Thomas Edward Geiger 

Defendant, Pro Se 

817 N. McCrary Rd. 

Columbus, MS 39702 

Telephone: (662) 328-3630 

GORDON ROY PARKER, a.k.a. Ray Gordon, dba 

Snodgrass Publishing Group, Filed: June 9, 2005 

4247 Locust Street, 0806 

Philadelphia, PA 19104 

Plaintiff, 

V*
 

Learn The Skills Corp., c/o Business Filings, Inc., 9 East
 

Lockerman Street, Suite 205 Dover, DE 19901;
 

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

Inc., 9 East Lockerman Street, Suite 205, Dover, DE 19901;
 

Thorn E. Geiger, 817 North McCrary Road, Columbus MS
 

39702-4320; Paul Ross, alk/a "Ross Jeffries" aIkIa
 -C I LED 

ErosLA77@aol.com, 310 Tahiti Way, Marina Del Ral CI\, I CASE NO.: 05-cv-2752 

90292-6789, Trustees ofthe University of Pennsylvania, N 2 2006 

133 South 36th Street, 3rd Floor, Philadelphia, PA. 1910~A I Hon. Harvey Bartle, III 

Matthew S. Wolf, Esq., 1236 Brace Road, Unit K, t;,b L E. K ,Clerk 

Hill, NJ, 08034, and John Does 1-100 By Dep.Clerk 

Defendants. 

DEFENDANT THOMAS GEIGER'S REBUTTAL TO PLAINTIFFS' BRIEF IN OPPOSITION 

TO MOTIONS TO DISMISS. 

-1­

CASE NO.: 05-cv-2752 

Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 1 of 13
[1] COMES NOW Thomas Geiger, Resident of THE State of Mississippi, and Defendant in the 

above entitled matter (hereinafter "Defendant"), to submit this, Defendant's REBUTTAL TO 

PLAINTIFFS' BRIEF IN OPPOSITION TO DEFENDANT'S MOTIONS TO DISMISS AND 

DEFENDANT'S NOTICE OF OPPOSITION TO PLAINTIFF'S MOTION TO CONDUCT 

JURISDICTIONAL DISCOVERY .. 

[2] Defendant herein addresses issues of error and admissions of fact in Plaintiffs' BRIEF IN 

OPPOSITION TO DEFENDANT'S MOTIONS TO DISMISS, as follows: 

[3] In his introduction, Plaintiff Gordon Roy Parker states Defendant has not followed generally 

acceptable form for filing motions, specifically, the motions are jumbled together, not dated, not 

organized properly, and in many cases, without citations or relevant case law. 

[4] While Defendant agrees that he has no legal experience or training, and as Plaintiff noted in 

his Brief, is proceeding pro se out of necessity and not by choice, Defendant disagrees with this 

characterization of his sincere efforts to mount an adequate defense as jumbled together, not 

dated, not organized properly, and in many cases, without citations or relevant case law. 

[5] Arguably, it can be claimed Plaintiffs many and numerous complaints and filings share that 

same description, an opinion shared by the Hon. James McGirr Kelley and recorded in Case 

number 2:03-cv-06936-JK, PAED, and in fact, in his current Amended Complaint, Plaintiff has 

so convoluted the meanings of "domain", "website" and "domain name", there is no rational way 

any defendant can ascertain the specific meanings of each use of each word in the Complaint. 

[6] The Motions filed by Defendant Geiger, although filed in one document, are listed and argued 

separately, the entirety of the collective Motions to Dismiss are dated as a single document, each 

page is numbered (as seen by the Court in it's own copy of the Motions as filed), individual 

paragraphs are numbered (as shown by Plaintiffs response by the same numerical listing) and 

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Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 2 of 13
when case law is referenced, citations are provided as researched by the Defendant in the only 

way Defendant knows how. 

[7] Defendant has, is and will continue to attempt to present all filings and responses to the Court 

in as intelligent and legible a manner as is humanly possible, but in spite of errors in appearance 

or compilation, Defendant believes his filings to be plain and straightforward for the purposes of 

resolving the current action and to realize justice and due process. 

[8] Plaintiff Gordon Roy Parker has, once again, repeated for the court record, the argument that 

the registration and/or pointing of a domain name allows a person to control any content the 

domain name is pointed to. As clearly stated in Defendant's Motions to Dismiss, this argument 

runs throughout Plaintiffs filings and actions and serves as the sole foundation of his conspiracy 

allegations against Defendant. 

