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Subject: Rtc v netcom et al complaint
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Date: Mon, 27 Feb 1995 12:39:18 +0000
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Andrew H. Wilson
WILSON, RYAN & CAMPILONGO
115 Sansome Street
Fourth Floor
San Francisco, California 94104
(415) 391-3900
Thomas M. Small
Janet Kobrin
SMALL, LARKIN & KIDDE
10940 Wilshire Boulevard, Suite 1800
Los Angeles, California 90024-3945
(310 209-4400
Helena K. Kobrin
7629 Fulton Avenue
North Hollywood, CA 91605
(213) 960-1933
Attorneys for Plaintiffs
RELIGIOUS TECHNOLOGY CENTER and
BRIDGE PUBLICATIONS, INC.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
RELIGIONS TECHNOLOGY CENTER, a
California non-profit corporation;
and BRIDGE PUBLICATIONS, INC., a
California non-profit corporation, No. C-95-20091-RMW
(EAI)
Plaintiffs,
v. VERIFIED COMPLAINT FOR
INJUNCTIVE RELIEF AND
DAMAGES FOR:
(1) COPYRIGHT
INFRINGEMENT; AND
(2) TRADE SECRETS
MISAPPROPRIATION (Cal.
Civ. Code 3426.1)
NETCOM ON-LINE COMMUNICATION
SERVICES, INC., a Delaware
corporation; DENNIS ERLICH, an
individual; and TOM KLEMESRUD, an
individual, dba CLEARWOOD DATA
SERVICES,
Defendants.
Plaintiffs Religious Technology Center ("RTC") and Bridge
Publications, Inc. ("BPI") allege as follows:
INTRODUCTORY AVERMENTS
1. Defendant Dennis Erlich ("Erlich") has been engaged
in extensive and continuing infringement of copyrights and
misappropriation of trade secrets belonging to plaintiffs.
Erlich has been posting plaintiffs' proprietary materials onto
the Internet computer network ("the Internet") without
authorization from plaintiffs and continues to do so despite
several warnings from plaintiffs to cease and desist his
activities in violation of their rights. Erlich has stated
that "[n]o local government or court in the US has the power to tell
me otherwise." (Exhibit J.) Erlich's access to the Internet
is achieved through two service providers which act as Erlich's
gateway to pass his unlawful copies onto the Internet, where
they may potentially be recopied by millions of users who are able
to access the Internet. Defendant Netcom On-Line Communication
Services, Inc. ("Netcom") provides the computer facilities
through which Erlich obtains access to the Internet for his
unauthorized copies. Defendant Tom Klemesrud, dba Clearwood
Data Services ("Klemesrud") is a subscriber to Netcom's services and
through a bulletin board service which Klemesrud maintains,
acts as the link between Erlich and Netcom, thereby facilitating
Erlich's infringements and misappropriations to reach the
Internet and, in effect, recopying and publishing the
unauthorized copies posted by Erlich. Both Klemesrud and
Netcom have refused to cease and desist from providing this entree
onto the Internet for Erlich's infringements and thereby
contributing to these infringements, in the face of multiple warnings to
cease and desist.
JURISDICTION AND VENUE
2. Subject matter jurisdiction of this action exists
pursuant to 28 U.S.C. 1331 and 1338(a) and (b) in that this
is an action for copyright infringement under 17 U.S.C. 501
joined with a claim for unfair competition through trade secrets
misappropriation. In addition, this court has pendent
jurisdiction over the trade secrets misappropriation claim
alleged herein, as an unfair competition claim that arises out
of the same transactions and occurrences.
3. Venue is proper in this District pursuant to 28
U.S.C. 1391(b) in that events or omissions giving rise to the claims
occurred in this district and one of the defendants is deemed
to reside in this judicial district.
THE PARTIES
4. RTC is, and was at all times relevant herein, a
California non-profit religious corporation having its
principal office in the City of Los Angeles, County of Los Angeles, State
of California.
