In December 2006, a band of Internet vigilantes (reportedly based in 4chan.org and 7chan.org) attacked Hal Turner’s ‘net audio broadcasts and Web Site.
The initial foray consisted of a coordinated series of prank calls to Hal Turner’s Internet talk show. Mr. Turner retaliated by posting the callers’ phone numbers at his Web Site.
The ePosse escalated the attack over a wider front. The pranksters posted the personal phone numbers of Hal Turner and his parents. Included in the message were allegations of domestic abuse and cruelty to animals, which Mr. Turner has denied. Supposedly Hal Turner’s wife, mother, and underage son received phone calls threatening assault and sexual assault.
The Battle of the Bandwidth
Hal Turner’s Web Site became the target of a Denial of Service attack. A Denial of Service attack is an automated process that sends a tsunami of ‘net traffic to a domain. This can cause the hosting server to grind to a halt, making a Web Site unavailable to visitors. According to Turner, the Denial of Service attack has cost him thousands of dollars in bandwidth charges. The attackers (possibly identified or associated with /b/tards and/or Anonymous) are quite proud of this and have openly gloated about it in message boards.
Hal Turner has stated that criminal charges were filed against John Does. He also posted that Skinheads in either Australia or New Zealand (Mr. Turner was not sure of a location more precise than “down under.”) located and beat one of the hackers. As proof, Hal Turner displayed on his Web Site a picture of a young man with a bloody face. Someone did a google image search using “bloody face” as the term. In this way, the identical photo was located immediately elsewhere on the Web in an unrelated context. Subsequently, the picture and the boast of assault disappeared from Hal Turner’s Web Page.
For a short time on the morning of December 28th 2006, Hal Turner’s Web Site forwarded to (loaded) the official FBI Web Site. I at first thought that Hal Turner’s Site was hacked. This does not seem to have been the case. A possibility is that the forward was intended to divert the Denial of Service attack to the FBI and so involve the Feds.
Click HERE for Online audio of what appears to be a call to the FBI.
Hal Turner appealed to other White Supremacists noting that they may be targeted next. Some of those claiming to be members of the ePosse have echoed this.
It’s not clear why visitors to 4chan.org or 7chan.org have decided to attack racism in general and Hal Turner in particular. 4chan.org and 7chan.org are best known for a focus on Japanese cartoons and comics.
In April 2006, Hal Turner was quoted as advocating the killing of undocumented aliens. He also was involved in an assault case against Jaime Vazquez, recipient of the Purple Heart, Frmr. Jersey City Councilman, and Frmr. Jersey City Deputy Mayor.
Hal Turner is best known for his advocacy of racism and of violence against immigrants and public officials. As a drumbeat to these rants, Turner also frequently reports (in the manner of Chicken Little) that the US economy is about to collapse.
Here is Hal Turner’s most recent “scoop” from 12/15/06:
CHINA TO DUMP ONE TRILLION IN U.S. RESERVES!
Tells visiting Bush administration officials they will not sit back and lose their shirts as U.S. Dollar collapses; they are getting out fast and large!
BEIJING, CHINA — Sources with a U.S. Delegation in Beijing have told The Hal Turner Show the Chinese government has informed visiting Bush Administration officials they intend to dump One TRILLION U.S. Dollars from China’s Currency Reserves and convert those funds into Euros, gold and silver!
. . .
7chan-ers distributed a poster to Hal Turner’s neighbors. The flyer announces Mr. Turner’s calling for the murder of minorities.
Click HERE to see the complete image.
The 7chan-ers displayed these images Online:
UNITED STATES DISTRICT COURT
District of New Jersey
Harold C. “Hal” Turner D/B/A : Hon. PETER G. SHERIDAN
Turner Radio Network D/B/A :
Hal Turner Radio Show :
Plaintiff,: Civil Action No.
