Wilmington, DE 19801; 

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presiding 

Formhandle@Fastseduction.com, c/o Business Filings, 

Inc., 108 West 13th Street, Wilmington, DE 19801; . . I TokyoPUA~fastseduction.com, c/o Business Filings, Inc" : 

108 West'13 Street, Wilmington, DE 19801; : 

Straightfonvard, Inc., 822 Eagle Point Rd. VanAlstyne, : 

TX 75495; and Paul Ross, a/k/a "Ross Jeffries," 310 Tahiti ; 

Way, Marina Del Ray, CA, 90292-6789 · · 

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Defendants. : .~

COMPLAINT FOR VIOLATIONS OF THE LANHAM ACT,
 

SHERMAN ANTITRUST ACT, CLAYTON ACT, DEFAMATION, TORTIOUS
 

INTERFERENCE, RACKETEERING (RICO), AND CIVIL CONSPIRACY
 

Plaintiff Gordon Roy Parker, in the above-styled action, states his claims and prayers for 

relief, and in support thereof, sets forth and avers the following: 

THE PARTIES 

1. Plaintiff Gordon Roy Parker, a.k.a. Ray Gordon, is an adult male resident of the 

Commonwealth of Pennsylvania, domiciled and residing at 4247 Locust Street, #806, Philadelphia, 

PA 19104. Plaintiffis the sole owner.of Snodgrass Publishing Group, a Pennsylvania sole 

proprietorship and internet publi~her, whose website is located at www.cybersheet.com. and whose 

seduction advice websites are located at http://www.cybersheet.com/library.html and 

http://www.cybersheet.c.orn/easy.html. 

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Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 4 of 53
2. Defendant Learn The Skills Corp. ("LTSC") is a Delaware corporation who can be 

served through its registered agent, Business Filings, Inc., at the address listed for it in the caption. 

3. Defendant Formhandle@fastseduction.com ("Fonnhandle") is the sole owner, or 

one of the owners, of Defendant LTSC, and can be served through LTSC's registered agent, at the 

address listed in the caption. Defendant LTSC operates a "seduction portal" website at 

http://www.fastseduction.com ("the LTSC website")and earns its revenue through affiliate 

commissions on sales of products which sponsor its site. The LSTC website also contains articl~s on 

seduction, a message board system it calls "mASF," or "moderated alt.seduction.fast," and a 

message board called PAIR, the "Pickup Artists' International Registry." 

4. Defendant Toykopua@fastseduction.com ("TokyoPUA") is an officer or director 

ofDefendant LTSC, and can be served through LTSC's registered agent, at the address listed in the 

caption. 

5. Defendant Straightforward, Inc. ("Straightforward") is a corporation located in 

Texas, who can be served at the address listed for it in the caption. Straightforward is the corporate 

distributor of the "Speed Seduction" line of products, a series of information products designed to 

teach men how to seduce women, and can be served at the address listed for it in the caption. 

6. Defendant Paul Ross is the creator ofthe "Speed Seduction" line of products, a 

series of information products designed to teach men how to seduce women, and can be served at the 

address listed for him in the caption. Defendant Ross exercises "substantive control" over the 

website that sells Speed Seduction products, http://www.seduction.com. The seduction.com domain 

is owned by Defendant Straightf,?rward. 

NATURE OF CASE/STATEMENT OF JURISDICTION AND VENUE 

7. This case is a "refiled" version of Parker v. Learn The Skills Corp. et aI., E.D.Pa. 

#05-cv-2752. In that case, Defendants LTSC and Ross were dismissed on March 23, 2006 for lack 

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Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 5 of 53
ofjurisdiction. In this case, Plaintiffis seeking relieffor claims ofLanham Act violations, 

defamation, tortuous interference, and civil conspiracy. 

8. Jurisdiction in Delaware over Defendant LTSC is conferred because LTSC is a 

registered Delaware Corpomtion, and is further confeiTed under §3104~c)(2) because LTSC sells 

products as an "affiliate" in partnership with its sponsors (:where it receives sales commissions) who 

sell products to residents ofDelaware, and because itsolicits contributions globally, including users 

in Delaware, on a persistent and ongoing basis. Jurisdiction is further conferred under §3104(c)(4) .. 

because Defendant LTSC has tortiously injUred Plaintiffoutside ofDelaware, while it conducts and 

solicits business (as a commissioned affiliate) to residents ofDelaware, on a persistent and ongoing 

basis, thus deriving substantial revenue from the use and consumption ofits affiliated products and 

services (which include Speed Seduction) within the state. 

9. Jurisdiction in Delaware over Defendant Straightforward is conferred by §3104(c)(2) 

. . ofthe Delaware Code because, during all relevant times, Straightforward sells the Speed Seduction 

product line (and solicits ~es ofsame) to residents ofDelaware, on an ongoing and persistent basis, 

thus contracting to supply goods and services in the state. Jurisdiction over Straightforward is 

further conferred by §3104(c)(4) because Straightforward has tortiously injured Plaintiffoutside of 

Delaware, while it conducts and solicits business on a persistent and ongoing basis with residents of 

Delaware, thus deriving substantial revenue from the use and consumption of its product line within 

the state. 

.10. Jurisdiction in Dela~eover Defendant Ross is conferred by §3104(c)(2) ofthe 

Delaware Code, because, during relevant times, Defendant Ross has been a party to all sales 

con~cts made by Defendant Straightforward of the "Advanced Home Study Course," in that he is 

contractually obligated, by purchase, to provide a one-hour telephone consultation with customers 

who purchase the course, including customers who reside in Delaware. Jurisdiction is further 

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Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 6 of 53
conferred by §31 04(c)(4) because Defendant Ross has tortiously injured Plaintiff outside of 

Delaware, but he derives substantial revenue from the sale and use of the Speed Seduction product 

line to residents of Delaware, for use and consumption in the state. 

11. Jurisdiction over Defendants Formhandle and TokyoPUA in Delaware is conferred 

because they are directors or officers of a Delaware corporation, and is further conferred under 

§31 04(c)(4), because each Defendant derives substantial revenue from the use of products and 

services that are sold to residents of Delaware, for use and consumption in the state. 

12. Federal jurisdiction is conferred by 28 USC §1331 and §1338(a) because ofthe 

existence of federal questions; the Lanham Act (15 USC §1125 et seq.); 15 USC §22, which confers 

jurisdiction over any district in which a corporation transacts business; jurisdiction over the 

defamation/civil conspiracy claims is conferred by virtue of diverse jurisdiction and the amount in 

controversy being greater than $75,000.00. Jurisdiction over the RICO claim is specifically 

conferred by 18 USC §1965(b), which provides for nationwide service of process. 

BACKGROUND 

13. The Defendants in this case all earn their livings through the sale of internet-based 

information products designed to teach men how to seduce women. The transactions which relate to 

this action occur primarily through three websites: a) Plaintiffs, for his products sold through his 

website; b) Defendants Ross and Straightforward, through the "Speed Seduction" products sold 

through http://www.seduction.com; and c) Defendants LTSC, Forrnhand1e and TokyoPUA, through 

sales commissions generated when sales of affiliated products, including Speed Seduction, are made 

through the LTSC website at http://www.fastseduction.com. 

The Seduction Cartel 

14. The bestselling book The Game, by Neil Strauss (HarperCollins, 2005) has shed 

light on what Strauss refers to as the "seduction community," a group of tightly-knit websites which 

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Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 7 of 53
offer advice to men seeking to become "pickup artists" or "PUAs." These websites are clearly direct 

competitors with each other, offering very similar products to a literally identical target market: the 

"average frustrated chump," ("AFC''), the typical "nice guy" male who did not get good results with 

women, and who feels betrayed. He decides to do wnatever he thinks will work with women, and 

turns to these "seduction gurus" for advice, either after reading The Game or seeing Neil Strauss on 

television, or after ~earching the internet with terms such as "how to get laid" or "how to get 

women" and so forth. The only problem is that what Neil Strauss called a "community," the courts .. 

usually refer to as a carteL 

15. These APC males Constitute the most fertile market for the seduction gurus, as they 

are "virgin" consum~rs who are desperate for results, ready to buy, and willing to spend up to 

$5,000.00 per day for individualized coaching from real-life men such as the one the movie Hitch 

was based on. These men are known as "whales" and provide the greatest revenue, bilt they sit atop 

a pyramid that includes less expensive products, such as $2,450.00 group "bootcamps" or 

"worskshops" that involved going out ''into the field" (nightlife) for lessons and critiquing of their 

practice with women. Moving down the pyramid, you have $1,000.00 seminars such as those run by 

Defendant Ross, $300.00 OVD courses, and e-books which usually retail for around $40.00. 

16. By comparison to the other gurus, Plaintiff's work is a bargain: his first four 

seduction e-books (Outfoxing The Foxes, 29 ~easons Not To Be A Nice Guy, Perfect Seduction, 

and Why Hottles Choose Losers) are all available absolutely free on Plaintiff's website. His current 

book, Seduction Made Easy, costs $19.95 for purchase, but includes lifetime free updates to the 

book for that price, and the book.can be had for free if a customer purchases any oftwo dozen 

competing products from Plaintiff's site (plaintiffreceives a sales commission averaging 50 percent 

on affiliated products, sufficient to offer his own work in tandem for free). 

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17. The contrast in Plaintiff's business model with that ofthe "seduction cartel" 

members cannot be overstated. His business model is futuristic in that it relies on a much larger 

internet audience - one that is still being built - to justify its existence. At $19.95 per reader, 

Plaintiffcould retire with 50,000 paying customers. The "pure intemet:' audience is currently 

insufficient to yield that type ofcustomer base without inCurring substantial marketing costs. 

Defendant LTSC, for example, had approximately 8,000 users·during the beginning ofthe time in 

controversy, and due to mainstream publicity, it now claims 20~000 users on its message boards. • 

18. The difference between plaintiff's "b~y the author" model and the seduction cartel is 

that Plaintiffbas chosen to take the'"long road" to intemet success, relying primarily on the growth 

ofthe medium, while the Cartel, led by Defendants Ross/Straightforward and 

LTSC/FormhandlelfokyoPUA, relies instead on anticompetitive behavior (excluding 95 percent of 

the advertiser pool), hard-selling its high-priced products to a limited audience, defaming its 

competition while agreeing to a "hands off" policy for itself, and enlisting the aid ofrank-and-file 

"seduction community" members to do their dirtywork, either for direct compensation (money, free 

product), or, sadly, for the simple feeling ofbelonging with the "cool guys," since many ofthese 

men were outcasts for their. entire lives before finding the cartel. 

IDstory of The Seduction Cartel 

19. The seduction cartel has its roots in Defendants Ross and Straightforward managing 

to secure their own USENET group, called alLseduction.!ast ("ASF''). 

.20. USENET is unlike any other internet message board system, because it is a 

decentralized compilation of ISP~based"news servers" that store messages for each USENET group. 

USENET groups are viewed by millions ofinternet users (according to various sources), while ASF . . 

has a substantial readership, and dozens ofregular posters as well as a steady flow of transients. The 

ratio of"lurkers" who do not post messages to those who do is thought to be substantial, and that 

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Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 9 of 53
ASF's actual readership is in the thousands if not tens ofthousands. This audience is expanding, due 

primarily to a) Google's archiving of the group and b) presenting it on its web-based news server 

("Google Groups"). 

21. Google is so dominant in the internet search market that it has become a verb (to 

"Google" someone is to use Google to research them), and according to a recent CNET article, now 

holds 42.3 percent of the domestic search market. 1 Google users who search for seduction advice 

will have the option of viewing search results not just from the web, but also from USENET, 

including ASF. Many of Google's USENET readers do not even know what USENET is, thanks to 

the "Google Groups" interface. USENET readers, by contrast, are well aware of Google and its 

USENET archive, and rely upon it regularly. Existing subscribers to other USENET groups will use 

Google Groups to augment their research into seduction information (and products). 

22. The ASF USENET group was created in 1994, primarily as a means of resolving a 

conflict between Defendants Ross/Straightforward and regulars in two other USENET groups, 

alt.romance and soc.singles. Those groups have a long history on USENET and, like most ofthe 

alt. * groups on USENET, have strict policies against SPAM. Defendant Ross at the time was very 

computer savvy (it is not easy to get a USENET group created and fully distributed), and rather than 

"SPAM" the group with direct promotions, he would have his students "discuss" his work to the 

point that alt.romance and soc.singles were beginning to resemble infomercials. Once ASF was 

created, Ross moved to that group, and since the internet audience was generally small, he was 

allowed to treat the group pretty much as his own, with little or no protest from others. 

23. In 1996, the internet changed drastically, when AOL replaced its $2.95-an-hour 

access fee with a $19.95/month unlimited subscription rate, and when AOL began, around that time, 

providing access to USENET. Suddenly, the general internet population flooded onto USa,mT, 

I Source: http://news.com.com/Googles+market+gap+widens/2100-10303-6054990.html
 

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including ASF. By mid-1998, ASF had become more than just a "Speed Seduction" group, and the 

seeds of what would become the "seduction community" were born. 

