(3( 

IN THE UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA 

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

Snodgrass Publishing Group, 

4247 Locust Street, #806 

Philadelphia, PA 19104 

Plaintiff, 

v. 

Learn The Skills Corp., et al. 

Defendants. 

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CASE NO.: 05-cv-2752 

Hon. Harvey Bartle, III 

ORDER 

AND NOW, this _ day of :, 2006, in consideration ofDefendant 

Learn The Skills Corp.'s Second Motion To Dismiss, and all responses thereto, the motion is 

denied. A memorandum opinion is attached. 

SO ORDERED. 

1. 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 1 of 21
IN THE UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA F I LED 

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

Snodgrass Publishing Group, 

4247 Locust Street, #806 

Philadelphia, PA 19104 

Plaintiff, 

v. 

Learn The Skills Corp., et al. 

Defendants. 

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DEC 052005 

M'CHAEDi' KUNZ, Clerk _ , 

f1 < Pep. Clerk

CASE NO.: 05-cv-2752 

Hon. Harvey Bartle, III 

PLAINTIFF'S BRIEF IN OPPOSITION TO 

DEFENDANT LTSC'S SECOND MOTION TO DISMISS 

Plaintiff Gordon Roy Parker, in the above-styled action, submits this Brief In 

Opposition to Defendant LTSC's Second Motion To Dismiss and Memorandum in support 

thereto. Since the Motion sets forth no facts, the Memorandum in support will be addressed here, 

along with the relevant parts ofthe motion. 

I. INTRODUCTIONIPROCEDURAL HISTORY 

Defendant LTSC, through its counsel and co-defendant Wolf, summarize the procedural 

history ofthis lawsuit and its previous incarnation, Parker v. LTSC I, I and requests that the Court 

focus first on the question ofjurisdiction. Plaintiff has filed a motion for jurisdictional discovery 

so that he may be afforded due process in securing evidence to refute any claims of a lack of 

jurisdiction by Defendants LTSC, Geiger, and Ross. 

Defendant LTSC does not address the antitrust claims, the state-law claims, or the 

Lanham Act claims beyond its jurisdictional objection. Instead, it makes broad, sweeping attacks 

against the overall viability and composition ofthe Amended Complaint, going so far as to call it 

frivolous and vexatious, yet at the same time providing no arguments which would support 

1 E.D.Pa .#03-cv-6936. 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 2 of 21
dismissal of the Lanham Act claims relating to deceptive advertising (something that does not 

even involve Plaintiff's conduct in any way), or anticompetitive conspiracy with Defendant Ross 

as it relates to the "ASF FAQ" and its exclusionary nature. Plaintiff therefore has nothing to argue 

against, and those claims should therefore survive the instant motion. 

To the extent this Court finds a lack ofjurisdiction, dismissal should be without 

prejudice, so that Plaintiff may refile against Defendant LTSC in Massachusetts, where it conducts 

business, or Delaware, where its corporation is registered and where its agent is located. Despite 

the benign nature of a denial ofjurisdiction (which by definition is not an adjudication on the 

merits), Defendant LTSC includes in its arguments claims that such a dismissal should be with 

prejudice and perhaps even the grounds for sanctions, when all it would do at most is move this 

lawsuit "next door" to Delaware, or a few hundred miles north, to Massachusetts. 

II. FACTSILEGAL STANDARD 

Defendant more or less summarizes the nature of this action. Plaintiff notes the 

reference to "an e-mail address" as one ofthe Defendants/ yet that address 

(Formhandle@fastseduction.com) refers to the individual commonly known as "Formhandle," 

who owns and runs LTSC, and who uses that name throughout what is commonly known as "the 

seduction community." Service ofthe Complaint and summons was effected on Defendant 

Formhandle through his usual place of business, LTSC, by certified mail, as provided for by the 

Pennsylvania rules, which the federal rules allow for service under in cases in federal courts in 

Pennsylvania. 

The legal standard for a motion to dismiss is well-established: all facts pled must be 

accepted as true construed in the light most favorable to the Plaintiff; motions to dismiss are 

generally disfavored unless compelling, even irrefutable, arguments are made that no relief is 

2 Defendant's Memorandum, 'il II, p. 4. 

2
 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 3 of 21
possible under any set of facts. Defects which can be cured by Amendment should allow for leave 

to cure them. Finally, a pro se pleading is entitled to an even more liberal construction than would 

normally be afforded Plaintiffs under the already-liberal "notice pleading" standard. (multiple 

generic citations omitted). 

III. ARGUMENT 

A. PERSONAL JURISDICTION. 

Defendant LTSC argues that this Court lacks personal jurisdiction over this case, 

despite the fact that LTSC, through its website,3 actively solicits contributions from internet users 

all over the world, including Pennsylvania. Additionally, Defendant LTSC sells and promotes 

seduction products from vendors who do business with Pennsylvania residents, as an "affiliate" 

who receives a percentage commission on each sale. 

Defendant LTSC, whose counsel is also a defendant in this case, once again relies 

on "debate tactics" more commonly associated with internet "flame wars" than with litigation. To 

wit: 

Defendant LTSC respectfully pleads with the Court to make a ruling on whether this 

Court has jurisdiction over LTSC so that once and for all the Plaintiff will not be 

able to endlessly torture LTSC and drag it into Court in this forum. The Plaintiff s 

repeated frivolous lawsuits are vexatious and an abusive nuisance. A ruling 

regarding jurisdiction would preserve the judiciary's resources by preventing the 

Plaintiff from further lawsuits unless he will willingly subject himself to Rule 11 

sanctions (a course of action the Plaintiffintends to pursue at the favorable 

conclusion ofthis lawsuit).4 (Emphasis Added). 

