UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

DALLAS DIVISION 

ALKIVIADES DAVID; FILMON TV LTD.; 

FILMON TV INC.; ALKI DAVID 

PRODUCTION INC.; HOLOGRAM USA;

and SWISSX. 

 Plaintiff(s) 

-vCOMCAST INC.; COMCAST VENTURES, 

LLC;. 

 Defendant(s) 

ANTITRUST COMPLAINT 

JURY TRIAL DEMAND

JURISDICTION 

This action commences under the TEXAS BUSINESS AND 

COMMERCE CODE, Title 2, Chapter 15.05 et seq., and applicable provisions of 

the CLAYTON ACT pursuant to 15 U.S.C. § 15(a). In addition, jurisdiction, in this 

case, is invoked onto the Court according to Article III, Section 2, to the 

Constitution of the United States codified under 28 U.S.C. § 1331; Diversity 

jurisdiction under 28 U.S.C. § 1332(a) is invoked in that most defendants are 

residents from different states of the Union. Finally, the TEXAS BUSINESS 

AND COMMERCE CODE 15.26 further invokes jurisdiction.

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LAW OFFICE OF MARK LIEBERMAN 

1704 Pine Hills Lane 

Corinth, Texas 76210 

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VENUE 

1. Venue is also proper within this Court pursuant to 28 U.S.C. § 1391(b)(2) and § 1391(c)1, 

in that, plaintiffs ALKIVIADESDAVID; FILMON TV LTD.; FILMON TV INC., ALKI 

DAVID PRODUCTION INC., HOLOGRAM USA, SWISSX, are business entities which 

conducts commercial business activities thru DISH NETWORK and across the United 

States to include the state of Texas, and the Eastern District of Texas. SWISSX conducts 

franchise commercial business activities across the United States to include the state of 

Texas, and the Eastern District of Texas. 

ABOUT THE PLAINTIFFS 

2. Plaintiff ALKIVIADES DAVID, known from hereinafter as DAVID, is a businessman and 

a natural person, and a citizen of the United Kingdom. DAVID is further Consul General 

at Large to the government of Antigua and Barbuda. 

3. Plaintiff FILMON TV LTD., known from hereinafter as, FILMON LTD, is a United 

Kingdom company doing business in the United States to include the state of Texas and 

internationally. 

4. Plaintiff HOLOGRAM USA., known from hereinafter as, HOLOGRAM, is a United 

Kingdom company doing business in the United States to include the state of Texas and 

internationally. 

5. Plaintiff FILMON TV INC., known from hereinafter as FILMON INC is a Delaware 

corporation, doing business internationally. 

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LAW OFFICE OF MARK LIEBERMAN 

1704 Pine Hills Lane 

Corinth, Texas 76210 

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6. Plaintiff ALKI DAVID PRODUCTIONS INC., known from hereinafter as ALKI DAVID 

PRODICTIONS INC., is a Delaware corporation doing business internationally. 

Plaintiff SWISSX, known from hereinafter as SWISSX, is a franchised company, and 

based in the state of Texas during all times relevant. SWISSX is a subsidiary company of 

FILMON TV INC. 

ABOUT THE DEFENDANTS 

7. Defendant COMCAST INC. (formerly known as American Cable Systems and Comcast 

Holdings) and known from hereinafter as COMCAST INC is headquartered 

in Philadelphia, PA. COMCAST INC., is the largest of America’s multinational 

telecommunications platforms for broadcasting and cable television. COMCAST has a 

registered agent for its Dallas, Texas, business market at CT CORPORATION SYSTEM, 

1999 Bryan St., Ste. 900, Dallas, Texas, 75201-3136, USA. 

8. Defendant COMCAST VENTURES, LLC., known from hereinafter as COMCAST 

VENTURES is a venture capital firm headquartered in San Francisco, California and a 

subsidiary of COMCAST INC. 

9. COMCAST INC. (formerly known as American Cable Systems and Comcast Holdings) 

is headquartered in Philadelphia, PA. COMCAST INC., is the largest of America’s 

multinational telecommunications platforms for broadcasting and cable television., 

10. COMCAST VENTURES, LLC., is a venture capital firm headquartered in San Francisco, 

California and a subsidiary of COMCAST INC. Both CONCAST INC., and COMCAST 

VENTURES, are associated together with NBC News, CNBC, and MSNBC are owned by 

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LAW OFFICE OF MARK LIEBERMAN 

1704 Pine Hills Lane 

Corinth, Texas 76210 

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COMCAST INC., which also owns UNIVERSAL PICTURES and is a minority partner to 

five Chinese state-owned companies. 

11. COMCAST INC., and COMCAST VENTURES, through their control of major media

networks and outlets, censored DAVID or caused DAVID to be censored.

12. Beginning in or about the year 2020, COMCAST INC., and COMCAST VENTURES

LLC., censored FILMON LTD., or caused its censoring to prevent FILMON LTD., from

exposing early on the corrupt and racketeering conduct of associates to and of attorney

Thomas Girardi and his wife Erica Jane Girardi, known from hereinafter as the GIRARDIS.

13. Attorneys associated with COMCAST INC, COMCAST LLC, and GIRARDI acted to

inflame the conditions of DAVID under Legal Abuse Syndrome and in violation of the

American Disabilities Act to further gain tactical advantages over litigation.

14. The censoring of FILMON LTD., by COMCAST INC., and COMCAST LLC., further

lessened streaming media competition with the telecommunications COMCAST

ONDEMAND brand(s) to include but not limited to NBC News, CNBC, and MSNBC and

Xfinity by injury, destruction, and or preventative competition to FILMON LTD., and its

customer base in the state of Texas.