: 07-306 (PGS)
:
V. :
:
4Chan.org : COMPLAINT
7chan.org :
Ebaumsworld.com :
NexisOnline.net
Abjects.com :
John Doe(s) 1-1000 :
Defendants:
Plaintiff, Harold C. “Hal” Turner by way of Complaint
against the internet web sites 4chan.org, 7chan.org,
ebaumsworld.com, nexisonline.com and abjects.com and John Doe(s)
1-1000 hereby says:
I. THE PARTIES
1. Plaintiff Harold C. “Hal” Turner is and at all relevant
times was a citizen of the State of New Jersey and the
United States of America, residing at 1906 Paterson Plank
Road, North Bergen, Hudson County, New Jersey within this
District, doing business as Turner Radio Network and The
Hal Turner Radio Show.
2. 2. n
internet web site whose owner information is presently
intentionally concealed and unavailable absent a
Subpoena, but whose business and activities relevant to
this Complaint took place substantially within this
District.
3.
Upon Information and belief, Defendant 7chan.org is an
internet web site whose owner information is presently
intentionally concealed and unavailable absent a
Subpoena, but whose business and activities relevant to
this Complaint took place substantially within this
District.
4.
Upon information and belief, Defendant Ebaumsworld.com
is an internet web site whose owner information shows an
address of eBaums World PO BOX 18091 Rochester, New York
14618 , but whose business and activities relevant to
this Complaint took place substantially within this
District
5.
Upon information and belief, Defendant Nexisonline.net
is an internet web site whose owner information indicates
it is a California corporation, Nexis Entertainment
located at 1675 Garnet Lane Concord, CA 94519 but whose
business and activities relevant to this Complaint took
place substantially in this District
6.
Upon information and belief, Defendant Abjects.com is
an internet web site whose owner information shows it is
a corporation Velocity Enterprises 1006 E. Market St,
York, PA 17320 whose business and activities relevant to
this Complaint took place substantially within this
District.
7. Upon information and belief, Defendants John Doe 1-1000
are presently unknown individuals acting in concert with
the named Defendants above, and whose activities relevant
to this Complaint took place substantially within this
District.
II. JURISDICTION AND VENUE
8. This Court has original jurisdiction over Plaintiff’s
claims pursuant to 28 U.S.C. 1338 (a) (original
jurisdiction in cases involving infringement of
Copyright), 28 U.S.C. 1331 (federal question) and 28
U.S.C. 1367(a) (supplemental jurisdiction)
9.
The matter in controversy exceeds the sum of $50,000
exclusive of interest and costs
10.
Venue is proper in this judicial District pursuant to
28 U.S.C. 1391(b)(2) because a substantial part of the
actions giving rise to Plaintiff’s claim have occurred in
this District.
III. FACTUAL BACKGROUND
A. The Business of the Plaintiff
11.
Plaintiff owns a Computer Server which is co-located
in a Data Center in Parsippany, NJ. Through this
computer server, Plaintiff engages in Interstate Commerce
by operating several internet web sites,
HalTurnerShow.com, TurnerRadioNetwork.com,
PrivateWebHosting.org. Through these sites, Plaintiff
provides web site hosting services for individuals and
groups needing such services and provides interstate
communication services for the broadcast of cyber-radio
shows by Plaintiff and other individuals and groups. One
such cyber-radio show is “The Hal Turner Show.” While it
is being broadcast live on the Internet “The Hal Turner
Radio Show” (hereafter referred to as “The Show”) is the
single, most-listened-to talk radio program in the entire
world on the America Online (AOL)/SHOUTcast internet
streaming audio system. While it airs, The Show has more
listeners on the internet than radio station WNYC AM 820,
in New York City; more listeners on the Internet than
radio station WBUR 90.9 FM in Boston, MA; and is growing
in popularity and listenership. The reasons The Show is
so popular has to do with unfettered free speech afforded
to callers and exercised by Plaintiff as Host. People
can call-in and use any language or terminology they
choose, to express their thoughts or feelings about
social, political, cultural, racial or religious issues,
without fear of being censored or cut off. The Show is
the literal embodiment of the First Amendment to the
Constitution for The United States of America. The Show
is a national treasure.
12.
Allowing and exercising such unfettered free speech
has caught the attention of a number of self-anointed
arbiters of political correctness who seem to think they
have a right to decide for others, what should and should
not be allowable public discourse. These self anointed,
politically correct tyrants have, for the six years that
the Show has aired, used every method possible to stifle,
censor, smear, vilify, besmirch, disrupt, interrupt and
shut down The Show. All their efforts have failed, until
now.