5. BPI is, and was at all times relevant therein, a
California non-profit religious corporation having its
principal office in the City of Los Angeles, County of Los Angeles, State
of California.
6. Plaintiffs are informed and believe, and on that
basis allege, that defendant Netcom is a Delaware corporation having
its principal place of business in the City of San Jose, County
of Santa Clara, State of California.
7. Plaintiffs are informed and believe, and on that
basis allege, that defendant Erlich is a resident of the City of
Glendale, County of Los Angeles, State of California.
8. Plaintiffs are informed and believe, and on that
basis allege, that defendant Klemesrud, is a resident of the City of
North Hollywood, County of Los Angeles, State of California.
GENERAL ALLEGATIONS
A. The Copyrighted Published and Unpublished Works of L. Ron
Hubbard
9. L. Ron Hubbard, a United States citizen who died in
1986, was a world-renowned philosopher and the prolific author
of numerous original works on applied religious philosophy and
spiritual healing technology, including training materials and
course manuals of the Scientology religion (hereinafter the
"Religion") of which Mr. Hubbard was the founder. Certain of
Mr. Hubbard's original written and recorded works have been
published and made generally available, while others have not.
Among the unpublished works is a body of special works, hereinafter
sometimes referred to as the "Advanced Technology materials,"
which contains confidential and proprietary information ("the
Advanced Technology") constituting trade secrets.
10. A list of the published literary works (hereinafter
the "Published Literary Works") that were created by Mr. Hubbard
and are relevant to this action is attached hereto as Exhibit "A,"
showing the titles of the works along with the numbers and
dates of the applicable United States copyright registrations.
Copies of the Published Literary Works are not attached in view of
their bulk, but will be available separately.
11. A list of the unpublished literary works (hereinafter
the "Unpublished Confidential Works") that were created by Mr.
Hubbard and are relevant to this action is attached as Exhibit
"B," showing the titles of the works along with the numbers and
dates of the applicable United States copyright registrations.
Copies of the Unpublished Confidential Works are not attached
in view of their bulk and confidentiality, but redacted copies
will be made available separately.
12. Initially, L. Ron Hubbard owned all rights in his
literary works, both published and unpublished, and all rights
the Advanced Technology, and granted licenses to others under h
rights, including the right to publish the Published Literary
Works and the right to use and license the use of the Advanced
Technology, with the obligation to protect the confidentiality
of the Advanced Technology and the Advanced Technology materials.
13. In 1982, L. Ron Hubbard assigned to plaintiff RTC his
entire right, title and interest (apart from copyrights) in and
to the Advanced Technology, including all rights to use and to
license the use of the Advanced Technology in the United
States. This assignment includes the obligation to protect the
confidentiality of the Advanced Technology and enforce the
obligation of confidentiality of all those who have received
disclosures of the Advanced Technology. A true and correct
copy of this assignment is annexed as Exhibit C to this Complaint.
14. Following Mr. Hubbard's death in 1986, ownership of
the copyrights in the Published Literary Works and the Unpublished
Confidential Works passed to his Estate, which granted to RTC,
on September 17, 1987, an exclusive license in the copyrights
pertaining to the Unpublished Confidential Works, with the
right and obligation to enforce all the copyrights in those works. A
true and correct copy of this License Agreement is annexed to
this complaint as Exhibit D.
15. In 1989, the assets of the Estate of L. Ron Hubbard,
including the copyrights pertaining to the Literary Works and
the Unpublished Confidential Works, were distributed to Author's
Family Trust-B ("the Trust"), and in 1993, the assets of the
Trust were distributed to Church of Spiritual Technology, a
California nonprofit religious corporation ("CST") which now is
the owner of the copyrights in the Published Literary Works and
the Unpublished Confidential Works. While the copyrights in
these works were held by the Trust, the Trustee entered into an
exclusive license agreement with BPI (hereinafter "the Literary
Agreement") which granted to BPI, inter alia, the exclusive
right to print, publish and sell the Published Literary Works, and to
make and publish compilations and derivative works of and from
the Published Literary Works, and to enforce all rights in the
Published Literary Works. A true and correct copy of the
Literary Agreement is attached hereto as Exhibit E.