[9] The argument that the registration of a domain name allows a person to control any content 

the domain name is pointed to is blatantly false, and Plaintiff has acknowledged being a domain 

name owner and a website author, and as such, knows the difference between the two. Still, 

Plaintiff has attempted to perpetrate upon the court an outright misrepresentation and false 

assertion not borne out by the facts as presented by Defendant in his demonstrations to the Court, 

which Plaintiff ignores and does not attempt to address in his Opposition to Defendant's Motions 

to Dismiss. 

[10] In response to Plaintiffs assertions that Defendant, by mere virtue of being the registrant and 

contact of record for a domain name, has complete control over any website the domain name 

points to, and since the entire history of this unending flow of frivolous and vexatious litigation 

involves one domain name, that being ray-gordon.net, Defendant Geiger has arranged for the raygordon.net domain name (as was done in his prior demonstration for this Court with the domain 

name TakebackcityhalJ.com) to point to the public website for this very Court. 

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Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 3 of 13
[11] As he failed to address the previous similar demonstration Defendant arranged for this Court, 

Plaintiff cannot, in any way whatsoever, justify his argument that the registration and/or pointing 

of a domain name allows a person to control any content the domain name is pointed to. 

[12] This demonstration proves beyond any doubt Defendant cannot control any content on a 

website the ray-gordon.net domain name is pointed to, simply because the name is pointed to the 

site. 

[13] Plaintiff Parker has once again attempted to obfuscate the nature of his allegations and cloak 

them in misrepresentations about the nature of a domain name, which cannot host a website or 

computer files. Defendant has proven a domain name is a name only, an alphanumeric pointer to 

a website, and in fact, Plaintiff admits same in his BRIEF IN OPPOSITION TO DEFENDANT'S 

MOTIONS TO DISMISS (Page 13, #38): 

38. Denied. Defendant is hair-splitting: a domain name is what people type into a 

computer, to get to a website. The domain name is merely a verbal representation of 

the website's IP address. The domain owner controls which IP the website is located 

at, and who may upload files to that domain. Any citations to previous evidence 

should also be pinpoint, but are not here. 

[14] This is the only instance Defendant can find in all Plaintiffs filings, in this and previous 

actions, where the true relationship between a domain name and a website are mentioned by 

Plaintiff, and the only instance Defendant can find in all Plaintiffs filings where Plaintiff 

accurately, honestly and truthfully differentiates between a domain name and a website, instead 

of using the single term "domain" interchangeably in referring to both. 

[15] This is not "hair-splitting" as inferred by Plaintiff, because, to use his analogy of cars, the 

license plate on a car is only a record ofthe car, not the car itself, just as a phone number is not a 

telephone and an address is not a physical residence. 

[16] Plaintiff has purposely misrepresented the relll.tionship between a domain name and a 

website throughout his numerous complaints and actions. Either one can exist without the other, 

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Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 4 of 13
and neither one confers control over the other, and Plaintiff continues the misrepresentations and 

obfuscations begun in his original complaint in his first action against Defendant Geiger, in 

attempting to use the single word "domain" in referring to both a domain name and to a website. 

[17] The confusion and false light such misuse of a single word, to describe two separate entities,
 

can cause is highly prejudicial, not accurate in any way and, given the fact that Plaintiff is a
 

domain name registrant and a web content author and intellectual property owner himself, can
 

only be used in Plaintiffs filings in such a manner to attempt to create that exact confusion and to
 

prejudice Defendant's attempts to mount a reasonable adequate defense.
 

[18] There is no requirement of any kind, technical, legal or otherwise, wherein a domain name
 

must be pointed to any website at all. Defendant Geiger has legally registered over sixty domain
 

names, less than half of which point to physical websites on the internet. Defendant Geiger has
 

proven a domain name can be registered and not pointed anywhere, another fact Plaintiff has not
 

refuted, but only ignored.
 

[19] The author ofthe content on this Court's public website is in no way impaired by Defendant
 

Geiger's pointing the ray-gordon.net domain name at the site, nor can Defendant Geiger control
 

any content on the public website by pointing the ray-gordon.net domain name at the public
 

website for this Court.
 

[20] Plaintiff Parker has ignored this fact and the evidence provided by the Defendant and cannot,
 

in any way or fashion, refute the facts as Defendant has presented them.
 

There are serious questions that remain as to the Plaintiffs own pleadings, as brought forth in
 

Defendant's Motions to Dismiss.
 

A. Does Defendant's pointing of the ray-gordon.net domain name at the public 

website for this Court confer any control over the site's content to Defendant 

Geiger? 