Defendant's posturing appears to be spawned from a belief that the best defense is 

a good offense. Rather than acknowledge the vicious conduct which has been targeted at Plaintiff, 

and simply argue an absence of liability, which would be more consistent with a party holding no 

malice towards Plaintiff, Defendant instead engages in an all-out attempt at character assassination 

3 http://www.fastseduction.com
 

4 Defendant's Memorandum, II1(A), p. 4. It should be noted that Defendant LTSC likely means that the Defendant,
 

not the Plaintiff, will be seeking Rule 11 sanctions.
 

3 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 4 of 21
of Plaintiff, to the extent where it cannot even fathom the legitimacy of an expectation of 

jurisdiction in a forum in which the Defendant's business actively solicits revenue for its website. 

Perhaps this Court will decide that Defendant LTSC's easily-proven contacts with 

the Commonwealth are not sufficient to confer jurisdiction, but that would be a far cry from 

anything justifying Rule 11 sanctions. Moreover, dismissal in this venue for lack ofjurisdiction 

would merely transfer the case to Massachusetts, with a far more generous statute of limitations 

for defamation, or Delaware, a mere "hop, skip and jump" from this Court, and would likely put 

an even greater burden on Defendant than continuing the case here would. Moreover, ifPlaintiff 

were really out to "stick it to" the Defendant, or even to just fully defend his rights, he could 

"forum shop" across the entire country's federal and state courts, to include places like Oregon, 

where criminal acts in commerce are actionable under that state's RICO laws. Even that would 

not be an abuse ofthe courts, as both Defendant LTSC and Plaintiff compete for revenue from 

residents of literally the entire globe. In any high-stakes business endeavor, litigation is a fact of 

life, as are the events which often lead to it. Plaintiff is no more enamored of litigation than 

Defendant, and if given a choice, would rather not have to drain his time and resources protecting 

his rights. 

1. No Affidavit In Support Of Lack Of Jurisdiction 

Defendant LTSC cites Defendant Ross's Motion To Dismiss for lack of 

jurisdiction,5 yet LTSC's motion lacks the necessary affidavit to shift the burden to Plaintiff on 

establishing jurisdiction. This very motion by Defendant Ross which Defendant LTSC praises 

explains the need for the affidavit: 

A court may consider the allegations in the complaint to be true "unless 

controverted by the defendant['s] affidavits." Catalina Mktg. Int'l, Inc. v. 

Coolsavins.Com Inc., Civ. A. No. 00-2447,2003 WL 21542491, at *1 (N.D. 

111. July 3, 2003). 

5 Id. 

4 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 5 of 21
Since no affidavit was filed by Defendant LTSe, there is no evidence to 

support its claim for lack ofjurisdiction. Defendant LTSe again resorts to character-assassination 

to explain why it should not have to meet a simple evidentiary standard: 

LTSC need not necessarily come forward with an affidavit regarding its 

activities, or lack thereof, in or related to the Commonwealth of Pennsylvania. 

Indeed, any affidavit would then reveal the identities of people who would 

expose themselves to the vexatious litigation tactics ofthe Plaintiffwho has 

stooped so low as to file a lawsuit against counsel for LTSC. Surely, this 

Plaintiff, who has an established track record of clearly frivolous litigation, 

would certainly hunt down any person who would dare challenge him and he 

would file a frivolous lawsuit against them. These are his demonstrated 

proclivities. As such, in challenging this Court's jurisdiction, defendant LTSC 

relies solely upon the inability ofthe Plaintiffto show a factual basis for 

jurisdiction knowing that there are no such facts, based upon the fear of 

reprisal should LTSC put forward an affidavit. 6 

Defendant LTSe, through its co-defendant counsel, speaks of a "fear of 

reprisal," yet it is Plaintiff who has endured ongoing reprisals and repeated, systemic, and massive 

threats to his person, his employment and livelihood, and even those who align themselves with 

Plaintiff in public support. Defendant LTSe has been the primary beneficiary of this conduct, 

profiting extremely from its successful conspiracy to "destroy" the USENET alt.seduction.fast 

("ASF") group, so that it could then offer its own commercial website as a "replacement for ASF" 

as stated in the "ASF FAQ" that LTSe publishes. 

Despite LTSe's wishes, Plaintiff has no "established track record of clearly 

frivolous litigation," Losing cases are not necessarily frivolous ones, and pro se litigants often 

find themselves not prevailing due to procedural or strategic errors inherent in not being licensed 

attorneys. Their choice is to defend their rights as best they can or watch limitations statutes 

expire. In Plaintiff's cases, no dismissal has ever noted that a case was frivolous, and Plaintiff has 

never been sanctioned under Rule 11. To equate a losing case with a frivolous one would have a 

6 Defendant's Memorandum, III(A), p. 5. 

5 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 6 of 21
chilling effect on litigants who are entitled to relief but fear exercising their rights in the event they 

may not prevail even when clear "probable cause" exists. 

