Attorney Marc Randazza sued me, his former client to intimidate me, harass and bully me. He wanted to create a precedence to steal intellectual property from those wealthier then me. Marc Randazza sues people to SHUT THEM UP. He uses his First Amendment knowledge to violate the constitutional rights of his TARGETS.

Document 90, Amended Answer to Randazza v. Cox and Bernstein Complaint.

A District of Nevada complaint filed against me by my former attorney to STOP me from talking about him online and to bully, threaten, intimate and harass me.


"Pro Se Defendant Crystal Cox ANSWER

Answer to Allegations in Introduction of Complaint

Pro Se Defendant Crystal Cox Defense Regarding Introduction Allegation 1.)

I, Defendant Crystal Cox have not engaged in an online harassment campaign against any
of the Plaintiff’s in this complaint. In fact Plaintiff has engaged in an online harassment
campaign against me, Defendant Crystal Cox.

I, Defendant Crystal Cox have not EVER bought a domain name related to Plaintiff or
anyone else, in effort to extort them or harass them in any way.

I, Defendant Crystal Cox bought domain names that were keyword rich regarding the
subject I was reporting on, I am a Media Defendant, and it is standard of practice to have a
domain name, a blog with the keywords relating to what that blog is about. My blogs
regarding Plaintiff were to review Plaintiff as he was my attorney at one time.

My blogs were also to report on cases Plaintiff was involved in, to Parody Plaintiff, to Criticize
Plaintiff, exercise my First Amendment Rights and to report on my own legal case.
My blogs regarding Plaintiff were also a Public service as to warn the public of important
related issues, and to report on Public Figure Marc Randazza.

I, Defendant Crystal Cox, never bought a domain name with Plaintiff’s last name in it to
“capitalize” on Plaintiff’s name in anyway, nor have I or Eliot Bernstein, that I know of, ever
made ANY money what so ever regarding domain names, or blogs with resembling
Plaintiff’s name or last name in the blogs.

I, Defendant Crystal Cox have every legal right to own a Domain Name and a blog with the
name of anyone in the title, as noted clearly in, case regarding the domain name
GlenBeckRapedAndMurderedAYoungGirl.com, in which Plaintiff Marc J. Randazza
represented the Domain Name owner and won the right for that person to continue owning
and using that Domain Name.

Regarding this same issue of a personal name in a Domain Name, Plaintiff Marc
Randazza wrote the following quote which is a letter from Attorney Marc J. Randazza,
Plaintiff in this case, to Matthew A. Kaplan Opposing Counsel, and is personally signed
by Plaintiff Marc John Randazza.

" View 1 states: “The right to criticize does not extend to registering a domain name that is
identical or confusingly similar to the owner’s registered trademark or conveys an association
with the mark.”

View 2 states: “Irrespective of whether the domain name as such connotes criticism, the
respondent has a legitimate interest in using the trademark as part of the domain name of a
criticism site if the use is fair and non­commercial.”

Naturally, View 2 is the prevailing view of American panelists and panels that apply American law
to UDRP proceedings. View 1 seems to be more popular with international panelists and panels
that apply European law."

Unfortunately, given that UDRP decisions regularly incorporate international legal principles, this
case could be assigned to a foreign panelist or to an American panelist who applies
transnational principles. I personally would find it distressing if the panel were to make a decision
that completely disregards the U.S. Constitution in favor of a foreign perspective that adopts
View 1."

"To be candid, we found the fact that Mr. Beck filed this action at all to be most
puzzling. Although, it was obvious why he did not file in a U.S. court given the law
surrounding nominative fair use of trademarks as fully explained in our Brief.
Naturally, a defamation claim as alluded to in Mr. Beck’s complaint would be
humiliatingly doomed as well in a U.S. court. "

The Document Goes on to Say:

"Accordingly, we found it to be most ironic that Mr. Beck, facing the fact that the
U.S. Constitution would stand in his way in a U.S. court, sought to bring this action
before an international domain name arbitration panel.
On March 20, 2009, he said on his show:

Let me tell you something. When you can't win with the people, you
bump it up to the courts. When you can't win with the courts, you
bump it up to the international level.

Of course, we levy no critique at Mr. Beck for seeking to vindicate his perceived
rights in this forum. We do not share his opinion as articulated on March 30, and we
respect his creativity in seeking an alternate avenue where his claims might have a
chance of success. Unfortunately, despite the general wisdom among UDRP
panelists, we find that occasionally they render decisions that make First
Amendment champions cringe."

"We are certain that despite our disagreement with Mr. Beck’s legal position, that all
parties involved hold equal reverence for the First Amendment. 

Therefore, I have prepared a proposed stipulation that will ensure that no matter which panelist is
assigned to this case, the First Amendment will illuminate these proceedings like
rays of light from the Torch of Liberty."

The Document Goes on to Say:

"I am certain that neither party wishes to see First Amendment rights subordinated
to international trademark principles, thus unwittingly proving Mr. Beck’s point. Lest
this case become an example of international law causing damage to the
constitutional rights that both of our clients hold dear, I respectfully request that
your client agree to stipulate to the application of American constitutional law to
this case. "

Yet, this court continues to favor this SAME attorney as a Plaintiff arguing
the Opposite Defense to his own favor, in Randazza V. Cox.

The Document Goes on to Say:

“Irrespective of whether the domain name as such connotes criticism, the
respondent has a legitimate interest in using the trademark as part of the domain
name of a criticism site if the use is fair and non-commercial.”

Eliot Bernstein nor Crystal L. Cox had commercial sites, nor were they in a
competing business. Eliot Bernstein got domain names in receivership of a debt
Crystal Cox owed him. Crystal Cox used the domain names to seriously criticize
Plaintiff / Counter Defendant Marc J. Randazza who she had personal experience of,
knowledge of, and who is a Public Figure.

This Hypocrisy of Plaintiff / Counter Defendant Marc J. Randazza, proves yet again
that he knew this lawsuit was a frivolous waste of the courts time and the
Taxpayers money, yet he sued anyway, in order to retaliate against a woman who
he had once represented and who he did not like or approve her on "online
speech", regarding her experience with him.

Plaintiff / Counter Defendant Marc J. Randazza is clearly acting outside of the law
and is clearly discriminating in who the Constitution applies to and who it does not.

Plaintiff / Counter Defendant Marc J. Randazza should be sanctioned and so should
his attorney Ronald D. Green.

The Constitution of the United States and the Laws, should not be disregarded
simply to protect the ego of Attorney Marc Randazza.

I, Defendant Crystal Cox have every legal right to make fun of, report on and parody Marc
Randazza’s wife.

This was not out of the blue, the blog posts were making fun of posts on
Marc Randazza’s own blog discussing a drunken tryst and knocking her up and he may as
well marry her. I have every lawful right to make fun of Marc Randazza and his Wife.

I, Defendant Crystal Cox have never had a blog regarding Plaintiff’s daughter, this is a false
statement by Plaintiff. I have NEVER made a statement online regarding Plaintiff’s
daughter, he himself has done this, that is a fact.

I, Defendant Crystal Cox has not engaged in Extortion.

Defendant Eliot Bernstein, to my knowledge has never been charged with,
investigated nor found guilty of the crime of Extortion.

I Defendant Crystal Cox, have never solicited Plaintiff Marc Randazza or anyone else for money
to remove a blog post or to remove any of my investigative reporting articles / blog posts.

 I have never bought a domain name with the intent to ask for money from anyone that I report on.
I Defendant Crystal Cox have never had a criminal complaint filed against me for Extortion. I
Defendant Crystal Cox have never been on trial or investigated for Extortion. I Defendant Crystal
Cox am not guilty of extortion.

To my knowledge and upon my belief, Defendant Eliot Bernstein has not been on trial for extortion nor investigated for extortion, nor has there ever been a criminal complaint filed against Defendant Eliot Bernstein for the crime of extortion to my knowledge.

I, Defendant Crystal Cox Deny allegations that “Bernstein” has ever conspired with me,
Defendant Crystal Cox, or anyone else to my knowledge to extort or harass anyone.

Defendant “Bernstein” has not acted in conspiracy regarding said domain names, and received
said domain names in receivership in a prior case and is not a proxy in any way, nor has
Defendant “Bernstein” been an author on said blogs connected to said domain names.

I, Defendant Crystal Cox have not engaged in illegal or unlawful acts regarding domain
names in ANY way.

Pro Se Defendant Crystal Cox Defense Regarding Introduction Allegation 2.)

I, Defendant Crystal Cox have not “victimized” anyone in any bizarre pattern. I am Media, I
have reported on hundreds of people, corporations, companies, attorneys, cases, judges,
cops, victims, and businesses over 7 years in my online media, my alternative news.

My strategy for getting my online media, the stories I report on strong in the search engines is
not about making victims, it is simply the lawful method I use of being better and stronger in
the search engine then my competition, which is those competing for the same search
engine, keywords.

My stories, reporting, is not about baseless accusations, they are all
rooted in stories I read, depositions I have read, tips I have received, hearings I have
listened to or read, documents I have read and are never baseless.

I, Defendant Crystal Cox have never, EVER, informed anyone that I report on that I would

stop reporting on them if they paid me, that is a False Allegation I firmly DENY. I have never

“escalated” any reporting due to not being paid, and I have never been paid to STOP

reporting on ANYTHING.

Pro Se Defendant Crystal Cox Defense Regarding Introduction Allegation 3.)

U.S. District of Oregon Case Obsidian V. Cox was a Civil Case regarding Defamation

Allegations by a Bankruptcy Trustee and had NOTHING to do with Extortion, nor a Domain Name

Dispute in any way.

Pro Se Defendant Crystal Cox Defense Regarding Introduction Allegation 4.)

I, Defendant Crystal Cox object to allegations of engaging in pervasive link spamming and

cybersquatting against Plaintiff. I, Defendant Crystal Cox was simply reporting on, blogging

about, making fun of, criticizing, reviewing and making parody of Plaintiff.

Pro Se Defendant Crystal Cox Defense Regarding Introduction Allegation 5.) 6.)

I, Defendant Crystal Cox Did NOT buy MarcRandazza.com to extort money from Plaintiff. I

bought MarcRandazza.com the very day I had a phone conference with Plaintiff to be my

attorney and bought MarcRandazza.com to report on my Ninth Circuit appeal as I knew that

would be yet another search term in my case, once he began filing on my behalf.