16. In an agreement dated November 29, 1993, CST assumed
and affirmed the Trust's September 17, 1987, license to RTC
regarding all copyrights pertaining to the Unpublished Literary
Works with the right and obligation to enforce all the
copyrights in these works. A true and correct copy of that Assignment
and Assumption agreement is attached as Exhibit F. In an agreement
dated November 29, 1993, CST also assumed and affirmed the
Literary Agreement with BPI. A true and correct copy of that
Assignment and Assumption agreement is attached as Exhibit G.
17. The Published Literary Works and the Unpublished
Confidential Works were wholly original with Mr. Hubbard and
are copyrightable subject matter under the laws of the United
States. Mr. Hubbard and his successors and licensees have complied in
all respects with the copyright laws of the United States, secured
the exclusive rights in and to the copyrights in the works, and
received from the Register of Copyrights Certificates of
Registration of these copyrights. Attached hereto as Exhibit H
are true and correct copies of those Certificates of
Registration.
18. The Advanced Technology contained in the Unpublished
Confidential Works is of immense value to plaintiffs, who have
taken and continue to take substantial measures to protect the
confidentiality of the Advanced Technology. These measures
include, inter alia, the numbering of all copies of the
materials containing Advanced Technology; locking all such materials in
locked cabinets or safes when not in use; logging of the
materials upon each use; electronically connecting the
materials to the cabinets in which they are stored and to the tables on
which they are used and monitoring of those connections by
security computers and alarm systems; issuing photo-identity
cards to those who are authorized to access the materials;
separating the Advanced Technology course rooms from all other
parts of the organization; locking the doors of the Advanced
Technology course rooms at all times and magnetically locking
them while materials are moving between a file cabinet and the
table where they will be used; and posting security personnel
at all times. RTC derives independent economic value from the
Advanced Technology, which is not generally known to the public
or to others who can obtain economic value from its disclosure
or use.
B. Defendant's Violations of Plaintiff's Rights
19. Defendants have been infringing plaintiffs'
copyrights in the Published Literary Works (Exhibit A) and in the
Unpublished Confidential Works (Exhibit B) by reproducing each
of those works electronically and publishing the works on the
Internet, all without any authorization from the plaintiffs.
20. Erlich is a former Scientologist who became a
parishioner of the Religion in or about 1968 and served in
various capacities in Churches of Scientology in the United
States between 1968 and about 1982. While a parishioner and
staff member of the Religion, Erlich received Scientology
ministerial training to enable him to provide ministerial
counselling services, known as "auditing," and received access
to a wide variety of written materials pertaining to the Religion
and its services and training, including the Published Literary
Materials and the Unpublished Confidential Materials.
21. Erlich left the Religion in or about 1982, and
subsequently has been engaged in activities hostile to the
Religion. Among those activities are the unauthorized copying
of the Published Literary Works and the Unpublished Confidential
Works, and the unauthorized publication of those copies on the
Internet.
22. No one has access to the Unpublished Confidential
Works without permission or unless they were obtained through illicit
means. Erlich could only have obtained copies of these
materials through his own theft, or by having received stolen property
from another.
23. Plaintiffs are informed and believe, and on that
basis allege, that defendant Netcom is engaged in the business of
providing access to others to the Internet for fees, and for
that purpose maintains and operates one or more computer facilities
in this judicial district through which customers of Netcom are
electronically connected to the Internet and send and receive
electronic messages that pass through the Internet to others.
