Case 1:18-cv-01011-RMC Document 42 Filed 08/09/19 Page 3 of 19 After Mr. Anglin’s article, Ms. Dumpson’s Facebook accounts and the AU, AU Student Government, and AU Student Government President Twitter accounts were targeted with messages. Id. ¶ 97. Mr. Ade participated in the troll storm by posting on Twitter comments including: (1) “I beez prezdent n sheeeeit,” (2) “Turdler takes a Dump son,” (3) “OOOOOOK EEEEEK CHIMPOUT!,” (4) “You beez 100% sheboon!,” (5) “Sheeeeit I dindu nuffins she was axing fo it n sheeeit!,” (6) “Racoons Rule, coons drool,” (7) “Waah, waah, Dats Rayceez!,” and (8) “Chimput!” Id. ¶ 100. In response to the AU Student Government’s post about a campus community meeting regarding the incident, Mr. Ade responded, “[s]o in black people time, this will start whenever.” Id. After receiving the messages3 from Mr. Ade and others, Ms. Dumpson began fearing for her life and suffering both physically and mentally. Id. ¶¶ 120-28. Ms. Dumpson felt constantly on edge when walking alone and became terrified of leaving her home at night. Id. ¶¶ 125-26. She started to carry an alarm on her keyring at all times and pepper spray for selfdefense. Id. ¶ 125. Because she no longer felt comfortable to walk, bike, or take public transportation to commute to school and travel around town, she began to take Ubers more frequently. Id. ¶ 126. Ms. Dumpson’s academics and preparation for law school also suffered as a result of the online harassment. She no longer felt safe studying late on AU’s campus at night, missed exams, and dropped her minor in sociology. Id. ¶ 128. Ms. Dumpson also continues to feel scared of being harassed and stalked online which has interfered with her online presence and self-expression. Id. ¶ 127. From July 2017 to the present, Ms. Dumpson has been receiving regular psychiatric counseling. Id. ¶ 123. She was diagnosed with Post Traumatic Stress Disorder (PTSD), an eating disorder, depression, and anxiety; and she is now being treated for 3 Ms. Dumpson provides more than thirty examples of messages. See Am. Compl. ¶¶ 99-118. 3