I never, EVER named Plaintiff’s child on a blog or blog post ever. I have called Ms.

Randazza a Slut and have every constitutional right to do so.

I, Defendant Crystal Cox have never falsified “wrongdoings” to destroy Plaintiff’s

Reputation. Plaintiff has, however, done that to me in accusing me of Extortion in published

material.

I, Defendant Crystal Cox NEVER used MarcRandazza.com as a pay per click, nor ever

made money from this site in any way. When you buy a domain name from Godaddy, they

park the domain name and they place ads on the domain name. Ads in which Godaddy

receives revenue, not me, Defendant Crystal Cox.

I, Defendant Crystal Cox NEVER offered to clean up Plaintiff’s reputation. Nor had I written

a review or made fun of Plaintiff in any way when I asked for a job. I was no source of

negative content that I offered to remove, that is a false allegation.

I, Defendant Crystal Cox NEVER offered to remove anything I had posted, for I had posted

NOTHING on any blog about Plaintiff when I asked for a job. I posted on blogs later to

defend myself after Plaintiff, who was once acting as my attorney, defamed me, attacked

me and launched a hate campaign against me.

I, Defendant Crystal Cox never bought a domain name to pressure Plaintiff into do any

action what so ever. I, Defendant Crystal Cox never bought a domain name to tamper with

a witness.

I, Defendant Crystal Cox OBJECT to number 8.), I have never engaged in a scheme to

cyberfly, and never attempted to avoid domain name seizure. These domain names, if

anything, are at this point a liability. They cost a yearly fee to renew, plus they are the

subject of constant threats at this point, and certainly not anything to hide in a cyberfly

scheme, that is simply a false allegation.

I, Defendant Crystal Cox OBJECT to number 9.), I never offered the .me to Plaintiff, I

posted a here Kitty Kitty JOKE on my blog about 5 Million Dollars, it was a JOKE.

I, Defendant Crystal Cox Deny violations of the Anti­Cybersquatting Consumer Protection

Act.

I, Defendant Crystal Cox OBJECT to number 11.), 

I have every right to use the word Randazza in my blog names, titles and domain names. Plaintiff is saying this is not defamation and I have every write to my “opinion” yet Plaintiff and this court have already wiped out massive blogs, online content and censored my online speech without

adjudication of the First Amendment Issues at concern.

I, Defendant Crystal Cox have every right to push out my competition in a fair marketplace,

and to rant, and to have as many websites as I please, that is my constitutional right.

I, Defendant Crystal Cox have NOT violated Plaintiff’s Constitutional or Lawful Rights.

Plaintiff has, however violated mine.

Regarding Allegations in Number 13.) 

Claims Jurisdiction Due to the Lanham Act, yet the Lanham Act Does not Seem to Be a Cause of Action. Nevada State Laws do not have jurisdiction over my domain names, nor my blogs, nor my First Amendment Rights.

The First Amendment Rights at issue in this case must be Adjudicated before domain names

can be seized, blogs deleted, links broken, and intellectual property taken, irreparable damage

caused.

If this court deems Nevada to have jurisdiction, then these blogs can only be blocked for the

State of Nevada and NOT the entire world.

Venue and Jurisdiction is Improper. I Object to District of Nevada having Jurisdiction over this matter.

Pro Se Defendant Crystal Cox Defense Regarding Jurisdiction

I, Pro Se Defendant Crystal Cox OBJECT to District of Nevada having Jurisdiction over my

blogs, my rights, my domain names, my constitutional rights and Plaintiff’s allegations in this

matter.

Pro Se Defendant Crystal Cox Defense Regarding “The Parties”

I, Pro Se Defendant Crystal Cox OBJECT to Plaintiff being a Minor, this is unlawful,

unconstitutional and Immoral.

Also under “The Parties” is listed large amounts of Domain Names, .blogspot blog names. I, Pro

Se Defendant Crystal Cox OBJECT to Plaintiff having any right to said Domain Names in

any way. I, Pro Se Defendant Crystal Cox do not own any .blogspot blog, those are owned

by GOOGLE, I am a blog author, exercising my First Amendment Rights and do not own

blogspot in any way.

Regarding 22.) Eliot Bernstein is NOT a Proxy, nor has EVER been a proxy of any kind in regard

to Crystal Cox and has every legal right to own MarcJRandazza.com, FuckMarcRandazza.com,

MarcRandazzaSucks.com, and MarcRandazzaIsALyingAsshole.com. Plaintiff’s name or last

name is NOT a household name and Plaintiff has no Trademark on these Names, period.

There is no way that FuckMarcRandazza.com, MarcRandazzaSucks.com, and

MarcRandazzaIsALyingAsshole.com could be confusingly similar to Randazza Legal Groups

Blog or Website. They are obvious gripe sites, critical sites, against Plaintiff and no reasonable

reader would confuse them with Plaintiff’s commercial blog or website in ANY way.

Defendant Crystal Cox has a Legal Right to operate / own all domain names listed in number

20.) of this complaint, and none would be confused as to be Plaintiff’s commercial site.

There is absolutely no way that a reasonable reader or a neutral Jury would ever see

MarcRandazzSucks.com, FuckMarcRandazza.com, HypocriteMarcRandazza.com,

TrollMarcRandazza.com, MarcRandazzaisALyingingAsshole.com,

RandazzaLegalGroupSucks.com, as a “confusing” or similar tradename. There is no way that

those domain names would cause confusion as to the source and origin of the Services.

There is no way whatsoever that there is “likely to cause confusion as to the source and origin”

of “services” in regard to these and other domain names in connection with this case:

MarcRandazzSucks.com, FuckMarcRandazza.com, HypocriteMarcRandazza.com,

TrollMarcRandazza.com, MarcRandazzaisALyingingAsshole.com. There is a Clear,

NON­Confusing Objective on those Domain Names in which no reasonable reader could EVER

miss. And it has nothing to do with a confusing mark or confusing services.

It is Clear, Obvious and Blatant that Defendant Crystal Cox’s blogs are critical of Marc

Randazza, she is very vocal about her feelings and experience regarding Plaintiff Marc and her

personal experience with Plaintiff Marc Randazza, there is no confusing similarities, there is a

distinct difference between the blogs and domain names used for these blogs then a SERVICE

connected to Randazza Legal Group.

Defendant Crystal Cox also posts tips she gets from Industry Insiders, Sources, Whistle

Blowers as she is MEDIA. There is no Trademark or “Mark” Violation and NO Reader would

assume that I am trying to lure them in to sell a similar, commercial product or service. It is

Obvious, Blatant and not Confusingly Similar in ANY way

No domain name owned or ever purchased by Defendant Cox, is infringing on any Trademark

that Plaintiff has, in any way.

Regarding 24) and 26) Plaintiff does not have common law rights to the name Randazza. And if

this court claims that Plaintiff does, then surely this is only in the State of Nevada.

Marc Randazza goes by the Trade name “Marco Randazza” as his online Persona. Not Marc

Randazza. Plaintiff has NO Trademark on the name “Randazza” or “Marc Randazza”.

Regarding 28.) Defendant Crystal Cox has no domain “enterprise”. I am Media and I am

reporting on, making fun of, criticizing, making a parody of and speak out regarding Plaintiff Marc

Randazza, I have every lawful and constitutional right to due so.

Plaintiff Marc Randazza advertises as a Domain Expert, and did not own MarcRandazza.com,

my blogs are a public service to expose Plaintiff, make fun of Plaintiff, Parody Plaintiff and warn

the public at large.

Pro Se Defendant Crystal Cox Defense Regarding Allegation in number 29

Defendant Crystal Cox nor Defendant Eliot Bernstein have ever registered a domain name in

attempt to extort anyone. Defendant Crystal Cox nor Defendant Eliot Bernstein have never had a

criminal complaint filed against them for extortion, been on trial for extortion nor been convicted

of extortion. If Plaintiff feels he has been extorted by Defendant Crystal Cox nor Defendant Eliot Bernstein, then this would better be in a criminal complaint vs. a civil complaint.

MarcRandazza.me was bought as a joke, and not to PROFIT in any way. It was bought after

Plaintiff Filed a Defaming WIPO Complaint. It was offered for $5 Million just after it was

purchased by me, in a blog post titled Here Kitty Kitty, as a Parody, a Joke to all my Readers.

This domain name was never a blog or a site, and the only one who made money from it was

godaddy with the original purchase fee and the ads that Godaddy placed on the parked page.

Pro Se Defendant Crystal Cox Defense Regarding Allegation in number 30, 31

I, Defendant Crystal Cox DENY the allegation of commercial use. I, Defendant Crystal Cox

nor Defendant Eliot Bernstein have made commercial use of any domain names in this

complaint. Nor did I sell domain names to a third party. In Fact Plaintiff offered to buy

MarcRandazza.com from me and I flat out refused at any price as the record shows.

I, Defendant Crystal Cox have made no pay per click money from said domain names, any

ads on the parked pages were placed by Godaddy and not by Defendant.

I, Defendant Crystal Cox DENY the allegation in number 31). I have NOT used the said

domain name in bad faith, they were used to parody Plaintiff, report on the First

Amendment, Make fun of Plaintiff, Criticize Plaintiff, Report on Plaintiff and report on my

own legal case, of which Plaintiff was once in negotiations as my acting attorney.

I, Defendant Crystal Cox DENY the allegation in number 31) as having intent to profit, nor

did I use Plaintiff’s name to sell any Product.

Pro Se Defendant Crystal Cox Defense Regarding Allegation in number 32, 33

I Deny allegations of registering a domain name to get Plaintiff to purchase Reputation

Services, this is a FALSE Allegation. I never offered the domain name to Plaintiff EVER. I

refused to sell the domain name to Plaintiff, and never held it as some sort of “ransom” in

any way, period.

My domain names, blogs, were ALWAYS to parody Plaintiff, report on the First

Amendment, Make fun of Plaintiff, Criticize Plaintiff, Report on Plaintiff and report on my

own legal case.

I, Defendant Crystal Cox DENY the allegation in the footnotes of page 9 of this complaint

that i have engaged in ANY extortion scheme. I have NOT EVER engaged in ANY extortion

scheme. I have never extracted money from anyone I report on, nor collected fees for “other

third parties”.

I, Defendant Crystal Cox object to number 33 state the “clear meaning”.. that is speculative

and not based in ANY fact. I never claimed that I would buy any domain name or post

anything online if Plaintiff did not pay me, this is false and fraud on the courts.