24. Plaintiffs are informed and believe, and on that
basis allege, that Defendant Klemesrud is engaged in the business of
operating a computer service for subscribers, for fees, and for
that purpose maintains and operates one or more computer
facilities that, among other things, provide access to the
Internet through Netcom's computer facility, to which Klemesrud
is a subscriber and for which service Klemesrud pays Netcom a
fee. Plaintiffs are informed and believe, and on that basis
allege, that Klemesrud's service is in the nature of a computer
Bulletin Board Service ("BBS").
25. Plaintiffs are informed and believe, and on that
basis allege, that, during the past approximately six months or less,
Erlich has, without authorization, reproduced the Unpublished
Confidential Works listed in Exhibit "B," in which the
exclusive rights under copyrights are owned by RTC, and has, without
authorization, electronically published copies of these works
in violation of the copyrights of RTC.
26. Plaintiffs are informed and believe, and on that
basis
allege, that, during the past approximately six months or less,
Erlich has, without authorization, reproduced the Published
Literary Works listed in Exhibit "A," in which the exclusive
rights under copyrights are owned by BPI, and has, without
authorization, electronically published copies of these works
in violation of the copyrights of BPI.
27. Plaintiffs are informed and believe, and on that
basis allege, that the infringing acts of Erlich alleged in
paragraphs 23 and 24 of this Complaint, and each such infringing act,
were performed through and with the assistance of the computer
facilities of Klemesrud and Netcom, and of each of them, and
caused those copies to be published, without authorization, on
the Internet through a newsgroup, or public discussion group,
called "alt.religion.scientology"; and further that Klemesrud
and Netcom, and each of them, thus have reproduced and published
plaintiffs' works listed in Exhibits A and B, and each such
work, without the authorization of plaintiffs. In this manner,
Klemesrud and Netcom have infringed, and contributorily
infringed, plaintiffs' copyrights.
28. Plaintiffs have objected repeatedly to the actions of
Erlich, Klemesrud and Netcom, as aforesaid, have informed each
of them that the actions constitute copyright infringement and
trade secret misappropriation, and have demanded that they cease and
desist from further infringement, misappropriation, and
contributory infringement. True and correct copies of selected
letters of plaintiffs' counsel to defendants are attached
hereto as Exhibit "I."
29. Erlich has refused to cease and desist from his
infringement, and has responded to plaintiffs' letters with
further unauthorized reproduction and publication in violation
of plaintiffs' copyrights. Erlich also has made defiant responses
to plaintiffs claiming the right to violate plaintiffs' rights.
He has said no local government or court in the U.S. has the
power to tell him otherwise. True and correct copies of
Erlich's responses are attached hereto as Exhibit "J".
30. Klemesrud and Netcom have refused to cease and desist
from receiving, transmitting and publishing Erlich's
unauthorized copies of plaintiffs' copyrighted works. True and correct
copies of Klemesrud's and Netcom's responses are attached hereto as
Exhibits "K" and "L," respectively.
31. All copying and publishing by Erlich of the works
listed in Exhibits A and B has been unauthorized and constitute
willful copyright infringement.
32. All copying and publication by Klemesrud and Netcom
of works transmitted through their facilities by Erlich after they
received notice of plaintiffs' rights and the continuing
violation of those rights by Erlich constitute willful
copyright infringement.
FIRST CLAIM FOR RELIEF
(Copyright Infringement of Published Literary Works,
17 U.S.C. 101 et seq.,
Against All Defendants by BPI)
33. BPI incorporates by reference the allegations
contained in paragraphs 2 through 31 above as though set forth fully
herein.
34. The Published Literary Works are protected under the
Copyright Act of 1909, 17 U.S.C. 1 et seq. (repealed), and
the Copyright Act of 1976, 17 U.S.C. 101 et seq., as amended.
35. The foregoing acts of defendants violate BPI's
exclusive rights to reproduce, publish and display the
Published Literary Works, listed in Exhibit A hereto, all in violation of
BPI's exclusive copyrights under 17 U.S.C. 106. Such acts
constitute copyright infringement under 17 U.S.C. 501 and
have contributed to infringement by others.