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Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 5 of 13
In his arguments, according to Plaintiffs averments, this would be true, but it is false and 

Defendant has so proven by this demonstration. 

B. Can the content on this Court's public website be changed, modified, updated or
 

even removed without Defendant Geiger's consent?
 

In his arguments, according to Plaintiffs averments, this would be false, but it is true and
 

Defendant has so proven by this demonstration.
 

C. Can Defendant Geiger's pointing of the ray-gordon.net domain name at this
 

Court's public website in any way prevent, inhibit or control any such change,
 

modification, updating, alteration or removal of any content on this Court's public
 

website?
 

In his arguments, according to Plaintiffs averments, this would be true, but it is false and
 

Defendant has so proven by this demonstration.
 

D. Does pointing the ray-gordon.net domain name at this Court's public website
 

qualify Defendant as the publisher of this Court's public website, as claimed in
 

Plaintiff's many actions before this and previous Courts?
 

In his arguments, according to Plaintiffs averments, this would be true, but the answer is
 

obviously "false".
 

E. Will the pointing of the ray-gordon.net domain to another website, anywhere on 

the internet, prevent public access to the public website for this Court? 

As there are alternate methods of reaching the public website for this Court, other than by 

way of the ray-gordon.net domain name pointing, the answer is "no" as proven by 

Defendant's demonstration. 

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Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 6 of 13
F. Is consent legally required from this Court, the web author of the public website 

for this Court, the Federal Judiciary, the U.S. Government or the Congress of the 

United States, in order for Defendant Geiger, or any citizen, to point a legally 

registered domain name to the public website for this Court? 

In spite of a thorough and diligent search by Defendant, he cannot find one instance of 

consent being required to point a legally registered domain name at any publicly 

accessible website anywhere on the internet and Plaintiff has failed to provide any such 

references. 

[20] When all of Plaintiff s misrepresentations concerning the true nature of domain names and 

websites is debunked and proven false, what remains is the question of whether Plaintiff has had 

sufficient knowledge and information with which to investigate the true identity of the author of 

the website containing the content he so strongly objected to. 

[21] As shown by the Defendant, Plaintiff publicly admitted having knowledge and information 

on which to proceed, to investigate the identity of the author of the intellectual property at the 

website Plaintiff disagreed with, but, as Plaintiff admits in his Brief in Opposition to Defendant's 

Motions to Dismiss, he chose to not fulfill his due diligence responsibilities before filing 

numerous actions and complaints before this and previous Courts, complete with allegations and 

accusations of criminal conspiracy and wrongdoing against Defendant Geiger. 

[22] Plaintiffs excuses about why he failed to carry out his due diligence duties, while having 

sufficient information to investigate the true identity of the website content author, as required 

under FRCP ll(b), are disingenuous and insufficient to justify his violations of the Federal Rules. 

[23] Such wanton disregard for the Federal Rules is no small matter and has led to hundreds of 

hours of unnecessary and time consuming research, monetary expenditures and public 

embarrassment on the part of the defendants in Plaintiff Parker's many frivolous actions. 

-7­

Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 7 of 13
[24] Defendant Geiger asks the court to consider the seriousness of the due diligence failure by 

Plaintiff, which Defendant has brought to the Court's attention, through Plaintiffs own 

admissions and filings. 

[25] Failing to pursue the information Plaintiff Parker publicly admitted having had at hand at the 

time he had it, information Defendant has proven would exonerate him of all allegations and 

accusation against him, is not the fault of the Defendant. It is the fault of Plaintiff Parker himself, 

and the excuses Plaintiff offers for not having explored and investigated said information as 

required under FRCP ll(b), namely, that in filing such averments with the Court, "an 

unrepresented party is certifying that to the best of the person's knowledge, information, 

and belief, formed after an inquiry reasonable under the circumstances", at the very time he 

had such evidence, fail on their face, as Plaintiff had stated time and time again when he had the 

information he fully intended to pursue the evidence, but instead chose to not carry through with 

those stated intentions. 

[26] This failure on the part of Plaintiff Parker to do that which the Federal Rules of Civil 

Procedure demand he do, with evidence he had before proceeding with the first action against 

Defendant, that would have exonerated Defendant Geiger of all allegations, is inexcusable and is 

suspicious in its very nature Defendant contends is in violation ofFRCP Rule ll(b)(l), namely; 

"it is not being presented for any improper purpose, such as to harass or to cause 

unnecessary delay or needless increase in the cost of litigation." 