I, Defendant Crystal Cox asked Marc Randazza for a job at one point or if he knew anyone

that need a search engine marketing expert, he said he did not mind me asking and

demanded the domain name I had bought when he was to be my attorney for my PR on my

Ninth Circuit appeal, I said I did not want to sell the domain name and he launched a

massive, vindictive, retaliation campaign against me. 

I bought domain names and started blogs to report on this story, to report on him, to warn others what he had done to me, to review his business, to gripe about him, to parody him, to criticize him and in NO way to Extort him in any way.

I, Defendant Crystal Cox have every right to buy and to own the domain name

FuckMarcRandazza.com and MarcRandazzaSucks.com ­ they were not purchased to

extort nor to flood the internet with untruthful information. They were AGAIN purchased to to

report on this story, to report on Plaintiff, to warn others what he had done to me, to review

his business, to gripe about Plaintiff, to parody him, to criticize him and in NO way to Extort

him in any way.

I, Defendant Crystal Cox never bought a domain name to intimidate Marc Randazza, that is

absurd, Plaintiff would never be intimidated by a purchasing of a domain name. I,

Defendant Crystal Cox never bought a domain name to interfere with a witness or to stop

Plaintiff from testifying in Obsidian V. Cox’s asset probe. As the record shows, I even filed

questions I hoped to ask Plaintiff Marc Randazza and to this day have no idea how he got

out of that deposition after he was subpoenaed to attend.

I, Defendant Crystal Cox have never purchased a domain name to HARASS Plaintiff.

I, Defendant Crystal Cox object to Plaintiff’s attempt to single me out as the only blogger

the only media to NOT be able to use his last name in blogs, especially when Plaintiff has

blogs in my name and reports on, blogs on me and uses my personal name to do so.

I, Defendant Crystal Cox have NOT harassed Plaintiff’s Family in any way. I have simply

exercised my First Amendment Rights and have spoke out about my grievances with

Plaintiff on keyword rich blogs and domain names. I have every lawful and constitutional

right to do so.

Pro Se Defendant Crystal Cox Defense Regarding Allegation in number 41, 42

I, Defendant Crystal Cox have not used domain names to harass and intimidate Plaintiff

nor to harm his family or his business, as stated above, domain names and blogs were to

gripe, parody, report on, make fun of and review Plaintiff. I have every constitutional right to

do so.

I, Defendant Crystal Cox have never had a blog regarding a Janelle Randazza and do not

even know who that is. I have never had a blog regarding a three year old child, that is a

FALSE allegation as well.

Plaintiff Marc Randazza posted pictures of his child on his blog and gave pictures to

Forbes, I posted NO pictures nor did I have a blog regarding Plaintiff’s child.

Any pictures of Marc Randazza’s wife were from Marc Randazza’s blog. If Jennifer

Randazza was a private citizen then Marc Randazza should not have had a blog post with

her picture and a mixed drink, talking about a drunken tryst and where babies come from.

My blog was making fun of Marc Randazza’s post on his own wife, it was his picture, NOT

mine. I, Defendant Crystal Cox have every right under the First Amendment to Call Marc

Randazza’s wife a SLUT.

I, Defendant Crystal Cox never got into the search engines nor had a blog regarding the

“toddler” discussed in number 42.

Per Footnote on Page 12, I, Defendant Crystal Cox do fully believe that Plaintiff Marc J.

Randazza is involved in organized crime and has insiders at Google and Godaddy who do

what he wants and violates the rights of his “marks”

Regarding Allegations in Number 46.)

Plaintiff Marc Randazza’s loss of control over his reputation and goodwill has had NOTHING to

do with Defendant Crystal Cox nor Defendant Eliot Bernstein. Plaintiff has not suffered any

damages regarding Defendant Crystal Cox nor Defendant Eliot Bernstein.

Plaintiff has NO Trademark on the Name “Randazza”

There is no ™ on Marc Randazza’s Blog. And there was no proof given to WIPO of Marc

Randazza’s “given name” as I believe his birth name is Marco Randazza and not Marc

Randazza. Also note that this Marc Randazza is not the only Marc Randazza in the world and

should not have a right to steal this intellectual property as the only rightful owner in the world.

On belief and knowledge of Defendant Crystal Cox, Plaintiff Marc Randazza has Criminally

and Civilly Conspired with INTA, Peter L. Michaelson, WIPO and John and Jane Does

Regarding the name “Marc Randazza and Fraudulent Trademark Claims.

Regarding Trademark issues, Defendant, Attorney Marc Randazza uses Marco Randazza as

his Twitter and YouTube User Name, as well as his username on his own blog. As Seen In

Exhibit Q. Defendant, Attorney Marc Randazza had no ™ posted at his blog regarding the

name Marc Randazza as beign trademarked and Plainiff Attorney Marc Randazza had no

Trademark when purchased Defendant Crystal Cox purchased MarcRandazza.com to use as

PR for Defendant Crystal Cox’s highly public First Amendment Case.

Marc Randazza has no common law trademark on his website, he had no Trademark when I

purchased the domain names yet seems to have convinced WIPO that he is the rightful owner

and has stolen several domain names from myself and Defendant Eliot Bernstein of iViewit

Technologies.

Marc Randazza had no lawful Trademark on the name Marc Randazza at the time Blogger

Crystal Cox purchased Domain Names, nor at the Time iViewit Technology Eliot Bernstein

received Domain Names in Receivership.

Even if Plaintiff Could prove a Trademark, Defendants First Amendment Rights TRUMP

Trademark Rights in this case.

Regarding Plaintiff’s Discussion of the Lanham Act, Though it does not seem to be a

cause of action, Plaintiff lists Lanham in this complaint at various points.

The Supreme Court has recognized the threat to freedom of speech. In Cohen v. California,

403 U.S. 15, 25, 91 S.Ct. 1780, 1788, 29 L.Ed.2d 284 (1971), it was decided that the right

to speak freely that is guaranteed by the First Amendment to the Constitution of the United

States includes the right to criticize others, voice highly controversial opinions, and

comment on public interest matters.

The First Amendment also protects free speech of extreme statements and intentional

exaggeration when it is clear the statements are insincere and done to frustrate the target,

and is not defamation but opinion, satire, or parody.

In Hustler Magazine v. Falwell; Parody is NOT Defamation. There are many other cases in

which discuss that Parody and Satire is not a Trademark or Defamation Issue. Plaintiff /

Counter Defendant Marc Randazza DEFENDS Satire and Parody Blogs, Sites, Domain

Names, Content, Radio, Television and More, Constantly,

YET he has committed Fraud on the courts in SEIZING MarcRandazaSucks.com,

FuckMarcRandazza.com, MarcRandazzaParody.com, RandazzaLegalGroupSucks.com

and other Domain Names and dot blogspots were clearly to express free speech, parody,

critisize, speak freely, voice highly controversial opinions, and comment on public interest

matters. 

As was MarcRandazza.com, and all the other blogs, .blogspot and Domain

Names, in which this court and WIPO illegally, unconstitutionally SEIZED in favor of Plaintiff

Marc Randazza. WITHOUT first adjudicating the First Amendment Issues.

The first step with free speech and the First Amendment and trademark law is whether the

speech in question is commercial or noncommercial. Commercial speech is bound by the

laws of the Lanham Act and is subject to less and sometimes no First Amendment

protection.

Noncommercial speech is not bound by the Lanham Act or trademark law, and is

guaranteed complete and full First Amendment protection. In fact, trademark law

specifically exempts noncommercial speech so that the law will not infringe on the First

Amendment. One case that supports this paragraph is Taubman Co. v. Webfeats, 319

F.3d 770, 774­75 (6th Cir. 2003). Another supporting precedent is Nissan Motor Co. v.

Nissan Computer Corp., 378 F.3d 1002, 1015­18 (9th Cir. 2004).

Pro Se Defendant Crystal L. Cox and Defendant Eliot Bernstein have made no money from

the Seized Domain names. Pro Se Defendant Crystal L. Cox, is an Investigative Blogger, a

Media Defendant and was giving Plaintiff Marc Randazza a bad review as she was a

former client of Plaintiff Marc Randazza.

Pro Se Defendant Crystal L. Cox was reporting on / blowing the whistle on / investigative

blogging on organized crime, porn industry hookers and human trafficking, video

technology infringement (iViewit), gang stalkings, threats of violence, intellectual property

theft, civil rights violations, civil and criminal conspiracy and more allegedly involving

Plaintiff Marc Randazza and his Clients.

There are many cases supporting that negative consumer commentary is core speech

protected by the First Amendment. Another case supporting this is, Bose Corp. v. Consumers

Union, 466 U.S. 485 (1984) Many other cases treat criticisms of a company, their business

practices, products and services, as speech protected by the First Amendment. Criticism would

be pointless if the person cannot name the company they are bashing by using its trademarks.

The Fourth Circuit explained that just because speech is critical of a corporation or company and

its business practices, it is not a sufficient reason to prevent or enjoin the speech. 

If a trademark owner could “enjoin the use of his mark in a noncommercial context found to be negative or offensive, than a corporation could shield itself from criticism by forbidding the use of its name in commentaries critical of its conduct.” CPC Int’l., Inc. v. Skippy Inc., 214 F.3d 456, 462 (4th Cir. 2000) (quoting L.L. Bean v. Drake Publishers, 811 F.2d 26, 33 (1st Cir. 1987)).

Pro Se Defendant Crystal L. Cox as every lawful and constitutional right to criticize Plaintiff Marc

Randazza and his Law Firm Randazza Legal Group. Just because speech is critical of a

corporation or company and its business practices, it is not a sufficient reason to prevent or

enjoin the speech and wipe out massive blogs, links, domain names and content of Investigative

Blogger Pro Se Defendant Crystal L. Cox.

Congress has decided that the Lanham Act ONLY applies to commercial speech. Under

§ 43 (15 U.S.C. §1125) explicitly defines that noncommercial use is not actionable. “The

following shall not be actionable under this section: . . .

(B) Noncommercial use of the mark.”

Pro Se Defendant Crystal L. Cox and Defendant Eliot Bernstein, had not commercial motives or

"speech" soliciting money in regard to blogs, domains, online media, investigative news blogs in

which exposed, created parody and satire, criticized, reviewed, report on Plaintiff / Counter

Defendant Marc Randazza and his Clients, Co­Conspirators, Counter Defendants.