B: B: t
13.
At some point prior to December 20, 2006, a group of
self-anointed tyrants utilized an internet relay chat
(IRC) known as irc.abjects.com in a chat room called
#halturner, to concoct and implement a scheme to disrupt
The Show by placing dozens of crank calls while the show
aired. Since callers to The Show are not pre-screened
for content, they were able to get on the air and pull
their pranks, thus successfully disrupting the program
for the three hours it aired.
14.
After The Show ended, Plaintiff decided to research
the Caller ID for phone lines coming into The Show. The
research allowed plaintiff to identify five or six
specific telephone numbers that had repeatedly called The
Show. Two days later, on December 22, 2006, Plaintiff
chose to publicly release those phone numbers via the web
site HalTurnerShow.com as a warning to others not to
engage in that type of activity anymore.
15.
When Plaintiff released those phone numbers, the John
Doe Defendants named in this action at law – and hundreds
of their John Doe cohorts from the Defendant’s web sites
-became enraged that Plaintiff dared to fight back.
16.
Later, on or about December 23, 2007, one or more of
the John Does posted to the internet Plaintiff’s
personal, private, unlisted home telephone number and the
private unlisted home telephone number of Plaintiff’s 62
year old mother, Kathleen Diamond in Tunkhannock, PA.
17.
Within hours of the publishing of the private unlisted
home telephone numbers above, Plaintiff began to receive
dozens of harassing, abusive and threatening calls. The
first such call was received by Plaintiff’s wife, Phyllis
Turner. Plaintiff later came to find that the John Doe
Defendant caller recorded that call and publicly
published the audio on the Internet for others to hear in
direct violation of 47 U.S.C. 605(a). This had the
effect of encouraging hundreds of others to engage in the
same activity. These calls continued into all hours of
the day and night, continued throughout Christmas Eve and
Christmas Day and became so bothersome that Plaintiff had
to shut off his telephone and, ultimately, change his
telephone number.
18.
Almost simultaneously with the calls to Plaintiff’s
home, Plaintiff’s 62 year old mother who lives with her
70 year old husband in Tunkhannock, PA, started receiving
similar calls. So determined were these John Doe
Defendants to disrupt and harass, they continued to place
these harassing and threatening calls throughout
Christmas Eve and even on Christmas Day. These calls
became so bothersome to Plaintiff’s mother and her
husband – who is recovering from Leukemia – they too had
to change their telephone number.
19.
At or about 12:30 PM EST on December 23, 2006,
Plaintiff examined the real-time, graphical data-flow
chart for his computer server. That real-time graphical
data-flow chart showed the computer server had begun to
receive extraordinary amounts of internet data traffic.
Data flow out of the computer server suddenly increased
about 100 times the normal rate. This became very
worrisome very quickly because Plaintiff must pay for all
data that flows into and out of the computer server.
Plaintiff logged-in to the administrative area of the
computer server and called up a “Netstat” report to
identify what connections were being made to the computer
server. Plaintiff found thousands of simultaneous
connections from dozens of users, but these connections
were strange: They were emanating from the same Internet
Presence (IP) addresses. These connections to
Plaintiff’s computer server were systematically and
deliberately calling for, and receiving, tens of
thousands of exact duplicate copies of Plaintiff’s web
sites and / or exact duplicates of certain files on those
sites. These exact duplicates were all going to the
exact same computers on the exact same day(s).
20.
In common internet parlance, data flow into and out of
a computer server is known as “bandwidth” and the type of
activity described in #19 above, being done to
Plaintiff’s computer server, is commonly called
“Bandwidth rape.” It is a malicious form of data
leeching activity designed specifically to suck the data
out of a web site, so thoroughly and for so long, that
the site is financially killed by increased bandwidth
costs.
21.
Upon realizing what was happening, Plaintiff began to
analyze the logs of connections to the computer server
using the “Netstat” command which shows all connections.