15. COMCAST, INC., has a registered agent in Texas: CT CORPORATION SYSTEM, 1999

Bryan St., Ste. 900, Dallas, TX, 75201-3136, USA 

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LAW OFFICE OF MARK LIEBERMAN 

1704 Pine Hills Lane 

Corinth, Texas 76210 

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INJURY TO PLAINTIFFS IN THE STATE OF TEXAS 

ALKIVIADES DAVID; FILMON TV LTD.; 

FILMON TV INC.; ALKI DAVID PRODUCTION INC. 

16. Plaintiffs are engaged in business contracts with Dallas, Texas, based company “SWISSX,"

inasmuch that BECAUSE OF THE conduct of the COMCAST...., Plaintiff’s ability to 

conduct trade or business in, through, and from the state of Texas, including the financial 

budgeting for advertising has been highly affected by the course of conduct engaged in 

by the Defendants. 

FIRST CLAIM FOR RELIEF 

(Antitrust CLAYTON ACT pursuant to TITLE 15 U.S.C. § 15(a)) and

TEXAS BUSINESS AND COMMERCE CODE, TITLE 2, CHAPTER 15.05 

COMCAST INC.; COMCAST VENTURES, LLC. 

17. Plaintiff incorporates by reference and realleges pages 1 through 4 as set forth above. Title 15

U.S.C. § 15(a) provides that any person who shall be injured in his business or property by 

reason of anything forbidden in the antitrust laws may sue therefor in any district court of the 

United States in the district in which the defendant resides or is found or has an agent. 

18. TEXAS BUSINESS AND COMMERCE CODE, Title 2, Chapter 15.05(a) further provides

“Every contract, combination, or conspiracy in restraint of trade or commerce is unlawful.” 

19. Beginning in or about the year 2020 but to the present day, COMCAST INC., and COMCAST

LLC., censored FILMON LTD., or caused its censoring to prevent FILMON LTD., from

exposing early on the corrupt and racketeering conduct of the GIRARDI-KEESE Enterprise.

The censoring of FILMON LTD., by COMCAST INC., and COMCAST LLC., lessened

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LAW OFFICE OF MARK LIEBERMAN 

1704 Pine Hills Lane 

Corinth, Texas 76210 

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competition with their telecommunications streaming brands by injury, destruction, and or 

preventative competition to FILMON LTD., and its subscribed customer base in the state of 

Texas. 

20. Plaintiffs demands for judgment against Defendants as to the First Claim as follows: 

1. Finding that all defendants are jointly and severally liable for all damage caused to 

Plaintiffs; 

2. Awarding Plaintiff monetary damages in an amount not less than $85,045,000.00 said 

amount to be proven at trial; 

3. Awarding Plaintiff its litigation expenses, including reasonable attorneys’ fees, costs, 

and disbursements; 

4. Awarding Plaintiffs treble the award as referenced in Part 20(2) as prescribed by law; 

5. Granting such other relief as the case may require or as may be deemed proper and 

equitable. 

SECOND CLAIM FOR RELIEF 

(Violation of the ADA ACT 42 U.S.C. § 12101) 

AMERICAN DISABILITIES ACT OF 1990 

COMCAST INC.; COMCAST VENTURES, LLC. 

 

21. Plaintiff incorporates by reference and realleges pages 1 through 4 set forth above. 

22. Plaintiffs demands for judgment against Defendants as to the Second Claim as follows: 

1. Finding that all defendants are jointly and severally liable for all damage caused to 

Plaintiffs; 

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LAW OFFICE OF MARK LIEBERMAN 

1704 Pine Hills Lane 

Corinth, Texas 76210 

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2. Awarding Plaintiff monetary damages in an amount not less than $15,000,000.00 said 

amount to be proven at trial; 

3. Awarding Plaintiff its litigation expenses, including reasonable attorneys’ fees, costs, 

and disbursements; 

4. Awarding Plaintiffs punitive damages in the sum of not less than $100,000,000.00 or an 

amount otherwise to be decided by a jury; and 

5. Granting such other relief as the case may require or as may be deemed proper and 

equitable. 

PRAYER FOR RELIEF WHEREFORE, Plaintiffs prays for judgment against Defendants as 

follows: 

1. Finding that all defendants are jointly and severally liable for all damage caused to Plaintiffs; 

2. Awarding Plaintiff monetary damages in aggregate amount not less than $270,135,000.00 said 

amount to be proven at trial; 

3. Awarding Plaintiff its litigation expenses, including reasonable attorneys’ fees, costs, and 

disbursements; 

4. Awarding Plaintiffs punitive damages in the sum of not less than $100,000,000.00 or an amount 

otherwise to be decided by a jury; and 

5. Granting such other relief as the case may require or as may be deemed proper and equitable. 

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LAW OFFICE OF MARK LIEBERMAN 

1704 Pine Hills Lane 

Corinth, Texas 76210 

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JURY DEMAND, Pursuant to Fed. R. Civ. P. 38(b), Plaintiffs hereby demand a trial by jury of 

all issues so triable that are raised herein, or which hereinafter may be raised in this action. 

 Respectfully Submitted, 

 

 MARK J. LIEBERMAN 

 Texas Bar No. 12332520 

 1704 Pine Hills Lane 

 Corinth, Texas 76210 

 (817) 905-3772 

 Mjc358@hotmail.com 

 Lead attorney of record 

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