Plaintiff Marc Randazza have used the Lanham Act to Suppress Free Speech, Intimidate a

Reporter / Whistleblower, and to Steal Massive Content / Intellectual Property AND to Eliminate Search Engine Competition for FREE.

15 U.S.C. § 1125(a) (1). The Lanham Act defines “use in commerce” as meaning “bona fide use

of a mark in the ordinary course of trade,” such as using the mark in conjunction with services or

goods in commerce. 15 U.S.C. § 1127. Without “use in commerce” “in connection with goods

and services,” there is no trademark infringement. Int’l Bancorp, LLC v. Societe des Bains de

Mer et duInternational Bancorp, LLC, 329 F.3d 359, 363 (4th Cir. 2003); People for Ethical

Treatment of Animals (PETA) v. Doughney, 263 F.3d 359, 365 (4th Cir. 2001); see also S. Rep.

No. 100­515, at 44 (1988), reprinted in 1988 U.S.C.C.A.N. 5577, 5607 (“Amendment of the

definition of ‘use in commerce’ [in § 45 of the Lanham Act) is one of the most far­reaching

changes the legislation contains. . . .

The committee intends that the revised definition of ‘use in commerce’ be interpreted to mean

commercial use which is typical in a particular industry.”). Basically, the Lanham act excludes all

noncommercial speech. Nissan, 378 F.3d at 1016­17; see also TMI, Inc. v. Maxwell, 368 F.3d

433, 436­38 (5th Cir. 2004), and even excludes commercial speech that does not use marks “in

connection with goods or services.” PETA, 263 F.3d 359, 365 (4th Cir. 2001).

First Amendment Rights And Constitutional Law trump Trademark law.

The first step with free speech and the First Amendment and trademark law is whether the

speech in question is commercial or noncommercial. Commercial speech is bound by the laws

of the Lanham Act and is subject to less and sometimes no First Amendment protection.

Noncommercial speech is not bound by the Lanham Act or trademark law, and is guaranteed

complete and full First Amendment protection. In fact, trademark law specifically exempts

noncommercial speech so that the law will not infringe on the First Amendment. One case that

supports this paragraph is Taubman Co. v. Webfeats, 319 F.3d 770, 774­75 (6th Cir. 2003).

Another supporting precedent is Nissan Motor Co. v. Nissan Computer Corp., 378 F.3d 1002,

1015­18 (9th Cir. 2004).

Despite many corporations using intimidation to try to silence people from speaking their minds

and using lawsuits, and threats of lawsuits, the Constitution continuously protects free speech.

It excludes commercial speech precisely for the purpose of avoiding infringement of First

Amendment rights. Taubman, 319 F.3d at 774­75 (6th Cir. 2003); Nissan, 378 F.3d at 1016­17.

Thus, when an action is brought against a noncommercial use of a trademark for either political

or consumer commentary, such as the SLAPP cases with Walmart, Starbucks, and others, the

courts do not usually hesitate to grant the defendant full First Amendment protection by holding

that trademark law does not apply and that First Amendment protects such speech. See CPC

Int’l, 214 F.3d at 461­64 (4th Cir. 2000); Nissan, 378 F.3d at 1017­18 (9th Cir. 2004); L.L. Bean,

811 F.2d at 33.

Noncommercial Speech Is NOT Subject to Trademark Law AND Is Fully Protected by the First

Amendment. Trademark law explicitly exempts noncommercial speech such as the alleged

emails and website(s) precisely so that the law will not run afoul of the First Amendment.

Taubman, 319 F.3d at 774 (6th Cir. 2003); Nissan, 378 F.3d at 1016­17 (9th Cir. 2004).

Numerous cases show that consumer commentary is core speech protected by the First

Amendment. See, e.g., Bose Corp. v. Consumers Union, 466 U.S. 485 (1984) (New York Times

standard applied in libel action brought by a manufacturer claiming that consumer group had

maligned its product). Many other cases similarly treat criticisms of a company’s products or

business practices as speech protected by the First Amendment. 

The criticisms would be pointless if they did not identify the company they were criticizing and by using its trademarks.

The Fourth Circuit explained: This is an admittedly partisan account  and one that vexes [the

plaintiff]. Yet just because speech is critical of a corporation and its business practices is not a

sufficient reason to enjoin the speech. As the First Circuit stated, if a trademark owner could

“enjoin the use of his mark in a noncommercial context found to be negative or offensive, then a

corporation could shield itself from criticism by forbidding the use of its name in commentaries

critical of its conduct.” CPC Int’l., Inc. v. Skippy Inc., 214 F.3d 456, 462 (4th Cir. 2000) (quoting

L.L. Bean v. Drake Publishers, 811 F.2d 26, 33 (1st Cir. 1987)). Congress has therefore limited

the application of the Lanham Act to commercial speech. First, § 43(c) expressly excludes non

commercial use of marks from the entire section’s reach: “The following shall not be actionable

under this section: . . . (B) Noncommercial use of the mark.” 15 U.S.C. § 1125(c) (4) (emphasis

added). Section (c) (4) was added to the Act when it was amended in 1989. The House Judiciary

Committee made explicit that the purpose was to avoid any impact on noncommercial speech:

The proposed change in Section 43(a) should not be read in any way to limit political speech,

consumer or editorial comment, parodies, satires, or other constitutionally protected material.

Noncommercial Speech Is NOT Subject to Trademark Law. Ads placed on Domain Names and

Blog in this case, as Plaintiff Marc Randazza knows full well, being an Expert in the Industry, are

placed by Google and by GoDaddy and that Pro Se Defendant Crystal L. Cox and Defendant

Eliot Bernstein have no control over such ads, and are not involved in a commercial endeavor in

REPORTING on Plaintiff Marc Randazza and his Clients, and in reporting on the biggest

Technology Theft in the WORLD, iViewit Technology, and it’s Founder, Inventor Eliot Bernstein.

Plaintiff Marc Randazza has no Trademark on the name Marc Randazza, yet this court

simply favored Plaintiff Marc Randazza and gave him what he wanted, and has thereby

PERMANENTLY altered the search engines, removed content on massive blogs, changed

thousands of links, and deleted blog / intellectual property of Pro Se Defendant Crystal L.

Cox and Defendant Eliot Bernstein.

Plaintiff / Counter Defendant Marc Randazza has no Trademark on the name Marc

Randazza, yet this court simply favored Plaintiff Marc Randazza and gave him what he

wanted, and has thereby PERMANENTLY altered the search engines, removed content on

massive blogs, changed thousands of links, and deleted blog / intellectual property of Pro

Se Defendant Crystal L. Cox and Defendant Eliot Bernstein.

Regarding Cause of Action (1) Violation of Individual Cyberpiracy

Protections under 15 U.S.C. § 8131;

Pro Se Defendant Crystal Cox DENIES a Violation of Individual Cyberpiracy Protections under 15

U.S.C. § 8131; Defendant ReAlleges all previous Paragraphs in Full.

I, Defendant Crystal Cox Deny registering infringing domain names.

I, Defendant Crystal Cox Deny registering any domain names associate with Plaintiff with a

specific intent to profit in any way, nor in “bad faith”.

I, Defendant Crystal Cox Deny accusations of attempting to monetize on Plaintiff’s name in any

way.

I, Defendant Crystal Cox Did not register any domain name regarding Plaintiff in attempt to solicit

business of any kind from Plaintiff.

I, Defendant Crystal Cox state that Plaintiff is not entitled to any relief regarding Violation of

Individual Cyberpiracy Protections under 15 U.S.C. § 8131; because there was no damage done

to plaintiff and there was no violation of this law

I, Defendant Crystal Cox did not register any domain name regarding Plaintiff with the intent to

profit and rejected offers to sell domain names. The Here Kitty Kitty, post was a JOKE, no one

would pay 5 Million for a Domain Name such as that, bought just days before and with no value

created. I have NEVER purchased a domain name associated with Plaintiff’s name with intent to

sell and profit, proven by my rejection of Plaintiff’s offer to buy domain name.

I, Defendant Crystal Cox bought said domain name to review Plaintiff as my attorney, to

reporting on Plaintiff, to blog on Plaintiff, poke fun at Plaintiff, criticize Plaintiff, report on first

amendment cases and making parody blogs about Plaintiff

I, Defendant Crystal Cox bought said domain name in good faith and under my constitutional

rights. And have NOT violated Individual Cyberpiracy Protections under 15 U.S.C. § 8131;

Plaintiff Marc Randazza has no Trademark on the Name Randazza or Marc Randazza.

Regarding Cause of Action (2) and (3)

Violation of Individual Cyberpiracy Protection ­ 15 U.S.C. 8131

Pro Se Defendant Crystal Cox DENIES a Violation of Individual Cyberpiracy Protection ­ 15

U.S.C. 8131

Defendant Crystal Cox did not buy said domain names with intent to profit.

I, Defendant Crystal Cox deny allegations of engaging in pervasive link spamming and

cybersquatting against Plaintiff. I, Defendant Crystal Cox was simply reporting on, blogging

about, making fun of, criticizing, reviewing and making parody of Plaintiff.

I, Defendant Crystal Cox did not offer to sell domain names to Plaintiff, in fact I rejected

Plaintiff’s offer to buy domain names as the record shows.

I, Defendant Crystal Cox did not offer to repair any damage that I had allegedly done to

Plaintiff. When I asked Plaintiff for a job, I, Defendant Crystal Cox had not written a word on

my blogs regarding Plaintiff. When Plaintiff attacked me online line, accused me of criminal

activity (Extortion), defamed and attacked me, 

I, Defendant Crystal Cox used my domain names to expose Plaintiff, make fun of Plaintiff, and warn others of Plaintiff who had been my attorney in negotiations regarding Obsidian V. Cox.

I, Defendant Crystal Cox did not instigate a scheme to smear Plaintiff. 

I, Defendant Crystal Cox exercised my first amendment right to speak out against Plaintiff, Criticize Plaintiff, Parody Plaintiff and warn others of his behavior from my personal experience, and to post

tips I received from whistle blowers regarding Plaintiff.

I, Defendant Crystal Cox never engaged in an extortion scheme, nor any other avenue of

profit regarding Plaintiffs alleged “mark”.

I, Defendant Crystal Cox have not damaged Plaintiff’s nor violated Individual Cyberpiracy

Protection ­ 15 U.S.C. 8131, and Plaintiffs are not entitled to relief of any kind.