24. In late 1998, Plaintiff released his first book, Outfoxing The Foxes, which sold for 

$29.95. Plaintiff had begun his own research into seduction in 1991, when he designed a 

mathematical fonnula for calculating "sexual market value" and compatibility called CUPID.2 In 

1997, he had released a database software based on CUPID, but in 1998, published the CUPID 

formula as the first four chapters of Foxes, devoting the remainder of the book to explaining how to • 

use CUPID as part of an overall "Foxhunting" strategy. Plaintiffs "Foxhunting" method and the 

Foxes book were in direct competition with Defendants Ross/Straightforward's Speed-Seduction 

products, which cost substantially more than Plaintiffs. 

25. Almost immediately after publication, Foxes began making steady sales, an average 

offive to ten books per week. The inexpensive price was siphoning ASF market share from 

Defendants Ross/Straightforward, because readers of Foxes who were able to solve their love life 

problems had no further need for expensive products like Speed Seduction. Defendant Ross did not 

take kindly to this new competition, and almost immediately began acting out against Plaintiff, while 

enlisting several of his estiI:nated 40,000 fans to follow suit. 

26. Examples ofthis "acting out" have been detailed in previous lawsuits, the most 

recent ofwhich being Parker v. LTSC (II), where the court in that case deemed the complaint too 

"voluminous." In the interest of brevity, Plaintiff will provide brief "highlights" of what he had to 

endure from 1998-2001 on ASF, from both Defendant Ross and his followers acting upon his 

wishes: 

2 The CUPID system assigns a score for an individual's "looks," "brains," "status" and "personality" based on how much 

each gender values those traits in the other gender. For example, "looks" is worth 80 percent ofa woman's score, but 

only 55 percent ofa man's, based on societal norms. The other half ofCUPID is a "partner rating" system which 

replaces the societal norms with that partner's specific preferences: e.g., a golddigger would value a man's money at 80 

percent rather than the norm of20 percent, etc. 

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a. Repeated defamation, including claims that Plaintiffwas a plagiarist, a "fraud," 

had invaded the privacy ofhis customers (to deflect criticism. against Defendant Ross, who had 

actually done this), and the posting of a pages-long "rap sheet" alleging Plaintiffhad a long criminal 

record from someone calling himself"PhillyCop8." . 

b. Near~perpetua1 attacks on his family, (with'whom Plaintiffhas lived off and on 

for many years), including referring to his mother as a prostitute, who drank during her pregnancy. 

c. A claim from "Mystery" (the seduction guru highlighted in The Game and for ' 

whom LTSC is now an affiliate) that Plaintiff's boo~ had been "scanned and put up on the web," 

thus inducing or promoting piracy bfPlaintiff's works. 

d. Repeated threats against Plaintiff, often involving the threatened use of alleged 

"government connections" by Defendant Ross (who claims to have influence over a "Mr. B" from 

the Justice Department), and a business associate ofbis, Michael Lee Emery ("Bishop"), who RIso 

claimed to have "connections deep within the government" and explicitly threatened Plaintiffwith 

their use. Mr. Emery was later convicted ofbreaking and entering the home ofhis ex-girlfriend, 

Renee Ross. Ms. Ross received a'subpoena from AOL in Parker v. Wintermute (B.D.Pa. #02-cv7215), admitted that Mr. Emery was using her AOL account, and settled all claims against Plaintiff 

in that action for $500.00 and an affidavit supporting her claim ofnot being involved. 

e. Direct threats against Plaintiff's life by "loose cannon" operatives working 

under the direction ofDefendant Ross, or alternatively, who were acting upon his wishes. 

The Current Seduction Cartel: October 2001-Present ("ASF FAQ" and "mASF info") 

27. In 1999, AltaVis~ who published a USENET archive, removed it from the web, 

making it impossible to search past postings on USENET. This archive was purchased by Google 

and returned to the web in 2000. While it was down, however, Defendant Formhandle took it upon 

himself in 1999 to archive ASF postings and make that archive available to readers of ASF. He also 

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formed LTSC aroUnd that time. A version ofthe "ASF FAQ" from that era: referred to LTSC as a 

''noncommercial website," and save for a few links to Amazon.com, it was. 

28. When Google returned the USENET archive to the web, as Google Groups, LTSC's 

main attraction to users was diminished, and the LTSC website began including articles on . seduction, and the PAIR system for enabling like-minded'males from ASF to meet otlline and pick , 

up women in tandem. LTSC also began hosting a copy of The Layguide, a compilation ofASF ' 

postings by Anton Klink, that was later turned into a book by the same name, by HarperCollins. • 

LTSe remained primarily a site with content, an ASF archive, and PAIR until late 2001. 

29. The Seduction Cartel as we know it, however, began its operations on October 28,' 

2001, when, in collusion and conspiracy with Defendants Ross/Straightforward Defendants 

FormhandleILTSClTokyoPUA began promoting a "moderated" (and commercial) message board 

system based on ASF's topic and hierarchy. They called this message board system "moderated 

ASF" ("mASF"). Unlike other web-based message boards, mASF was available not just as a webbased message board, but ~ugh a web-based NNTP server designed to make the groups appear 

like a regular USENET group. Unlike regular USENET groups, however, users ofmASF must fIrst 

register with LTSC in ordef to gain access, rather than having it provided through their own ISP's 

news server. Also unlike the regular USENET, LTSC users must give LTSC a nonexclusive right to 

publish their posts in perpetuity. 

30. From the moment the mASF message boards were initially marketed on October 28, 

2001, Defendants Ross and Formhandle (inclusive ofthe other defendants) conspired and colluded 

to market mASF as a ''ray free a1~mative" to ASF. A strategy was designed whereby anytime 

Plamtift'posted a message to ASF, he would be attacked, defamed, threatened, and otherwise 

harassed. Not only did Defendants Ross and Formhandle have full knowledge ofwhat was 

happening to Plaintiff, they openly encouraged it and would themselves mock Plaintiffanytime he 

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complained. Often they would engage in defamation or threats themselves, but for the most part, 

they left that to their "fans," in order to deflect liability and spread Plaintiff thin while making it 

impractical if not impossible to prosecute. 

31. While reviewing the USENET archives for October 28~ 200 I, Plaintiff uncovered a 

message praising both his work and the relatively low cost. On ASF, a user named "Razor Roberts" 

posted the following message concerning Plaintiffs work, while noting the exmbitant prices of the 

Speed Seduction products: 

Hey, I've gone though several e-books on the subject and have been impressed little. Tlte 

only ebook Ifound sofar to be useful was "Ray's 29 Reasons for Beeing the Jerk Women 

Want." I know Ray gets a lot of flack on this board, but the first 8 or so chapters of that 

ebook are really useful, though. I wonder at times if being such a blatant misogynist hurts 

his game. I can't really afford to go to one ofRoss's seminars, or get his homestudy 

course, for that matter. 

32. Accompanying the creation ofthe mASF message boards was the publication of a 

new "ASF FAQ" document that effectively "carved up" ASF among several commercial interests, 

including the defendants in this action. The purpose ofmASF was to provide a base of operations 

for the Seduction Cartel, and through publication of an apparently neutral "FAQ" document, to serve 

as the propaganda arm for Speed Seduction, by promoting it in this "FAQ," which stated, in relevant 

part (with emphasis added): 

*"'* READ THE MATERIALS BEFORE POSTING (SEE BELOW) *** 

Do this group (and yourself) a favor and read the FAQ before asking newbie 

questions. Do the group an even bigger favor and lurk here for at least a few days 

before making your first post. We all know this group is the greatest gift to man, but 

we don't need to hear it3 times a day and we don't want to hear things like "Hey, I 

want to try this out... what do you guys think?" Just go out and DOlT (after reading 

up on the materials) then report back here as to the results. lfyou want to post a 

question, check the FAQ first to make sure it isn't already answered there. 

After you're done reading the FAQ, here are some other resources: 

Main group-related sites: 

http://www.fastseduction.coml(Fonnhandle·s site) 

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http://www.pickupguide.com/(Maniac.s site)3 

http://www.speed-seduction.coml(Ross· site) 

Ross' newsletters: 

http://www.speed-seduction.comlnews.htm 

Most commonly recommended books/movies on ASF: 

http://www.fastseduction.com/boo~.shtml	 I 

Master kill-filter (aka killfile or kiIl-file) list for ASF: . 

http://www.fastseduction.com/filters.shtml 

Access to moderated ASF groups: 

http://www.fastseduction.comldiscussionl 

And don 'tforget: USE THE KILL-FILTER LIST!!!! 

33. The "killfilter list" referenced in paragraph 32 above contained detailed instructions 

on how to filter out Plaintiffs postings to ASF, with the imputation that he should be ostracized and 

ignored, and a strong encouragement not to do business with Plaintiff, under the false pretext of the 

"ASF FAQ." A normal USENET group "FAQ" is supposed to set protocol for that USENET group. 

Here, the Seduction Cartel has chosen to use this noncommercial device (most FAQs actually 

prohibit commercial promotion altogether or require it to be labeled as such) to assert a formal 

authority in the group, since USENEI group FAQs are often used by ISPs as the basis for 

terminating or suspending accounts for IOS (Terms of Service) or AUP (Acceptable Use Policy) 

violations. 

34. Since or shortly after the inception ofmASF, Defendant LTSC became an "affiliate" 

of Speed Seduction products, and links to the Speed Seduction website were tracked with a referral 

code. This was a pecuniary exchangeinvolving Defendant Ross/Straightforward giving LTSC 

"permission" to market its websi~e through the ASF group on USENET, giving LTSC the pecuniary 

benefit of being able to claim, through its "ASF FAQ," that it had the authority to declare mASF a 

"replacement for ASF," as it would be referred to in later versions of the "ASF FAQ." 

3 http://www.pickupguide.comis part ofthe LTSC w~bsite	 structure and published by LTSC. 

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35. In addition to the "ASF FAQ" document that is posted on a weekly basis to ASF, 

Defendant Formhandle also causes an automatic message to be posted entitled "mASF (aka 

"Moderated ASF") Forum Info & Access." This post was not an alleged FAQ, but carries a similar 

tone. Like the FAQ, the purpose of the posting is an attempt to legitimize Defendant Formhandle's 

SPAM of his website to the ASF group. 

36. The "moderated ASF info" posting began appearing around the same time as the 

"ASF FAQ" document. Plaintiff found an archived message on Google from December 20, 2001 

(previous posts were alluded to but not archived). That post4 was roughly similar to the one which is 

currently posted by Defendant Formhandle, and states, in relevant part (emphasis added): 

[this message is posted to alt.seduction.fast on a daily basis] 

Welcome to alt.seduction.fast (ASF). ASF is a public USENet newsgroup and, as such, is 

essentially an unmoderated discussion forum within a communication anarchy. In many 

ways, this is good. However, this leads to a problem with what the USENet community 

refers to as "trolls", "flame wars", "newsloons", "off-topic" posts, "cross" posts, "spam", 

and a mess of other annoying disturbances which disrupt the topic ofdiscussion. There is 

a moderated evolution to this group, which is available through: 

http://www.fastseduction.comldiscussion/ 

You can subscribe to that newsserverjust like any other news server. 

Your username/password is required to access the newsgroujJ interface 

The groups available on that server are: 

alt.seduction.fast.general (replacement for ASF) 

alt.seduction.fast.tactics-techniques 

alt.seduction.fast.fieldreports 

alt.seduction.fast.advanced (primarily for PUAs) 

jay <formhan...@fastseduction.com> 

Fast Seduction' I01 - http://www.fastseduction.coml 

Class is now in session... 

4 Message ID: <th.] 008878400_3c2fd4631c9a5e60483828f@discussion.fastseduction.com> 

13 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 16 of 53
37. The "FAQ" and "moderated forum" postings are the staple ofthe seduction cartel's 

operations, and set the stage for virtually all the actionable conduct cited in this Complaint. 

Defendants Formhandle/LTSC and Ross created a mutually beneficial partnership designed to give 

themselves an exclusive "right to SPAM" the "mASF" boards to USENET's ASF (the real ASF). 

Going a step further, Defendants Ross and LTSC also made sure to declare to ASF, on a regular 

basis, themselves and through third parties, that Plaintiff had "destroyed" the ASF group, and that 

the mASF message boards were the "solution" to what they referred to as ASF's "problem child." 

To the extent that Plaintiff caused any "problems" for an illegal cartel, he considers that a 

compliment. 

