Connelly Filed FAC

Case 8:15-cv-01255-CJC-JCG Document 14 Filed 03/07/16 Page 1 of 27 Page ID #:482
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Bennet Kelley (SBN 177001)

INTERNET LAW CENTER
100 Wilshire Blvd., Suite 940
Santa Monica, CA 90401
Telephone: (310) 452-0401
Facsimile: (702) 924-8740
bkelley@internetlawcenter.net
Attorney for Plaintiffs
TAMMY CONNELLY and
A SCOTT CONNELLY, MD
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UNITED STATE DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
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)
)
)
)
)
)
)
RICHARD ALLEN d/b/a VIRTUAL
)
ACCOUNTING SERVICE, LLC;
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BETAFORCE NETWORKS, LLC;
)
BLACKSEXFINDER CORP.; CHANEL
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FAULKNER d/b/a BLACKSEXFINDER; )
HARGRAY COMMUNICATIONS GROUP,)
INC.; M. BROWN BOOKS PUBLISHING )
)
GROUP, INC; MICHAEL, LAUDICK &
)
ASSOCIATES, LLC; DAVID MORGAN; )
PASSING LEADS, LLC; RIDE BEST, LLC; )
CURATORS OF THE UNIVERSITY OF
)
MISSOURI; and ERROL WILSON.
)
)
)
Defendants.
)
TAMMY CONNELLY, and A. SCOTT
CONNELLY, M.D.,
Plaintiffs
vs.
Case No.: 8:2015cv01255

Hon. Cormac J. Carney
PLAINTIFFS FIRST AMENDED
COMPLAINT FOR DAMAGES AND
INJUNCTIVE RELIEF FOR (1)
VIOLATIONS OF THE COMPUTER
FRAUD AND ABUSE ACT; (2)
VIOLATIONS OF THE RACKETEERING
AND CORRUPT ORGANATIONS ACT; (3)
VIOLATIONS OF THE CALIFORNIA
ANTI-SPAM ACT; (4) VIOLATIONS OF
CALIFORNIAS COMPREHENSIVE
COMPUTER DATA ACCESS AND FRAUD
ACT; (5) E-PERSONATION; (6) FOR
UNFAIR COMPETITION; and (7)
NEGLIGENCE
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CONNELLY v DOE FAC
Case No.: 8:2015cv01255
PLAINTIFFS TAMMY CONNELLY and A. SCOTT CONNELLY, M.D., hereby
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complain against Defendants RICHARD ALLEN d/b/a VIRTUAL ACCOUNTING SERVICE,
LLC; BETAFORCE NETWORKS, LLC; BLACKSEXFINDER CORP.; CHANEL FAULKNER
d/b/a BLACKSEXFINDER; HARGRAY COMMUNICATIONS GROUP, INC.; M. BROWN
BOOKS PUBLISHING GROUP, INC; MICHAEL, LAUDICK & ASSOCIATES, LLC; DAVID
MORGAN; PASSING LEADS, LLC; RIDE BEST, LLC; CURATORS OF THE UNIVERSITY
OF MISSOURI; and ERROL WILSON as follows:
PARTIES
1.
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Plaintiffs Mrs. TAMMY CONNELLY (MRS. CONNELLY) and A. SCOTT
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CONNELLY, M.D. (CONNELLY) are a married couple that live, and at all times relevant
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hereto lived, in Orange County, California.
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2.
On information and belief, Defendant Richard Allen d/b/a Virtual Accounting
Service, LLC (ALLEN) is an individual that at all times relevant hereto resided in Sherman
Oaks, California.
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3.
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On information and belief, Defendant Betaforce Networks, LLC (BETAFORCE)
is a Florida limited liability company with its principal place of business in Pembrokes Pines,
Florida.
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4.
Defendant Blacksexfinder Corp. (BSF) is a Florida corporation with its principal
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place of business in Jacksonville, Florida. On information and belief, BSF, which was an adult
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African-American dating website, was administratively dissolved on or about September 14,
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2007.
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5.
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On information and belief, Defendant Chanel Faulkner d/b/a Blacksexfinder
resides in Jacksonville, Florida (FAULKNER). FAULKNER was the Chairwoman of BSF.
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CONNELLY v. DOE FAC
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6.
On information and belief, Defendant M. Brown Books Publishing Group, Inc.
(BROWN BOOKS) is a Texas corporation having its principal place of business in Dallas,
Texas. On information and belief, BROWN BOOKS is a publishing company.
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On information and belief, Defendant Hargray Communications Group, Inc.
(HARGRAY) is a South Carolina corporation with its principal place of business in Hilton
Head, South Carolina. On information and belief, HARGRAY provides communications and
entertainment services to residential, business, large enterprise, and resort customers in South
Carolina and Georgia.
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On information and belief, Defendant Michael, Laudick & Associates, LLC is an
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Indiana LLC with its principal place of business in Indianapolis, Indiana. Defendant does
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business as Laudick, Brown & Associates (LBA).
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9.
On information and belief, Defendant The Curators of the University of Missouri
(MIZZOU) is a body politic in which the state university is incorporated, which is governed by
a board of nine curators who are appointed by the Governor with the advice and consent of the
senate, with its principal place of business in Columbia, Missouri.
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10.
On information and belief, Defendant David Morgan (MORGAN) is an
individual that, at all times relevant hereto, resided in Claremore, Oklahoma doing business as
Davismor, Inc.
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On information and belief, Defendant Passing Leads, LLC (PASSING LEADS)
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is a Wisconsin limited liability company with its principal place of business in Green Bay,
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Wisconsin.
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On information and belief, Defendant Ride Best, LLC (RIDE BEST) is a
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Delaware corporation having its principal place of business in San Francisco, California. On
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information and belief, RIDE BEST d/b/a bestklothing.com and bestkiteboarding.com, sells kite
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boarding equipment and accessories.