Regarding Cause of Action (4) (5)

Cybersquatting under 15 U.S.C. § 1125(d);

Pro Se Defendant Crystal Cox DENIES a Violation of "Cybersquatting under 15 U.S.C. §

1125(d)" Defendant ReAlleges all previous Paragraphs in Full.

Domain Names and blogs were not used for commercial purposes, and were NOT purchased with

ANY intent to Profit whatsoever. Defendant has not engaged in Extortion with Plaintiff nor anyone Else.

Defendant has not been under criminal investigation for Extortion and has not violated Cybersquatting under 15 U.S.C. § 1125(d).

There is no false designation of Origin, or confusion of any kind to any reasonable reader of these blogs or sites, or use of said domain names. The Origin is clear that the blog author is criticizing, mocking, making a parody of, reporting on, and giving their opinion of Plaintiff Marc Randazza and his cases, as he is a Public Figure.

There is no confusion of similar goods or services offered, no commercial advertising or promotions,

and no misrepresentation in any way that would confuse a reader that my blogs were connected to

Randazza Legal Group, or a similar product or service.

(d) Plaintiff has no “mark” ownership, has no Trademark on the name Randazza or Marc Randazza.

Defendant Crystal Cox had no bad faith, and no intent to profit from the alleged “mark”.

Plaintiff has No Trademark and Defendant has Not “trafficked” in infringing domain names regarding Plaintiff’s Trademark. Defendant Crystal Cox has not registered domain names to prevent

Plaintiff from buying said domain names. Plaintiff had over a decade to buy

MarcRandazza.com and as far as the other domain names go, Plaintiff would never have

bought those domain names to do business as Attorney Marc J. Randazza of Randazza

Legal Group.

Pro Se Defendant Crystal Cox has not registered domain names nor blogs names in bad

faith to profit from Plaintiff’s alleged “mark”.

In the Motion for Summary Judgement in this case, Plaintiff states that he does not have a Trademark on the name Randazza or Marc Randazza and therefore this Legal Action is Moot and should be

dismissed. Plaintiff admits to having no Trademark as seen in the Motion for Summary Judgement filed against Defendant Crystal Cox. All through this Complaint Plaintiff accuses Defendant of infringing on his Mark, yet admits in a Motion for Summary Judgement that he has no “Trademark”, no “Mark” Regarding Cause of Action (6) Right of Publicity ­ NRS 597.810;

Pro Se Defendant Crystal Cox DENIES a Violation of "Right of Publicity" ­ NRS 597.810.

Defendant ReAlleges all previous Paragraphs in Full.

Right of Publicity under Nevada Revised Statute 597.810 does not apply to all Internet

activity in all states, this would only apply to those in the State of Nevada viewing my blogs on

Nevada Web Servers.

Defendant Crystal Cox had no unauthorized commercial use of said blogs.

Plaintiff has no lawful right to Injunctive Relief. 

Defendant Crystal Cox has First Amendment rights to own and operate said blogs and domain names. Injunctive Relief is unconstitutional. The Constitution of the United States Trumps Nevada Revised Statute 597.810.

Regarding Cause of Action (7) Common Law Right of Publicity

Pro Se Defendant Crystal Cox DENIES a Violation of "Common Law Right of Publicity.

Defendant ReAlleges all previous Paragraphs in Full.

I, Pro Se Defendant Crystal Cox did not registered domain names or blogs to compete

with Plaintiff to my commercial advantage.

I, Pro Se Defendant Crystal Cox have had no extortion scheme in any way. Plaintiff has no

protected Trademark on the name Randazza or Marc Randazza.

I, Pro Se Defendant Crystal Cox have never had an unlawful enterprise of ANY kind.

I, Pro Se Defendant Crystal Cox have never had a financial gain regarding Plaintiff’s name.

Regarding Cause of Action Common Law Right of Intrusion Upon Seclusion;

(Please Note Complaint Says Cause of Action Sixth, However there is already a Cause of

Action 6 and X means 10, yet this is number 8.

Pro Se Defendant Crystal Cox DENIES a Violation of "Common Law Right of Intrusion Upon

Seclusion". Defendant ReAlleges all previous Paragraphs in Full.

I, Pro Se Defendant Crystal Cox have never posted a picture of Plaintiff’s daughter on any

blog, nor have I, Pro Se Defendant Crystal Cox written a word regarding Plaintiff’s daughter

or had a blog regarding Plaintiff’s Daughter. Plaintiff, himself gave Forbes Reporter

Kashmir Hill pictures of his daughter and she posted those photos on Forbes, Plaintiff

posted photos on his blog of this child. I, Pro Se Defendant Crystal Cox did now use the

child’s name nor photo in any blog.

Plaintiff Jennifer Randazza has photos online of her fashion, and Plaintiff Marc Randazza has photos of her on his own blog. I have name called and reported on Plaintiff Jennifer Randazza and have every constitutional right to do so, and have never done so for commercial reasons.

I, Pro Se Defendant Crystal Cox have called Plaintiff Jennifer Randazza a Slut, and this was after Plaintiff Marc Randazza went on CNN and other publications to defend Rush Limbaugh for calling Sandra Fluke a slut, which was, at the time a highly political topic in mainstream media. I also had just read a post on Plaintiff Marc Randazza’s blog regarding a drunken tryst and knocking Jennifer up, so he may as well marry her. Yes, I called Plaintiff Jennifer Randazza a Slut.

I, Pro Se Defendant Crystal Cox have never used Plaintiff’s daughters name in any crusade

to extort Plaintiff or anyone else.

Regarding Cause of Action (9) Civil Conspiracy.

Complaint Call It XI. Seventh Cause of Action

Pro Se Defendant Crystal Cox DENIES a Violation of "Civil Conspiracy". Defendant ReAlleges all

previous Paragraphs in Full.

I, Pro Se Defendant Crystal Cox have never engaged in any kind of Criminal Conspiracy with

Eliot Bernstein or anyone else ever.

I, Pro Se Defendant Crystal Cox respectfully state that all of the below listed

documents have pertinent and important information regarding this case and the

reasons Plaintiff filed this case, and I request that ALL prior documents be

considered as included in this Court Ordered Amended Complaint Answer

I, Pro Se Defendant Crystal Cox respectfully Re­Submit / Re­Allege in FULL all following

paragraphs, statements, documents of this case thus far with this Complaint Answer and with it I

Reallege all I, Pro Se Defendant Crystal Cox / Pro Se Counter Plaintiff stated in ALL prior

motions in this lawsuit, included and not limited to my Original Complaint Answer, My Motion in

Opposition of Ex Parte Motion, My Motion for Removal / Reclusal / Disqualification of Judge

Gloria Navarro, My Motion Requesting a Protective Order, My Motion to Notify Auditors, My

REPLY to Response to 2 MOTION for Temporary Restraining Order, My MOTION to Request

This Court Investigate Plaintiff Marc Randazza,

Also; my Original Counter Claim, my Amended Counter Claim, my RESPONSE to 2 MOTION

for Temporary Restraining Order, my MOTION Motion Requesting Plaintiff Inform Insurance

Providers of Liability, Seek Outside Counsel, and Disclosing Malpractice Issues, regarding

Plaintiff Randazzas Ex­Client Defendant Crystal Cox, and case related issues, my REPLY to

Response to 47 MOTION for Protective Order filed by Counter Claimant Crystal L Cox,

Also; Counter Defendant Crystal L Cox, ADDENDUM to REPLY to Response to 47 MOTION for

Protective Order, my Court Notice of Emergency Notice to Court of Violent Actions of Counter

Defendant Ari Bass aKa MIchael Whiteacre and Sean Tompkins. Protective Ordered Requested,

my MOTION/APPLICATION for Leave to Proceed in forma pauperis, REPLY to Response to 60

First MOTION Requesting Court Notify Investigators/Authorities Regarding Suspected Criminal

Actions/Activities of Plaintiff Marc Randazza and Counter­Defendants/Co­Conspirators, my

Motion for Summary Judgement against Plaintiff, Memorandum to my Summary Judgement

against Plaintiff, Motion to File In Forma Paupus, 

Reply to Opposition of Forma Paupus, Motion to Sanction Marc J. Randazza and Ronald D. Green, Reply to Response to Motion to Sanction, Counter Complaint, Amended, and all motions, addendums and exhibits previously filed in this case, as they have lots of factual, pertinent, relevant information in my defense and in this case as a whole.

Note To Court: This Court has DENIED requests to sign a conflict of Interest Disclosure,

though requested several times by Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox.

Any action forward by Judge Gloria M. Navarro or Judge Peggy A. Leen, who refuses to

admit/deny conflicts and rules forward will be charged with Obstruction of Justice through

conflicts of interest, violations of attorney and judicial cannons in order to Deny Due Process via

aiding and abetting the alleged civil and criminal conspiracy through Fraud on the Court.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox intend to file criminal complaints

against any officer of the court, including opposing counsel, who violates any law or ethical

statues in order to perpetrate the fraud through obstruction via conflicts, or has violated any law

already in previous rulings affecting me, Pro Se Defendant, Pro Se Counter Defendant Crystal

Cox.

Therefore every ruling of this court on a motion without conflict disclosure will be charged for

each and every act a in a criminal complaint, forthcoming.

Judge Gloria Navarro is alleged by Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox to be

acting in criminal and civil conspiracy with Plaintiff / Counter Defendant Marc J. Randazza and

ALL Connected Co­Conspirators and Counter Defendants of District of Nevada Case

2:12­cv­02040­GMN­PAL and therefore this court has a duty to notify all applicable authorities,

bond carriers, insurance carriers, AND State and Federal Auditors of the liability of this allegation

in a Federal Court Proceeding.

Judge Gloria Navarro refuses to disqualify herself and has conflict with the Plaintiff. Judge Gloria

Navarro consistently gives Plaintiff unconstitutional Preliminary Injunctions. The Righthaven

case, Liberty Media V. Magnus, and Viaview are recent cases where Judge Gloria Navarro has

favored Plaintiff.

Plaintiff is a Nevada Attorney and is believed to have mafia connections. Judge Gloria Navarro

has violated my rights and has not treated me fairly or equal under the law or the Constitution of

the United States.

I once again request that Judge Gloria Navarro and all making decision in this case sign a

Conflict of Interest Disclosure admitting or denying conflict. It is the law and it is my legal and

constitutional right. I have a lawful right to an impartial judge.