38. While Defendants Ross and Formhandle were building the structure ofthe seduction 

cartel, they were simultaneously enlisting the aid of Defendant Ross's "fans" and a coalition of other 

internet users who disliked Plaintiff in an attempt to create a "Black PR" campaign against Plaintiff. 5 

This campaign involved the use of several operatives - some anonymous, some pseudonymous, and 

some who use their real names - whose (often sole) purpose for posting to ASF was to further the 

Black PRo The operatives, who continue to "operate" to this day, number in the dozens if not over a 

hundred since 2001, each with a specific role, and collectively with the purpose of dividing the 

"dirtywork" among so many individuals that it appears that no single operative is crossing the line, 

and to give the appearance of general agreement among "the group." The operatives also enable the 

principals of the seduction cartel to take the high road, as they travel upon the low road built by the 

principals. 

Specific A~titrust Behavior By Defendants LTSC/Ross 

39. Defendant LTSC is not bashful about its role in the "seduction community." The
 

www.fastseduction.com website has trademarked itself as "the center ofthe seduction universe."
 

5 "Black PR" is a term popularized by the Church of Scientology, and refers to an all-out attempt to destroy an
 

individual's reputation.
 

14 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 17 of 53
DUring most ofthe relevant times in this action, indeed it was, thanks in large part to the conduct on 

USENET set forth herein. Intemet business analysts speak ofthe rule calledfU'St in wins, where 

whoever carves out a market niche before their competitors reaps most ofthe revenue from that 

industry. This has been true for many internet compwes, and LTSC is no exception. Unlike those 

other intemet companies, however, LTSC got its "head start" through its commandeering ofASF in 

collusion with Defendants Ross/Straightforward, who used LTSC as a means of~tainingcontrol 

.. over the ASF audience, as that was no longer possible in 2001, due to the influx ofa much wider 

audience than the original Speed Seduction followers,who populated the group when USENET was 

a mere backwater ofthe internet in: 1994. 

40. Defendant LTSC did not take many sponsors at first. At the direction of Defendant 

Ross, and in retwn for Defendant Ross's permission to promote mASF on USENET (as long as the 

Speed Seduction website was listed in the "FAQ" as a "main, group-related site), LTSC's first 

"sponsor" other than the Amazon book links was Speed Seduction, to whom all referrals from LTSC 

were tracked. "Tracking" hyperlinks are advertising-specific in that they measure exactly how many 

leads a referral source produces, and the ultimate value ofthose leads by the revenue they generate. 

Defendant LTSC's links contained tracking information that identified it as a Speed Seduction 

Affiliate. 

41. In 2002, the seduction cartel began expanding as LTSC began accepting more 

advertisers. Unlike most publications that adhere to antitrust laws, LTSC does not have a rate card, 

and only accepts advertising from sel~t sources. As its site grew; LTSC gained more power and 

influence than Ross and Straightforward due to its appearance ofneutrality, but the Speed Seduction 

website being listed on the USENET group, and likely a reduced or nonexistent compensation for 

the affiliate links on the LTSC website were sufficient compensation for the partnership with LTSC, 

15
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 18 of 53
who either claimed or was given the :freedom to expand the cartel, while the cartel still benefited 

Defendants StraightforwardIRoss substantially. 

42. Since its inception, LTSC has maintained a policy whereby any mention of 

Plaintiff's name or his products on its message boards is verboten, and ,grounds for banning any user 

who violates the rule. Plaintiff, his company, and his prOd,ucts are also listed repeatedly illthe "ASF 

killfilter list" that is referenced in the "ASF FAQ" posting. 

43. Since 2002, LTSC bas added several advertisers who produce seduction products • 

that include e-books, CDIDVD courses, workshops,semi;nars, and one-on-one "bootcamps." The 

first addition known to Plaintiff was the Double Your Dating e-book sold by Eben Pagan, who also 

offers seminars and DVD products. After that (around 2003) came several other products, including 

an e-book called High Status Male, and another called David Shade's ManuaL These books are 

targeted at the same audience as Plaintiff's, and purport to teach the same skills (seduction). 

44. In 2004, the "seduction community" began getting mainstream'media coverage, most 

notably in the form of a New York Times article by Neil Strauss which was a precursor to the game, 

and which popularized the individualized insti'Uction provided by Erik von Markovic, alkJa 

"Mystery" (upon whom the movie Hitch was partially based). This created a substantial new market 

for expensive workshops and seminars, as well as an increase in the market for e-books and DVDS. 

LTSC began accepting more affiliate programs at this point, including the "Real Social Dynamics" 

workshops (Mystery's original company), Mystery's workshops and seminars (the "Mystery 

Method"), and later his $58.00 e-book and $300.00 DVD set entitled The Venusian. Arts. Other new 

sponsors include DynamicSa Life (by "Gunwitch''), Seduction Science (an e-book), Real World 

Seduction ("Juggler's e-book''), The Appl'Oach (a workshop run by "Woodhaven and Dimitri," two 

Massachusetts-based friends ofDefendant Formhandle). Once The Game was published, LTSC 

began marketing that book as well, through its Amazon links. 

16 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 19 of 53
45. The affiliate revenue is substantial: Mystery pays his affiliates $275.00 for each 

workshop/bootcamp referral, while e-books such as Dynamic Sex Life net LTSC approximately 50 

percent of that book's purchase price.($50.00). The typical affiliate revenue for e-books is 50 

percent, and for seminars and workshops, 10-20 percent, while DVD pfoducts are variable but pay at 

least as much as the workshops. Its large audience, rare among similar internet sites of this time 

period, enabled LTSC to become a virtual cash machine. 

46. Defendant LTSC admits on its own site that "advertisements are accepted/rejected at· 

our discretion.,,6 Regarding its affiliate programs, it states: "Fast Seduction 101 engages in affiliate 

programs with vendors of qualified products." 7 

47. As even rudimentary discovery would confirm, Defendants LTSClFormhandle have 

become kingmakers among the seduction gurus, and have routinely abused that power by leveraging 

its exclusionary and anticompetitive advertising policies. Several of its sponsors began with the 

"gurus" gaining a following through the LTSC message boards. Sponsors of LTSC were not and are 

not permitted to speak highly of Plaintiff, and are routinely encouraged not to mention him at all, on 

LTSC' s message boards, or anywhere else on the internet. Anyone who breaks rank on this policy 

would risk being blackball~d and cut off from communication with LTSC's purported membership 

of 20,000 users. 

48. LTSC, as the "center of the seduction universe," is abusing its market position in 

order to artificially inflate the prices of its sponsors' products and to restrain the trade of advertisers 

who have "qualified products" but who are banned from advertising on the site, even ifthey paid the 

normal rates. This is done for the benefit of LTSC and all of its sponsors, including Defendants 

Ross and Straightforward. Plaintiff is one such advertiser whose trade has been restrained, but he is 

6 Source: http://www.fastseduction.com/advertise.shtml
 

7 Source: http://www.fastseduction.com/adproducts.shtml#ad2
 

17 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 20 of 53
by no means the only one. Absent discovery, the full breadth ofthis abuse ofpower cannot be 

known. 

The Seduction Mafia CRJCO Enterprise) 

49. Parker v. LTSC an alleged an associanon-in-fact RICG> enterprise called the 

"Seduction Mafia," whose purpose was, through a patteni.ofracketeering activity, to act as enforcers 

for the seduction cartel. That case named defendants Ross, LTSC and Fonnhandle~ as well as three 

other defendants, including Thom E. Geiger, owner ofthe domam http://www.ray-gordon.com.at .

which a "hate website" targeted at Plaintiffcalled Th~ OFFICIAL Ray Gordon FAQ: A Document 

About Gordon Roy Parker (''the RayFAQ") was published. Defendant Geiger was ruled not to be 

subject to the Pennsylvania jurisdiction, and has not been named here due to his allegedly 

noncommercial involvement 

50. The RayFAQ site contained numerous malicious lies concerning Plaintiff, including 

but not limited to clm that a) "law enforcement is well aware of [plaintift] and thinks he is 

mentally unstable," b) that Plaintiffwas an imminent danger to himselfand others and in need of 

involuntary commitment, and c) that he has plagiarized the work ofothers. Additionally, the site 

encouraged users to contact anyone and eVeryone in Philadelphia concerning Plaintiff. including all 

levels oflaw enforcement, state and local prosecutors, mental health agencies, the University of 

Pennsylvania (whom Plaintiff sued for employment discrimination), and a dozen or more media 

outlets, with full contact information listed. The site also encouraged third parties to link to the 

RayFAQ site. and one third party in particular would link to the RayFAQ while also linking to the 

"mASF" message boards on LT~C's website. 

51. The Seduction Mafia in general, and the RayFAQ site in particular, were published 

in retaliation for Plaintiffbeing in competition with the defendants in this case, and also in retaliation 

for Plaintiffhaving made numerous reports to law enforcement in the past, including in response to 

18
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 21 of 53
threats made against him by Geiger dating back to 1998 in the USENET group alt.sports.gymnastics. 

Mr. Geiger has had an "axe to grind" against Plaintiff ever since Plaintiff exposed child abuse in 

gymnastics, and was recruited specifically to use his domain to publish the RayFAQ, while claiming 

anonymous, third-party authorship ofthe site. Discovery, however, rev,ealed that Mr. Geiger was the 

only billing and administrative contact for the domain. and he never supplied the name of any 

alleged third-party publisher. 

52. The conduct of the Seduction Mafia was undertaken in furtherance of the seduction • 

cartel alleged here, at the express and implied direction ofDefendants Ross and Formhandle, for the 

pecuniary benefit of all defendants, including but not limited to following the general instructions in 

the "ASF FAQ" (published by LTSC/Formhandle/TokyoPUA), and the many specific instructions 

from Defendant Ross to ostracize and act out against Plaintiff. In both cases, Defendants Ross and 

Formhandle, acting on behalf of the other defendants through their respective corporations, have 

declared ASF as their personal "marketing turf' and enlisted the support of their followers 

(operatives) to commit predicate acts against Plaintiff. often anonymously. 

53. In several specific 'cases. the preponderance of evidence that can be obtained without 

the benefit offull discovery leads Plaintiff to aver. upon that information and belief. that Defendants 

Ross and Formhandle. acting for themselves and their corporations, conspired and colluded an10ng 

themselves to enlist numerous third parties to carry out their wishes, while in other cases, they aided 

and abetted the commission of predicate RICO acts. Plaintiff further avers that full discovery would 

uncover a "money trail" (or other pecuniary reward trail) which reflects a true quid pro quo between 

the defendants and the "operatives" who were directed to appear to be acting as disconnected 

individuals. but who in reality were deriving profits from the seduction cartel. 

54. Relevant acts by Defendants Ross/Straightforward. Relevant acts by Defendant 

Ross (acting for himself and Defendant Straightforward) include the following: 

19 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 22 of 53
a. As far back as December 12,2002, Defendant Ross, who was named as a John 

Doe defendant in Parker v. Wintermute, was aiding and abetting the Seduction Mafia by publicly 

threatening Plaintiff in response to a subpoena to AOL for his identity, as well as promoting his 

website in the same posting. The posting states, in relevant part: 

I received notice from AOL that Mr. Parker is seeking my information from
 

them(I received a copy of a very sloppy subpoena duces tecum).....Should I
 

indeed be named and served in a suit I wiII immediately cross-claim against Mr.
 

Parker-although he likely has few monetary assets, we will seek as compensation
 

all ofhis copyrights, computer equIpment, etc. As well, since I have seen some •
 

of the alleged "offending posts" contain my allegations that Mr. Parker is .
 

.....mentally imbalanced, we will seek a court-ordered psychiatric examination of
 

Mr. Parker, to prove the truth ofthese assertions.....! would strongly suggest that
 

Mr. Parker pick a less resourceful and powerful target.
 

Get Laid NOW!
 

Ask me how!
 

Free Get LaidIPersuasion Newsletter
 

www.seduction.com
 

b. Posting a message to ASF and giving clear legal advice and instruction to 

readers of ASF, despite his not being an attorney. Specifically, he stated the following: 

"Ifyou are sued by Ray, IMMEDIATELY after filing your answer, begin 

propounding discovery, first and foremost requesting any and all documents 

supporting his assertions that his business has been damaged. Enjoy the show as 

he squirms and avoids and gets hit with sanctions and fines by the court. Move 

for a psychiatric examination IMMEDIATELY. Watch him squirm." 

(03/24/2004).8 (Emphasis Added). 

c. A day later, Defendant Ross posted the following, to ASF (Emphasis Added): 

"Ray...where do you get the time during the day to make these zillions of 

posts? TAKE YOUR MEDSL..Sue RAYNOW! Ask me how! PUT AN END TO 

HARASSMENT AND ABUSE OF PROCESS!" (03/25/2004).9 

d. On July 27,2005, Defendant Ross responded to an anonymous posting by 

"Editorial Staff," the alleged pub.1isher of the RayFAQ. The "Staff' had published a forged e-mail 

8 Message ID: <20040324102448.07304.00000017@mb-mI8.aol.com>. This message was posted to ASF, from 

Defendant Ross's "ErosLA77@aol.com" account. This account was revealed by AOL to belong to Defendant Ross in 

discovery in Parker v. Wintennute. The title of the message, which was not posted in response to anything, was 

"Defeating Ray's Lawsuit." 