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CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
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On information and belief, Defendant Erroll Wilson (WILSON) is an individual
that, at all times relevant hereto, resided in Port St. Lucie, Florida.
JURISDICTION AND VENUE
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This Court has original subject matter jurisdiction over the claims in this action
6 pursuant to 28 U.S.C. 1331 under the provisions of the Racketeer Influenced and Corrupt
7 Organizations Act, 18 U.S.C. 1961 et seq. and the Computer Fraud and Abuse Act. This Court
8 has jurisdiction over the claims in this action that arise under the law of the State of California
9 pursuant to 28 U.S.C. 1367(a), because the state law claims are so related to the federal claims
10 that they form part of the same case or controversy and derive from a common nucleus of operative
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Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b) because the
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FACTUAL BACKGROUND
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A.
Overview
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This case is about reputation racketeering and the use of the internet to retaliate
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against individuals who step forward to bring online racketeers to justice by deploying defamatory
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websites, spam and malware attacks. This is a recent phenomenon which was given much
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attention in the recent prosecution and conviction of revenge porn operator Kevin Bollaert who
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simultaneously disseminated compromising photos of women through one website while
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soliciting victims to pay for the removal of such content through a bogus reputation management
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site.
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Feb. 21, 2015).
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See People v. Kevin Christopher Bollaert, Case No. CD252338 (Cal Super. Ct. (SD Cty)
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Reputation racketeering can also involve using mechanized defamation tools to
punish anyone who steps forward. For example, in Commonwealth v Stephen Fustolo, Case No.
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CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
1553CR001562 (Mass. Dist. Ct. (Middlesex Cty) July 14, 2015), the Massachusetts Attorney
General filed a complaint against a party who posted defamatory content on hundreds of blogs and
optimized the content for maximum impact in retaliation against a lender preceding on its claim
in bankruptcy. In doing so, one of Fustolos service providers explained that it is easier to ruin
someones reputation than clean it up.
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Both elements are present here and this action will depict a very real and growing
problem which poses a threat to our system of justice. As an Iowa prosecutor recently noted that
No greater threat to our criminal justice system exists than allowing convicted,
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incarcerated murderers (criminals), and their friends and family, to destroy the
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livelihoods and personal reputations of the people brave enough to testify against
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them in open court.

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In Re Application for A Search Warrant for The Residence At 4221 155th Street,
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Urbandale, Iowa 50323 (Iowa Dist. Court (Sac Cty) July 9, 2014) (SAC COUNTY
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WARRANT) < https://www.scribd.com/doc/233387848/Application-for-Search-
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Warrant>.
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B.
Progenex and Adam Stuart Zuckerman
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In 2007, Adam Stuart Zuckerman (ZUCKERMAN) was the lead defendant in
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scheme the Federal Bureau of Investigation named Operation Lease Fleece" which caused more
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than $20 million in losses to several lending institutions that believed they were financing
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equipment leases. As explained by the Department of Justice in announcing the indictments:
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[Defendants] marketed cash loans to small businesses experiencing credit

problems. Once small businesses agreed to apply for loans, some of the
defendants instead submitted equipment-lease applications to lenders. The
equipment-lease applications, which were inflated so that the defendants could
obtain lucrative commissions for themselves, were submitted along with false
invoices that purported to document the sale of computer equipment to the small
businesses . . . . After the lending institutions approved financing for the
equipment leases, the proceeds were not used to purchase equipment as promised
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CONNELLY v. DOE FAC
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to the lenders. Instead, the money was used to make improper cash loans to the
small businesses and to pay lucrative commissions to employees at Capitalwerks,
Brickbanc and the other companies. Hundreds of bogus equipment-lease
packages with fake invoices were presented to financial institutions.
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Twenty-Three Charged In Leasing Fraud Scheme That Caused More Than $20 Million In Losses
To Lenders, Department of Justice Release No. 07-141 (Nov. 7, 2007)
<http://docslide.us/documents/07-official-lease-fleece-press-release.html>.
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ZUCKERMAN pled guilty to the charges in 2007, but remained on supervised
release until 2012 when he was sentenced to thirty-seven (37) months in prison at the Federal
Correctional Institution at Terminal Island, San Pedro California. Under the terms of such
supervised release, ZUCKERMAN was to obey the law and not have any contact with the other
defendants.
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In 2009, CONNELLY and Murray Goulburn Nutritionals (Australia) sought to
raise capital to bring the Progenex product to market. CONNELLY was referred to an investment
firm by the name of Mercury Ventures LLC and its wholly-owned subsidiary VenturePharma
LLC. ZUCKERMAN controlled both entities as Managing Director, albeit under the assumed
named of Adam Stuart, working with Operation Lease Fleece co-defendants Kirk McMahan and
Paul Arnold (both formerly of Brickbanc Capital) in violation of the terms of his supervised
release. ZUCKERMAN falsely represented that he had access to millions in investment capital
and could easily raise the seed capital needed for Progenex. As a result, in November 2009
CONNELLY, Murray Goulburn Nutritionals (Australia) and VenturePharma LLC agreed to set up
a new company to further develop the Progenex products that was to be financed by $4.0 million
in capital raised by VenturePharma and another $1 million from CONNELLY (which was to be
used solely for medical research).
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C.
The Cool Technique
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Instead of using the money invested by CONNELLY for product development,
ZUCKERMAN seized control over the Progenex company and business assets from its inception
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CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
in November 2009 and in February 2011 diverted Progenex funds to acquire rights to a new sort
of malicious code dubbed THE COOL TECHNIQUE.
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THE COOL TECHNIQUE was a SQL Injection Code developed by Matthew
Grant Cooke (COOKE), which would enable the owner to turn off and deindex or restore pages
on third-party websites to public view. See Online reputation manager hacked websites to 'inject'
illegal code, FoxNews.com (January 20, 2012) (Attached hereto as Exhibit 1)
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Webopedia defines a Structured Query Language (SQL) Injection as[a] form of
attack on a database-driven Web site in which the attacker executes unauthorized SQL commands
by taking advantage of insecure code on a system connected to the Internet, bypassing the
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firewall. According to the Open Web Application Security Project, [a] successful SQL injection
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exploit can read sensitive data from the database, modify database data (Insert/Update/Delete),
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execute administration operations on the database (such as shutdown the DBMS), recover the
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content of a given file present on the DBMS file system and in some cases issue commands to the
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operating system.
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On or about February 24, 2011, ZUCKERMAN, using an assumed name of Alex
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Borgia, entered into an exclusive license for use of THE COOL TECHNIQUE using Progenex
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funds. See Email Exchange Attached as Exhibit 2. He quickly began marketing it and made as
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much of $50,000 in just one week using it.
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C.
Targeting Connelly
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As CONNELLY began to learn the true state of affairs with respect to
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ZUCKERMAN and Progenex, ZUCKERMAN acted preemptively to force CONNELLY into
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submission by tying him up in frivolous and vexatious litigation through a state court action for -
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of all things fraud (VenturePharma v. Connelly, OCSC Case No. 30-2010-03716-CU-BC-CXC).
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CONNNELY refused to relent to Zuckermans actions and instead filed a cross-claim alleging
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fraud on the part of ZUCKERMAN and his associates. ZUCKERMAN, however, ultimately
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CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
dismissed the action rather than comply with a court order to produce Progenexs bank records;
while CONNELLY obtained a settlement on his cross-claim.
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ZUCKERMAN next escalated the battle through a witness intimidation cyber-
smear campaign against CONNELLY in which he published websites using CONNELLYs name
and likeness (including ascottconnelly.com, scottconnellyscam.com and various Blogspot,
WordPress and Tumblr sites) as well as others bearing the names of his associates to make
scandalous accusations against him involving fraud and sexual deviancy. A former Zuckerman
employee disclosed under oath that these tactics were designed to prevent public disclosure of
Zuckermans ongoing criminal activity while on supervised release and to coerce a settlement. To
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obtain the maximum impact, Zuckerman used Progenex funds to employ a team of people to
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optimize the smear sites for search engines so that it would rank among the first entries on search
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engines such as Google, Yahoo, Bing, Ask and AOL.
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In an attempt to prevent his fraudulent actions from becoming known to federal