Those logs helped to isolate and allow the blocking of
the offending IP addresses. Plaintiff contacted the data
center where the server is located and asked them to
begin blocking the worst offending IP addresses. They
did. The server bandwidth started returning to normal.
22.
Apparently, the attackers realized they were being
blocked out, so they publicly published messages on the
one or more of the Defendants web sites, asking others to
join in the attacks and providing detailed instructions
about how to perpetrate the attacks. The data flow once
again jumped to 100 times normal. Late in the day on
December 23, or early in the morning on December 24,
Plaintiff decided to temporarily shut off the web sites
hoping that the attackers would go away.
23.
Over the Christmas holiday, Plaintiff researched
Bandwidth rape and learned that it can be defended
against by installing a file which tells automated
software that Plaintiff’s sites will not accept their
use. Plaintiff installed on the computer server a file
called “robots.txt” which instructs automated software
that my computer server will not accept their
connections. Plaintiff thought the problem was solved.
It was not.
24.
On December 26, 2006 Plaintiff turned the web sites
back on and almost immediately attacks began anew, but in
a different, more destructive form: SYN-ACK data packet
floods.
25.
When one computer tries to communicate with another
computer over the Internet, the origin computer sends a
“SYNCHRONIZE (SYN)” data packet to the target computer it
is trying to reach. This data packet tells the target
computer to prepare to communicate with the origin
computer via certain internet addresses, IP’s. The
target computer then sets aside a small amount of its
resources to be able to handle whatever the origin
computer needs and sends and ACKNOWLEDGEMENT (ACK) data
packet to the origin computer saying it is ready to
communicate. In a SYN-ACK flood attack, the origin
computers deliberately send a SYN data packet but never
follow through with communication. This is a malicious
act because as the target computer sets aside resources
to prepare to communicate with tens of thousands of these
origin SYN requests, the resources of the target computer
get used up, making the computer unable to continue
handling other, legitimate SYN requests. This type of
activity is specifically designed to cause the target
computer to be unavailable to legitimate users, who, when
they try to connect, can get no reply from the targeted
computer because its resources have become overloaded.
26.
Since SYN-ACK data packets are absolutely essential
to the proper operation of computer communication via the
internet, there is absolutely no technological defense
that Plaintiff is aware of, which can prevent this type
of attack. As such this type of activity – designed to
make data unavailable – was specifically outlawed by the
Computer Fraud and Abuse Act 18 USC 1030.
27.
For the purposes of this Complaint, Plaintiff’s
computer server is a “protected computer” as defined in
18 USC 1030 because it is “used in interstate commerce”
for the purpose of “communication.” Hence, the provisions
of 18 USC 1030 apply to Plaintiff’s computer server.
28.
On December 28, 29 and 31, 2006, additional SYN-ACK
attacks were launched against Plaintiff’s computer,
flooding it with upwards of 100 times the normal inbound
data, which Plaintiff has to pay for, and making it
impossible for the computer server to handle legitimate
communication requests. On December 31, 2006, Plaintiff
had to shut off his web sites again to protect from being
Bankrupted by these attacks.
29.
On or about Tuesday, December 26, Plaintiff received
an e-mail from a local Papa Johns Pizza Store advising
they were filling my internet order for about $93 in
pizza and stating the pizzas would be delivered soon.
Plaintiff placed no such order. Plaintiff called the
store to cancel it and told them it was a case of WIRE
FRAUD.
30.
On or about Wednesday, December 27, Plaintiff once
again aired “The Hal Turner Show” which ended around
11:00 PM EST. At about 1:00 AM on Thursday, December 28,
our home doorbell rang waking up Plaintiff and his
family. It was a Pizza delivery from a local pizza
store, filling another Pizza order which Plaintiff did
not place. The pizza delivery man showed me his delivery
slip which showed Plaintiff’s name, address and telephone
number. Plaintiff placed no such order. Plaintiff told
the delivery person this was another case of WIRE FRAUD.
31.
On or about Friday, December 29, at about 1:00 in the
afternoon, Plaintiff’s home doorbell rang again with yet
another pizza delivery, this one telephoned into the
pizza shop by someone fraudulently claiming to be
Plaintiff, but which Plaintiff did not order. As before,
the pizza delivery man showed Plaintiff a delivery slip
with Plaintiff’s name, address and home telephone number.