9 Message ID: < 0040325111427.03590.00000079@mb-mOl.aol.com> The "sue ray now" signature was used in many 

posts by Defendant Ross and is a play on his marketing for Speed Seduction: "get laid now; ask me how." 

20 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 23 of 53
which alleged that Plaintiff had harassed a nonexistent woman named "Jeri Ryan," and threatened 

Plaintiff with "paying him a visit." Defendant Ross quoted this mail in its entirety and stated the 

following in addition: 

I swear to Jeri; if Mr. Parker E>OES sue me, he ~ill be reading this piece of sick, 

twisted, hateful email that he.sent, into the record when I take his deposition. 

Ray, you are sick, twisted, evil bilStard and I am going to clean your clock in 

court." (07/27/2005).10 (emphasis added). . 

e. On August 17,2005, Defendant Ross commented on Parker v. LTSC (II): 

Now, let's assume, for a country second, Raytard actually manages to get 

defendants served, cost free, by some magic. How is he going to conduct 

depositions without paying/or a court reporter? (Emphasis Added).! J 

f. On March 28,2006, Defendant Ross posted a message to ASF where he· 

attempts to intimidate Plaintiff into not refiling this case in Delaware, despite him being the one who 

moved for dismissal based on lack ofjurisdiction. He made the following statements in response to 

a posting by another ASF user who claimed that Plaintiff could not refile due to being time-barred: 

I would think that knowingly refiling a case that is time-barred would certainly 

subject the moving party to serious sanctions, perhaps even deliberate attempt to 

defraud the court could result in criminal investigation and penalties as well. 12 

. 55. Relevant acts by Defendants FormhandletroykoPUAILTSC. For the most part, 

Defendant Formhandle has relied on others, including Defendant Ross and the other operatives, to 

"do his dirtywork" for him. He has, however, committed several relevant acts of his own, which 

were made on behalf of LTSC and in conspiracy and collusion with Defendant ToykoPUA: 

a. Defendant Formhandle is the creator ofthe "mASF" message boards, and the 

individual who has been promoting the boards on behalf ofDefendant LTSC, including but not 

limited to the "ASF FAQ" and "moderated forum info" postings. This began on October 28, 2001, 

and continues to the present. This promotion includes referring to the "mASF" boards as a 

10 Message 10: <BFOCn08.15265%notmyemail@address.com>. A copy of the posting is included in Exhibit A, 

which is Plaintiffs abuse report to Comcast made the day ofthe posting. 

II Message ID: <BF355526.165C8%notmyemail@address.com>. 

12 Message ID: <C04ED255.IF14C%notmyemail@address.com> 

21 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 24 of 53
"replacement for ASF" in the context of a "group FAQ" that most internet users consider formal 

policy for a USENET group. 

b. Once the LTSC message board were running, Defendant Formhandle 

repeatedly referred to Plaintiff in derogatory terms wfrile using his site'B exclusion of Plaintiff as its 

primary marketing tool. He referred to Plaintiff as "his bitch,,13 and as a "newsloon" or "problem 

child" that was disrupting the USENET group, this despite most of the "off topic noise" in the group 

being created by Defendant Ross and his followers. 

c. On April 23, 2002, someone posted a message to the LTSC message boards' 

asking about Plaintiffs Outfoxing The Foxes book. Defendant Formhandle responded with the 

following: 

"The guy that wrote that shit was and remains an endless troll to the public 

ASFnewsgroup. His demented bipolar disorder garbage posts, threats of 

lawsuits, misogyny, and general degenerative psychotic paranoia stank up the 

newsgroup so badly for so long that it lead to theformation ofthe mASFforum 

on this server. He's still posting his shit to public ASF because, well, he is 

completely banned from posting on this forum. Which is one of the primarily 

reasons the discussions are flourishing here while the original public ASP turns 

into a cesspool of off-topic useless feces. Oh, and his books are shit. 14 

d. On April 27, '2004, Defendant Formhandle enlisted the aid of the ASF 

readership, including various Seduction Mafia operatives, to "dig up dirt" on Plaintiff. 

"I'm a bit swamped right now but would appreciate someone or a few people 

to take the time to dig up specific pasts posts of Gordon Roy Parker (aka Ray 

Gordon) where he publicly admits to having bipolar/bi-polar disorder (suffers 

from manic depression). Yes, it's related to the case.,,15 

e. On April 30, 2004, Defendant Formhandle posted to ASF, a comparison of 

Defendant Ross's products, and Plaintiffs products, while neglecting to mention his business 

affiliation with Defendant Ross: ' 

13 Message In: <3BF268E9.2A8C3A3C@aol.com>. November 24,200 I.
 

14 Message ID: <17765.2657@discussion.fastseduction.com>.
 

15 Message ID: <408FOOB9.7A65FOI2@fastseduction.com>.
 

22 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 25 of 53
LE!\DEfl 

"Ray, Ross' products rival yours the way chocolate mousse in a crystal serving 

bowl rivals a shit stain on the heel of a shoe. And THAT is my OPINION." 

(04/30/2004) 

f. On February 20, 2006, Defendant Formhandle posted, to the LTSC message 

boards, a message in which he stated a desire to 'implement "comm9n pricing" in the seduction 

industry: 

I will gladly accept definitions of validating what is to be expected & "industry 

standard" and host such on FS. This would include common pricingfor any 

product or service, based on not just perceived value but actual value, and 

numerous points to define that value. This would allow ANYONE with an 

interest in ANY PU-related product to have a reference point for relating value in 

offerings in this industry.16 . 

g. On May 27, 2004, Defendant Formhandle threatened Plaintiff with bogus 

criminal prosecution even for quoting messages from the LTSC message boards, despite courts 

already having ruled that accessing a publicly available board is not trespass, and despite having an 

attorney at the time who could have advised him ofthis: 

"Ifhe does quote or provide some sort of reference, and it's a forum for which 

he's been told he's been told he's not allowed any form of access, and confirmed 

receipt of such a statement, he will be admitting to electronic trespass over state 

lines." (05/27/2004).17 

h. On June 2, 2004, Defendant Formhandle encouraged readers of ASF to 

interfere with Plaintiffs affiliate advertising agreements, by posting the following statements: 

"[Plaintiffs] affiliates probably have some form of affiliate agreement. Or, at the 

very least, they would probably be interested to know the type of person/business 

promoting their products...ifany ofthem were to get numerous e-mailsfrom 

people in regards to an affiliate, they mars decide having that person as an 

affiliate might not be such a good idea." 8 

1. On August 25, 2004, Defendant Formhandle made the following statements to 

ASF after Plaintiff questioned the "altruistic" nature ofLTSC and the other seduction "gurus," 

inquiring about their income, since income is relevant to how easily a man can attract women: 

16 Source: http://fastseduction.com/mast/114/297531/
 

17 Message In: <XbOdnSqsFKVHySvdRVn-hg@giganews.com>.
 

18 Message ID: <3eidne54aesxQyDdRVn-uA@gigan~ws.com>.
 

23 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 26 of 53
• t,';' : 

"LTSC's income is disclosed regularly -- to its accountant and to the IRS. Would 

you like the contact info ofthe IRS?..I can also inform them ofyour WTC 

comments, as well as the time you quoted a story here about a gun/violencerelated incident in a PA court. I'm not sure how they will connect all that 

information but I'm certain they will find it interesting.,,19 (Emphasis Added). 

J. On November 19,2004, Defendant Formhandle posted to ASF, the statement I 

concerning Plaintiff, "You are not a [business] competitor. You are, however, an annoying fuckwit 

and a poo-poo head.,,20 

k. On or around April 3, 2006, it was alleged on "Thundercat's Seduction Blog" 

that there exists a "private mASF" board for the "top community guys," including several members 

ofthe seduction cartel. 21 

56. Other relevant acts by unnamed co-conspirators. The Seduction Mafia operatives 

are numerous, as are their predicate/relevant acts. Following is an extremely small sample of the 

overall conduct, kept small in the interest of concision pursuant to Rule 8(a): 

a. Thorn E. Geiger was dismissed as a defendant from Parker v. LTSC (II). His 

relevant acts included registration ofthe ray-gordon.com domain, publishing or causing to be 

published, the RayFAQ website, with each time he had the site put up on another server after it was 

taken down constituting a separate relevant act. 

b. "Player88" is a man believed to be James King, a member of Defendant Ross's 

"SS List" and a customer of Straightforward, who was acting in conspiracy with Defendant Ross. 

Player88 made a series of death threats against Plaintiffthat were posted to USENET in October 

2004. The messages stopped when Player88 realized that his ISP was going to reveal his identity if 

he continued. Following is a brief sample of his relevant statements: 

19 Message ID: <XZOdneXiBOoqkLDcRVn-qQ@giganews.com>. 

20 Message ID: <Op-dnSXIPIgROgPcRVn-iw@giganews.com>. 

21 http://www.thundercatseductionlair.comis the location ofthe blog. Defendant Formhandle posted a public denial that 

this board exists, but previously, Plaintiff had once downloaded newsgroups from the LTSC website that included a 

listing for a message board named "alt.seduction.fast.private" and which had thousands ofmessages. Plaintiff also 

recently checked out the link http://www.fastseduction.com/private.and found a login prompt, further evidencing the 

existence of the private message board. 

24 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 27 of 53
•
 

1.	 Asking (concerning Plaintiff): "I wonder if a person soaked in premium gasol ine 

bums hotter and longer than a person soaked in regular." (10/03/2004).22 

2.	 I know exactly where you live. Knocked on your door tonight, even. You didn't 

answer. I was dressed in a Grim Reaper outfit. (10/31/2004).13 

3.	 29 days before I become your. "neighbor." And there's not a single sol itary thing 

you can do about it. EXCEPT ... demonstrate corlvincingly that you renounce 

your views and beliefs regarding women deserving to be raped, beaten, abused, 

and murdered. If you choose not to do this, well, then ... as I said, I have rules 

regarding men who believe that women deserve to be raped and 

murdered....You've told others to wait until my internet access was yanked 

...well, I'm still here. And 1 will godammed be here until the day I die or until 

*you* stop posting. (11/02/2004).14 

4.	 I'll be moving intothe Fairfax December 1. I believe that's 30 days away. That 

gives you 30 days to demonstrate convincingly that you have disavowed those 

statements before you have to deal with me personally. (11/02/2004).25 

c.	 "Editorial Staff' is an anonymous poster to ASF whose identity cannot be 

traced, and who claims to be the author ofthe RayFAQ. During the relevant times in this lawsuit, 

this poster linked to the RayFAQ website hundreds oftimes.26 Following are a few relevant postings 

from this user: 

1.	 If you think you are, open that faggoty little mouth of yours again, trying to 

threaten us, and we will see who runs and hides. We'll even call the cops/or you, 

22 Message In: <1096832391.08fYlp/j2Mk8IzXpt5upmw@teranews >. The remainder of the message gives a horrorfilm like description of what Mr. King intended to do to Plaintiff, to torture and kill him. reads as follows: "Probably 

hotter, but not longer. But first, I'd remove the person's teeth one at a time, but leave the nerve endings intact. Then I'd 

pour boiling coffee (decaf so the person wouldn't shake) over the gummy nerve endings, then I'd pour ice water over the 

sensitive nerves, causing intense contrasting pain (with enough relief to make the following pain feel that much worse.) 

Then I'd pull out the nerve endings one by one using microscopic tweezers. No anesthesia, of course. But I would 

paralyze the vocal cords so no screaming could take place. Just suffering ...I'd perform liposuction on the overweight 

person's body and then force them to eat French fries cooked in their own fat. Anything thrown up would be refed until it 

was digested. Then I'd give the person two paper cuts ... one on each eyeball. I'd administer an overdose of sleeping pills 

and modafinil so they'd want to fall asleep but couldn't. They'd feel their heartbeat slow down. Then I'd speed it up with 

Bronkaid (legally available ephedrine). Then I'd use hypnosis to intensify the pain in the same way that Darth Vader 

would torture Princess Leia in the NPR version of Star Wars. Then I'd soak their bodies in 37% salicylic acid until the 

skin begins to flake off like a leper. Then I'd read some Vogon poetry and blast them with the Shoe Intensifier Ray. 

Resistance is useless! Resistance is useless! Then I'd bathe them in 93 octane gasoline and then take a smoke break, but 

forgeting my lighter, I'd have to use flint and steel to make sparks to create a fire. *poof* The flaked skin will burn faster 

and hotter than unflaked skin." 