authorities, [ZUCKERMAN] launched a preemptive, vexatious civil action
against [CONNELLY] to deflect his personal culpability in the creation of the
investment fraud. When his expected result of a quick settlement and exhaustive
non-disclosure agreement did not materialize, ZUCKERMAN instigated a
systematic online defamation campaign against [CONNELLY] in the hopes that
the publication of these libelous and untruthful allegations would coerce
[CONNELLYs] acquiescence to [ZUCKERMAN's] desired cover up.
[ZUCKERMAN] and his felonious cohorts hired Darren Mitchell Meade
[MEADE] as Progenex's CEO to front their group's efforts to harass and
intimidate [CONNELLY]. [MEADE] would later admit in a two-day deposition
that he was hired . . . solely for the purpose of harassing and intimidating
[CONNELLY] into settling his civil case with [ZUCKERMAN] and
[ZUCKERMANs] criminal organization. [ZUCKERMAN] and his criminal
organization paid [MEADE] a salary and agreed to pay him a $200,000.00 bonus
if he was able to coerce and intimidate CONNELLY in settling his civil case
against [ZUCKERMAN] and his criminal organization.
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This campaign was detailed in Sac County Warrant as follows:
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(SAC COUNTY WARRANT at 16.)
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CONNELLY v. DOE FAC
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23.
CONNELLY refused to yield to ZUCERKMANs tactics and began bringing
ZUCKERMANS behavior to the attention of law enforcement and regulatory agencies at the
Federal, state, and local levels in multiple jurisdictions.
D.
Jail and Malware Attacks
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Prior to ZUCKERMANs entry into custody at Terminal Island in 2012,
CONNELLY estimates he received less than 6 unsolicited commercial emails (UCE) per week
at his BodyRx email address. Shortly after ZUCKERMAN was in custody, albeit with Internet
privileges, CONNELLYs level of spam emails began to increase exponentially to the point where
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on August 20, 2013 CONNELLY received 230 UCEs during a single 24 hour period and
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thereafter on average was receiving 350 UCEs per week during the period from September 2013
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through May of 2014.
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For example, 39 of the 230 UCEs delivered on August 20, 2013 were exact copies
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of one another with each, upon examination, having links to malicious websites. In addition, five
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of the identical UCEs were routed through servers controlled by the United States government and
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foreign entities.
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Table 1
Email
From: skozak@headstrong.ie
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Sender Lookup: 123.27.94.35
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Subject: Email SPAM for

malekal.com
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Date: Tuesday, 20/08/2013

12:17 AM
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From: vera.hinson@cjharter.net
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malekal.com
Sent From
Routed Through
56.215.102.223
Raleigh, NC, United States
Provider: United States Postal
Service
123.27.94.35
Hanoi, Vietnam
RDNS: localhost
Provider: VietNam Post and
Telecom Corporation
132.62.24.71
Montgomery, AL, United
States
Provider: 754th Electronic
Systems Group
14.97.196.199
Mumbai, India
RDNS: static-199.196.97.14tataidc.co.in
Provider: TATA
TELESERVICES LTD - TATA
INDICOM - CDMA DIVISI
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CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
Date: Tuesday, 20/08/2013 3:33 501 E. Moore Drive, MAFBAM

Gunter Annex, AL 36114 US
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From: iq5la@misys.ca

malekal.com
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Date: Tuesday, 20/08/2013 4:48

AM
From: spatel@begoro.com.ec
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malekal.com
55.212.115.198
Fort Huachuca, AZ, United
States
Provider: Headquarters,
USAISC
124.66.184.4
Seongnam, Korea, Republic of
Provider: SK C&C Co., Ltd.
152.80.166.27
Virginia Beach, VA, United
States
Provider: Navy Network
Information Center (NNIC)
2.184.215.18
Iran, Islamic Republic of
Provider: Information
Technology Company (ITC)
28.215.201.194
Columbus, OH, United States
Provider: DoD Network
Information Center
59.92.42.45
Chennai, India
Provider: NIB (National Internet
Backbone)
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Date: Tuesday, 20/08/2013 5:05

AM
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From: sware@quadrem.com
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malekal.com
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Date: Tuesday, 20/08/2013 9:44