Defendant LTSC is not some "helpless rabbit" who is being picked on by 

Plaintiff It has asserted itself a de-facto "owner" of a public USENET group, given itself a "right 

to SPAM" the group by declaring it "dead," blaming Plaintiff for "killing" it, and then telling the 

entire public that the ASF traffic has been relocated to its website, while allowing other Seduction 

Mafia operatives to do the "dirtywork" of defaming, harassing, and threatening Plaintiff, while 

ensuring that they create so much "noise" in the process, that any readers of ASF become 

frustrated and seek out alternatives on the web, namely Defendant LTSC's website. No American 

should have any reasonable expectation of engaging in conduct ofthis nature without having to 

answer for it in a court of law. 

Plaintiff has never abused any discovery information, and in fact has kept 

confidential, without prompting by any court, a large volume of highly sensitive and personal 

information that he would have publicized had his character been anything resembling 

Defendant's portrait ofit. Plaintiff is not seeking any information greater than that necessary to 

litigate this matter, and even ifDefendant's fears were founded, it could have filed an "in camera" 

copy ofthe affidavit with the Court, and a redacted one with Plaintiff. Nevertheless, Plaintiff is 

already entitled to Formhandle's identity, as he is a defendant in this action, and he is entitled to 

jurisdictional discovery in order to meet his burden for establishing jurisdiction, as noted by 

Defendant Ross: 

A plaintiff can not just rely on bald assertions regarding the defendant's contact with the 

forum state. Carteret Sav. Bank v. Shushan, 954 F.2d 141, 146 (3d Cir. 1992). Rather, a 

plaintiff is required to present evidence sufficient to establish a prima facie case for the 

exercise of personal jurisdiction. Mellon Bank v. Farino, 960 F.2d 1217, 1223 (3d Cir. 

1992), Carteret Sav. Bank, 954 F.2d at 146.7 

7 Defendant Ross's Memorandum, III(A)(2), p. 5. 

6 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 7 of 21
A summary denial ofjurisdiction, without affidavits or evidence, as LTSC is 

attempting, contravenes existing case law. Further, in Toys "R" US, Inc., v. Step Two, S.A., 318 

F.3d 446 (3d Cir. 2003), the Third Circuit remanded the case back to the District Court to allow 

for exactly this type of discovery when jurisdiction was in controversy, refusing to allow a motion 

to dismiss for lack ofjurisdiction without the Plaintiff having the benefit ofsuch discovery. 

Plaintiff has yet to be afforded such discovery, so dismissal for lack ofjurisdiction would be 

premature. 

2. Purposeful Availment by LTSC. 

Defendant LTSC argues: 

In paragraph 13, the plaintifffails to assert sufficient facts to justify 

jurisdiction. First, he alleges that solicitation of donations "all over the world, 

including in the Commonwealth of Pennsylvania and Philadelphia" might 

justify jurisdiction. This is completely frivolous. Assuming the allegations to 

be true, worldwide solicitations do not even hint at suggesting a "purposeful 

availment,,8 

Plaintiff had set forth several grounds for jurisdiction against all Defendants in 

paragraph 11, which was not noted by Defendant. Additionally, Plaintiff first will recite 

Paragraph 13 ofthe Amended Complaint: 

13. Jurisdiction over Defendant LTSC is further conferred by virtue of LTSC 

soliciting and receiving donations to its website from internet users all over the 

world, including in the Commonwealth of Pennsylvania and Philadelphia, and 

by the "100-mile bulge" that extends to Wilmington, Delaware, which is where 

its registered agent, Business Filings, Inc., is located. Further, since 

Defendant LTSC receives donations via e-mail through Paypal, it has no 

way ofknowing ifthose users are from Pennsylvania, as Paypal users are 

not required to share their addresses with merchants. 9 (Emphasis Added). 

Defendant LTSC neglects to reference the emphasized part of paragraph 13, 

which shows that even it has no way ofknowing the residence of all who donate, presuming even 

8 Id.
 

9 Amended Complaint, 13, p. 4.
 

7 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 8 of 21
that it has never received donations from a Pennsylvania resident, or that doing so is even 

necessary, since it solicits donations from the Commonwealth just the same. 

The most relevant precedent for the instant motion would be Zippo Mfg. Co. 

v. Zippo Dot Com, Inc., 952 F. Supp. 1119, 1122 (W.D. Pa. 1997), where that court engaged in an 

extensive analysis of internet jurisdictional issues in a manner which clearly favors the Plaintiff in 

this motion, and noted: 

The likelihood that personaljurisdiction can be constitutional(v exercised is 

direct(v proportionate to the nature and quality of commercial activity that 

an entity conducts over the Internet ... .Ifthe defendant enters into contracts 

with residents of a foreign jurisdiction that involve the knowing and repeated 

transmission of computer files over the Internet, personal jurisdiction is proper. 

E.g., CompuServe, Inc. v. Patterson, 89 F.3d 1257 (6th Cir.1996). (Emphasis 

Added). 

Traditionally, when an entity intentionally reaches beyond its boundaries to 

conduct business with foreign residents, the exercise of specific jurisdiction is 

proper. Burger King,1O 471 U.S. at 475, 105 S.Ct. at 2183- 84. Different results 

should not be reached simply because business is conducted over the 

Internet.... Defendants who "'reach out beyond one state' and create 

continuing relationships and obligations with the citizens of another state are 

subject to regulation and sanctions in the other State for consequences oftheir 

actions." International Shoe Co. v. Washington, 326 U.S. 310, 319,66 S.Ct. 