36. Unless restrained, defendants will continue the acts
complained of herein, to BPI's irreparable injury.
37. Defendants' unlawful acts set forth above constitute
willful copyright infringement under 17 U.S.C. 504.
38. As a direct and proximate result of the foregoing
acts of defendant, BPI has suffered damages in an amount which
cannot now be ascertained but that is capable of proof at trial.
39. In the alternative, BPI seeks statutory damages from
defendants under 17 U.S.C. 504(c)(1) and (2) for such
infringement of BPI's copyrights in the Published Literary
Works, in the amount of $100,000 for each such work.
SECOND CLAIM FOR RELIEF
(Copyright Infringement of Unpublished Confidential
Works
17 U.S.C. 101 et seq.
Against All Defendants by RTC)
40. RTC incorporates by reference the allegations
contained in paragraphs 2 through 31 above as though set forth fully
herein.
41. The unpublished Confidential Works are protected
under the Copyright Act of 1909, 17 U.S.C. 1 et seq. (repealed),
and the Copyright Act of 1976, 17 U.S.C. 101 et seq.
42. The foregoing acts of defendants violate RTC's
exclusive rights to reproduce, publish and display the
Unpublished Confidential Works, listed in Exhibit B hereto, all
in violation of RTC's exclusive copyrights under 17 U.S.C.
106. Such acts constitute copyright infringement under 17 U.S.C.
501 and have contributed to infringement by others.
43. Unless restrained, defendants will continue the acts
complained of herein, to RTC's irreparable injury. 44.
Defendants' unlawful acts set forth above constitute willful
copyright infringement under 17 U.S.C. 504.
45. As a direct and proximate result of the foregoing
acts of defendant, RTC has suffered damages in an amount which
cannot now be ascertained or computed but that is capable of proof at
trial.
46. In the alternative, RTC seeks statutory damages from
defendants under 17 U.S.C. 504(c)(1) and (2) for infringement
of RTC's copyrights in the Unpublished Confidential Works, in
the amount of $100,000 for such work.
THIRD CLAIM FOR RELIEF
(Misappropriation of Trade Secrets,
Against Erlich by RTC)
47. RTC incorporates by reference the allegations in
paragraphs 2 through 31 above as though set forth fully herein.
48. Erlich was employed between 1975 and 1982 as a member
of the staff of the Church of Scientology Flag Service
organization ("Flag"). Prior to working for Flag, Erlich was a
parishioner of another advanced Church of Scientology known as
Church of Scientology Advanced organization of Los Angeles
("AOLA"). Flag is licensed by RTC for the use of the Advanced
Technology in accordance with Church doctrine, with disclosure
strictly limited to its staff and parishioners who are
qualified, according to religious tenets, to receive these materials,
and who undertake the obligation to maintain their confidentiality.
All staff members of Flag, including Erlich, were and are
required to agree to be bound by all administrative and
ecclesiastical policies of the Church of Scientology, which
require that all Advanced Technology materials be kept
confidential at all times and that each person who receives a
disclosure of any of the Advanced Technology materials agree
not to disclose the Advanced Technology to anyone not authorized to
receive it.
49. At various times from 1968 through 1982, Erlich
received Scientology ministerial training to enable him to
provide ministerial counselling services, known within the
Churches of Scientology as "auditing," to the Church's
parishioners. During this training and as a staff member of
Flag, Erlich studied, acknowledged, and agreed to be bound by
the policy requiring extreme security precautions to be taken with
regard to the Advanced Technology materials and the requirement
of agreeing to maintain the confidentiality and the security of
the Advanced Technology materials before being permitted access
to the Advanced Technology.
50. As a staff member of Flag, Erlich agreed that he
would protect and maintain confidential all information contained in
the Advanced Technology that was disclosed to him. As a result
of his acceptance of those confidentiality obligations,
confidential information contained in the Advanced Technology
materials and constituting trade secrets, including the
Unpublished Confidential Works, was disclosed to Erlich. Such
information was of a highly confidential and proprietary nature
and Erlich received the information in trust and confidence.