PM
31.
On May 23, 2014, CONNELLY extinguished incoming email traffic access to his
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email account at BodyRx.com due to the volume of spam. The next day, MRS. CONNELLYS
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email account at Roadrunner.com received 25 UCEs over a single 12 hour period each bearing
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subject headers (e.g. medical billing and coding) duplicating hundreds of UCEs previously
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received by Dr. Connellys email at BodyRx.com. In the 15 years MRS. CONNELLY has owned
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this account she had never received this volume of UCE traffic in a single day, nor had she ever
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received any emails with the subject header medical billing and coding. Since that time MRS.
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CONNELLYS Roadrunner account has been receiving similar UCE traffic (as well as UCEs
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bearing Trojan malware attachments) on a daily basis.
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CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
32.
CONNELLYS personal email accounts at gmail.com, yahoo.com, and
roadrunner.com remained free of atypical UCE traffic until August of 2014 when all 3 accounts
began receiving incremental numbers of UCEs with volumes reaching as many as 25 atypical
UCEs per day. The vast majority of these UCEs contained recurring subject headers denoting
salacious solicitations from female aliases and Russian pharmacy malware bearing attack
websites. Over 90% have contained links (URLS) delivering malicious code.
33.
The UCEs had many similar characteristics, demonstrating that this was a
coordinated attack, including, inter alia: (i) many were routed through common hosts but in
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innumerable cases were deployed in a similar manner using relay servers belonging to
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governmental agencies (e.g. Department of Defense, US Postal Service, Egov.net Information

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Center in Beijing, China, and the British government) and public and private universities in the
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United States and abroad (e.g. Florida State University, Massachusetts Institute of Technology,
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University of Missouri and the University of Limerick in Ireland); (ii) over 90 % used and/or were
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routed through domains that were newly registered on the day they were sent; and (iii) many e15
personated third parties ranging from governmental entities to established businesses including but
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not limited to Wells Fargo, Bank of America, Kohls, FedEX, PayPal, PG&E, Ray Ban, Facebook
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and LinkedIn in addition to bodyrx.com and other domains registered by CONNELLY.

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While the UCEs, including malware, continued regardless of any response or
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action on the part of CONNELLY, any effort on his part to indicate an awareness of the ongoing
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online racketeering, yielded a prompt spike in the level of UCE received within a matter of 24
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hours of any such communication from CONNELLY.
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As the Sac County Iowa investigation into reputation racketeering gained public
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attention and the Sac County District Attorney Ben Smith (SMITH) reported his findings to
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ZUCKERMANS parole officer, nearly identical emails having links to malicious sites were also
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sent to SMITH and to John Gladych, CONNELLYs attorney in the Progenex dispute.
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CONNELLY v. DOE FAC
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36.
On information and belief, ZUCKERMAN lacks the technical prowess to directly
deliver such email attacks and therefore relies on a network of hacker and cyber criminals who
provide templates for his email campaigns which they then either distribute via emails and/or host
the landing page for the link contained in the emails which usually contain malware. More
importantly, the emails are distributed to email accounts belonging to Plaintiffs that are not in
public circulation but which are known to ZUCKERMAN.

37.
Figures 1A and 1B below illustrate this process, as Figure 1A is a January 16, 2016
UCE sent to CONNELLY at a non-public address stating that H0rnyTara is available at
sxybook.com and contains a link to landing page containing malware. Figure 1B is a similar
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February 24, 2016 UCE sent to CONNELLY at the same address but which reveals the existence
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of the template by omitting its data fields as the annotations indicate.
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Figure
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1A
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CONNELLY v. DOE FAC
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Figure
1B
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38.
Figure 2 illustrates how these email attacks are deployed. Figure 2A is an August
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4, 2015 UCE with the subject line 1 Pending Hot BOOty Call sent to CONNELLYS G-mail
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address inviting him to send a f#ck request. The email was sent from a Brazilian email address
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but a WHOIS search reveals that this domain is not registered and the routing path from the
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email header (as depicted in Figure 2B) reveals that it originated from brownchristianpress.com.
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Figure 2A
Figure 2B
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39.
Figure 2A contains a link labeled view my profile here. This is a dynamic link in
that it continues to auto-update and redirect to different sites, presumably as the prior URL is shut
down for abuse. The link originally landed at nice-neighbors.org, but within a few days it
redirected to a new URL (hot-top-girls.com) with identical screen imagery and source code.
The
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CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
link was still redirecting to updated versions (having the same source code and screen imagery)
of the original (hot-top-girls.com) as late as February 8, 2016.
40.
Exhibit 3 depicts the dynamic and international component of this campaign. The
UCE was sent to CONNELLYS non-public Yahoo! email address from Defendant PASSING
LEADS on or about October 7, 2015. On that day, the website redirected to Defendant BSF, but
by February 24, 2016 the website redirected to hot-top-a-juicyladies.org, a day old domain
registered to a third-party in Moscow.
41.
A substantial number of the UCEs received from September 2012 through to date
either contain pernicious malware as attachment or had links to malicious websites. Connelly had
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a portion of the UCE analyzed and discovered that they contained, inter alia, (i) the Zeus Trojan
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Horse which it is often used to steal banking information by man-in-the-browser keystroke

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logging and form grabbing; (ii) Trojan.Fakeavlock which locks applications making the computer
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unusable and attempts to convince the user to purchase software in order to remove non-existent
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malware or security risks; (iii) Downloader.Upatre which is a Trojan horse that downloads
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potentially malicious files onto the compromised computer; (iv) Win32/Boaxxe.E which is a
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Trojan horse that drops Trojan:Win32/Boaxxe.F that installs itself as a browser helper object and
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may contact remote sites in order to download and execute arbitrary files; (v) Bladabindi which is
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a Trojan horse that steals confidential information from the compromised computer; (vi)
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Win32/Gamarue which is part of a family of malware that can download files and steal
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information about the compromised computer; and (vii) Downloader.Ponik which is a Trojan
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horse that downloads more malware onto the compromised computer and may also steal
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passwords from the compromised computer.

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CONNELLY v. DOE FAC
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E.
The Cyber Conspirators
Larger Defendants
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Blacksexfinder Corp., Chanel Faulkner and Passing Leads, LLC
42.
CONNELLY has received over 100 UCEs promoting links to malicious content
hosted by BSF and/or FAULKNER starting in August 2015, including the following.
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Exhibit
Date
Ex. 4
8/15/15
Email Details
From: Margaret Garner
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To: Dr. Connelly Gmail Account
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Re: Answer an Urgent FastDown Call

Ex. 3
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10/7/15
Malware
From: Deborah Ramos
Via Link
Via Link
To: Dr. Connelly Yahoo Account
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Re: Bang with An adroit mother
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Ex. 5
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10/15/15
From: Lora Castro
Via Link

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Re: Sex tonight
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43.
The UCEs improperly distributed a malicious link and were deceptive in terms of
the email sender and its use of malicious links.

