Case 1:18-cv-01011-RMC Document 42 Filed 08/09/19 Page 9 of 19 a. Mr. Anglin/Moonbase Holdings (Count I)8 Ms. Dumpson alleges that Mr. Anglin and Moonbase Holdings invited interference and interfered with her right to full and equal enjoyment of places of public accommodation, specifically the AU campus. Am. Compl. ¶¶ 129-44 (Count I). Ms. Dumpson alleges that she was engaged in a protected activity under the DCHRA by using the resources on the AU campus. See id. ¶¶ 131-32. The DCHRA defines places of public accommodation as “restaurants or eating houses, or any place where food is sold for consumption on the premises; . . . establishments dealing with goods or services of any kind . . . ; swimming pools, . . . amusement and recreation parks, . . . gymnasiums, . . . garages, . . . [and] public halls and public elevators.” D.C. Code 2-1401.02(24). AU is considered a place of public accommodation under the DCHRA because it has restaurants, other places where food is sold, establishments dealing with good or services, swimming pools, gymnasiums and recreational parks, garages, and buildings with public halls and elevators that are available to AU students and the public. Am. Compl. ¶¶ 134-35. Additionally, the lampposts the bananas were hung from were near the Mary Graden Center, the student center where the AU Student Government offices are located. Id. ¶ 135. The Mary Graden Center is centrally located on campus near the gym and bookstore and holds restaurants open to the public. Id. Ms. Dumpson alleges that the troll storm initiated by Mr. Anglin and Moonbase Holdings interfered with her enjoyment of places of public accommodation. See id. ¶¶ 138-41. The harassment targeted her because of her race and gender, see id. ¶ 138, and affected her use and enjoyment of the AU campus because she no longer felt safe on campus in the way she had 8 Because Mr. Anglin is the registered agent, founder, and publisher of Moonbase Holdings, and thus exercises control over the company, the Court considers these Defendants together. See Am. Compl. ¶ 30. 9

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