154, 159- 60, 90 L.Ed. 95 (1945) 

In Maritz, Inc. v. Cybergold, Inc., 947 F.Supp. 1328 (E.D.Mo.1996), the 

defendant had put up a Web site as a promotion for its upcoming Internet 

service. The service consisted of assigning users an electronic mailbox and 

then forwarding advertisements for products and services that matched the 

users' interests to those electronic mailboxes. Maritz, 947 F.Supp. at 1330. The 

defendant planned to charge advertisers and provide users with incentives to 

view the advertisements. Id. Although the service was not yet operational, 

users were encouraged to add their address to a mailing list to receive updates 

about the service. Id. The court rejected the defendant's contention that it 

operated a "passive Web site." Id. at 1333- 34. The court reasoned that the 

defendant's conduct amounted to "active solicitations" and "promotional 

activities" designed to "develop a mailing list ofInternet users" and that the 

defendant "indiscriminately responded to every user" who accessed the site. Id. 

at 1333-34. 

JO Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475, 105 S.Ct. 2174,2183-84,85 L.Ed.2d 528 (1985) 

8 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 9 of 21
Defendant LTSC argues that even if it did receive contributions from Paypal 

from Pennsylvania residents, that this would not amount to purposeful availment. That is a matter 

of law for this court to decide, and the precedent appears to weigh heavily in favor ofthe Plaintiff. 

3. RICO'S Nationwide Service of Process. 

Defendant LTSC invoked Defendant Ross's second motion to dismiss, but filed its 

motion to dismiss prior to Plaintiff s brief in opposition to Defendant Ross's motion, in which 

Plaintiff noted that he had asserted jurisdiction under RICO in paragraph 11 of the Amended 

Complaint. Under 18 USC §1965(b), RICO provides for nationwide service of process. 

In Rolls-Royce Motors Inc. v. Charles Schmitt & Co., 657 F. Supp. 1040 

(S.D.N.Y. 1987), which involved RICO as well as trademark infringement claims, a district court 

judge in New York agreed with Rolls-Royce that it had personal jurisdiction over a Missouri car 

dealership's president, despite the absence of any tort in New York, simply because RICO allows 

for nationwide service ofprocess: 

"When such nationwide service of process is authorized, a federal district count's 

jurisdiction is coextensive with the boundaries ofthe United States, [and] due 

process requires only that a defendant in a federal suit have minimum contact with 

the United States." 

In ESAB Group, Inc. v. Centricut, Inc., 126 F.3d 617,629 (4th Cir. 1997), for 

example, the standard for allowing a Plaintiff to claim jurisdiction due to nationwide service of 

process is that the RICO claims must not be "immaterial or insubstantial." That is clearly not the 

case here, as Plaintiff is suing over a "Seduction Mafia" whose structure and operation resembles 

that of any organized-crime outfit. 

Additionally, since the predicate acts alleged in the Amended Complaint occurred 

in part in Pennsylvania (specifically, Defendant Penn's obstruction ofjustice with regard to 

Wintermute), the alleged RICO enterprise has engaged in operations in the Commonwealth which 

also subject it and any of its members to its jurisdiction. 

9 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 10 of 21
Regarding the" 1OO-mile bulge," Plaintiff included that as a grounds for conferring 

jurisdiction under RICO rather than personal jurisdiction. The argument was not "nonsense" as 

that "bulge" is a factor in RICO cases or any case where convenience is a factor. Delaware is 

almost identical in distance from Massachusetts as Pennsylvania, and Plaintiff certainly has 

jurisdiction in those courts, given that Defendant LTSC's registered agent is now located in 

Wilmington. A removal ofthis case to Delaware would certainly prejudice Plaintiff far more than 

Defendant LTSC, as Plaintiffwould have to travel dozens of miles, while LTSC would barely be 

farther away from the new venue. 

B. The Amended Complaint States A Claim For Which Relief Can Be Granted. 

Defendant LTSC makes extensive arguments concerning past filings and past cases 

which are not germane to the present case, and attempts to use those arguments to justify 

dismissing this action. Obviously, this pleading should be judged solely on its merits, and as the 

previous orders dictated, withoutprejudice to the previous dismissals, which were strictly for 

procedural reasons. Contrary to Defendant LTSC's portrayal ofPlaintiff as having a "lack of 

respect" for this Court, Parker v. LTSC (1) was dismissed only because of a heightened pleading 

standard invo lving pro se Defendant Geiger. The merits ofthe previous cases were never 

adjudicated, and the dismissals could not even have been appealed. Defendant LTSC seems more 

agitated by the nature of civil process than Plaintiffs correct use of it. Plaintiff has taken into 

consideration the previous rulings and has laid out a far more concise, readable, and better-pled 

Complaint. 

Defendant LTSC argues: 

The problem with the Plaintiff s Amended Complaint is that he leaps from insults against 

him to the legal conclusion that there is a cause of action that he can assert in a court of 

law. Based on the assumption that any of what the Plaintiff alleges makes any sense, it 

appears that he is alleging that there is a criminal conspiracy against him which underlies 

his civil racketeering claim and other claims. As to all ofthe claims against all ofthe 

parties (a statement which Plaintiff will allege is in furtherance ofthis conspiracy) it only 

10 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 11 of 21
appears that everything he alleges amounts to the following: That there is protected free 

speech in where people may be resorting to hyperbole in criticizing the Plaintiff. Insults, 

however, no matter how base, cannot form the basis for the claims that the Plaintiffhas 

asserted in the case at bar. 