Hargray Communications Group, Inc.
21
22
23
24
44.
CONNELLY has received at least four UCEs promoting links to malicious content
hosted by HARGRAY. This includes the examples in Figure 1A and 1B and the following:
Exhibit
25
26
27
Date
12/5/15
Ex. 6
Email Details
Malware
From: Grey Parson

Via Link
Re: 1 HOrnyBuddy Request
28
15
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
45.
After receiving Exhibit 6 from HARGRAY, CONNELLY alerted HARGRAY and
sent a preservation of records notice to HARGRAY to multiple HARGRAY email addresses on
December 7, 2015, only to receive three more UCEs thereafter.
4
5
46.
On information and belief, the routing information and links deployed in the
HARGRAY emails have similarities with an additional 427 UCEs.
6
7
8
9
47.
The UCEs improperly distributed a malicious link and was deceptive in terms of

David Morgan
10
11
12
13
48.
Beginning in July 2015, CONNELLY has received at least 51 UCEs that originated
from MORGAN d/b/a Davismor, Inc. and whose links redirects to sweet-hookupgirls.com,
including the following:
14
Exhibit
15
12/5/15
16
Ex. 7
17
18
19
Date
Email Details
Malware
From: Laurena
Via Link
Re: hoooolaaaaaaa!!!
49.
The UCEs improperly distributed a malicious link and was deceptive in terms of
20
21
22
23
Ride Best, LLC

50.
CONNELLY has received three UCEs promoting links to malicious content hosted
by RIDE BEST beginning in April 2015, including the following:
24
25
26
27
28
16
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
Exhibit
Date
4/21/15
6
7
From: Paige
Malware
Via Link
Ex. 8
4
5
Email Details
Re: please be my f@ck buddy
51.
On information and belief, the routing information and links deployed in the RIDE
BEST emails have similarities with an additional 25 UCEs that also redirect to get-laid-atnight.com.
8
9
10
52.
The UCEs improperly distributed a malicious link and were deceptive in terms of
11
University Emails
12
13
53.
Plaintiffs have received a number of UCEs from university addresses, including
14
prestigious institutions such as Massachusetts Institute of Technology and Princeton University.
15
On information and belief, many of these educational institutions use Proofpoint, Inc. for email
16
hosting and security. Plaintiffs suspect that this is not coincidental.
17
Curators of the University of Missouri
18
19
20
21
22
54.
CONNELLY has received at least one UCE containing a malicious Trojan zip file
that originated from the University of Missouri and which used CONNELLYS bodyrx.com
domain as the sending address.
Exhibit
23
24
25
Date
4/21/15
Ex. 9
Email Details
From: Administrator
Malware
Trojan Zip
File
To: info@bodyrx.com
Re: FW: Last Month Remit
26
27
28
17
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
55.
1
2
3
The UCE improperly delivered a Trojan zip file; was deceptive as to the sender and
its use of malware; and improperly e-personated CONNELLY by using the bodyrx.com domain.
Betaforce Networks, LLC
56.
CONNELLY has received at least three UCEs connected to BETAFORCE, two
examples of which are set forth below. In Exhibits 10 and 11, both emails e-personate actual
university employees at St. Cloud State University (Minnesota) and North Central State College
(Ohio) without their prior knowledge or consent. The emails were sent through internet protocol
addresses used by BETAFORCE through Database By Design, LLC.
10
Exhibit
11
Date
10/21/15
12
Email Details
From: Match.com
Re: Unread Message
14
Ex. 11
12/11/15
From: Will WIns
15
To: [blank]
16
Re: Hello Pretty
17
19
Via Link
To: Undisclosed recipients
Ex. 10
13
18
Malware
57.
n/a
The UCEs improperly e-personate actual members of the university and
Match.com; and were deceptive as to the sender and, in the case of Exhibit 10, its use of malicious
links.
20
Smaller Defendants
21
22
Richard Allen d/b/a Virtual Accounting Service, LLC
23
24
25
26
58.
CONNELLY received one UCE that originated from ALLEN on February 20,
2016 under the name Easy Kitty as set forth below that was routed through India and was
flagged by Gmail as a potential phishing email.
27
28
18
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
Seconds later, CONNELLY received another Easy Kitty email that was sent
59.
1
2
from the same iPad but which originated in Uzbekistan and was routed through Ukraine,
demonstrating how the conspiracy is coordinated through multiple email accounts throughout the
world.
5
Exhibit
Date
Email Details
Malware
6
2/20/16
From: Easy Kitty
Via Link
To: Dr. Connelly Gmail Account
Ex. 12
8
Re: Sup!8-)
9
10
11
12
60.
The email improperly distributed a malicious link and was deceptive in terms of the
email sender and its use of malicious links.

M. Brown Books Publishing Group, Inc.
13
14
15
16
17
61.
CONNELLY has received at least the one UCE depicted in Figure 2A from
BROWN BOOKS on August 4, 2015.

62.
sender and its use of malicious links.
18
Michael, Laudick & Associates, LLC

19
20
21
63.
MRS. CONNELLY has received at least one UCE originating from MLA on
November 19 2015 that contained a link to a malicious site as set forth below.
22
Exhibit
Date
Email Details
Malware
23
11/19/15
24
Ex. 13
From: Synergyshow
To: Mrs. Connelly
Via Link
25
Re:
26
64.
27
email sender and its use of malicious links.

28
19
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
1
2
3
4
Erroll Wilson
65.
CONNELLY has received at least one UCE from WILSON that was routed
through United Kingdoms Ministry of Defence, as set forth below. The email is one of 135
UCEs CONNELLY has received that were routed through the Ministry of Defence.
5
6
66.
The UCE was deceptive as to the email sender.

Exhibit
Date
9/15/15
Ex. 14
10
Email Details
From: LOAN OFFER
Malware
n/a

Re: loan at 3%
11
12
13
FIRST CLAIM FOR RELIEF
14
BY PLAINTIFFFS AGAINST ALL DEFENDANTS EXCEPT WILSON
15
VIOLATION OF THE COMPUTER FRAUD AND ABUSE ACT
16
17
18
19
20
21
22
23
24
25
18 USC 1030
67.
PLAINTIFFS hereby re-alleges and incorporates by reference the allegations
contained in the preceding paragraphs as if set forth fully herein.