23 Messaue In: <311020042338329395%name@host.ws>. 

24 Message 10: <021120040900101465%name@host.ws>. 

25 Message In: <021120040059145128%name@host.ws> 

26 A Google search in June 2005 for "ray-gordon.com" and "Editorial Staff' for the group alt.seduction.fast returned 282 

results, indicating at least that many postings and separate links to the RayFAQ. 

25 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 28 of 53
and make sur~ that the ambulance is there to patch up your injuries. " 

(08/01/2003).2 (Emphasis Added). 

2.	 ifhe's stupid enough to ever try to get us into court, we will then movefor him 

to be Baker Acted and committed to a psychiatric institution for his own (and 

our) protection. (10/30/03).28 (Emphasis Added). 

, 3.	 Just wait. You're about to find out the cost of fooling with the wrong people. And 

the sweet part of it is, you won't even be able to see it coming. It wi II descend on 

you when you least expect it, from the most unlikely direction...Are you looking 

over your shoulder yet? Well, it won't do you any good. 

Hahahahahahahahahahahaha..." (08/11/03).29 

4.	 We received an interesting email a few days ago, from someone who was 

connected to Dr. Ryan, and with that person's permission, we post it here, so that 

everyone will know just what Mr. Parker is attempting to do here ....<snip of 

forged e-mail> We wonder what could be done about this? We do know that an 

attorney representing the person in question has contacted law enforcement in 

Philadelphia, in an attempt to forestall this kind of behavior in the future. We 

wonder if it won't take more than that. Perhaps someone actually paying a visit 

to Philadelphia to explain the consequencesfor actions like this, in person. 

(07/26/2005).30	 . 

5.	 We do not see that "suffering" is an option that Gordon Roy Parker is remotely 

capable of dealing with. The facts have shown in the past that he NEVER takes 

responsibility for his own actions, his own words, or anything else that he, 

himself, is responsible for creating. He will allow this ignominious defeat to 

fester in his diseased mind, and soon enough, will snap. At that point we will 

all see on CNN, or AP, or some other news source that there has been a mass 

killing in Philadelphia, because Gordon Roy Parker will want to take out as many 

people as is possible, in order to exact revenge. This action will give him a 

Godlike feeling of power, in that he will finally be able to pick and choose who 

will suffer at his hands, for all the wrongs HE has had to endure. (03/26/06).31 

d.	 "Thrasher Remailer" is another anonymous user who posts a "SPAM" 

message in response to as many of Plaintiffs ASF messages as possible. This operative's purpose is 

to disrupt any ASF threads where Plaintiff posts messages, and promote LTSC as the solution to the 

27 Message lD: <fe06681414ceafad47a9138t274521ge@dizum.com>.
 

28 Message lD: <ZP008M4A37924.4036226852@anonymous>. The TRO was denied not because ofthe merits,
 

and not because this court recognized the site's right to exist, but rather because the TRO motion was filed ex-parte, and
 

this court said that injunctive relief could be sought at a later time. Plaintiff later filed a DMCA notice against Geiger
 

and had the site successful1y removed. No orders of this court were disobeyed, no laws were broken, and no crimes were
 

committed.
 

29 Message 10: <c9d998tlO62bf5f7b42ba4745c538120@dizum.com>.
 

30 Message TD: <INFIGX5238560.4338078704@reece.net.au>. This message was quoted in its entirety by Defendant
 

Ross, who added that he would have Plaintiff "read the e-mail he sent into the record."
 

31 Message ID: <EXLRKS2V38803.0499652778@reece.net.au>. This message was also quoted by Defendant Ross in
 

its entirety.
 

26 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 29 of 53
disruption. This was done in conspiracy with and with the full encouragement of Defendants Ross 

and Formhandle. Following are this user's relevant postings: 

I)	 New visitors to alt.seduction.fast are welcomed and directed to the main website 

http://www.fastseduction.com Most seduction discussion has been relocated to 

theforums on this website, which are also known/as mASF. These forums can be 

accessed through your news reader just like this newsgroup, or through a web 

interface. The forums were created as an alternative to the large amount of 

spamming, misinformation, and offensive behavior by a high-volume poster 

known to unfotunately suffer disabling mental illness, in the regular 

alt.seduction.fast newsgroup. As the forums require registration (which can be done 

through an anonymous email account), disruptive individuals are completely 

prevented from posting. This results in a much more useful and productive forum. 

Drop by and see for yourself. For information on a particularly disruptive poster 

in the alt.seduction.fast newsgroup and his history of mental illness and harassing 

others, visit http://www.ray-gordon.com.(08/12/03.11/21/2003 and 06/02/2005).32 

(emphasis added). 

2)	 Welcome CF! Please be aware that the vast majority ofasfactivity has moved to 

the forums on our official website at http://www.fastseduction.comIf you sign up 

for an anonymous account then you can access the forums right through your 

newsreader,just like here. Otherwise you'll have to use the web interface. You'll 

find many other resources on the site also. (09/22/03).33 (emphasis added). 

e.	 "Vijay." This internet user, a "fan" of Speed Seduction (and follower of 

Defendant Ross, in conspiracy with Defendant Ross, threatened, on or around April 26, 2005, to kill 

Plaintiff by shooting him, and repeatedly threatened around that time to ambush Plaintiff in his 

home. 

f. Osgaldor Storm, alk/a Don_Juan@nlp-nhs.org, who posted a series of 

messages to ASF from Apri11-25, 2005 whereby he counted down Plaintiffs "remaining days," 

referred to Plaintiff as a "terrorist," and made several repeated threats to murder Plaintiff. These 

threats were made in collusion and conspiracy with Defendant Ross. 

g. Derek Trunk, alk/a "Odious," and Alex Kaufmann, a/k/a 

"AKaufmann@nyc.rr.com, who have both posted hundreds of messages during the relevant times in 

32 Message 10: <c9d998flO62bf5f7b42ba4745c538120@dizum.com> and <NL477QS737946.9433796296@Gilgameshfrog.org>, and <II9QKKQP38505.6344791667@anonymous.poster>, respectively. A Google search performed on June 

3,2005 for the term "unfotunately" for the ASF newsgroup returned 562 nearly identical results, with all postings made 

anonymously. 

33 Message 10: <N6WGD5TL37886.5640277778@Gilgamesh-frog.org>. 

27 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 30 of 53
this action promoting the LTSC website, supporting its mission to exclude Plaintiff, and disparaging 

Plaintiffs work whenever possible while attacking Plaintiffs mental state is deficient. Both ofthese 

users routinely provide links to the LTSC website when users have questions on ASF, and advise 

new ASF readers that Plaintiffhas somehow "ruined'Y ASF. These messages were posted in 

collusion and conspiracy with Defendants Ross and Fonnhandle. 

h. Vincent Runza, Jr. Mr. Runza, a convicted heroin trafficker,34 and also a 

moderator in the "mASF chatroom," an #IRC channel that is directly linked to from the LTSC 

website, and from which LTSC has also instructed to bar Plaintiff and any mention of him or his· 

products. Some of his relevant statements include the following: 

1)	 Gee, I sure hope Ray doesn't think about KILLING HIMSELF BEFORE 

SOMEBODYDOES IT FOR HIM! Y'know, like my late friend Jack suggested? 

And I mean that in an unqualified, totally sincere way. (12/04/02) (Emphasis 

Original and added). 

2)	 What I would really like to do is send afew bikers to your how;e to beat the 

living shit out ofyou, but I'm not going to do that. Instead, I'm gonna let you 

twist what Ijust said around to being a REAL threat. Hopefully, you'lljump in 

head first and make a wild claim of terroristic threats to law enforcement. That's 

when I'll spring my trap! (01/08/04) 3S (Emphasis added). 

i. Aardvark, alkIa Aardvark9084@insightbb.com, a self-admitted Speed Seducer 

and follower ofDefendant Ross's, has been among the most active operatives in recent times. 

Following is a sampling ofsome ofhis more vitriolic statements (emphasis added), which were 

made at the direction of and in conspiracy with Defendants Ross and Formhandle/LTSC: 

1)	 "he has criminally tresspassed (afederal offense) into websites andforums.... 

ray gordon or gordon roy parker or whatever he wants to call himself belongs in 

jail for his crimes. i told him that as a memher ofthe media i would hold him 

accountable for his actions and call him on the carpet whenever he makes a 

statement." (07/24/04).36 (Emphasis Added). 

2)	 "i just want him to know that he's facing prison time, time away from usenet and 

instead his gross shell of a body in the clutches of equally evil men who won't 

34 USA v. Plummer et aI., D.NJ, #OO-M-7082 is the record of his conviction.
 

35 The full posting is attached hereto as Exhibit H-3 and incorporated by reference as iffully stated verbatim herein.
 

36 Message ID: <8nwMc.23088$8_6.6086@attbts04>.
 

28 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 31 of 53
...... : 

'" ".,r 

put up with his games. men who look to stretch the anus of a punk like him." 

(07/25/04).37 

3)	 [T]his wasforwarded to all the email addresses provided in the original plea 

for help [the RayFAQ]. courts, sheriffs office, dist atty, etc. they all got it. my 

grandpa always said that ifyou sling enough shit, some of it's bound to stick 

somewhere. lets just see where some of this sticks, shall we? [Following is the 

alleged "letter" he sent]: I 

Gordon Roy Parker/4247 Locust Street, #806/Philadelphia, PA 19104/ 

(215) 386-7366 

The above individual (AKA Ray Gordon) has publicly admitted to the 

crimes of "hijacking" a website and replacing the information with false 

information in an effort to have the site shut down. He has also been 

engaging in threatening Internet Service Providers into giving up 

information on their clients by falsely claiming, over the phone, to be a bar 

certified lawyer in an attempt to coerce said providers into bowing to his 

will. Mr. Parker has also been caught reposting information to a usenet 

newsgroup(s) obtainedfrom a website and message forum that Parker 

was forbidden from accessing due to his behavior. Even after being 

warned to cease and desistfrom such behavior, Parker kept "hacking 

into the site, using alternative aliases to hide his identity.38 

He has engaged in outright barratry and threats oflawsuits to silence his 

critics who only wish for Parker to refrain from illicit or discourteous 

behavior. He has libeled users of the usenet group with terms such as 

"hypno-rapist" and "mind rapist". Parker has wished death upon the 

children of his detractors. This individual is a danger to the public at large 

and a man admittedly enjoying what he perceives to be an "immunity" from 

punishment for his acts bragging about being such engaged in criminal 

activities on a regular basis. It is my sincere hope that you would be able 

to assist with the apprehension and seclusion from decent society ofMr. 

Gordon Roy Parker, be it in a jail or perhaps a mental institution should 

it be deemedfitting ifParker is declared incompetent. 

4)	 "you ripped off[Plaintiffs first book] from ross jeffries." (08/27/04i 9 

5)	 "ray is a fugitive from justice who forgets that that will be very likely 

brought up at any of his future courtjesterings." (03/08/05).40 

6) "i wonder what kind of dirt the pennsylvania bar association has on ray or 

could have." (03/11/05).41 

7)	 "jsn't it illegal to falsely portray oneself as a lawyer?" (03/27/05).42 

37 Message In: <ZqUMc.27641$eM2.1960@attbU51> 

38 This is a furtherance ofLTSC's threat to prosecute Plaintiff for merely viewing its website. 

39 Message In: <_4LXc.320029$a24.128714@attbi_s03> 

40 Message In: <TtjXd.45782$r55.7075@attbi_s52>. 

41 Message In: <p9iYd.118012$t13.40457@attbU02>. 

42 Message In: <D%Fle.9292$NW5,4368@attbi_s02>. 

29 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 32 of 53
8) "you need to be put away. a mental institution or jail without the benefits 

ofan internet connection for you, will do just fine." (04/12/05).43 

9) "you are not fit to comment on anyone who is employed because you are 

100% unemployable." (04/18/05).44 

10)	 hey fathead...over here,.dummy. guess what really angers *real* mafia 

types? jerks like you, gl;)mby. you know, tHe kind of schmucks that casually 

throw around terms like "mafia" and "rico" and say that they are going to 

use the heavy hand of government to push people around. you best thank 

your lucky stars that none ofthem read this newsgroup (not yet at least) 

since your home address is on all ofusenet to read; you bent head buffoon. 

(06/13/2005).45 

57. There are many more operatives than those listed. The operatives act as 

"gatekeepers" for ASF, posting actionable messages in response to Plaintiffs postings, defaming 

Plaintiff repeatedly to "newbies" (new readers of ASF who are often ready to purchase, "unclaimed" 

as a referral, and therefore very lucrative), declaring the ASF group to be ruined by Plaintiff, 

creating the very noise they claim has "destroyed" the USENET group. 