Defendant LTSC completely ignores the Lanham Act claim, which simply states that 

Defendant's publication ofthe "ASF FAQ" document amounts to deceptive advertising (a clearlypled claim), but also attempts to classify the alleged conduct as mere "insults" and "hyperbole," or 

"protected free speech." Following are some examples ofwhat Defendant LTSC is attempting to 

sweep under that rug: 

1. Repeated threats against Plaintiff, such as those from "Player88," where he 

stated "[ 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). II 

2. The following threatening remarks from Vincent Runza, If. (a former 

moderator ofthe "ASF chat" on IRC and regular contributor to the LTSC website), who also took 

time out to promote LTSC when he wasn't attempting extortion against Plaintiff to get him to 

leave the group for LTSC's benefit (these are from 120 ofthe Amended Complaint): 

a.	 What I would really like to do is send a few bikers to your house to beat the 

living shit out of you. (01/0812004).12 

b.	 Interesting coincidence - I was chatting with Jack's brother last night. Gordo 

came up in the convo. Jack's brother would like to stomp your ass, Nutso. 

BTW, you FAILED to mention contacting Jeri's sister by phone and the 

exchange between her husband the COP and yourself. Wanna keep pushing 

people? You may find that others, less patient than myself, will do something 

about your abusive behavior that will land you in jail. (03/1 0/2004).13 

c.	 Jack died in service to his country. The Editorial Staff identified the accident 

that killed him. Jeri is a wonderful woman, widowed in a most terrible manner. 

Jack's brother, who shall remain nameless because Cavescum might try 

harassing him to serve his own twisted ends, is definitely alive and kicking. I 

hope people will just leave them in peace. I was disturbed to see that the 

11 Message ID: <311020042338329395o/ollame@host.ws>.
 

12 Message ID: <e5187c40.0401082330.6b356Iea@posting.google.com>
 

13 Message ID: <e5187c40.0403100520.186a2ba@posting.google.com>. This is the same "Jeri Ryan" who it has
 

been falsely claimed is a woman that Plaintiff has stalked and threatened, including but not limited to with the forged
 

e-mail posted by "Editorial Staff' and quoted by Defendant Ross.
 

11 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 12 of 21
Editorial Staff had contacted Jeri, but I realized they were NOT harassing hertheir own actions with respect to me convince me of their honor and rectitude. 

If Ray Gordon doesn't realize he's hurting good people, innocent people, with 

his demented pursuit ofhis 'enemies', then he needs to be put in an insane 

asylum. (03/1112004).14 

d.	 http://web.archive.org/web/20030620 133157/http://www.ray-gordon.coml. 

This link is purely for informational purposes and is in no way representative 

of an attempt to defame Ray Gordon. (04/14/2004). [Message Subject: "Link 

To Ray-gordon.com].15 

f.	 By annoying everyone who asks a seduction question here, GORK drives 

honest seekers of information to http://www.fastseduction.comlfor real 

answers to seduction questions. (06/18/2004).16 

g.	 Manic phase today, GORK? I emailed [Formhandle] to make sure he cuts off 

your AOL access. As you said, I'm mistaken. You're even crazier than I 

represented. (07109/2004).17 

h.	 I've been working on a book about inner game, in a desultory fashion. I've 

also noticed that my .gzip archive is hard to use as a reference, since there's a 

ton of responses to other posts that don't really offer content (never mind the 

clever flames and one-liners). (07/10/2004).18 

3.	 More threats and defamation amounting to extortion from "Aardvark," a 

"fan" of Defendant Ross (who is affiliated with Defendant LTSC in promoting Speed Seduction) 

and "SSer" whose main function is to deflect liability from Defendant Ross and the Seduction 

Mafia. The following statements are taken from paragraph 121 ofthe Amended Complaint: 

a.	 "he has criminally tresspassed (a federal offense) into websites and forums.... 

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 member ofthe media i would hold 

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

a statement." (07/24/04).19 

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

him." (07/25/04)?O 

14 Message ID: <e5187c40.0403111444.259dl17b@posting.google.com>.
 

15 Message ID: < e5187c40.0404140506.5454273e@posting.google.com>. This is a link to the "internet archive" of
 

the RayFAQ page.
 

16 Message ID: <2jhf4sFI0r4ddUl@ooi-berlin.de>.
 

17 Message ID: <217spnF9rheuUl@ooi-berlin.de>.
 

18 Message ID: <21a78gFaku42UI@ooi-berlin.de>. This post shows a desire to enter the commercial market through
 

the LTSC message boards, where the message was originally posted.
 

19 Message ID: <8nwMc.23088$8_6.6086@attbi_s04>.
 

20 Message ID: <ZqUMc.27641$eM2.1960@attbi_s51>
 

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Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 13 of 21
c.	 [T]his wasfonvarded to all the email addresses provided in the originalplea 

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

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

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

alleged "letter" he sent]: 

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) obtained from a 

website and message forum that Parker was forbidden from accessing due to 

his behavior. Even after being warned to cease and desist from such behavior, 

Parker kept "hacking into the site, using alternative aliases to hide his identity. 