51. RTC and BPI are members of the group of entities for
whose benefit the contracts, policies, rules and doctrines of
Flag are created and maintained.
52. Erlich left the Religion in or about 1982 and has
subsequently been engaged in various activities hostile to the
Religion. Upon leaving the Religion, Erlich lost any rights
and privileges he had acquired as a Scientology minister and any
right to hold himself out as such.
53. By his acts, as aforesaid, Erlich has disclosed,
without authorization, confidential, trade secrets information
constituting portions of the Advanced Technology that are
contained in the Unpublished Confidential Works listed in
Exhibit B hereto, in violation of his long-standing obligations to
maintain and protect the secrecy of that information.
54. Erlich's acts, as aforesaid, were done with full
knowledge that the Unpublished Confidential Works contained
confidential trade secrets information, and with intent to
publicize that confidential information.
55. By his acts, as aforesaid, Erlich has misappropriated
RTC's trade secrets in violation of RTC's rights under
California law, California Civil Code 3426.1 et seq.
56. Unless restrained by this Court, Erlich will continue
the acts complained of herein, and RTC will incur (and is
currently incurring) irreparable injury, for which there is no
adequate remedy at law.
57. As a direct and proximate result of the foregoing
acts of Erlich, RTC has suffered damages in an amount which cannot
now be ascertained but that is capable of proof at trial.
58. Plaintiff RTC is informed and believes, and on that
basis alleges, that, in committing the foregoing acts, Erlich
acted with fraud, oppression and malice, thereby entitling
plaintiff to punitive damages in an amount not less that
$500,000.
WHEREFORE, plaintiffs pray for the entry of judgment
against defendants as follows:
1. ON THE FIRST CLAIM FOR RELIEF:
(a) For an award of damages to BPI against
defendants, and each of them according to proof at trial, and for all
gains, profits and advantages derived by defendants by their
infringement of the copyrights of BPI in the Published Literary
Works;
(b) For an award of statutory damages to BPI under
17 U.S.C. 504(c)(1) of $20,000.00 for each of the Published
Literary Works infringed by defendants Klemesrud and Netcom
and, in addition, an award of statutory damages to BPI of
$100,000.00 for each of the Published Literary Works infringed by Erlich,
pursuant to 17 U.S.C. 504(c)(2);
(c) For an order that defendants, and each of them,
and all of their officers, agents, employees, partners and
attorneys, and all persons in active concert or participation
with them having notice of this order, be enjoined, during the
pendency of this action, and permanently thereafter, from
making or publishing, or causing to be made or published, any
unauthorized reproductions of the Published Literary Works or
of the Unpublished Confidential Works, including, without
limitation, transmitting or loading of any of them into, or
downloading any copies of them from, any computer, database,
information service, electronic bulletin board service or
network; and that defendants, and each of them, be required to
remove from the Internet, Netcom's computer facilities,
Klemesrud's computer facilities, and any other computer
facility, database, information service, bulletin board service, or
network, or other medium, all copies of the Published Literary
Works and the Unpublished Confidential Works which defendants,
or any of them, have loaded or caused to be loaded; and
(d) For an award of BPI's attorneys' fees and costs
pursuant to 17 U.S.C. 505.
2. ON THE SECOND CLAIM FOR RELIEF:
(a) For an award of damages to RTC against
defendants, and each of them according to proof at trial, and for all
gains, profits and advantages derived by defendants by their
infringement of the copyrights of RTC in the Unpublished
Confidential Works;
(b) For an award of statutory damages to RTC under
17 U.S.C. 504(c)(1) of $20,000.00 for infringement of the
copyrights in the Unpublished Confidential Works by defendants
Klemesrud and Netcom and, in addition, an award of statutory
damages to RTC of $100,000.00 for each of the Unpublished
Confidential Works infringed by Erlich, pursuant to 17 U.S.C.
