03/02/2020 AYYADURAI v. FLOOR64, INC | 270 F.Supp.3d 343... | 20170907d75| Leagle.com IV.  Conclusion For the reasons stated above, the motion of Floor64, Inc. and Michael Masnick and the motion of Leigh Beadon to strike the complaint pursuant to the California anti-SLAPP law are DENIED. The motion of Floor64, Inc. and Michael Masnick and the motion of Leigh Beadon to dismiss for failure to state a claim are GRANTED. So Ordered. [270 F.Supp.3d 371] Appendix A Ayyadurai v. Floor64, Inc. et al., 17-10011-FDS Alleged Defamatory Statements 1) The headline: "Why Is Hu Ex. G) ngton Post Running a Multi-Part Series to Promote the Lies of a Guy Who Pretended to Invent Email?" (Compl. ¶ 34(a), 2) "... [Dr. Ayyadurai's] continued false insistence that he invented email is reaching really questionable levels." (Compl. ¶ 34(b), Ex. G) 3) "Dr. Ayyadurai is perpetuating a `fake story' with respect to his claims of invention of email." (Compl. ¶ 34(c), Ex. G) 4) "Dr. Ayyadurai and his friends `totally misrepresent' a technical report relating to computer messaging." (Compl. ¶ 34(d), Ex. G) 5) "[Dr.] Ayyadurai has built up his entire reputation around the (entirely false) claim that he `invented' email." (Compl. ¶ 34(e), Ex. G) 6) "[Dr. Ayyadurai] misrepresents what a copyright registration means." (Compl. ¶ 34(f), Ex. G) 7) "But [Dr. Ayyadurai is] simply not telling the truth when he claims to have invented email." (Compl. ¶ 34(g), Ex. G) 8) "[The Hu ngton Post article] is nothing more than a PR campaign for a liar." (Compl. ¶ 35(a), Ex. H) 9) "[The Hu ngton Post article] just repeats the same false claims (using nearly identical language) as Ayyadurai and his friends in their original posts." (Compl. ¶ 35(b), Ex. H) 10) "... Ayyadurai is using one of the oldest trolling tricks in the book, in pretending that everything that he is actually doing is actually being done nefariously against him." (Compl. ¶ 35(c), Ex. H) 11) "Instead, the only one whose entire `identity' is built o a fake claim to have invented email is ... Dr. Ayyadurai." (Compl. ¶ 35(d), Ex. H) 12) "The only fabricated controversy is by [Dr. Ayyadurai]." (Compl. ¶ 35(e), Ex. H) 13) "[Dr. Ayyadurai] claims that those of us debunking his bogus claim refused to look at the primary documents." (Compl. ¶ 35(f), Ex. H) 14) "There is no controversy other than the one that [Dr. Ayyadurai is] manufacturing." (Compl. ¶ 35(g), Ex. H) 15) "The question is whether or not Hu ngton Post will recognize that it's being used as part of an e ort to drum up a faux controversy over something that is blatantly untrue." (Compl. ¶ 35(h), Ex. H) 16) "Not only do Ayyadurai and his friends misrepresent reality, they fraudulently make claims that are easily debunked." (Compl. ¶ 36(a), Ex. I) 17) "... [Dr. Ayyadurai's and his friends'] two biggest claims are (1) that the `US government o cially recognized Ayyadurai as the inventor of email' in 1982 and (2) that a leading analysis of electronic messaging in 1977, by Dave Crocker at RAND, claims that a full intero ce email system is `impossible.' Both of these claims are absolutely false." (Compl. ¶ 36(b), Ex. I) 18) "... [T]he rst [claim] relies on blatantly misleading people about what a copyright is and what Ayyadurai [270 F.Supp.3d 372] copyrighted." (Compl. ¶ 36(c), Ex. I) 19) "... [T]he fact that [Dr. Ayyadurai] and his friends continue to pretend that a copyright is something it is not is farcical." (Compl. ¶ 36(d), Ex. I) 20) "[Dr. Ayyadurai and his friends] are relying on the ignorance of reporters and the public about what a copyright is." (Compl. ¶ 36(e), Ex. I) 21) "[Dr. Ayyadurai and his friends] deliberately misrepresent what Crocker said by taking two separate sentences, from di erent pages in the report, removing the context around them, and mashing them together to pretend they say something they do not." (Compl. ¶ 36(f), Ex. I) 22) "Computer historian Thomas Haigh has been tracking Ayyadurai's lies and misrepresentations for years, and alerts us to the fact that Ayyadurai's story has notably changed over the years, revealing additional misrepresentations and attempts to change history." (Compl. ¶ 36(g), Ex. I) 23) "... Ayyadurai has conveniently tried to rewrite his own history to counter the debunkings." (Compl. ¶ 36(h), Ex. I) 24) "So Ayyadurai changed the story, and pretended that he was both challenged and wrote his `50,000 lines of code' and got it all working in 1978." (Compl. ¶ 36(i), Ex. I) 25) "... Ayyadurai and his friends are now trying to rewrite history...." (Compl. ¶ 36(j), Ex. I) 26) "[The Hu ngton Post article] is merely a repeating of Ayyadurai's lies." (Compl. ¶ 36(k), Ex. I) https://www.leagle.com/decision/infdco20170907d75 11/15