The Complaint names Janice Shell, John Doe No. 1 a/k/a "Paul Kersey," John Doe No. 2 a/k/a "Mayor," John Doe No. 3 a/k/a "Mr. Pink,"
John Doe No. 4 a/k/a "mshater," and John Doe Nos. 5-100 as Defendants (collectively the "Defendants"). The Complaint alleges that,
beginning at least as early as May 1999 and continuing through to the present, the Defendants intentionally and maliciously published and
republished a variety of false and defamatory statements about Hitsgalore.com in a nationwide "cybersmear" campaign on electronic bulletin
boards on the Internet maintained by Raging Bull, Inc. ("Raging Bull") and Silicon Investor, Inc. ("Silicon Investor"). These statements either
explicitly state or imply that Hitsgalore has engaged in illegitimate, illegal, dishonest, fraudulent, and criminal business operations, when, in
truth and fact, the Defendants knew or should have known that such statements were false and libelous per se.
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