504(c)(2);
(c) For an order that defendants, and each of them,
and all of their officers, agents, employees, partners and
attorneys, and all persons in active concert or participation
with them having notice of this order, be enjoined, during the
pendency of this action and permanently thereafter, from making
or publishing, or causing to be made or published, any
unauthorized reproductions of the Unpublished Confidential
Works, including, without limitation, the transmitting or loading of
any of them onto, or downloading any copies of them from, any
computer, database, information service, electronic bulletin
board service or network, and that defendants, and each of
them, be required to remove from the Netcom's computer facilities,
and Klemesrud's computer facilities, and any other computer
facility database, information service, bulletin board service, or
network, or other medium, all copies of the Unpublished
Confidential Works which defendants, or any of them loaded, or
caused to be loaded; and
(d) For an award of RTC's attorneys' fees and costs
pursuant to 17 U.S.C. 505.
3. ON THE THIRD CLAIM FOR RELIEF:
(a) For an order that Erlich, and all his agents,
employees, partners and attorneys, and all persons in active
concert or participation with them having notice of this Order,
be enjoined, during the pendency of this action and permanently
thereafter, from further unauthorized disclosure of any of the
Unpublished Confidential Works or any of the Advanced
Technology, and specifically from transmitting or otherwise loading of any
of the Advanced Technology materials onto the Netcom's computer
facilities, or Klemesrud's Computer facilities, or any
computer, database information service, electronic bulletin board service
or network, or other medium;
(b) For an order directing Erlich, and his agents,
employees, partners and attorneys, and all persons in active
concert or participation with them having notice of this order,
to return immediately to counsel of record herein for plaintiff
Religious Technology Center all documents in their possession,
custody or control that contain any of the Advanced Technology;
(c) For an order enjoining Erlich and his agents,
employees, partners and attorneys, and all persons in active
concert of participation with them having notice of this Order,
from filing with the Court, except under seal, and from
otherwise disclosing, any documents that contain any of the Advanced
Technology;
(d) For compensatory damages according to proof at
trial; and
(e) For punitive damages in an amount to be
determined at trial.
4. For such other and further relief as this Court deems
just and proper.
DATED: February /8/, 1995 WILSON, RYAN & CAMPILONGO
By: /s/
Andrew H. Wilson
Thomas M. Small
Janet A. Kobrin
SMALL, LARKIN & KIDDE
Helena K. Kobrin
Attorneys for Plaintiffs
RELIGIOUS TECHNOLOGY CENTER and
BRIDGE PUBLICATIONS, INC.
VERIFICATION
I, Warren McShane, am the President of Religious
Technology
Center, plaintiff in this action. I have read the VERIFIED
COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES FOR: (1) COPYRIGHT
INFRINGEMENT; AND (2) TRADE SECRETS MISAPPROPRIATION (CAL. CIV.
3426.1) and know the contents thereof.
The same is true of my own knowledge, except as to matters
which are stated on information and belief, or are based on the
personal knowledge of a co-plaintiff, and as to those matters,
I believe them to be true.
I declare under penalty of perjury that the foregoing is
true and correct. Executed this 7th day of February 1995, at
Los Angeles, California.
/s/
Warren McShane
VERIFICATION
I, John Goodwin, am the President of Bridge Publications,
Inc., plaintiff in this action. I have read the VERIFIED
COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES FOR: (1) COPYRIGHT
INFRINGEMENT; AND (2) TRADE SECRETS MISAPPROPRIATION (CAL. CIV.
3426.1) and know the contents thereof.
The same is true of my own knowledge, except as to matters
which are stated on information and belief, or are based on the
personal knowledge of a co-plaintiff, and as to those matters,
I believe them to be true.
I declare under penalty of perjury that the foregoing is
true and correct. Executed this 7th day of February 1995, at
Los Angeles, California.
/s/
John Goodwin
-------------------
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