Plaintiff placed no such order and told the delivery
person this was another case of WIRE FRAUD.
32.
On or about Saturday, December 30, 2006, two large
boxes were delivered to Plaintiff’s home by the United
States Postal Service. Inside were bulk amounts of
shipping boxes shipped to Plaintiff’s home by the
internet auction web site, EBAY.com. These boxes are
shipping supplies which are designed to allow EBAY
sellers to ship goods to EBAY buyers. Plaintiff placed
no such order for any such supplies. Plaintiff has told
EBAY this was a case of MAIL FRAUD and EBAY told
Plaintiff to ship the supplies back to them.
33.
Since these attacks commenced, Plaintiff has received
e-mails and electronic messages posted to his web site
visitor comments area trying to Extort a surrender. The
wording varied, but the message is the same:
“We will not stop until you shut down your web site
and your radio show.” This attempt to force Plaintiff
to do something he is unwilling to do – terminate a
lawful $60,000 per year and growing enterprise – is
Extortion.
34.
On January 3, 2007, during Plaintiff’s live radio show
which airs from 9:00 PM until 11:00 PM EST, the computer
server suffered the largest, most disruptive attack to
date. A sudden and dramatic increase of inbound traffic
hit the server at six-hundred-sixty megabits per seconds
(660 Mbps.) This attack was so enormous and so sustained
that it saturated routers in the data center, taking
Plaintiff’s web sites off line and also halting normal
computer data flow for hundreds of other customers whose
computers are also inside the data center. So damaging
was this attack that the data center had to “null route”
(shut off all access to) the computer server, rendering
Plaintiff unable to conduct a radio show or to do
business through that server for the next ten hours,
until the data center could clear the inbound data
backlog.
35.
On or about Friday, January 5, 2007, a Manager from
the United States Post Office at North Bergen, NJ came to
Plaintiff’s home to ask if he had ordered a truckload of
postal shipping supplies. Plaintiff told him no. The
Postal manager advised that the North Bergen Post office
had one or more Pallets of shipping supplies, allegedly
ordered by Plaintiff, but they were hesitant to deliver
it because it appeared to be a fraud. Plaintiff told the
Postal Manager it was, in fact additional mail fraud and
the manager told Plaintiff he would alert U.S. Postal
Inspectors for federal investigation.
36.
On or about Friday, January 5, 2007, the owners of
web site 7chan.org removed the front page of their site
and put in its place an apology to Plaintiff. The page
showed an image of a Five Dollar Bill, with an altered
photograph of Plaintiff in the middle of that bill, and
the caption above the bill read as follows” WE’RE SORRY
WE TOOK ALL UR MONIES, HERE” as if to give Plaintiff the
fake five dollar bill. This act appears to be an overt
acknowledgement that Defendant 7chan.org deliberately
attacked my web site and deliberately cost me money.
37.
On or about January 4, 2007 I received an email from
a person calling himself Joey Bernert, purporting to be
an administrator, a person in authority at the web site
ebaumsworld.com. That e-mail acknowledged that their
site supported the attacks launched against Plaintiff,
which indicates they were willing participants,
facilitators or accessories to the acts described herein.
38.
On January 3, another Denial of Service attack was
launched at Plaintiff’s server, taking The Show off the
internet.
39.
On January 9, 2007, Plaintiff was notified in writing
by Net Access Corporation, that due to the repeated
Denial of Service attacks against the server, they will
not continue service to Plaintiff. They further advised
that if future inbound attacks occurred, they would be
forced to immediately halt service to me so as to protect
their other customers. Their letter requires Plaintiff
remove the server from their data center on or before
February 15. While Plaintiff has made arrangements for a
new data center to provide service, the cost for such
service is sixty-one percent (61%) more expensive per
month at minimum. If these Denial of Service attacks
continue, the added costs and possibility of being thrown
out of the new data center are causing incalculable harm
to Plaintiff.
40.
On January 10 and 17, two additional Denial of
Service attacks occurred against Plaintiff’s server, both
organized and promoted on the Defendant(s) web sites.