Lanham Act/False Designation of Origin 

58.	 While Defendants LTSC/Formhandle were excluding, disparaging, and encouraging 

others to act out against Plaintiff, on their very own website, they saw fit to include, without 

authorization, at http://www.pickupguide.com/layguide/fox.htm). they saw fit to include, a USENET 

posting from Plaintiff on the "returning fox" technique. The relevant text from that page as it existed 

on April 25, 2005 is as follows (emphasis added): 

Update. The Returning Fox theory explained by the originator himself. Ray Parker, 

ASF: "A Returning Fox is one who has shown no previous interest in you or rejected 

you, but who has "returned" and approached you after you have forgotten her. This 

puts you in a temporary position of power. With a Returning Fox, you should ask for 

whatever it is you want from her at the piont of return. If she does not come across, she 

likely never will, and you can send her packing once again, repeating the process as 

many times as you have to each time she returns. For example, if she turned you down 

for a date, you stopped talking to her, and she now contacts you "just to say hi" just ask 

her out on the spot. Optionally, you can add a reference to how puzzled you are she'd 

contact you and how you don't really need to talk. If she doesn't bail out there, just ask 

43 Message ID: <kT06e.8365$Bb3.5498@attbi_s22>. 

44 Message 10: <ehQ8e.26776$xL4.16892@attbi_s72>. 

4S Message 10: <Wyare.54809$nG6.12847@attbU2~>.

30 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 33 of 53
for what you want. An aggressive version of this strategy has the man asking for sex 

or requiring it for her to get back into his life. The theory is she must want something 

out of you to seek you out after rejecting you, and unless she agrees to your terms, she 

can just go packing again. The method works very well in many situations. It also has 

short-term applications for Foxes who ignore you at clubs or parties and then "return" 

later." 

59. Aside from using Plaintiffs writing wjthout authorization, Defendants 

LTSClFormhandle attributed Ray Parker rather than Ray Gordon, in a. manner designed to 

knowingly mislead anyone seeking the source of the infringed material. Plainiiffhad this page 

removed from the LTSC website via a DMCA notice when he learned ofits existence. 

60. In addition to the "returning fox" writing above, Defendant LTSC also misdesignated 

the origin of the tenn "pivot" as it relates to "ASF theory.,,46 Plaintiff coined this term in 1999 to 

describe what has become a very potent seduction weapon for men, so potent that websites now 

offer pivots-for-hire for up to $75.00 an hour. By neglecting this mention, Plaintiff was never given 

proper credit for designing a technique which is more commonly used by even LTSC readers than 

almost any other. 

"The Game" by Neil Strauss 

61. The impact of the conduct alleged in this Complaint has been tremendous, in large 

part due to the "breakthrough" work for the "seduction community," the bestselling book The Game, 

by Neil Strauss. As is often the case with internet websites, publicity in the mainstream media can 

catapult them to fame and wealth, and this is no exception. 

62. Neil Strauss joined the LTSC message boards in 2001 after being "redirected" there 

by the seduction cartel. The Game contains references to USENET and to alt.seduction.fast, and 

many of its readers have found the USENET group 

63. Since its September 2005 release, The Game: Penetrating The Secret Society Of 

Pickup Artists, by Neil Strauss, has resided on many bestseller lists, including #1 on Amazon.com at 

46 A "pivot" is a woman who goes out with a man "as friends" simply to build his reputation, with or without her
 

knowledge that she is doing so.
 

31 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 34 of 53
· .. . : 

l.:..4 

least once, and #9 on the New York Times bestseller list for three consecutive weeks.47 The Game is 

one of those seminal books which becomes fodder for the "water cooler" and which is discussed and 

debated intensely among its audience. It documents and demonstrates just how much money and 

market is at stake here. This is not some minor interriet niche, but a movement begun on the internet 

which has "penetrated" American society on its deepest levels. 

64. In the "Acknowledgements" section of The Game (p. 450), Neil Strauss writes: 

"[t]hanks to Formhandle, who has thanklessly and tirelessly kept this community running. His Fast· 

Seduction website remains the clearinghouse/or all matters pickup-related." (Emphasis Added).48 

65. On page 445 of The Game, Neil Strauss includes in his glossary of pickup terms a 

description of the term pivot, a term coined by Plaintiff in his 1999 book 29 Reasons Not To Be A 

Nice Guy. The term refers to the use, by a male, of an attractive female with whom he goes out with 

platonically, to build his reputation. Despite his having credited the source of other terms in his 

glossary, Mr. Strauss neglected to attribute this term to Plaintiff, following the lead of LTSC and the 

seduction cartel, trading for insider access to the "community" by adhering to the principle of not 

naming Plaintiff, to whom they refer as. 

COUNT I: LANHAM ACT VIOLATIONS AGAINST ALL DEFENDANTS 

66. Plaintiff incorporates and sets forth verbatim by reference, the entire contents of 

paragraphs 1-65. 

67. The "ASF FAQ" and "moderated forum info" postings are published in collusion 

and conspiracy by Defendants Ross and Formhandle, on behalf ofDefendants LTSC and 

Straightforward, and with the knowledge and approval of Defendant TokyoPUA. 

47 As of October 24, 2005, "The Game" was at #24 on Amazon, which reflects sales in the previous 24 hours.
 

48 Concerning the "thankless" part, Plaintiff avers that the substantial revenue generated by advertising and affiliate
 

sponsorship (including the outfit with which Mr. Strauss worked), is considered to be "thanks" by most individuals.
 

32 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 35 of 53
. '. '.' : , " '., 

68. The statement in the "moderated forum info" posting that liSts the LTSC message 

board alt.seduction.fast.general as a "replacement for ASF" (see paragraph 34) is false and 

misleading in that it implies that a commercial website's message board has supplanted the USENET 

group. It is also false and misleading to claim that this is a legitimate purpose for posting a "FAQ" 

to a USENET group. 

69. The joint statement published by Defendant Formhandle, for all defendants, in the 

ASF FAQ, that only LTSC's and Straightforward's websites (FastSeduction and Speed Seduction) 

were "main, group-related sites" (see paragraph 40) is, false and misleading. USENET is a 

decentralized message board system with no owner. Its policies are generally anti-commercial, and 

most advertising is considered SPAM. Further, no one commercial website enjoys any special 

privileges in any USENET group. To the extent advertising is allowed, that it is determined by ISP 

policy, although group FAQs are often relied upon to set that policy. 

70. The use ofthe term "moderated ASF' to describe the LTSC message board (see 

paragraph 32) is false and ~sleading because it gives the impression that "mASF' is amoderated 

USENET group rather than· a moderated newsgroup that exists outside ofUSENET and on a private, 

commercial web server. In~eed, USENET has moderated groups with descriptive titles. Ifthere 

were a "moderated ASF' on USENET, it would be called alLseducnon.jasLmode,ated, and would 

be available on USENET through regular ISPs rather than a single, commercial website which 

requires registration. 

71. As a direct and proxin;tate result ofthe false and intentionally misleading descriptive 

statements above, which were made in the furtherance ofDefendants' commercial interests, Plaintiff 

has suffered and, unless enjoined by this court, he will continue to suffer permanent and irreparable 

competitive harm, in an amount to be proven at trial, to his seduction-information business. 

Specifically, the harm inflicted is that of "ready to buy" consumers in all parties' target audience are 

33
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 36 of 53
being misled into migrating from USENET to the LTSC website, where LTSC then cashes in on any 

referrals it generates, as well as to Defendants Ross/Straightforward's website, listed as a "main, 

group related site" and appearing to be formally endorsed by "ASF." This costs Plaintiff sales, 

advertising revenue, goodwill, audience, media exposure, and investment potential. 

72. Pecuniary harm to Plaintiff as a direct result of Defendants' intentional, wanton and 

willful conduct as set forth in this count includes lost audience, lost affiliate commissions, lost value 

to investors, loss of past, present, and future sales, and loss of business and personal reputation, in an' 

amount to be specified at trial. 

73. For the conduct set forth in this count, Plaintiff is entitled to relief under the Lanham 

Act, 15 USC §1125 et seq., from all Defendants. This relief includes a) compensatory damages; b) 

due to the wanton and willful nature of the conduct, punitive damages; c) injunctive relief sufficient 

to terminate the enterprise; d) costs ofsuit, including any reasonable attorney fees should Plaintiff 

secure counsel; and e) such other relief as this Court deems just and proper. 

COUNT II: LANHAM ACT VIOLATIONS
 

AGAINST DEFENDANTS LTSCIFORMHANDLErrOKYOPUA
 

74. Plaintiff incorporates and sets forth verbatim by reference, the entire contents of 

paragraphs 1-73. 

75. Defendant Formhandle, acting on behalf ofDefendants LTSC and TokyoPUA, made 

false and misleading descriptive statements and engaged in a false designation of origin concerning 

Plaintiffs "returning fox" article when they reposted it on the LTSC website, as set forth in 

paragraph 58, including but not limited to their failure to attribute the article to Plaintiff, instead 

attributing it to "Ray Parker" and not providing a link to Plaintiffs website or otherwise properly 

identifying Plaintiff. 

76. Defendant Formbandle, acting on behalf of Defendants LTSC and TokyoPUA, made 

false and misleading descriptive statements and engaged in a false qesignation of origin concerning 

34
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 37 of 53
Plaintiff's ''pivot'' technique as set forth in paragraph 60, by deliberately omitting all references to 

Plaintiffas the creator ofthis technique, instead attributing it to a false and improper source. 

77. Other false and misleading statements concerning Plaintiffby Defendant 

Fonnbandle, for Defendants LTSClfokyoPUA, inclWie: 

a. The statement that "Ross' products rival [Plainti.t'rs] the way chocolate mousse 

in a crystal serving bowl rivals a shit stain on the heel ofa shoe!' (paragraph 55(e). 

b. The statement that Plaintiff"is not a business competitor.," (paragraph SSG». 

78. As a direct and proximate result ofth~ false and misleading descriptive statementS 

above, which were made in the furtherance ofDefendants' commercial interests, Plaintiffhas, 

sUffered and, unless enjoined by this court, he will continue to suffer permanent and irreparable 

competitive harm to his seduction-information busineSs, including but not limited to lost sales, lost 

advertising revenue, lost audience, and lost investment value, in an amount to be proven at trial. 

79. Pecuniary harm to Plaintiffas a direct result ofDefendants' intentional, wanton and 

willful conduct as set forth in this count includes lost audience, lost affiliate commissions, lost value 

to investors, loss ofpast, present, and future sales, and loss ofbusiness and personal reputation, in an 

amount to be specified at trial. 

80. For the conduCt set forth in this count, Plaintiffis entitled to reliefunder the Lanham 

Act, 15 USC §1125 elseq., from all Defendants. This relief includes a) compensatory damages; b) 

due to the wanton and willful nature ofthe conduct, punitive damages; c) injunctive relief sufficient 

to terminate the enterprise; d) costs of.suit, including any reasonable attorney fees should Plaintiff 

secure counsel; and e) such other relief as this Court deemsjust and proper. 

COUNTS ill-IV: DEFAMATION AND LANHAM ACT VIOLATIONS
 

AGAINST DEFENDANTS ROSSISTRAIGHTFORWARD
 

81. Plaintiffincorporates and sets forth verbatim by reference, the entire contents of
 

paragraphs 1-80.
 

35
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 38 of 53
82. The statement (see paragraph 54(d) and Exhibit A) that Plaintiff had sent "that 

hateful e-mail" (which was also threatening) to the nonexistent "Jeri Ryan" is wholly false. 

83. At the time of publication, Defendant Ross could not possibly have verified the truth 

of the anonymous poster who made the claim which lie repeated, and therefore either knew or should 

have known that it was false, while displaying reckless disregard for the truth. 

84. Defendant Ross's statements were a) not privileged; b) concerning Plaintiff; c) in a 

manner that was very clear to third parties (Plaintiffs birth name was used in the post); and d) third 

parties saw the posting and related it to Plaintiff. 

85. The full extent of Defendant Ross's actionable statements concerning Plaintiff is not 

known at this time, as Plaintiff avers, based on information and belief (including third-party 

statements) that Defendant Ross makes similarly untrue statements concerning Plaintiff in private 

internet communications. All statements, including those set forth herein, constitute a separate 

injurious falsehood. 

86. Defendant Ross's statements were taken in the furtherance of his business interest in 

selling "Speed Seduction" products, which compete in the same market as Plaintiffs, and caused 

Plaintiff a competitive business harm through lost sales, potential sales, investment potential, and 

goodwill. 

87. As a direct and proximate result of Defendant Ross's conduct as set forth in this 

count, Plaintiff has suffered irreparable and ongoing injury, in an amount to be proven at trial, both 

with his target business audience, and with anyone who might "Google" Plaintiff by typing his name 

into that search engine, includin~ potential employers or lovers. He has lost sales and advertising 

revenue, and Defendant Ross has enriched himself unjustly at Plaintiff s expense. 

