03/02/2020 AYYADURAI v. FLOOR64, INC | 270 F.Supp.3d 343... | 20170907d75| Leagle.com 27) "We're curious if Ayyadurai would like to try to present any evidence that a giant defense contractor is paying us o law and (2) point to the actual 1977 paper that Ayyadurai himself totally misrepresents." (Compl. ¶ 36(l), Ex. I) to (1) explain basic copyright 28) The headline that Dr. Ayyadurai's claims with respect to invention of email are "blatantly false claims." (Compl. ¶ 37(a), Ex. J) 29) "The key arguments in [Dr. Ayyadurai's] claim are obviously false, and prey on (1) a misunderstanding or misrepresentation of copyright law and (2) an almost fraudulent misquoting of Dave Crocker...." (Compl. ¶ 37(b), Ex. J) 30) "... [The Hu ngton Post] won't retract and renounce this series [about Dr. Ayyadurai] as a PR campaign for a series of blatantly fraudulent claims...." (Compl. ¶ 37(c), Ex. J) 31) "... Hu Po Live ... picked up on the completely bogus campaign and did a whole fawning interview with Ayyadurai, never once presenting the evidence that he's fraudulently misrepresenting basic facts." (Compl. ¶ 37(d), Ex. J) 32) "... Hu Po and Hu Po Live are... actually actively promoting a lie." (Compl. ¶ 37(e), Ex. J) 33) "... Hu ngton Post is actively claiming that a clearly false story is true." (Compl. ¶ 37(f), Ex. J) 34) The headline that refers to Dr. Ayyadurai as "Fake Email Inventor." (Compl. ¶ 38(a), Ex. K) [270 F.Supp.3d 373] 35) "... Hu ngton Post [allowed] Shiva Ayyadurai and his friends to post an entirely bogus `history of email' series, all designed to make it look like Ayyadurai himself had invented email — a claim he's been making for a few years, despite it being entirely false, based on totally misrepresenting a number of things, including what copyright means, misquoting a 1977 research paper and playing `no true scotsman' over what is a `true' email system." (Compl. ¶ 38(b), Ex. K) 36) "... [The Hu ngton Post] allowed the series [on Dr. Ayyadurai] to go on with more false claims, and then told me it had `added a clari cation' that didn't clarify anything, but was a statement written by Ayyadurai, repeating the false claims." (Compl. ¶ 38(c), Ex. K) 37) "[The Hu ngton Post] admit[s] that [the series on Dr. Ayyadurai] was a `blogger-generated series,' which is an attempt to distance the fake series, put together by Shiva Ayyadurai himself with PR guru Larry Weber, from Hu ngton Post's journalistic `news' side." (Compl. ¶ 38(d), Ex. K) 38) "Ayyadurai and Weber had been banking on the fact that most people don't realize that the blogging side of Hu Po has no editorial controls to pretend that the series had some sort of journalistic credibility. They appear to be promoting the fake articles everywhere...." (Compl. ¶ 38(e), Ex. K) 39) "There's no controversy at all. Ayyadurai is simply making false claims...." (Compl. ¶ 38(f), Ex. K) 40) "... `[G]oing to the people' is great, but historically [Dr. Ayyadurai has] done that with clearly bogus claims — such as misquoting Dave Crocker's 1977 research and pretending that his 1982 copyright on his EMAIL software is the equivalent of a patent for the concept of email." (Compl. ¶ 38(g), Ex. K) 41) The headline that refers to Dr. Ayyadurai as the "Fake Inventor of Email." (Compl. ¶ 39(a), Ex. L) 42) "Ayyadurai has built up quite a reputation around this false claim, even though it's been debunked over and over and over again." (Compl. ¶ 39(b), Ex. L) 43) "Ayyadurai keeps coming back, often moving the goalposts and changing his de nitions, but still ultimately `invented' email." (Compl. ¶ 39(c), Ex. L) at out lying in pretending to have 44) "Ayyadurai, however, has cleverly used misleading (to downright false) claims to make what appears on its face to be a credible story, fooling a number of gullible reporters." (Compl. ¶ 39(d), Ex. L) 45) "... [M]any people [are] wondering if the whole Hu Po series [about Dr. Ayyadurai] was ramped up prior to [Ayyadurai`s'] `wedding' to get the mainstream press to roll with the bogus claim." (Compl. ¶ 39(e), Ex. L) 46) "Ayyadurai has been trying to make this lie [regarding the invention of email] stick for years...." (Compl. ¶ 39(f), Ex. L) 47) "... [T]he mainstream press is repeating [Dr. Ayyadurai's] bogus claims as facts." (Compl. ¶ 39(g), Ex. L) [270 F.Supp.3d 374] 48) "UPI has an article that doesn't mention Ayyadurai's false claims in the text of the article, but does falsely call him `email creator' in the headline...." (Compl. ¶ 39(h), Ex. L) 49) "Headline and Global News `reporter' Dina Exil repeatedly calls Ayyadurai the inventor of email and also claims he `is known for being the person to invent email,' except none of that is true. He's known for pretending that." (Compl. ¶ 39(i), Ex. L) rst 50) "... Ayyadurai has been focused on using any and all press mentions as `evidence' in his bogus campaign to declare himself the inventor of email...." (Compl. ¶ 39(j), Ex. L) 51) "... [W]e have `trusted' media like ABC and CBS repeating [Dr. Ayyadurai's] totally false claims...." (Compl. ¶ 39(k), Ex. L) 52) "... Ayyadurai will continue to press his bogus claims again and again and again." (Compl. ¶ 39(l), Ex. L) 53) The headline that refers to Dr. Ayyadurai as "A `Fake' Brilliant Inventor." (Compl. ¶ 40(a), Ex. M) 54) The headline that refers to Dr. Ayyadurai as the "Guy Who Pretends He Invented Email." (Compl. ¶ 41(a), Ex. N) 55) "... [Dr. Ayyadurai is] a guy who's basically staked his entire life on the misleading to false claim that he `invented' email." (Compl. ¶ 41(b), Ex. N) 56) "Every couple of years [Dr. Ayyadurai] pops up again as he's able to fool some reporters into believing him." (Compl. ¶ 41(c), Ex. N) 57) "In 2012, [Dr. Ayyadurai] fooled the Washington Post and, astoundingly, the Smithsonian." (Compl. ¶ 41(d), Ex. N) 58) "Ayyadurai also totally misrepresents what copyright is, and insists that his copyright is just like a patent, because you couldn't patent software https://www.leagle.com/decision/infdco20170907d75 12/15