The attack on the 17th, forced Net Access Corporation to
once again ‘null route” Plaintiff’s server to protect
their other data center customers.
41.
On January 18, 2007, a number of regular visitors to
Plaintiff’s web site telephoned saying they could not
access Plaintiff’s sites. Upon investigation, Plaintiff
determined that Net Access Corporation has, in fact, null
routed access to the server again to protect their other
customers and as a result, Plaintiff is effectively out
of business because of the Denial of Service attacks.
C. The Business of the Defendants
42.
4chan.org is an internet web site that allows users to
post messages and images of various types seemingly
without restraint. Criminal activity seems to be rampant
and well documented on this web site. The site contains
pornographic depictions of children and well publicized
terrorist bombing threats. The Court’s attention is
directed to an incident which occurred in October 2006.
Late that month, the United States Department of Homeland
Security issued a nationwide terrorist attack alert over
the alleged planned truck bombings of NFL Football
Stadiums. The threats to truck-bomb those stadiums was
posted on the web site 4chan.org upwards of forty (40)
separate times before authorities arrested the
perpetrator.
43.
7chan.org is an internet web site that allows users to
post messages and images of various types. Criminal
activity on this web site includes pornographic
depictions of children and photographs of pre-teen and
teenage girls in various states of undress. One area of
this site is specifically set up to foster criminal
attacks against other web sites. That area, called /i/
for INVASION allows users to anonymously conspire
together, in public, to arrange criminal attacks against
various web sites around the world similar to the attacks
outlined in this Complaint.
44.
Ebaumsworld.com is an internet web site offering
examples of prank phone calls and telephone harassment
against a variety of targets similar to those outlined in
this complaint. The site also offers a message forum in
which users can talk about various topics or plan and
coordinate illegal activities against a variety of web
sites similar to those outlined in this complaint.
45.
NexisOnline.net is an internet web site which offers
IRC chat and the ability to download “malware.” Malware
is malicious computer software which can be used to
attack internet users and web sites similar to the
attacks outlined in this complaint.
46.
Abjects.com is an internet web site offering free
Internet Relay Chat (IRC) through which its users can
talk about a variety of topics including planning illegal
attacks against computer servers as outlined in this
complaint.
47.
The business of John Doe(s) 1-1000 is not known at
this time.
COUNT ONE
COPYRIGHT INFRINGEMENT (17 U.S.C. 501 et. seq.)
48.
John Doe Defendants perpetrated infringement upon
Plaintiff’s Copyright by making copies of his radio shows
of December 20 and December 27, posting copies of those
shows on free file storage services and then advertising
a link on the named Defendants web sites encouraging
users to take copies of those shows. By making the
shows available free, the general public was able to
avoid paying Plaintiff for subscription access to such
shows, thus causing incalculable harm to plaintiff in
lost revenues from subscription sales. By allowing users
to post links to the infringed material, named Defendants
facilitated wide distribution of the infringed material.
49.
Further irreparable harm to Plaintiff is imminent as a
result of Defendants conduct and Plaintiff is without an
adequate remedy at law. Plaintiff is entitled to
injunctive relief, restraining named defendants, their
agents, employees, representatives and all persons acting
in concert with them from engaging in further Copyright
infringement.
50.
Plaintiff is further entitled to recover from
Defendants, monetary damages as a result of defendant’s
acts of Copyright Infringement in an amount to be
determined at trial.
51.
Plaintiff is also entitled to recover from Defendants,
the gains, profits and advantages they have obtained as a
result of their acts of copyright infringement in an
amount to be determined at trial.
COUNT TWO
COMPUTER FRAUD AND ABUSE 18 U.S.C. 1030)
52.
John Doe Defendants willfully engaged in activities
specifically designed to cause the data on Plaintiff’s
server to be made “unavailable.” The named Defendants
willfully facilitated, aided and abetted those activities
by allowing users of their web sites to conspire, plan,
organize, incite and teach others how to commit similar
acts via their web sites, and in the case of Defendant
7chan.org, by featuring a specific area of their web site
designed to aid, abet and further attacks against
internet web sites.
