X-Mailer: TBBS/PIMP v3.25/PRIMP 1.56p Subject: Rtc v netcom et al complaint X-Posting-Host

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Path: news.media.mit.edu!bloom-beacon.mit.edu!spool.mu.edu!howland.reston.ans.net!pipex!peernews.demon.co.uk!support.com!mail.processor Newsgroups: alt.religion.scientology From: mail.processor@support.com (mail.processor) Organization: L.A. Valley College Public BBS (818)985-7150 X-Mailer: TBBS/PIMP v3.25/PRIMP 1.56p Subject: Rtc v netcom et al complaint X-Posting-Host: [163.179.3.2] Date: Mon, 27 Feb 1995 12:39:18 +0000 Message-ID: <9502272039.0T0LX02@support.com> Sender: usenet@demon.co.uk Lines: 706 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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