Case 1:18-cv-01011-RMC Document 42 Filed 08/09/19 Page 2 of 19 hung nooses with bananas inscribed with racist and derogatory messages around the AU campus, including near the Mary Graden Center, the student center which houses the AU Student Government offices. Am. Compl. [Dkt. 16] ¶¶ 51, 61, 63-64. It is alleged that the bananas were inscribed with phrases such as “AKA Free” (a reference to Ms. Dumpson’s sorority, Alpha Kappa Alpha) and “Harambe bait” (a reference to a gorilla because comparing African Americans to apes is a common racist slur). Id. ¶ 64. Ms. Dumpson, AU, and law enforcement all believed Ms. Dumpson to be “the primary target of the hate crime.” Id. ¶ 74. After the media reported on this crime, Mr. Anglin posted an article about Ms. Dumpson on his website, the Daily Stormer,1 writing: “No one feels safe around bananas. Some racists have taken to calling this African Queen ‘Dumpy Dumpson,’ smdh [shaking my damn head].” Id. ¶¶ 89-90. Mr. Anglin then published Ms. Dumpson’s name, photo, and direct links to her Facebook account and the AU Student Government Twitter account with which Ms. Dumpson was associated as AU Student Government President. Id. ¶ 90. Mr. Anglin further directed his followers to “troll storm”2 Ms. Dumpson, id. ¶ 2, encouraging them to troll Ms. Dumpson saying: “Be sure to send her some words of support on Facebook, and hit up the AU Student Government on Twitter. Let her know that you fully support her struggle against bananas.” Id. ¶ 90. 1 Mr. Anglin is the founder and publisher of the Daily Stormer. Am. Compl. ¶ 25. Mr. Anglin registered Moonbase Holdings, a for-profit, limited-liability corporation under the laws of the State of Ohio. Id. ¶ 30. Moonbase Holdings provides Mr. Anglin and the Daily Stormer with financial support. Id. 2 “‘Troll storms’ involve the coordinated trolling of a person by multiple individuals via messages sent over social media platforms, postal mail, and phone.” Am. Compl. ¶ 25 n.11. “Trolling is mocking, insulting, harassing, threatening, humiliating, defaming, and/or intimidating a targeted person through communications (typically, but not exclusively, online).” Id. ¶ 20. 2

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