He has engaged in outright barratry and threats of lawsuits to silence his critics 

who only wish for Parker to refrain from illicit or discourteous behavior. He 

has libeled users ofthe 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 ajail 

or perhaps a mental institution should it be deemedfitting ifParker is 

declared incompetent. 

I would be happy to provide my name you you upon request should it be 

absolutely necessary on the condition that such private information about 

myself is not made available to Parker for his misuse and further criminal 

mischief making. I hesitate to give it now as I simply do not wish for Mr. 

Parker to see it attached to theis message as he is often engaged in the 

merciless harassment of his perceived "enemies" once he has their personal 

information in hand. Parker has been known to also masquerade as a bar 

certified attorney to threaten and harass the families of his said "enemies". 

Thank you in advance for your attention to this matter. 

d. "you ripped off [Plaintiff's first book] from ross jeffries." (08/27/04)Z1 

e.	 "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)?Z 

21 Message ID: <_4LXc.320029$a24.128714@attbi_s03> 

22 Message ID: <TtjXd.45782$r55.7075@attbi_s52>. 

13 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 14 of 21
f.	 "i wonder what kind of dirt the pennsylvania bar association has on ray or 

could have." (03/11/05).23 

g.	 "isn't it illegal to falsely portray oneself as a lawyer?" (03/27/05)?4 

h	 "you need to be put away. a mental institution or jail without the benefits of 

an internet connection for you, will do just fine." (04/12/05)?5 

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

100% unemployable." (04/18/05).26 

J.	 hey fathead...over here, dummy. guess what really angers *real* mafia types? 

jerks like you, gumby. 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 ofgovernment 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).27 

4.	 Defendant LTSC has hardly assumed a passive role in this conduct, either. 

The following statements by LTSClFormhandle are taken from paragraph 65 ofthe Amended 

Complaint (it should be noted that Defendant only cites paragraph 65(a) in his motion): 

a.	 "is there really no Ray here?" 

"As long as he's not posting, that's all that matters. Once he does break down 

temptation and actually post, he'll be spotted quite easily and have his account 

and whatevr posts he made deleted (including all responses to his post). But I 

doubt he would even create an account here. It would be very easy to then 

determine his ISP's address blocks and deny access to his entire ISP if 

necessary." (11/02/01, to the LTSC message boards).28 

b.	 "> You've officially turned Ray out and made him your bitch, and I 

> commend you. (From "Odious") 

Well done! LOL - I [Formhandle] was saying basically the same thing to one of 

my wings. That the solution to the Ray crap wasn't to constantly feed him with 

what he wants - attention - but rather use that psychological need ofhis to turn 

him into my bitch. It's now like shoveling putting coal into steam engine. 

(11/14/2001).29 

c.	 Candor wrote: 

23 Message In: <p9iYd.118012$tl3.40457@attbi_s02>. 

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

25 Message In: <kT06e.8365$Bb3.5498@attbi_s22>. 

26 Message In: <ehQ8e.26776$xL4.16892@attbi_s72>. 

27 Message In: <Wyare.54809$nG6.12847@attbi_s22>. 

28 Message ID: <208.72@discussion.fastseduction.com>. 

29 Message In: <3BF268E9.2A8C3A3C@ao1.com>. 

14 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 15 of 21
> I've been ridiculously busy with work the last couple of months, so I 

> haven't had much time to contribute to the newsgroup. 

Now that you're back, take a note that most regular (normal, troll-free, 

spam-free) ASFdiscussions are happening on the priivate moderatedASF 

forums. You can create an account at: 

http://www.fastseduction.com!discussion/ 

You'll get e-mailed a password with instructions and then will be able to gain 

access to the newsgroup version ofthe conferences. The conferences are 

accessible with a web browser, newsreader, and even through e-mail, and are all 

synchornized with full threading support. Real-time search is supported and 

there are moderation features in place which allow me to keep garbage at bay ­

primarily to keep away any threat of Ray's presence and the crap he drags around 

with him. Most ofthe ASF regulars have already created accounts there. 400 

people have signed up in about 3 weeks and another 1,000-2,000 people are 

lurking there regularly rather than here. Most of what fills ASF now are Ray 

trolls, useless off-topic cross-posts from Ray, Ray rants, responses to Ray 

garbage, spam, and lost newbies. (11/17/2001, to ASF). 

-- jay (formhandle@fastseduction.com). Fast Seduction 101 

http://www.fastseduction.com!Class is now in session...Say goodbye to trolls, 

news100ns, and spam.Gain access to the moderated ASF newsgroups at: 

http://www.fastseduction.com!discussion/3D 

d.	 "Has anyone read a once online book entitled "Outfoxing The Foxes"? The 

author seems to have certain ideals about chycks, particularly hot looking chicks 

and how they act in society." (From: "observer"). 