88. For Defendant Ross's willful, malicious, and intentional conduct as set forth in this 

count, Plaintiff is entitled to relief under the Lanham Act, 15 USC §1125 et seq. 

36
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 39 of 53
89. For any acts in this count, or any relief sought that is not covered by the Lanham Act, 

Plaintiff is also entitled to relief under the Delaware common law tort of defamation. 

90. Plaintiff is entitle to compensatory damages (trebled if under the Lanham Act), and 

punitive damages, costs of suit (including reasonable "attorney fees if under the Lanham Act), 

injunctive relief barring any future defamation of Plaintiffby Defendant Ross, and such other relief 

as this Court may deem just and proper. 

COUNT IV: TORTIOUS INTERFERENCE AGAINST ALL DEFENDANTS 

91. Plaintiff incorporates and sets forth verbatim by reference, the entire contents of 

paragraphs 1-90. 

92. The "ASF FAQ" document set forth in paragraph 32 is "co-published" by 

Defendants Ross and Formhandle, on behalf oftheir corporate interests and that of their partners 

(i.e., Straightforward, LTSC and TokyoPUA). 

93. The "ASF FAQ" self-asserts "FAQ authority" over a public USENET group, and 

abuses that "authority" by corrupting the FAQ and making its purpose instead to direct "newbies" to 

the LTSC and Speed Seduction websites and message boards, as well as to an "ASF Killfilter List" 

on the LTSC website. 

94. The "ASF Killfilter List" urges consumers to "killfile" Plaintiffs postings while 

providing explicit instructions on how to get their newsreaders to do this. The "FAQ" which links to 

this list refers to Plaintiff as a "newsloon" who is responsible for "disrupting ASF" and making 

LTSC's message board somehow "necessary." 

95. In addition to the killfilter list, LTSC openly states as its policy that Plaintiff is not 

allowed to post on its site, nor is anyone on the LTSC message boards allowed to mention Plaintiff 

or his products. Those few who have inadvertently done so have been quickly reprimanded and 

warned not to do so again. 

37 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 40 of 53
96. In paragraph 59(h), Plaintiff set forth statements by Defendant Formhandle whereby 

he encouraged his audience to "complain" to Plaintiffs affiliate sponsors and urge them 110t to do 

business with Plaintiff. 

97. Defendant Formhandle's actions as set forth in this count have been taken in 

agreement, collusion and conspiracy with all other Defendants. 

98. The purpose ofthe conduct set forth in this count was to intentionally interfere with 

Plaintiffs customer base, specifically his readership, for which Defendants compete for the attention· 

of. Defendants were well aware ofthis expected customer base, as it forms the basis for Defendants' 

marketing to the ASF audience, from which it literally built its business "from scratch." 

99. As a direct and proximate result of this intentional interference, Plaintiff has suffered 

and will continue to suffer damages which include, but are not limited to, lost sales and advertising 

revenue, lost goodwill, audience size, lost media coverage, and lost investment value. 

100. For the conduct set forth in this count, Plaintiff is entitled to relief under Delaware 

law for tortuous interference with an advantageous business relationship. 

101. Plaintiff is entitled to compensatory and punitive damages, costs of suit, injunctive 

relief sufficient to terminate the actionable conduct, and such other and further relief as this Court 

may deem just and proper. 

COUNT V: ANTITRUST VIOLATIONS AGAINST ALL DEFENDANTS 

102. Plaintiff incorporates and sets forth verbatim by reference, the entire contents of 

paragraphs 1-101. 

103. The name says it all: seduction community. When a "community" involves several 

leading players in an industry, the law has another term for it: cartel. 

38
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 41 of 53
' .. ' .. 

104. The seduction cartel was fonned at a time when the internet seduction industry was 

taking shape, a time when fair competition was essential to ensure that any growth experienced by 

any "seduction guru" in his business would be earned by merit rather than collusion and conspiracy. 

105. Defendants have not only not denied, but have publicly, embraced the exclusion of 

Plaintiff from their "group." Plaintiff is also not the only "seduction guru" who has been excluded 

by this cartel. Indeed, just recently, the "community" built itself a page on Wikipedia (created 

February 28,2006), in which it made the following statements relevant to this count, including a 

false claim that ASF (which also has its own page) had been "overrun by SPAM" (LTSC and 

Defendant Ross are its main spammers), and further confinnation ofthe cartel's exclusive behavior: 

a.	 "When alt.seduction.fast became overwhelmed with internet spam, a moderated 

commercial alternative called Fast Seduction was created, which is now one of the 

biggest commercial enterprises in the scene. The seduction community has historically 

been a combination of commercial organizations and the more underground, 

independent, and often free, information sources." 49 

b.	 "How do we decide notable vs. non-notable here? We don't particularly want Ray 

Gordon adding himself a page.,,50 

c.	 "'alt.seduction.fast"', known in the Seduction Community as 'ASF', is a newsgroup that 

was started by Ross Jeffries in the 1980s to discuss his 'Speed Seduction' series of 

products. As the community grew, so too did the traffic to the newsgroup, and the level 

of spam and trolling. A new, moderated discussion forum was created, referred to as 

'mAS!" (moderated ASF), and is currently frequented and posted on by all 'big names' 

in the community, including Jefferies himself. 51 

106. The "discussions" which take place on the LTSC public message board tend to 

revolve solely around LTSC's sponsors and affiliated products, while on the private LTSC board, the 

seduction cartel members commiserate and conspire among themselves, out of the view ofthe 

general public at large, who has not even been made aware previously ofthis group's existence. 

107. During the relevant times in this action, Defendant LTSC maintained a policy of 

allowing its sponsors and affiliates to promote their websites in their "signature" to their message 

49 Source: http://en.wikipedia.orglwikiiSeduction Community
 

so Source: http://en.wikipedia.orglwikiffalk:Seduction Community#Long lists of gurus
 

SI Source: http://en.wikipedia.orglwiki/Alt.seduction.fast
 

39 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 42 of 53
· '. 

postings, while not allowing the same privilege to nonsponsors. This was done for a very explicit, 

anticompetitive purpose, namely to keep the message boards focused on topics more likely to lead to 

the purchase of LTSC-endorsed products. 

108. LTSC selects its sponsors based solely on its desire to include them in the seduction 

cartel, and on the sponsor's compliance with the cartel's rules and policies, including the exclusion 

of Plaintiff and his business. 

109. As set forth in paragraph 59(f), LTSC has gone as far as to solicit feedback upon 

which it intended to construct a "common pricing" model for workshops and other seduction 

information products. 

110. LTSC selects its advertisers for the purpose of maximizing revenue for those 

advertisers by restricting the number of competing products which can advertise on the site. This is 

done in order to keep prices artificially high, competition artificially low, and to specifically exclude 

Plaintiff by restraining him in his trade. 

Ill. The "ASF FAQ" is published in part to compensate Defendants 

Ross/Straightforward for their "permission" to market through the FAQ on ASF. This "permission" 

allowed LTSC to build its audience, as Defendant Ross and his followers were largely responsible 

for the "noise" on ASF that LTSC was then offered as a solution to. Defendant Ross is also given 

permission to include a link to his website in all of his messages posted to the LTSC message board, 

and links to his website are tracked by an affiliate link. 

112. In paragraph 59(h), Plaintiff set forth statements by Defendant Formhandle whereby 

he encouraged his audience to "c,omplain" to Plaintiff's affiliate sponsors and urge them not to do 

business with Plaintiff, with the intent of harming Plaintiff's ability to compete and dilute the value 

of LTSC' s own partnership with these same affiliates. 

40 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 43 of 53
113. Plaintiff has suffered massive, permanent and ongoing injury to his business which is 

directly attributable to the anticompetitive conduct set forth in this count. Were he able to advertise 

on LTSC and be free of the anticompetitive behavior (which includes defamation designed to reduce 

his market share), Plaintiff would realize approximately the same revenue as LTSC sponsors and 

affiliates with similar products. 

114. As a direct and proximate result of Defendants' anticompetitive conduct as set forth 

in this count, Plaintiff has suffered damages, in an amount to be proven at trial, including lost sales, 

lost potential sales, lost audience, lost media coverage (including but not limited to The Game, 

which included Plaintiffs "pivot" concept in its glossary without attribution, while attributing any 

terms attributable to LTSC users), lost investment value, and lost goodwill. 

115. The conduct set forth in this count affects interstate commerce negatively because it 

is designed to manipulate a market of sexually frustrated men who are highly vulnerable to social 

pressure, especially when applied by a group such as the seduction cartel. Word-of-mouth is often 

their initial referral source, and the seduction cartel has worked, through ASF and then the LTSC 

message boards, to present the cartel as the ideal source for free seduction information and products, 

while simultaneously denying access to that source and collectively badmouthing those who are not 

cartel members. Consequently, many of these sexually frustrated men wind up spending more 

money than they should on a product or service selected from a highly restricted menu, with a 

stifling impact on competition. 

116. Plaintiff avers that the conduct set forth in this count, for each act, constitutes a 

separate violation of the Sherman Antitrust Act, 15 USC §1, for a conspiracy among business 

competitors listed as Defendants to induce the restraint ofPlaintiffs trade, restraint of competition 

through leveraging LTSC' s audience to fix prices and restrict competition among LTSC' s sponsors 

41
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 44 of 53
through a group boycott (exclusion) and a vertical restraint on trade (banning as an advertiser in 

order to fix prices higher in the market and reduce competition with other sponsors). 

117. Plaintiff avers several violations ofthe Clayton Act, including 

a. Price-fixing and price-discrimination under 15 USC §13 (for a selective 

advertiser acceptance policy whose purpose is to reduce competition); and 

b. Sale or use contingent on nonuse of competitor's goods, by virtue of LTSC 

denying access to its site to anyone who mentions Plaintiff or his work, even in reviewing or 

comparing them, for a clearly anticompetitive purpose, in violation of 15 USC §14. 

118. For the antitrust violations set forth in this Count, Plaintiff is entitled to relief under 

15 USC §15 et seq. (the Clayton Act, for violations ofthe Sherman Antitrust Act and other acts).. 

119. Plaintiff is entitled to compensatory damages for all injuries to his business, trebled, 

including (but not limited to) lost sales revenue, lost advertising revenue, lost investment value and 

goodwill, and loss of audience, in an amount to be proven at trial. He is further entitled to punitive 

damages, costs of suit (including attorney fees if he retains counsel), injunctive relief sufficient to 

terminate the actionable conduct, and such other and further relief as this Court may deem proper. 

COUNT VI: RACKETEERING (RICO) AGAINST ALL DEFENDANTS 

120. Plaintiff incorporates and sets forth verbatim by reference, the entire contents of 

paragraphs 1-119. 

121. Plaintiff alleges, for this count, an association-in-fact RICO enterprise called the 

"Seduction Mafia." 

122. The RICO enterprise includes, but is in no way limited to, of all five defendants and 

each of the nine unnamed co-conspirators/operatives listed in paragraph 60. 

42
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 45 of 53
ir .. 

123. Defendants Ross and Formhandle constructed the Seduction Mafia and have 

mutually directed its affairs since its inception, while acting as agents for Defendants LTSC and 

Defendant Straightforward, with the full knowledge and approval of Defendant TokyoPUA. 

124. In addition to their own predicate acts listed in the next/paragraph, Defendants Ross 

and Formhandle aided and abetted the predicate acts by other operatives listed below by specifically 

requesting, encouraging, or directly conspiring with these individuals to commit the predicate acts. 

125. The Seduction Mafia began its current pattern of racketeering activity when the 

LTSC message boards began being marketed to ASF on or around October 28, 2001.52 

126. The predicate acts in furtherance of the RICO enterprise include, but are not limited 

to, the following: 

a. Defendant Formhandle's statements 1) in paragraph 59(g) threatening 

Plaintiff with criminal prosecution for electronic trespass for merely viewing his website; 2) in 59(h) 

threatening Plaintiff with the fear of losing his affiliate partnerships to an organized campaign 

directed by Forrnhandle to encourage third parties to induce severance of Plaintiffs sponsorship 

revenue; and 3) threatening to "notify the IRS" of Plaintiffs newsgroup postings in response to his 

filing suit. Plaintiff avers that these constitute separate violations ofthe Hobbs Act, for the use of 

fear and coercion (both of which were felt by Plaintiff) in an attempt to get Plaintiff to stop 

publishing to ASF, so that the Seduction Mafia could increase its revenue at Plaintiffs expense.. 

b. Defendant Ross's statements 1) in paragraph 58(a) where he threatens to "take 

[Plaintiffs] computer equipment" and other resources ifPlaintiff Serves him with a lawsuit; 2) in 

paragraph 58(b), where he advis~s anyone Plaintiff sues to move the court for a psychiatric 

evaluation, and paragraph 58(c), where he urges others to "sue ray now"; 3) in paragraph 58(d), 

52 Suit over this conduct was brought in the Eastern District ofPennsylvania in Parker v. LTSC em, E.D.Pa. #04-cv2752, and was dismissed for lack ofjurisdiction on March 23, 2006. Any statute of limitations is therefore tolled, as the 

action was brought in the wrong forum. 