Defendant Crystal Cox has a right to be heard and a right to due process of law. 

This court continues to deny my lawful and constitutional rights. I have the right of a Defense, and of a counter claim and my intellectual property, blogs, domain names and voice have Been taken by

this court, repeatedly. This court has allowed my life to put in danger and has taken all my rights.

I, Pro Se Defendant Crystal Cox specifically Invoke the following laws, statutes, nd

constitutional amendments in my Defense in this case.

Laws Specifically Invoked by Defendant Crystal Cox in Her Defense.

Defendant Crystal Cox Specifically Invokes Anti­Slapp Laws, Nevada SLAPP Statutes.

This Lawsuit was filed frivolously and has cost taxpayer and defendants.

Defendant Crystal Cox Specifically Invokes the First Amendment of the United States

Constitution. can be seized, blogs deleted, links broken, and intellectual property taken,

irreparable damage caused. The First Amendment Rights at issue in this case must be

Adjudicated before domain names.

Defendant Crystal Cox Specifically Invokes the Fourteenth Amendment of the United States

Constitution.

Defendant Crystal Cox Specifically Invokes Anti­Trust Laws, the Sherman Act, Fair Competition

Laws, as Plaintiff is interfering with fair competition with search engine results.

Defendant Crystal Cox Specifically Invokes The Fair Competition Act (FCA), The Sherman

Antitrust Act (1890), Antitrust Policy and Competition.

Defendant Crystal Cox Specifically Invokes all Freedom of Speech Laws. Freedom of speech is

the political right to communicate one's opinions and ideas.

The right to freedom of expression is recognized as a human right under Article 19 of the

Universal Declaration of Human Rights and recognized in international human rights law in the

International Covenant on Civil and Political Rights (ICCPR). 

Article 19 of the ICCPR states that "[e]veryone shall have the right to hold opinions without interference" and "everyone shall have the right to freedom of expression; this right shall include freedom to seek, receive and impart information and ideas of all kinds, regardless of frontiers, either orally, in writing or in print, in the form of art, or through any other media of his choice".

Defendant Crystal Cox Specifically Invokes Nevada Retraction Laws in her Defense. As Plaintiff

did not ask for a retraction before filing a frivolous and costly lawsuit.

Defendant Crystal Cox Specifically Invokes ALL Malpractice Laws as Plaintiff was Defendants

Attorney in related matters.

I, Defendant Crystal Cox Declare the following Cases Connected to This Case

(this is important for any future RICO Legal Action and the Public at Large)

Case 2:12­cv­02040­GMN­PA District of Nevada is connected to Case CV­11­57­HZ U.S.

District Court District of Oregon, Case 2:12­mc­00017­JPH Eastern District of Washington

Circuit Court of Oregon Multnomah County Case No. 121215329 and Ninth Circuit Appeal

Case: 12­35319. All case dockets, documents, exhibits are hereby included in this case as

evidence of criminal and civil conspiracy. Also this case is related to Rakofsky V. The

Internet a New York Case with same people involved.

Respectfully Submitted

Investigative Blogger Crystal L. Cox

Pro Se Defendant Crystal Cox

Case 2:12­cv­02040­GMN­PAL"

Source

http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.90.0.pdf

Here is the Complaint

http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.1.0.pdf

Full Docket

http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.docket.html

District of Nevada Trademark Case, Lanham Act, used to Suppress and Chill Speech and Violate First Amendment Rights. Crystal Cox Objection to Summary Judgement.

Document 80, District of Nevada Trademark Case, Lanham Act, used to Suppress and Chill Speech and Violate First Amendment Rights.

Defendant Crystal Cox’s OBJECTION to
Plaintiff’s MOTION FOR SUMMARY JUDGMENT

"Notice To Court: This Court has DENIED requests to sign a conflict of Interest

Disclosure, though requested several times by Pro Se Defendant / Pro Se Counter Plaintiff

Crystal L. Cox. Any action forward by Judge Gloria M. Navarro or Judge Peggy A. Leen, who

refuses to admit/deny conflicts and rules forward will be charged with Obstruction of Justice

through conflicts of interest, violations of attorney and judicial cannons in order to Deny Due

Process via aiding and abetting the alleged civil and criminal conspiracy through Fraud on the

Court.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox intend to file criminal complaints

against any officer of the court, including opposing counsel, who violates any law or ethical

statues in order to perpetrate the fraud through obstruction via conflicts, or has violated any law

already in previous rulings affecting me, Pro Se Defendant, Pro Se Counter Defendant Crystal

Cox.

Therefore every ruling of this court on a motion without conflict disclosure will be charged for

each and every act a in a criminal complaint, forthcoming.

Judge Gloria Navarro is alleged by Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox to be

acting in criminal and civil conspiracy with Plaintiff / Counter Defendant Marc J. Randazza and

ALL Connected Co-Conspirators and Counter Defendants of District of Nevada Case

2:12-cv-02040-GMN-PAL and therefore this court has a duty to notify all applicable authorities,

bond carriers, insurance carriers, AND State and Federal Auditors of the liability of this allegation

in a Federal Court Proceeding.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox object to Plaintiff’s MOTION

FOR SUMMARY JUDGMENT.

Plaintiff Claims I have not disputed facts, when I, Pro Se Defendant / Pro Se Counter Plaintiff

Crystal L. Cox have disputed Plaintiff’s Allegations over and over to the absolute best of my

ability. Plaintiffs / Counter Defendants have not Disputed ONE Allegation I have Claimed against

them in my Counter Complaint, however.

Plaintiff has not made one valid point of law in which entitles them to a Summary Judgement,

instead Plaintiff has used this MOTION FOR SUMMARY JUDGMENT as further harassment,

intimidation, defamation to Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox, “genuinely” dispute ALL claims in

Plaintiff’s claims against me and have repeatedly.

Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox has not had a “campaign” in bad faith to

harass Plaintiff. Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox has fought back against

Plaintiff and Counter Defendants attack on her. This court should not grant summary judgement

to Plaintiff, as Plaintiff has simply used the courts in bad faith to ATTACK a blogger he does not

like, or approve of her blog content and to wipe out his competition in the search engines by

using the courts.

Plaintiff and Co-Conspirators have taunted me, harassed, me, defamed me, attacked me

constantly and the only way I have to fight back is to post my proof online. It is a violation of my

Freedom of Expression and my First Amendment Rights to stop the flow of information on my

blogs, to delete my blogs, redirect my domain names and harass me.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Plaintiff continues to LIES to this court and to publicly defame me in court documents, as I did

NOT extort Plaintiff. I asked Plaintiff for a Job, and he was upset at a Domain Name I owned and

then contacted the Plaintiff in Obsidian V. Cox and conspired to set me up for extortion in

revenge for me owning a domain name he did not approve of. If he thought he had a Trademark

then why not just take the name from me, Pro Se Defendant / Pro Se Counter Plaintiff Crystal

Cox or from Monica Foster when she owned it.

Plaintiff offered Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox and Monica Foster for

the domain name and we both turned him down.

There was no Cyber Extortion and if Plaintiff really believes this and has evidence of this then

Plaintiff should file a criminal complaint so that I, Pro Se Defendant / Pro Se Counter Plaintiff

Crystal Cox, am entitled to due process of law. Instead Plaintiff is abusing his power over the

courts and simply stating I am guilty of extortion with no proof, no evidence of Extortion.

I did not offer Reputation Services and then attack Plaintiff in the search engines to retaliate. I

asked for a job, he said no and then demanded I turn over domain names. I stood up for myself

and he conspired with others to ruin me and to make it look like I was guilty of the crime of

extortion.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox, was not on trial for extortion, never

had due process of law for this accusation, never had a criminal investigation, yet Counter

Defendant / Plaintiff Marc Randazza and Co-Conspirators continue to publicly state that I am

guilty of extortion. Why not file criminal charges, and then if a court of law convicts me of

extortion, then publish Crystal Cox is an Extortionist. Defendant / Plaintiff Marc Randazza and

Co-Conspirators did not do this, they simply attacked me, painted me in false light and made me

look to be an extortionist when that is not true.

I have made a living from Real Estate and from Online Supplements, My Anti-Corruption Blogs

have been to give victims of corruption a voice. The search engine management offer in the

Obsidian V. Cox case was part of a Settlement Negotiation, a month after a legal threat, and a

week after a 10 Million Dollar Lawsuit was filed against me. There were approx. 10 Settlement

Offers in that case. Those emails were between two attorneys negotiating a settlement, I was

Pro Se and acting in my Pro Se Capacity, and this ONE email out of 5 was used out of context

to defame and harass, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox, and to retaliate

against me, AFTER David Aman, Tonkon Torp, Opposing Counsel had already won a 2.5 Million

Dollar Judgement.

Counter Defendant / Plaintiff Marc Randazza saw those eMails, he had ALL my files, and he

negotiated with David Aman, Tonkon Torp on my behalf in the Obsidian Case. As per those he

told in the First Amendment Bar that he represented me and was negotiating a deal.

Counter Defendant / Plaintiff Marc Randazza acted with intentional harm against Pro Se

Defendant / Pro Se Counter Plaintiff Crystal Cox,, when he broadcast that I am an Extortionist

and continues to accuse me, using the courts to further harass and defame me and State that I

am guilty of a crime that I am NOT guilty of nor have been charged with, little own prosecuted for.

Counter Defendant / Plaintiff Marc Randazza does not have the legal or constitutional right to, in

retaliation, hate or whatever reason to simply accuse who ever he please of a crime and then

broadcast that accusation as fact, BEFORE an innocent victims, such as Pro Se Defendant /

Pro Se Counter Plaintiff Crystal Cox is permanently harmed and defamed.

Counter Defendant / Plaintiff Marc Randazza had my personal information, confidential details of

my life and my strategy, and Defendant / Plaintiff Marc Randazza knew that I had not been on

trial for extortion nor charged with extortion, he had seen ALL my files. Counter Defendant /

Plaintiff Marc Randazza had requested all these files as email records show, BEFORE he

negotiated with David S. Aman, Opposing Counsel in the Obsidian V. Cox case.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

I, Pro Se Defendant / Pro Se Counter Plaintiff Crystal Cox am one woman. Counter Defendant /

Plaintiff Marc Randazza has a strong blog, several online sites that are very strong, and lots of

connections with other attorneys and big media. When he posted that I was an Extortionist, the

only way I had to post the facts, and to save my reputation was to start multiple blogs. The more

I started, the more he got deleted. 