COUNT THREE
COMMON LAW FRAUD
53.
John Doe Defendants engaged in Common Law Fraud in
violation of the laws of the State of New Jersey by
intentionally using automated software to repeatedly
download content from my web sites for the sole purpose
of causing harm in the form of increased bandwidth costs.
These acts deprived Plaintiff of the inestimable right of
fair dealing and were done with malice for the sole
purpose of inflicting financial harm. Named Defendants
willfully facilitated, aided and abetted this Fraud by
allowing users of their web sites to conspire, plan and
organize these acts through publishing instructions on
the methods and tasks to be undertaken for the purpose of
harming Plaintiff.
COUNT FOUR
MAIL FRAUD
54.
John Doe Defendants committed numerous acts of mail
fraud by placing orders for goods, services and
merchandise to be shipped to Plaintiff via United States
Postal Service, with Plaintiff being billed for such
goods and merchandise, when Plaintiff made no such
requests for any goods, services or merchandise. Named
defendants facilitated, aided and abetted such Mail Fraud
by allowing users of their web sites to conspire, plan,
organize and incite such acts via their web sites.
COUNT FIVE
WIRE FRAUD
55. John Doe Defendants committed numerous acts of Wire
Fraud by placing orders via telephone for goods, services
and merchandise to be shipped to Plaintiff, with Plaintiff
being billed for such goods and merchandise, when Plaintiff
made no such requests for any goods, services or
merchandise. Named defendants facilitated, aided and
abetted such Wire Fraud by allowing users of their web
sites to conspire, plan, organize and incite such acts via
their web sites.
COUNT SIX
EXTORTION
55.
John Doe Defendants committed extortion by demanding
Plaintiff quit, shut down and/or cancel his radio show
and web sites under threat of continuing Computer Fraud
and Abuse, Mail Fraud, Wire Fraud. Attempting to force
someone to give up his radio show and web sites, an
estimated $60,000 per year enterprise which is something
of value, under such threats of continued computer
attacks and fraud is extortion. Named Defendants
facilitated, aided and abetted such Extortion by allowing
users of their web sites to publicly and repeatedly
conspire, plan, organize and implement the attacks in
furtherance of the effort to force Plaintiff to give up
his business.
COUNT SEVEN
RACKETEER INFLUENCED CORRUPT ORGANIZATION(S) (18 U.S.C.
1961-1968)
56.
Since two or more people from each of the named
Defendant web sites, acting in concert, engaged in the
“predicate felonies” of Mail Fraud, Wire Fraud and
Extortion, within a ten year period, and since the named
defendants 4chan.org, 7chan.org, Ebaumsworld.com,
Nexisonline.net and Abjects.com, willfully facilitated,
aided and abetted these acts, the named defendants are,
in fact, Racketeer Influenced, Corrupt Organizations.
Pursuant to 18 U.S.C. 1964(a) Plaintiff is entitled to
triple damages in an amount to be determined at trial.
Whereas Plaintiff has suffered substantial harm as
outlined above and has no other remedy at law, Plaintiff
hereby demands a Trial by jury to recover monetary
damages as a jury may see fit to award.
I declare under penalty of perjury and pursuant to 28
U.S.C. 1746 that the foregoing is true and correct.
Dated: North Bergen, New Jersey
January 19, 2007
BY:
_____________________________________
Harold C. “Hal” Turner
Plaintiff
4CHAN IS RUN BY SEVERAL JEWS AT THE TOP WHO ATTACK THE WHITE RACE.
THEY USE A GENTILE AS A FRONT FOR HACKING ATTACKS ORDERED BY THE JEW
THE JEW WHO ORDERS THE ATTACKS OWNS AND OPERATES THE “HUFFINGTON POST” AND HIS NAME IS KEN LERER. HAL OR NOT ANYBODY KNEW THAT IT WAS JEW-LERER WHO ORDERED THE 4 CHAN ATTACKS.
ARIANNA IS JUST A STUPID GENTILE WHO LOVES TO BE USED BY LERER, WHO FINDS STUPID GENTILES TO DO HIS JEW BIDDING.
DO YOUR HOMEWORK