68.
PLAINTIFFS computers are protected computers as that term is defined in
Computer Fraud and Abuse Act (CFAA) 18 USC 1030(e), in that they are used in and affect
interstate commerce and communication.
69.
DEFENDANTS have attempted to access PLAINTIFFFS protected computers
with an intent to defraud PLAINTIFFS via emails sent by DEFENDANTS containing malware or
links to malicious websites designed to access or damage PLAINTIFFS computer without their
knowledge and/or consent in violation of 18 USC 1030(a)(5)(A)
26
27
28
20
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
70.
As result of the DEFENDANTS misconduct, PLAINTIFFS have suffered loss
during the last twelve months aggregating at least $5,000 in value in attempting to identify and
remediate the malware attacks and unauthorized access by DEFENDANTS.
SECOND CLAIM FOR RELIEF

5
BY PLAINTIFFS AGAINST DEFENDANTS

6
VIOLATIONS OF RACKETEER
7
INFLUENCED AND CORRUPT ORGANIZATIONS ACT

8
18 U.S.C. 1961 et seq.
9
10
11
12
71.

72.
On information and belief, beginning in September 2012 and continuing therefrom,
13
DEFENDANTS began working in concert for the purpose of punishing and harassing
14
PLAINTIFFS to force CONNELLY to relent in his battles with ZUCKERMAN and his allies,
15
with the transmission of unsolicited emails and malware being the weapon of choice.
16
73.
DEFENDANTS collectively constitute an association in fact, and/or legal entity,
17
and therefore an enterprise, within the meaning of 18 U.S.C. 1961(5) and were engaged in, and
18
its activities affected interstate and foreign commerce, within the meaning of Racketeer Influenced
19
and Corrupt Organizations Act (RICO), 18 U.S.C. 1962(c).
20
74.
At all times relevant hereto, DEFENDANTS, by their acts specified above,
21
conducted or participated and/or conspired to conduct or participate, directly or indirectly, in the
22
conduct of certain enterprises affairs through a pattern of racketeering activity, thereby
23
proximately causing injury to Plaintiff.
24
75.
Each of the DEFENDANTS knew the essential nature and scope of the enterprise
25
or enterprise(s) that he, she, or it was employed by or associated with, and each of the
26
DEFENDANTS intended to participate in the affairs of the particular enterprise or enterprise(s).
27
28
21
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
76.
The conduct of DEFENDANTS violated the law, inter alia, since it (i) is in
retaliation for CONNELLYs provision of information to law enforcement about
ZUCKERMANs illegal activities (18 U.S.C. 1513(b)); (ii) involved the sending of fraudulent
email to PLAINTIFFS by means of interstate wires (18 U.S.C. 1343); and (iii) violating
Californias Comprehensive Computer Data Access and Fraud Act (CCDAF) by transmitting
malware (Cal. Penal Code 502).
7
8
77.
PLAINTIFFS have been injured by, inter alia, having to spend money to
investigate and remediate Defendants unlawful conduct.
THIRD CLAIM FOR RELIEF

10

11
VIOLATION OF CALIFORNIA ANTI-SPAM ACT

12
Cal. Bus. & Prof. Code 17529.5
13
14
15
16
17
18
19
20
21
22
78.
PLAINTIFFS incorporate each and every preceding paragraph in this cause of
action as though fully set forth herein.

79.
The California Anti-Spam Act (CASA) prohibits the sending of unsolicited
commercial emails using a third party domain without permission; or which contain falsified,
misrepresented or forged header information; or that include deceptive subject lines. (Cal.
Business & Prof. Code 17529.5.)
80.
PLAINTIFFS have received over 3,000 UCEs from August 2014 to present most
containing at least one of these elements.

81.
For example, on August 4, 2015, CONNELLY received an email with the subject
23
line 1 Pending Hot BOOty Call inviting him to send a fuck request. The email was sent from
24
capelania@agricultursepp.ag.br but a WHOIS search reveals that this domain is not registered
25
26
and the routing path was through brownbooks.com, a book publisher. (See Figure 2A.) This was
identical to dozens of emails he and MRS. CONNELLY had received using spoofed domains with
27
28
22
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
separate routing information and deceptively promoting malicious websites as set forth above and
in the exhibits.
3
4
82.
DEFENDANTS acted willfully and with malice, fraud and/or oppression in
transmitting the emails.
FOURTH CLAIM FOR RELIEF

6
BY PLAINTIFFS AGAINST DEFENDANT MIZZOU

7
VIOLATIONS OF CALIFORNIAS COMPREHENSIVE
COMPUTER DATA ACCESS AND FRAUD ACT

9
California Penal Code Section 502
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
83.

84.
MIZZOU in transmitting malware to PLAINTIFFS knowingly and willfully
introduced a contaminant into a computer system or network in violation of the California

Comprehensive Computer Data Access and Fraud Act (CCDAF), California Penal Code Section
502(c)(8).
85.
In addition, on information and belief, MIZZOU accessed without authorization,
CONNELLYS and/or GoDaddy.coms protected computers to access information on domains

privately registered to CONNELLY and have sent emails directly to CONNELLY at such domain
addresses in violation of CCDAF 502(c)(2) and (3).
86.
As a result of MIZZOUS conduct, PLAINTIFFS have suffered loss during the last
twelve months aggregating at least $5,000 in value in attempting to identify and remediate the
malware attacks by MIZZOU.
87.
MIZZOU acted willfully and with malice, fraud and/or oppression in transmitting
such malware.
26
27
28
23
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
FIFTH CLAIM FOR RELIEF
BY DR. CONNELLY AGAINST DEFENDANTS
BETAFORCE, MIZZOU AND WILSON
E-PERSONATION
California Penal Code Section 528.5
6
7
8
9
10
11
12
13
88.

89.
The named Defendants have sent emails to CONNELLY using his name and/or
domain names for purposes of harming, intimidating and/or threatening CONNELLY.

90.
Such emails were sent knowingly and without consent of CONNELLY in violation
of California Penal Code Section 528.5.

91.
The named Defendants acted willfully and with malice, fraud and/or oppression in
transmitting such e-personating emails.
14
15
SIXTH CLAIM FOR RELIEF
16
17
UNFAIR COMPETITION
18
California Business & Professions Code Section 17200 et seq.
19
20
21
22
23
24
25
26
92.