(From Formhandle): "The guy that wrote that shit was and remains an endless 

troll to the public ASFnewsgroup. His demented bipolar disorder garbage 

posts, threats oflawsuits, misogyny, and general degenerative psychotic 

paranoia stank up the newsgroup so badly for so long that it lead to the 

formation 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 ofthe primarily reasons the discussions are flourishing 

here while the original public ASF turns into a cesspool of off-topic useless 

feces. Oh, and his books are shit. (04/23/2002, to the LTSC message board 

"alt.seduction.fast.tactics-techniques).31 

e.	 "Scientifikx wrote: http://www.[******].comlhotties.html. Anyone seen 

[Plaintiff's "Why Hotties Choose Losers"] site? >It's like a website that teaches 

women to go for AFC's and avoid the players. The player techniques that we use 

on women are discussed and shows women how to combat against these 

techniques. " 

[From Formhandle]: Yeah, that's R*y G*rd*n's web site. He's 100% off-topic on 

30 Message In: <3BF69CA6.300328A5@fastseduction.com>. 

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

15 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 16 of 21
mASF. If you don't know why, take a peek at uASF...and it's all retarded. 

(03/12/2004, to the LTSC message board "alt.seduction.fast.off-topic. ")32 

f.	 [From a post entitled "Moderating alt.hypnosis?"] "Hi, not sure ifthis is of 

interest to you folks here, but the "Ray problem" was solved about 2 years ago 

on ASF (alt.seduction.fast). Not only was it solved, but the subsequent solution 

allowed the ASF community to thrive." (03/21/2004, to alt.hypnosis).33 

g.	 "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." (04/27/2004)34 

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

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

(04/30/2004)35 

1.	 "I believe Gordon Roy Parker is in the midst of a full blown manic." 

[From Fonnhandle]I hope you guys aren't suprised. It seems the details ofthe 

motion to dismiss are finally sinking in for him." (05/06/2004)36 

J.	 "You're not banned because you have a dissenting opinion, you're banned 

because you're an asshole who has a habit of annoying the hell out ofpeople 

endlessly." (05/14/2004)?7 

k.	 "As LTSC's lawyers have also done - arguments in regards to all the other 

defendants. Parker seems to believe he can magically apply some rule to 

convince the court that such a move somehow denotes an appearance on the part 

ofLTSC's counsel in regards to the other defendants." (May 19, 2004)?8 

1.	 "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." (05/2712004)?9 

m.	 "[Plaintiff's] affiliates probably have some fonn 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-mails from people in regards to an affiliate, they may decide having that 

person as an affiliate might not be such a good idea." (06/02/04 to ASF).40 

32 Message ID: <137639.2l500@discussion.fastseduction.com>. 

33 Message ID: <405E13D7.35D29B72@fastseduction.com>. 

34 Message ID: <408FOOB9.7A65F012@fastseduction.com>. 

35 Message ID: <409lF32E.25E7FED@fastseduction.com>. 

36 Message ID: <409AFE8A.E9677074@fastseduction.com>. This post was made in response to a post that said "I 

believe Gordon Roy Parker is in the midst of a full blown manic." It also referenced the Motion To Dismiss filed by 

Defendant Wolf on behalf of all defendants in Parker v. LTSC (1). 

37 Message ID: <jOedndnc77UIbDndRVn-vA@giganews.com>. 

38 Message ID: <voWdnWfYt6B3TDbdRVn-jg@giganews.com>. 

39 Message ID: <XbOdnSqsFKVHySvdRVn-hg@giganews.com>. 

40 Message ID: <3eidne54aesxQyDdRVn-uA@giganews.com>. 

16 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 17 of 21
n.	 ''The only other legal liability I'm aware of is an admission from you in regards 

to accessing mASF when you've been informed multiple times not to and that it 

would be treated as electronic tresspass across state lines." (06/09/2004).41 

o.	 "Ray Gordon is Off·Topic on all ofmASF. Not even in Off-Topic. Period." 

(06/1 0/2004 to the LTSC message board "alt.seduction.fast.general).42 

p.	 "It would be pretty simple for me to pass along the block [IP] definitions to 

Thundercat, presuming his web host uses Apache and allows URL re-writing in 

the configuration file. Maybe I'll get around to it after the database/search 

upgrades..." (06/30/2004).43 

q.	 "The automatic posts are meant to save uASF newbies from the garbage and 

offer them the mASF option. (07/11/04).44 

r.	 "Crazy fucked up deranged people tend to believe they are sane and repeat the 

same mistakes over and over. Gordon Roy Parker aka Ray Gordon always 

believes he's in the right and tends to repeat the same bullshit over and over." 

(08/14/2004).45 

s.	 "I wonder how he'll be able to log onto the Internet and claim victory when a 

court-appointed mediator is taking away his computer as part of compensatory 

damages to LTSC. I surely would hope he finds a cyber cafe so he can let us all 

know about that victory." (08/23/2004).46 

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

IRS. Would you like the contact info ofthe IRS?.1 can also inform them of your 

WTC comments, as well as the time you quoted a story here about a 

gun/violence-related 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." (08/25/2004).47 

u.	 "Apparently you need a study to inform you ofthis, as it doesn't seem (by your 

own accounts) you've been able to stay in any workplace long enough to see it 

for yourself." (09/01/2004).48 

v.	 "The only one doing any "scorching" here the past few years has been Gordon 

Roy Parker." (09/022004 to ASF).49 

w.	 "An ultimate solution was found in regards to the Ray problem. See my sig." 

(November 19, 2004 to ASF).50 

41 Message ID: <OfidnSpjH5kqOFrdRVn-gQ@giganews.com>. 

42 Message ID: <157535.24781@discussion.fastseduction.com>. The subject responded to was entitled "Ross 

Jeffries And Ray Gordon." 