This is not a “Google Bomb”, it is an internet marketing tactic to get my story found in the search engines. Instead of using co-conspirators as the Plaintiff does in this case and in Rakofsky V. the Internet, I am simply use my own sites and post in my own name. 

This is not a Google Bomb nor cybersquatting, it is online competition in the search engines, in which Plaintiff Marc Randazza used this court to simply wipe out all my work, and without any due process or First Amendment Adjudication.

Counter Defendant / Plaintiff Marc Randazza states that “"Defendants Crystal L. Cox (“Cox”) and

Eliot Bernstein (“Bernstein”) registered the Infringing Domain Names (as defined in ECF #1 at

6-7) in an attempt to extort Plaintiffs and in violation of the Anti-cybersquatting Consumer

Protection Act (the “ACPA”) (15 U.S.C. § 1125(d)), individual cyberpiracy protections (15 U.S.C.

§ 8131), and rights of publicity under the laws of the State of Nevada Plaintiffs, as well raised

common law claims of intrusion upon seclusion and publicity and civil conspiracy. Plaintiffs’

claims arise from Defendants’ registration and use of Plaintiffs’ personal names as Internet

domain names."

Plaintiff flat out lies to this court, as Plaintiff knows full well that Eliot Bernstein never registered

those domain names. Plaintiff deliberately lies in court documents to defame and harass

Defendants Crystal L. Cox and Defendant Eliot Bernstein. Counter Defendant / Plaintiff Marc

Randazza is very familiar with Obsidian V. Cox, and Plaintiff knows that there are documents

filed as to how and why Defendant Eliot Bernstein got those domain names. Yet, Counter

Defendant / Plaintiff Marc Randazza deliberately lies to this court in retaliation. Counter

Defendant / Plaintiff Marc Randazza represents clients who LITERALLY owe Eliot Bernstein

billions of dollars. This lawsuit naming iViewit Founder Eliot Bernstein is simply to attempt to

discredit, harass, defame and intimidate Eliot Bernstein and to remove blogs that expose the

iViewit Technology theft, with is the biggest technology crime in the world, EVER.

Counter Defendant / Plaintiff Marc Randazza knowingly lies about domain names being

registered to Extort him somehow, that has no TRUTH what so ever to it. Neither Defendant

EVER asked Marc Randazza for money and said they would post “bad faith” or anything at all if

he did not pay, there WAS not Extortion. Counter Defendant / Plaintiff Marc Randazza continues

to use court documents, Big Media, blogs and more to defame, taunt, harass, retaliate, bully and

paint in false light, Defendant / Counter Plaintiff Crystal L. Cox and Defendant Eliot Bernstein.

There is not VIOLATION of the Anti-cybersquatting Consumer Protection Act (the “ACPA”) (15

U.S.C. § 1125(d)), there was NO bad Faith. There was and is not rights of publicity under the

laws of the State of Nevada Plaintiffs and even if the Nevada courts found this to be so, then the

blogs could be banned ONLY In Nevada.

Counter Defendant / Plaintiff Marc Randazza is an expert in this industry, Plaintiff knows that he

is lying to this court deliberately to defame, attack and paint Defendants in false light.

Counter Defendant / Plaintiff Marc Randazza is NOT a household name and does not have an

automatic, exclusive right over the the name “Randazza” or “Marc Randazza” and Plaintiff Does

not have a Right to exclude ONE investigative Blogger from reporting on, publishing, using the

name Randazza” or “Marc Randazza”.

Counter Defendant / Plaintiff Marc Randazza, as in the Domain Name

GlenBeckRapedAndMurderedAYoungGirlIN1990.com and other Domain Name Cases, has

himself represented the domain name owner and argued in favor of the constitutional and lawful

right of the domain owner to own that domain name. 

Yet, in a complete opposite, hypocritical defense in this case, Counter Defendant / Plaintiff Marc Randazza claims that CCC has no right to own such a name with the name Randazza in it, as that name is his and his alone to use. 

As if to say no reporter, no news, no blog, no media can utter the word “Randazza” or “Marc Randazza” without his exclusive permission and that simply is not true.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Counter Defendant / Plaintiff Marc Randazza Says "Specifically, Cox registered Plaintiff

Randazza’s personal name, under which he has conducted business at his well-known law firm,

in multiple domain names and attempted to extort Plaintiff, as is her demonstrated modus

operandi (See “Why an Investment Firm was Awarded $2.5 Million After Being Defamed by

Blogger, attached as Exhibit B) by offering her “reputation management services” in order to “fix”

Randazza’s business reputation that she, herself, harmed."

Counter Defendant / Plaintiff Marc Randazza disturbingly continues to involve his young

daughter, as if to get sympathy from the courts and public at large. Counter Defendant / Plaintiff

Marc Randazza knows full well that CCC never had a blog regarding his daughter, never posted

ONE WORD regarding her, and yet Counter Defendant / Plaintiff Marc Randazza used his own

daughter to paint ccc in false light and defame me, make me look like a monster to the public

and use her to STEAL blogs he has no right to. 

Counter Defendant / Plaintiff Marc Randazza gave picture of his young daughter to big media and flat out lied that I had blogged about her when I did not EVER publish anything in regard to his daughter.

Counter Defendant / Plaintiff Marc Randazza even added his daughter to this lawsuit as a

Plaintiff, that is SICK. I, Defendant / Counter Plaintiff Crystal L. Cox have not mentioned her

name and I have not counter sued Plaintiff’s Daughter and Wife, deliberately, as neither had

anything to do with Counter Defendant / Plaintiff Marc Randazza’s hate, rage and retaliation

tactics against Defendant / Counter Plaintiff Crystal L. Cox . Counter Defendant / Plaintiff Marc

Randazza continues to use court dockets to lie about and defame Defendant / Counter Plaintiff

Crystal L. Cox. And he continues to use his young child as a weapon in the courts, SICK.

Counter Defendant / Plaintiff Marc Randazza claims that owning a person’s name in a domain

name is fine if it’s his client, yet wages a retaliation legal war against Defendant / Counter Plaintiff

Crystal L. Cox for owning such a Name. Counter Defendant / Plaintiff Marc Randazza LIES to

this court in AGAIN stating that I tried to extort his well known law firm. First of all he is NOT well

known, not a common household name. Secondly, I, Defendant / Counter Plaintiff Crystal L.

Cox, NEVER ever attempted to use a domain name to Extort Marc Randazza, as email records

show I told him I would not SELL the domain name at ANY price and in FACT gave it to

Investigative Blogger Monica Foster to help expose human trafficking, bad things happening to

kids in porn, prostitution rings, whistleblower retaliation and all that she exposes on

PornNewsToday.com.

Monica Foster aKa Alexandria Melody, was threatened by Marc Randazza and Co-Conspirators /

Counter Defendants, she was in fear of her life and therefore I told her I would take the domain

name back. Shortly after that, Counter Defendant / Plaintiff Marc Randazza filed a fraudulent

WIPO Claim, and then filed this Lawsuit in retaliation.

Counter Defendant / Plaintiff Marc Randazza claims this “by offering her “reputation

management services” in order to “fix” Randazza’s business reputation that she, herself,

harmed.” This is FALSE. I never EVER offered to “FIX” Randazza’s business reputation, email

records show that I, Defendant / Counter Plaintiff Crystal L. Cox, never said that. Counter

Defendant / Plaintiff Marc Randazza continues to use his power in the courts to defame and flat

out lies about Cox.

I, Defendant / Counter Plaintiff Crystal L. Cox, never wrote ONE word about Marc Randazza

when I sent the email asking for a Job. I posted blogs regarding Counter Defendant / Plaintiff

Marc Randazza AFTER he contacted the Plaintiff and the Judge in my Obsidian V. Cox case

and conspired to set me up for a Crime, I started the blogs AFTER that to Defend Myself from

his RAGE and retaliation.

Counter Defendant / Plaintiff Marc Randazza should not be able to simply LIE to a court and

because he is an attorney, it is taken as fact. Counter Defendant / Plaintiff Marc Randazza

should not be able to submit blogs to the courts of his co-conspirators and have those blog

posts used as evidence to harm his intended target, defendant.

Counter Defendant / Plaintiff Marc Randazza is flat out lying about Defendant / Counter Plaintiff

Crystal L. Cox Extorting him. Email records and communications PROVE there was no

Extortion. YET, Counter Defendant / Plaintiff Marc Randazza continues to use motions in the

courts to attack, defame, taunt, harass, bully and paint Defendant / Counter Plaintiff Crystal L.

Cox in false light INTENTIONALLY.

Counter Defendant / Plaintiff Marc Randazza continues to use Kashmir Hill’s post about CC to

defame CC.” (See “Why an Investment Firm was Awarded $2.5 Million After Being Defamed by

Blogger, attached as Exhibit B) “

Kashmir Hill of Forbes is from AboveTheLaw.com, and Counter Defendant / Plaintiff Marc

Randazza is their attorney. Kashmir Hill of Forbes is a co-conspirator and that article is

DEFAMATION with actual malice. Kashmir Hill of Forbes is liable for the defamation in that post.

Counter Defendant / Plaintiff Marc Randazza knows the information is false, yet uses Kashmir

Hill’s post as some sort of evidence that Defendant / Counter Plaintiff Crystal L. Cox did

something unlawful or prove that Defendant / Counter Plaintiff Crystal L. Cox extorted him, or did

something that would warrant deletion of massive online content, stealing domain names,

removing blogs, redirecting servers and constantly attacking and harassing Defendant / Counter

Plaintiff Crystal L. Cox .

Counter Defendant / Plaintiff Marc Randazza told me Defendant / Counter Plaintiff Crystal L.

Cox, that if I did not GIVE him the Domain Name he wanted, he would make me an ENEMY. Now

that’s Extortion and he sure did follow through. Counter Defendant / Plaintiff Marc Randazza has

RUINED my life, with ACTUAL MALICE, actual knowing of the Facts of the Matter.