[27] Plaintiffs failure to diligently investigate profound evidence he publicly acknowledged 

having, and later choosing to make false and untrue claims against Defendant, shows Plaintiff has 

undertaken a program of frivolous and vexatious action against Defendant, not for the purpose of 

determining the identity of the author of any website Defendant Geiger pointed the raygordon.com domain name at, such investigation Plaintiff publicly admitted he could have done, 

-8­

Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 8 of 13
and even intended to do at the time, but is solely an attempt by Plaintiff to harass and embarrass 

Defendant Geiger, and to interfere with Defendant's employment in a trusted position with the 

U.S. Department of Defense. 

[28 In his Brief in Opposition of Defendant's Motions to Dismiss, Plaintiff Parker states, "That 

Defendant Geiger, through his stated claim he does not know who the author of the 

RayFAQ website is, has made it impossible to subpoena their identity, since the only way to 

find out who is publishing a website is to find out who owns the domain, and to find out 

from the domain owner who has permission to upload files to it via FTP." 

[29] As evidenced by Plaintiffs own admissions in the original complaint and his Brief in 

Opposition of Defendant's Motions to Dismiss, Plaintiff Parker is again being untruthful here, as 

authorship has been claimed by an individual who is not Defendant Geiger, and evidence and 

information proving that fact has been in the possession of Plaintiff since June 5, 2002, yet 

Plaintiff has steadfastly refused to pursue the evidence and information he has publicly 

acknowledged having, evidence which totally proves Defendant's claim he is not the person 

Plaintiff is claiming him to be, i.e. the author of intellectual property on a website Plaintiff 

objected to and forms the basis for all Plaintiff's claims against Defendant. 

[30] Once again, Plaintiff has fallen back on misrepresentations and obfuscations in using the 

single word "domain" when referring to both a domain name and to a website. Plaintiffs 

continuing misuse of the single word "domain" does not afford Defendant sufficient specificity 

with which to respond to the averments and allegations in an intelligent and rational manner. 

[31] The foundation of Plaintiffs averments of wrongdoing against Defendant Geiger, which 

Plaintiff feels are important enough to warrant federal litigation, are that Defendant Geiger either 

is the author of the website Defendant pointed a domain name at, or he knows the identity of the 

website author and only by revealing such can Defendant prove he is not said author. 

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Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 9 of 13
[32] Again, Defendant brings to the Court's attention the issue of the information Plaintiff has 

publicly admitted to having, but not acted upon, in the almost four years he has been in 

possession of the information. 

[33] Defendant Geiger has authored intellectual property content for the World Wide Web, and as 

an author, is very mindful of the issues involved in IP intellectual property rights issues, which is 

a very important topic of social and legal commentary, discussion and concern today. 

[34] Never would Defendant Geiger attempt, under any circumstances, to lay claim to the 

authorship of the creative works of another individual, and, whether or not Plaintiff Parker cares 

for any particular content on any websites, that content is intellectual property and is covered by 

copyright. 

[35] Defendant objects, in the most stringent way possible, to Plaintiffs attempts to assign to 

Defendant, the creative and legal intellectual property rights of another person. In spite of 

Defendant's repeated assertions he is not the content author Plaintiff is claiming him to be, and in 

spite of information Plaintiff has had for almost four years that substantiates Defendant's 

assertions, and in spite of Plaintiffs acknowledging he is aware another individual has claimed 

authorship of the intellectual property at issue in his filings, Plaintiff has insisted on falsely 

attempting to characterize and misidentify Defendant as the author and intellectual property rights 

owner of said content. 

[36] Throughout several iterations of Iitigation before this and previous Courts, Plaintiff has not 

made use of the same investigative processes and procedures with the evidence and information 

he has acknowledged having as to the true identity ofthe author of the intellectual property on the 

website he so strongly objected to, yet he is asking this Court to warrant those processes and 

procedures against Defendant Geiger with not merely less than the same information and 

-10­

Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 10 of 13
evidence concerning the Defendant than the, as yet, unidentified author, but having no 

information at all concerning Defendant Geiger, save the lawful registration and pointing of a 

domain name. 

[37] Plaintiff has presented no facts or evidence of wrongdoing by Defendant, but rather admits to 

a wanton and blatant disregard for the Federal Rules of Civil Procedure by offering only excuses 

as to why he did not pursue the information he had which would have exonerated Defendant 

Geiger. 

[38] Plaintiff has, in the span of time covered by his first original complaint on Parker v. LTSC 

(2:03-cv-06936-JK), either threatened to abuse subpoenas from this and the previous court, or 

has abused said subpoenas, solely for the purpose of obtaining personal information about anyone 

who publicly disagrees with Plaintiff or criticizes Plaintiff's business efforts and commercial 

products. 