93.
DEFENDANTS have engaged in unlawful business acts or practices by
committing illegal actions, including computer fraud as alleged above. DEFENDANTS have also
false information in their domain registrations so as to conceal their identities.
94.
The acts and conduct of DEFENDANTS constitute fraudulent, unlawful, and unfair
competition as defined by California Business & Professions Code Section 17200 et seq.
27
28
24
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
95.
DEFENDANTS should be compelled to restore any and all money or property they
may have obtained in violation of California Business & Professions Code Section 17200 et seq.,
and should be enjoined from further unlawful, unfair and deceptive business practices.
SEVENTH CLAIM FOR RELIEF
BY PLAINTIFFS AGAINST ALL DEFENDANTS
NEGLIGENCE
California Penal Code Section 528.5
8
9
10
96.
11
12
97.
15
DEFENDANTS owed PLAINTIFFS a duty of care not to permit their operations to
be used to spread malware in violation of applicable law.
13
14
98.
By permitting malware to be distributed from their websites and/or businesses,
DEFENDANTS violated the duty of care owed to PLAINTIFFS and they have suffered damages
as a result.
16
17
//
18
19
//
20
21
22
23
24
25
26
27
28
25
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
PRAYER FOR RELIEF
1
2
3
WHEREFORE, PLAINTIFFS demands entry of a judgment against the DEFENDANTS as

follows:
1.
5
6
alleged herein;
7
8
9
That this Court enter findings that the DEFENDANTS have engaged in the conduct
2.
That DEFENDANTS, their agents, servants, employees, representatives, successors
and assigns, and persons, firms or corporations in active concert or participation with said
DEFENDANTS be immediately and permanently enjoined from engaging in such conduct;
10
3.
11
12
remediating the malware and spam attacks;
13
14
That PLAINTIFFS be awarded damages for the costs incurred in investigating and
4.
That PLAINTIFFS be awarded treble damages pursuant to 19 U.S.C. 1961 et
5.
That PLAINTIFFS be awarded damages under CASA of $1,000 for each UCE
seq.;
15
16
received;
17
18
6.
19
Section 528.5;
20
21
7.
That PLAINTIFFS be awarded exemplary damages under CCDAF and Penal Code
That PLAINTIFFS recover its costs of this action together with reasonable
attorneys fees, expenses and prejudgment interest.
22
23
24
8.
That the Court grant PLAINTIFFS such other and further relief as it deems just and
equitable to make PLAINTIFFS whole for the damage caused by DEFENDANTS.
25
26
27
28
26
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
1
2
JURY DEMAND
3
4
5
Pursuant to Federal Rule of Civil Procedure 38(b), PLAINTIFFS hereby demand a trial by
jury on all issues.
6
7
8
Dated: March 7, 2016
Respectfully submitted,
10
INTERNET LAW CENTER

11
BY:
12
/s/ Bennet G. Kelley /s/
Bennet G. Kelley
13
100 Wilshire Blvd, Suite 940

Santa Monica, CA 90401
14
15
Attorney for Plaintiffs
16
17
18
19
20
21
22
23
24
25
26
27
28
27
CONNELLY v. DOE FAC
Case No.: 8:2015cv01255
Case 8:15-cv-01255-CJC-JCG Document 14-1 Filed 03/07/16 Page 1 of 61 Page ID #:509
EXHIBIT 1
Connelly v Doe
Case No. 8:2015cv012
Connelly v Doe
Case No. 8:2015cv01255
Page E-1
FAC Exhibits
Connelly v Doe
Page E-2
FAC Exhibits
Connelly v Doe
Page E-3
FAC Exhibits
EXHIBIT 2
Connelly v Doe
Case No. 8:2015cv01255
Connelly v Doe
Page E-4
FAC Exhibits
Connelly v Doe
Page E-5
FAC Exhibits
Connelly v Doe
Page E-6
FAC Exhibits
EXHIBIT 3
Connelly v Doe
Case No. 8:2015cv01255
Connelly v Doe
Page E-7
FAC Exhibits
REDACTED
Connelly v Doe
Page E-8
FAC Exhibits
REDACTED
REDACTED
Connelly v Doe
Page E-9
FAC Exhibits
Case 8:15-cv-01255-CJC-JCG Document 14-1 Filed 03/07/16 Page 10 of 61 Page ID

#:518
Connelly v Doe
Page E-10
FAC Exhibits

#:519
Connelly v Doe
Page E-11
FAC Exhibits

#:520
Connelly v Doe
Page E-12
FAC Exhibits

#:521
Connelly v Doe
Page E-13
FAC Exhibits

#:522
EXHIBIT 4
Connelly v Doe
Case No. 8:2015cv01255
Connelly v Doe
Page E-14
FAC Exhibits

#:523
REDACTED
Connelly v Doe
Page E-15
FAC Exhibits

#:524
REDACTED
Connelly v Doe
Page E-16
FAC Exhibits

#:525
Connelly v Doe
Page E-17
FAC Exhibits

#:526
EXHIBIT 5
Connelly v Doe
Case No. 8:2015cv01255
Connelly v Doe
Page E-18
FAC Exhibits

#:527
REDACTED
Connelly v Doe
Page E-19
FAC Exhibits

#:528
Connelly v Doe
Page E-20
FAC Exhibits

#:529
Connelly v Doe
Page E-21
FAC Exhibits

#:530
Connelly v Doe
Page E-22
FAC Exhibits

#:531
EXHIBIT 6
Connelly v Doe
REDACTED
Connelly v Doe
Page E-23
FAC Exhibits

#:532
Connelly v Doe
Page E-24
FAC Exhibits

#:533
EXHIBIT 7
Connelly v Doe
Connelly v Doe
Page E-25
FAC Exhibits

#:534
REDACTED
Connelly v Doe
Page E-26
FAC Exhibits

#:535
EXHIBIT 8
Connelly v Doe
Connelly v Doe
Page E-27
FAC Exhibits

#:536
REDACTED
Connelly v Doe
Page E-28
FAC Exhibits

#:537
EXHIBIT 9
Connelly v Doe
Connelly v Doe
Page E-29
FAC Exhibits

#:538
Connelly v Doe
Page E-30
FAC Exhibits

#:539
Connelly v Doe
Page E-31
FAC Exhibits

#:540
EXHIBIT 10
Connelly v Doe
Connelly v Doe
Page E-32
FAC Exhibits

#:541
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Page E-33
FAC Exhibits