43 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 46 of 53
where he attempted to incite violence against Plaintiff by falsely accusing him ofthreatening the 

nonexistent "Jeri Ryan" bye-mail; and 4) in paragraph 58(f) where he attempts to strike the fear of 

filing this lawsuit into Plaintiffby "threatening" criminal sanctions ifhe files. Plaintiff avers 

separate violations of the Hobbs Act, for Defendant Ross was using fear and coercion (both of which 

were felt by Plaintiff), 

c. Defendant LTSC and Straightfonvard's participation in the Seduction Mafia 

was carried out by Defendants Ross and Formhandle, who were acting as their agents. 

d. Defendant TokyoPUA aided and abetted the Seduction Mafia by giving his 

approval for the predicate acts set forth herein, and conspiring with the other defendants to commit 

the predicate acts. 

e. Predicate acts by unnamed co-conspirators include: 

1. The publication ofthe RayFAQ on the ray-gordon. com domain, which 

was owned by Thorn E. Geiger, who has never named any other individual as author or publisher of 

the site. Plaintiff avers that the contents of the RayFAQ are designed to interfere with his 

employment in retaliation for Plaintiff having reported previous threats against his life made by Mr. 

Geiger to law enforcement, in violation ofthe Sarbanes-Oxley Act, 18 USC §1513.53 

2. The threats by "Player88" were made at the specific direction of 

Defendant Ross, as Mr. King is a long-time member ofthe "SS list." Plaintiff alleges separate 

violations ofthe Hobbs Act for each act set forth in that paragraph. 

3. The threats by "Editorial Staff' (or Geiger, if that is him) set forth in 

paragraph 60(c), were made in violation ofthe Hobbs Act, to further the Seduction Mafia through 

extortion, and the Sarbanes-Oxley Act, as the purpose was to retaliate against Plaintiff in his 

livelihood in retaliation for his having reported federal crimes to law enforcement (the threats by 

53 18 USC §1513, the provision against employment retaliation in response to reporting "any" federal crime, is a
 

predicate RICO act, even if the Sarbanes-Oxley Act as a whole is not.
 

44 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 47 of 53
5. The threats by "Vijay" and "Osgaldor Stonn" (paragraphs 60(e-f) were 

made in furtherance ofDefendant Ross's directive to his NLP/SS followers to harass Plaintiff, for 

the purpose ofobtaining property in the fonn of audience share by the use offear and coercion (both 

of which were felt by Plaintiff) to get him stop writing to ASF. 

6. ~e conduct of "Odious" and "Alex Kaufmann" repeatedly disparaging 

Plaintiff, linking to the RayFAQ (as Kaufmann did twice in 2002), and using their harassment of 

Plaintiffto direct traffic to ~e LTSC website, as set forth in paragraphs 60(g-h), constitute separate 

violations ofthe Hobbs Act for each posting, through the use offear and coercion (both of which 

were felt by Plaintiff) to get him to stop writing to ASF and to secure market share for LTSC. 

7. The harassment and threats by Vincent Runza, Jr. (see paragraph 60(h)) 

were made at the direction and for the, benefit ofDefendant LTSC 'and Mr. Runza (who has been 

contemplating his own e-book ~d building his own audience inthe chatroom), constitute separate 

violations ofthe Hobbs Act for each posting, through the use offear and coercion (both ofwhich 

were felt by Plaintiff) to get him to stop writing to ASF and to secure market share for LTSC, at the 

direction ofDefendants Formhandle and TokyoPUA, acting as agents for Defendant LTSC. 

45
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 48 of 53
c.",:.~ ',~~

8. The threats by "Aardvark" via his letter to courts~ employers, and law 

enforCement in Philadelphia urging that Plaintiffbe "involuntarily committed," and his repeated 

threats to Plaintiffrelating to bogus claims ofelectronic trespass (see paragraph 60(i». Plaintiff 

alleges separate violations ofthe Hobbs Act for each Bet set forth in that paragraph, taken at the . direction of Defendant Ross. 

127. For ~vesting the racketeering proceeds from the Seduction Mafia into commerce 

and further racketeering activity, all defendants have violated 18 USC §1962(a). 

128. For directing the affairs ofthe Seducti~n Mafia and assuming control ove~ the 

enterprise's activities, all defendants have violated 18 USC §1962(b). 

129. For committing or causing the commission oftwo predicate acts, and engaging in a 

pattern ofracketeering activity for the Seduction Mafi~ for the benefit ofthe seduction cartel, all 

defendants have violated 18'USC §1962(c), with each predicate act constituting a separate violation. 

130. For aiding and abetting the predicate acts comMitted by others,' and for the violations 

of 18 USC §1962(a.c) abov~, all defendants have violated 18 USC §1962(d). 

131. For each violation'of 18 USC §1962(d), Plaintiffis entitled to reliefwtder 18 USC 

§1964(c), or "Civil RICO.'~

132. As a direct and proximate result ofthe racketeering conduct set forth in this COlUlt, 

Plaintiff has suffered permanent and irreparable injuries to his business and property, including lost 

sales, lost advertising revenue, lost investment value, lost audience, and lost goodwill. 

133. The conduct ofthe Se~uction Mafia has been continuing for a period oflonger than 

twelve months, and will contin~ indefinitely into the future ifnot enjoined by this Court. 

134. Plaintiffis entitled for compensatory damages, trebled, for all injuries to his business 

and property, including but not limited to lost sales, lost audience, lost investment value, and lost 

goodwill, in an amount to be proven at trial. 

46
 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 49 of 53
, r 

135. Plaintiff is further entitled to punitive damages, costs of suit (including attorney fees 

if he retains counsel), injunctive relief sufficient to terminate the actionable conduct, and such other 

and further relief as this Court deems just and proper. 

COUNT VII: CIVIL CONSPIRACY AGAINST ALL DEFENDANTS 

136. Plaintiff incorporates and sets forth verbatim by reference, the entire contents of 

paragraphs 1-135. 

137. For each count in this complaint against more than one Defendant, two or more 

Defendants conspired to violate Delaware law against Plaintiff, including the counts for defamation, 

tortuous interference, the Lanham Act violations (or unfair competition and Defamation, if the 

Lanham Act is not predicate), the antitrust laws (state law antitrust violations if the federal law is not 

applicable to this count), and the racketeering violations. 

138. For each separate act taken in conspiracy set forth in this Complaint and actionable 

under Delaware (or federal) law, Plaintiff is entitled to relief under the Delaware tort of civil 

conspIracy. 

139. As a direct and proximate result of Defendant's willful and intentional conduct 

(designed to injure Plaintiff), Plaintiff has suffered, and will continue to suffer unless enjoined by 

this court, damages to his business and person including lost sales, lost advertising revenue, lost 

investment value and goodwill, lost employment, loss of reputation, pain and suffering, to an extent 

which will not be fully understood until well into the future, but which is already substantial, 

persistent, ongoing, and accruing literally every day. 

140. Plaintiff is entitl~d to compensatory damages for the injuries set forth above, punitive 

damages, costs of suit, injunctive relief sufficient to terminate the actionable conduct, and such other 

and further relief as this court deems just and proper. 

47 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 50 of 53
I.;..;. '."" 

PRAYER FOR RELIEF 

WHEREAS, for the claims set forth herein, Plaintiff seeks the following relief: 

1. Unspecified compensatory damages in an amount to be proven at trial, but 

which is not less than FIFTY MILLION DOLLARS ($50 million), trebled for the violations of the 

Lanham Act, RICO, and antitrust laws. 

;. 

2. The maximum punitive damages allowed by law, where applicable. 

3. An accounting of all profits realized from Defendants' sale, publication, and 

marketing ofseduction-related materials. 

4. Costs of suit, including reasonable attorney fees (in the event Plaintiff retains 

counsel), where applicable. 

5. Injunctive relief sufficient to terIilinate all actionable conduct. 

6. Such other and further relief as this Court deems just and proper. 

DEMAND FOR JURY TRIAL 

Plaintiff demands the right to a trial by jury in this case.
 

This the 7th day of April, 2006.
 

Gordon 

~~~ Roy Parker 

Plaintiff, Pro Se 

4247 Locust Street, #806 

Philadelphia, PA 19104 

(215) 386-7366 

GordonRoyParker@aol.com 

48 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 51 of 53
I swear to Jeri; if Mr. Parker DOES sue me, he will be reading this piece of 

sick, twisted, hateful email that he sent, into the record when I take his 

deposition. 

Ray, you are sick, twisted, evil bastard and I am going to clean your clock 

in court. 

RJ 

> Gordon Roy Parker wrote: 

» 

» He was just a convenient diversion created by someone 

» who didn't want to take credits for the threats that 

» were made under that name. 

> 

> We received an interesting email a few days ago, from someone 

> who was connected to Dr. Ryan, and with that person's permission, 

> we post it here, so that everyone will know just what Mr. Parker 

> is attempting to do here. . 

> 

.~ -.._----_......---...-------------------_... ------_...-----.._----------------_..­

> X-Apparently-To: jerisnow@··".com 

> X-Date: Tue, 21 June 2005 01 :32:39 -0500 

> X-Originating-IP: [24.193.236.213] 

> Return-Path: <ray@cybersheet.com> 

> Authentication-Results: mta221.mail.dcn••••.com 

> from=twister.nyc.rr.com 111934828224.193.236.213 

> (Tue, 21 J\ln 2005 06:04:42 EDT) 

> Received: from 24.193.236.213 by mta221.mail.dcn......com with 

> SMTP; Tue, 26 Jul2005 18:32:39 -0700 

> Received: from ([24.193.236.213]) by 

> omta03sl.mx.bigpond.com with SMTP id 

> <20050727013237.WFYU21373.omta03sl.mx.bigpond.com@workshop>; 

> Wed, 27 Ju12005 01:32:37 +0000 

> To: jerisnow@.....com . 

> From: "Ray Gordon" <ray@cybersheet.com> 

> Date: 21 Jun 200501:33:10 -0000 

> Message-ID: <DG0J7MAE38560.3980324074@twister.nyc.rr.com> 

> Subject: You had better watch out BITCH..... 

> -­

> 

> I'm tired of all the men who are attacking me in your name 

> and with your approval, and I am going to fix your CUNT ass soon. 

> You had better watch out, because I am going to come and find you, 

> and show you what I think of you and your dead husband. 

> 

> Georgia is only a plane ride away....... 

> 

> You think you can get away with harassing me, threatening me and 

> hiding behind that dead asshole husband of yours, but you 

> can't. Your husband was a rapist, and you are nothing but a SLUT for 

> having married a player like him. Your actions show your poor 

> judgment picking men, and they reveal you to be a PATHETIC little 

> SLUT the world would definitely be better off without. 

> 

> If I ever hear another word about "Jack Ryan" ever again, I am 

2 

Case 2:05-cv-02752-HB Document 47 Filed 04/10/06 Page 52 of 53
> going to shut up that mouth ofyours, and the pussy mouth of everyone 

> who you have gotten to attack me. He's DEAD, rotting in a grave, 

> and the worms are eating up all you love. That make you feel good 

> CUNT? I hope so. 

> 

> Women like you NEVER find good men. All SLUTS like you can get are 

> players and rapists. There's a reason for that. 

> 

> I am hereby officially warning you that any more attacks pn me will 

> cause great harm to come down on you. You have been warned. Cease and 

> Desist IMMEDIATELy.... # 

> 

> Ray Gordon 

> 

> ----------------•.•.••.••••.••....••.••.._--.....••__._.._.__....-..• 

> 

> We wonder what could be done about this? We do know that an attorney 

> representing the person in question has contacted law enforcement in 

> Philadelphia, in an attempt to forestaUthis kind ofbehavior in the 

> future. We wonder if it won't take more than that. Perhaps someone· 

> actually paying a visit to Philadelphia to explain the consequences 

> for actions like this, in person...
 

>
 

> We are watching this situation, very carefully.
 

>
 

> -­

> The Editorial Staff
 

> ----­

> A quote from Gordon Roy Parker, AKA "Ray Gordon":
 

> "(For a dissenting opinion on my character, please visit
 

> the following website: http://members.tripod.coml-rayfaq.htmJ)*
 

> This site contains many lies about me, but as a defender of
 

> free speech I fully support its right to exist."
 

> -Message-ID: <6ertau$76b$1@nnrp1.dejanews.com>
 

> . 

> *The original RayFAQ was removed from the internet as a 

> result of dozens of complaints from Gordon Roy Parker. 

> 

> Freedom of Speech is WORTHLESS without Social Responsibility. 

> 

> 

> 

3
 

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