43 Message ID: <PbCdnbub9uLIIH7dRVn-hA@giganews.com>. 

44 Message ID: <7cOdnTDCxPkpa23dRVn-vw@giganews.com>. 

45 Message ID: <mdGdnSZHOOFPOYPcRVn·rQ@giganews.com>. 

46 Message ID: <McOdnfjnIYzSALTcRVn·sg@giganews.com>. 

47 Message ID: <XZOdneXiBOoqkLDcRVn·qQ@giganews.com>. 

48 Message In: <h7adnYWtxMAi46vcRVn·rg@giganews.com>. 

49 Message In: <4sydnfEhy_T-PKrcRVn-oA@giganews.com>. 

50 Message ID: <86Wdna3nB4Kx2QPcRVn·qA@giganews.com>. 

17 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 18 of 21
x.	 "You are not a [business] competitor. You are, however, an annoying fuckwit 

and a poo-poo head." (November 19, 2004 to ASF).51 

It should now be clear that the use ofthe terms "fuckwit" and "poo-poo head" were not 

the basis ofthis action, but instead were included to demonstrate malice and Defendant LTSC's 

utter contempt for the notion that Plaintiff has rights. This very conspiracy that Defendant LTSC 

is attempting to vacate itself from is the same one whose defendants received the benefit of legal 

services which were paid for by LTSC (in the form of a motion to dismiss on their behalf), with 

money that was earned through the very RICO conduct alleged by Plaintiff There could not be a 

clearer violation of 18 USC §1962(a)'s investment-of-proceeds language. 

C. Lanham Act/Other Claims 

Since Defendant LTSC called this conduct "protected free speech," it has not addressed 

the RICO, Lanham Act or Antitrust claims as a matter oflaw. A finding by this court that the 

statements set forth could give rise to liability under those Acts would therefore be sufficient to 

deny the motion to dismiss. Plaintiff has alleged interaction, profitability, acting in concert, and 

general conspiracy between LTSC and Ross. 

Further, as it relates to the Antitrust claims, Defendant LTSC has made no legal 

arguments which refute Plaintiff's claim that the "ASF FAQ" is anticompetitive and in violation 

of antitrust law, or that its policy of excluding Plaintiff as even a topic of discussion, and its 

general exclusion of certain advertisers in favor ofthe "Seduction Mafia," also constitute antitrust 

violations in general or restraint-of-trade violations as they relate to Plaintiff 

The "ASF FAQ" document published by Defendant LTSC (even after being put on 

notice ofthis lawsuit) is designed to convince readers ofASF that Defendant's "commercial 

website" is a "replacement for ASF," a group which has no owner and which cannot be 

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

18 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 19 of 21
..moderated.. by anyone. Plaintiff has alleged the requirements of a Lanham Act claim by pleading 

that the statements are deceptive (false and misleading), were made in commerce, and caused a 

competitive harm to Plaintiff, who equated them with advertising a private park in a public park 

and telling the public that the public park was closed so they should visit the private park instead. 

That claim more than any other has nothing whatsoever to do with any "insults and hyperbole" 

directed at Plaintiff, or as Plaintiff calls it, defamation, commercial disparagement, invasion of 

privacy, and extortion in violation ofthe Hobbs Act. 

IV. CONCLUSION 

For the reasons set forth hereinabove, Defendant LTSC's Second Motion To Dismiss 

should be denied, and his Conclusion (paragraph III of his Memorandum) should be struck from 

the record. An appropriate form oforder is attached. 

This the 5th day of December, 2005. 

Gordon Roy Parker 

Plaintiff, Pro Se 

4247 Locust Street, #806 

Philadelphia, PA 19104 

(215) 386-7366 

GordonRoyParker@ao1.com 

19
 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 20 of 21
IN THE UNITED STATES DISTRICT COURT
 

EASTERN DISTRICT OF PENNSYLVANIA
 

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

Snodgrass Publishing Group, 

v. 

Plaintiff, 

CASE NO.: 05-cv-2752 

Learn The SkiBs Corp., et al. 

Defendants. 

Hon. Harvey Bartle, HI 

CERTIFICATE OF SERVICE 

I, Gordon Roy Parker, hereby certify that I have served the foregoing Brief In Opposition 

To Defendant University of Pennsylvania's Second Motion To Dismiss, B."ief in Opposition 

To Defendant LTSC's Second Motion To Dismiss, and Brief in Opposition To Defendant 

WoWs Second Motion To Dismiss, on the following Defendants, by the following means: 

Trustees ofthe Univ. of PA Mary Kay Brown, Esq. Matthew S. Wolf, Esq. 

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

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

Walker & Rhoads Philadelphia, PA 19103 Attorney For LTSC And 

123 South Broad Street, 28th F1. Hand Delivery Defendant 

Philadelphia PA 19109 Regular Mail 

Hand Delivery 

Fomlhandle@fastseduction.col11 

Thol11 E. Geiger 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 5

th day of December, 2005. 

Gordon Roy Parker 

4247 Locust Street, #806 

Philadelphia, PA 19104 

(215) 386-7366 

GordonRoyParker@aol.com 

Plaintiff, Pro Se 

Case 2:05-cv-02752-HB Document 31 Filed 12/05/05 Page 21 of 21