#:542
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Page E-34
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#:543
Thu, 15 Oct 2015 06:01:20 -0700

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Connelly v Doe
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#:544
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#:545
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#:546
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#:548
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EXHIBIT 11
Connelly v Doe
Connelly v Doe
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#:551
Connelly v Doe
Page E-43
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#:552
From Will WIns Fri Dec 11 08:03:22 2015

REDACTED Fri, 11 Dec 2015 08:05:24 +0000
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Page E-44
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FAC Exhibits

#:553
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From: Will WIns <DSmith@ncstatecollege.edu>
Subject: Hello Pretty
Connelly v Doe
Page E-45
FAC Exhibits

#:554
Date: Fri, 11 Dec 2015 00:03:22 -0800

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Connelly v Doe
Page E-46
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#:555
Connelly v Doe
Page E-47
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#:556
EXHIBIT 12
Connelly v Doe
Connelly v Doe
Page E-48
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#:557
Connelly v Doe
Page E-49
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#:558
REDACTED
Connelly v Doe
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#:559
EXHIBIT 13
Connelly v Doe
Connelly v Doe
Page E-51
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#:560
REDACTED
Connelly v Doe
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#:561
REDACTED
Connelly v Doe
Page E-53
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#:562
REDACTED
Connelly v Doe
Page E-54
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#:563
Connelly v Doe
Page E-55
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#:564
EXHIBIT 14
Connelly v Doe
From LOAN OFFER Wed Sep 16 04:40:34 2015

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Connelly v Doe
Page E-56
FAC Exhibits

#:565
ecJQ1R_hZ7eXE8QKSbY8_n3ZAlRX_mM5TrhrDrODxWKoSdKKyGfYbXNGEX8h
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To: Recipients
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Connelly v Doe
Page E-57
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#:566
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Connelly v Doe
Page E-58
FAC Exhibits

#:567
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Connelly v Doe
Page E-59
FAC Exhibits

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Connelly v Doe
Page E-60
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Page E-61
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Connelly Filed FAC

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Case 8:15-cv-01255-CJC-JCG Document 14 Filed 03/07/16 Page 1 of 27 Page ID #:482

Bennet Kelley (SBN 177001)

UNITED STATE DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

Case No.: 8:2015cv01255

CONNELLY v DOE FAC

Case No.: 8:2015cv01255

Case 8:15-cv-01255-CJC-JCG Document 14 Filed 03/07/16 Page 2 of 27 Page ID #:483

PLAINTIFFS TAMMY CONNELLY and A. SCOTT CONNELLY, M.D., hereby

complain against Defendants RICHARD ALLEN d/b/a VIRTUAL ACCOUNTING SERVICE,

LLC; BETAFORCE NETWORKS, LLC; BLACKSEXFINDER CORP.; CHANEL FAULKNER

d/b/a BLACKSEXFINDER; HARGRAY COMMUNICATIONS GROUP, INC.; M. BROWN

OF MISSOURI; and ERROL WILSON as follows:

Plaintiffs Mrs. TAMMY CONNELLY (MRS. CONNELLY) and A. SCOTT

hereto lived, in Orange County, California.

On information and belief, Defendant Richard Allen d/b/a Virtual Accounting

On information and belief, Defendant Betaforce Networks, LLC (BETAFORCE)

Defendant Blacksexfinder Corp. (BSF) is a Florida corporation with its principal

African-American dating website, was administratively dissolved on or about September 14,

On information and belief, Defendant Chanel Faulkner d/b/a Blacksexfinder

resides in Jacksonville, Florida (FAULKNER). FAULKNER was the Chairwoman of BSF.

CONNELLY v. DOE FAC

Case No.: 8:2015cv01255

Case 8:15-cv-01255-CJC-JCG Document 14 Filed 03/07/16 Page 3 of 27 Page ID #:484

On information and belief, Defendant M. Brown Books Publishing Group, Inc.

Texas. On information and belief, BROWN BOOKS is a publishing company.

On information and belief, Defendant Hargray Communications Group, Inc.

On information and belief, Defendant Michael, Laudick & Associates, LLC is an

business as Laudick, Brown & Associates (LBA).

On information and belief, Defendant The Curators of the University of Missouri

On information and belief, Defendant David Morgan (MORGAN) is an

On information and belief, Defendant Passing Leads, LLC (PASSING LEADS)

On information and belief, Defendant Ride Best, LLC (RIDE BEST) is a

boarding equipment and accessories.

CONNELLY v. DOE FAC

Case No.: 8:2015cv01255

Case 8:15-cv-01255-CJC-JCG Document 14 Filed 03/07/16 Page 4 of 27 Page ID #:485

On information and belief, Defendant Erroll Wilson (WILSON) is an individual

JURISDICTION AND VENUE

simultaneously disseminated compromising photos of women through one website while

Feb. 21, 2015).

Reputation racketeering can also involve using mechanized defamation tools to

CONNELLY v. DOE FAC

Case No.: 8:2015cv01255

Case 8:15-cv-01255-CJC-JCG Document 14 Filed 03/07/16 Page 5 of 27 Page ID #:486

someones reputation than clean it up.

them in open court.

WARRANT) < https://www.scribd.com/doc/233387848/Application-for-Search-

Progenex and Adam Stuart Zuckerman

In 2007, Adam Stuart Zuckerman (ZUCKERMAN) was the lead defendant in

equipment leases. As explained by the Department of Justice in announcing the indictments:

[Defendants] marketed cash loans to small businesses experiencing credit

CONNELLY v. DOE FAC

Case No.: 8:2015cv01255

Case 8:15-cv-01255-CJC-JCG Document 14 Filed 03/07/16 Page 6 of 27 Page ID #:487

ZUCKERMAN pled guilty to the charges in 2007, but remained on supervised

In 2009, CONNELLY and Murray Goulburn Nutritionals (Australia) sought to

The Cool Technique

Instead of using the money invested by CONNELLY for product development,

CONNELLY v. DOE FAC

Case No.: 8:2015cv01255

Case 8:15-cv-01255-CJC-JCG Document 14 Filed 03/07/16 Page 7 of 27 Page ID #:488

of malicious code dubbed THE COOL TECHNIQUE.

THE COOL TECHNIQUE was a SQL Injection Code developed by Matthew