[39] Plaintiff has posted public messages wherein he boasts to having obtained stacks of blank 

subpoenas and will use them for purposes of invasion of privacy and harvesting personal data on 

his critics, to stifle free speech he finds offensive, to chill open public debate and opinion on the 

value, marketability and worth of his purported commercial products. 

[40] Even though Pennsylvania has passed no anti-SLAPP legislation, the freedom of speech we 

all enjoy as Americans includes the right to openly discuss and debate, to exchange ideas and 

philosophies and to express thoughts and opinions, even those concerning commercial business 

and products, even to the extent such thoughts and opinions are not popular, are controversial or 

even offensive. 

[41] Through his successive pleadings and complaints, Plaintiff has, as a self-described 

commercial interest, attempted to squelch all public expressions and free speech he feels is not 

complimentary to his business, his products and himself. 

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Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 11 of 13
[42] Based on the lack of substance in Plaintiffs pleadings against Defendant Geiger, bearing no 

facts or evidence of wrongdoing, only the legal registration and pointing of a domain name, and 

based on the admissions of Plaintiff to having had vitally important and pertinent evidence at the 

time of the events on which Plaintiff's allegations are based, evidence that would have proven 

beyond any doubt the innocence of the Defendant of all accusations of criminal wrongdoing by 

Plaintiff against the Defendant, Defendant Geiger submits his separate Motion in Opposition to 

the Plaintiffs Motion to Conduct Jurisdictional Discovery and therein joins in Defendant Learn 

the Skills Corpo's Opposition to the Plaintiffs Motion to Conduct Jurisdictional Discovery and 

reserves his right to file a motion to limit the scope of discovery should this court grant the 

Plaintiffs request for jurisdictional discovery. 

hom 

/ 

of January 2006 

r, Defendant Pro Se 

817 N. McCrary Rd. 

Columbus, MS. 39702 

662-328-3630 

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Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 12 of 13
GORDON ROY PARKER, a.k.a. Ray Gordon, dba I 

Snodgrass Publishing Group, Filed: June 9, 2005 I 

4247 Locust Street, 0806 I 

Philadelphia, PA 19104 I 

I 

Plaintiff, I 

I 

y* I 

I 

Learn The Skills Corp., c/o Business Filings, Inc., 9 East I 

Lockerman Street, Suite 205 Dover, DE 19901; I 

Formhandle@fastseduction.com, c/o Business Filings, I 

Inc., 9 East Lockerman Street, Suite 205, Dover, DE 19901; I 

Thorn E. Geiger, 817 North McCrary Road, Columbus, MS I 

39702-4320; Paul Ross, a/kla "Ross Jeffries" a/kla F IILEn 

ErosLA77@aol.com, 310 Tahiti Way, Marina Del Ray, CAl, I <::ME NO.: 05-cv-2752 

90292-6789, Trustees ofthe University of Pennsylvania, I 

133 South 36th Street, 3'd Floor, Philadelphia, PA. 19104, JAN12 3 ?[\llan. Harvey Bartle, III 

M.atthew S. Wolf, Esq., 1236 Brace Road, Unit K, Che~CH IE. KU , lark 

Hdl, NJ, 08034, and John Does 1-100 By' . Dep.Clerk 

Defendants. 

DEFENDANT THOMAS GEIGER'S REBUTTAL TO PLA TIFFS' BRIEF IN OPPOSITION 

TO MOTIONS TO DISMISS. 

GORDON ROY PARKER 

Plaintiff, Pro Se 

4247 Locust Street, #806, 

Philadelphia, PA 19104 

(215) 386-7366 

Matthew S. Wolf, Esquire,pro se Defendant 

241 Kings Highway East 

Haddonfield, NJ 08033 

Mary Kay Brown 

Shernese Y. Woodbine 

Pa. I.D. Nos. 54327 and 91209 

1835 Market Street, 14th Floor 

Philadelphia, PA 19103 

Dennis G. Young, Jr., Esquire 

Montgomery, McCracken, Walker & Rhoads, 

LLP 

123 South Broad Street 

Philadelphia, PA 19109 

on the 19th day of January 2006, postage prepaid in the United States Postal Service. 

f January 2006 

Defendant, Pro Se 

817 N. McCary Rd., 

Columbus, MS. 39702 

(662) 328-3630 

homas e r. 

Case 2:05-cv-02752-HB Document 38 Filed 01/23/06 Page 13 of 13