Counter Defendant / Plaintiff Marc Randazza Constantly Accuses Defendant / Counter Plaintiff

Crystal L. Cox of being involved in a conspiracy that does not exist, meanwhile he daily

conspires to harm Defendant / Counter Plaintiff Crystal L. Cox, retaliate, defame, intimidate and

ruin Defendant / Counter Plaintiff Crystal L. Cox Facts, Documented Facts and Evidence SHOULD be at Issue in this Case. Instead Plaintiff simply supplies this court with blog posts and words of co-conspirators, in which are NOT documented FACT.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Counter Defendant / Plaintiff Marc Randazza blogs about Defendant / Counter Plaintiff Crystal L.

Cox and constantly discusses his opinion of me on twitter, facebook, and encourages others to

publish online about me, make videos lying about me and defaming me.

Plaintiff Stating this “Another District Judge, Marco Hernandez of the District of Oregon,

euphemistically described Cox’s scheme as repairing the damage she had caused for a

“tasteful” fee. Obsidian Finance Group LLC v. Cox, 2012 WL 1065484 (D. Ore. 2012).” Is

defamatory. I was not on trial for extortion, this was in regard to a settlement negotiation

communication, and has nothing to do with the material facts of Randazza V. Cox. This is

placed in a Motion for a Summary Judgement, with Malice, to further paint Counter Plaintiff /

Defendant Crystal Cox in false light, defame her, harass and intimidate her.

Counter Plaintiff / Defendant Crystal Cox posted remarks and poked fun at what Plaintiff Marc

Randazza had said about his own wife, in a drunken tryst post on his own blog. Counter Plaintiff

/ Defendant Crystal Cox never EVER posted anything online regarding Marc Randazza’s child,

he himself did that.

Again Counter Defendant / Plaintiff Marc Randazza uses the court docket, abuses his power,

and defames, harasses Counter Plaintiff / Defendant Crystal Cox.

Counter Defendant / Plaintiff Marc Randazza Says, “Plaintiffs are not the only victims of the Cox

scheme. Ms. Cox has targeted several dozen other victims, registering their full names as

domain names and falsely accusing them of any manner of wrongdoings.” This is false and

defamatory and has nothing to do with the material facts of Randazza V. Cox. I am a reporter,

an investigative blogger, what Plaintiff refers to as victims, are subjects of my stories, and yes, of

course I get the best keyword rich domain name I can to get strong in the search engines, that is

taught in EVERY book and class regarding SEO and Internet Marketing. I have never asked for

MONEY to remove any information, no have I ever written a story with the intention to ask for

money to remove it. Nor has I ever stated that if you don’t pay me, I will post bad stuff. That is

simply further defamatory fraud on the courts. I am an investigative blogger exposing corruption

in New Media, with the best possible marketing techniques I know of. I have not extorted anyone

nor received payment from anyone to remove information I have written.

Counter Defendant / Plaintiff Marc Randazza is discriminating against Citizen Journalists and

Bloggers not affiliated with Big Media. The New York Times, Forbes and other Big Media posts

stories daily on companies, individuals and they are not called victims. Often times the The New

York Times, Forbes and other Big Media are asked to remove information or even sued for

inaccurate information, this is not deemed Extortion. Why are my Investigative Blogs called

Extortion? 

The reason is because those I expose for alleged corruption and the tips I get on them

in which I post, they don’t like this information out there, so they claim me an Extortionist, when I

have Extorted NO ONE, and received no money for such, nor been under investigation for the

crime of Extortion, yet Counter Defendant / Plaintiff Marc Randazza and Counter Defendant

Ronald Green continue to use this court docket to defame me and flat out state as fact that I

have committed Extortion when I have not had due process, nor a criminal investigation or trial

regarding this allegation. Yet Counter Defendant / Plaintiff Marc Randazza State it as fact.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Counter Defendant / Plaintiff Marc Randazza State “Just as she has done with Plaintiff Marc

Randazza, Cox then offers her “reputation services” to the people whose names she has

registered. See Obsidian Finance Group, LLC v. Cox, 2012 WL 1065484 (D. Ore 2012)

(“[D]efendant offered ‘PR,’ ‘search engine management,’ and online reputation repair services to

Obsidian Finance, for a price of $2,500 per month ... 

The suggestion was that defendant offered to repair the very damage she caused for a small but tasteful monthly fee”);” I object to this statement, Obsidian V. Cox was a CIVIL trial regarding defamation, it had NOTHING to do with Extortion, which would be a Criminal Trial. This $2500, was one sentence pulled from 5 emails between Pro Se Defendant Crystal Cox, acting in her Pro Se Capacity and David S. Aman, Tonkon Torp Opposing Counsel. These 5 emails were a Settlement Negotiation in response to a Cease and Desist Legal Threat and sent after a 10 Million Dollar Defamation Lawsuit had been filed by David S. Aman, Tonkon Torp on behalf of Federal Bankruptcy Trustee Kevin Padrick and his Company Obsidian Finance Group.

This one sentence, has been used out of context to retaliate on a Reporter exposing the clients

of Counter Defendant / Plaintiff Marc Randazza and Counter Defendant David. S. Aman. The

facts of the case are all of record, and Extortion was not a material fact. Also I, Counter Plaintiff /

Defendant Crystal Cox object to speculation stating that “The suggestion was that defendant

offered to repair the very damage she caused for a small but tasteful monthly fee” this is false, I

only offered any negotiation, AFTER I had been threatened with a 10 Million Dollar Legal Action.

This was a negotiation settlement communication to try and STOP the next several years of my

life from being in legal action. The Plaintiff made 8 Settlement Offers to me, and they are not

deemed Extortion yet the Plaintiff offered I pay them $5000 every time I mention their name and

that I blame my whistleblower and her father for my posts, which is illegal. This is all a matter of

record.

Regarding this, “Randazza’s name functions as a trademark. Randazza is an individual, an

attorney, a legal author, and a resident of Clark County, Nevada. (ECF #1 ¶23;Randazza Decl. ¶

1). Plaintiff is the owner and managing partner of RLG, with offices located in Nevada, Florida,

and Arizona. (ECF #1 ¶ 23; Id.). Since 2008, RLG has done business using Marc Randazza’s

personal name as a source identifier for its services. (ECF #1 ¶ 23).”

Counter Defendant / Plaintiff Marc Randazza has NO Trademark or exclusive right to use the

word “Randazza” or Marc Randazza. “Randazza’s name” does NOT function as a Trademark

anymore then I can say no one can use the name Crystal Cox in the reporting of my case or

their opinion of my case. It is not a Trademark violation to report on Marc Randazza.

Counter Defendant / Plaintiff Marc Randazza says, “Cox registered the Infringing Domain Names

with the intent to capitalize on the use of Plaintiff Randazza’s personal name, extort money from

Plaintiffs, and engage witness intimidation. (Exhibit H; Blog post asking for $5 million for sale of

<marcrandazza.me>, attached as Exhibit M; ECF #12-4 video from Cox admitting witness

intimidation, a relevant transcript of which is attached as Exhibit N). In fact, the profit in Ms. Cox’s

endeavor flows directly from her extortion scheme.”

I Counter Plaintiff / Defendant Crystal Cox, Object to that statement. I joked about $5 Million just

after I bought MarcRandazza.me, I titled the post here Kittty Kitty, it was a Parody. I had just

bought it for 10 Dollars, there was no blog on it or value in it. Counter Defendant / Plaintiff Marc

Randazza is trying to make it look like I offered the name for that real price, and that is not True.

However, people buy and sell domain names every day, and can buy and sell LEGALLY for

whatever price they want. Even if their is a possible Trademark. Godaddy has thousands of

domain names on auction sites that have other peoples names or possible trademark names in

them, they sell them all the time. It is not illegal nor has it cause and harm to the Plaintiff.

No Domain Names were EVER bought to tamper with a witness, they were purchased to

report on a story, period.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

I Counter Plaintiff / Defendant Crystal Cox, have never had an Extortion scheme nor have I ever

taken in ANY money they could possible be mistook as Extortion. If Counter Defendant / Plaintiff

Marc Randazza really believes this and has convinced this court I am guilty of Extortion then why

not file Criminal Charges, give me an Criminal Attorney and due process under law, BEFORE

publishing widely that I, Counter Plaintiff / Defendant Crystal Cox and Eliot Bernstein are Guilt of

Extortion, as if already convicted. And then Using this Court to further that false defamatory

statement as fact, when it is not fact.

“On December 10, 2011, Crystal Cox registered <marcrandazza.com> in the publicly

available Whois information. (See Exhibit K). On January 16, 2012, Cox sent an email to Plaintiff

stating that she had purchased his personal name as a domain name. (See Exhibit H). She then

asked Plaintiff to purchase her “reputation management services” in an attempt to extort money

from Plaintiff. (See Exhibit H). This is her modus operandi. See Obsidian Finance Group, LLC v.

Cox, 2012 WL 1065484 (D. Ore)

This statement is not true. The New York Times was already defaming me, and there was no

way I would have sent anything that would have even remotely have suggested extortion. I asked

Marc Randazza for a Job, plain and simply. I had the dotcom at issue when he was my attorney,

to report on my own story. He said he did not want to hire me then he proceeded to act and

defame me so I used the name to report on him, expose him and warn the public at large, as a

Public Service.

Counter Defendant / Plaintiff Marc Randazza offered to buy the domain name from me and from

Monica Foster, we both said no. I told him I would not sell for any price, this is NOT extortion.

Plaint then launched into a year long and continued retaliation. Counter Defendant / Plaintiff Marc

Randazza also asked me what I wanted from him, email records prove that. Plaintiff said that I

made my point, if I was an extortionist I would have demanded money, I rejected his offers,

Plaintiff Retaliated over and over.

Counter Defendant / Plaintiff Marc Randazza says, “Defendant Cox will not stop until she is

satisfied that she has successfully intimidated Plaintiff or until he pays the requested ransom.”.

I, Counter Plaintiff / Defendant Crystal Cox, OBJECT to this, I never offered an ransom request,

this is fraud on the courts. Also why would I, over any other reporter, have to be singled out to

stop reporting on, having an opinion on, or making fun of Marc Randazza?

This violated my constitutional and civil rights.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Counter Plaintiff / Defendant Crystal Cox NEVER had “bad faith” intend. My Intent is to report on

and expose corruption in the United States Judicial System. I have been dedicated to this for

over 7 years, at great personal cost. I have been fighting and exposing corruption and Counter

Defendant / Plaintiff Marc Randazza has painted me to look like the criminal, when the truth is I

am reporting on, exposing the crimes.

Regardless of the Defamatory Lies in publications by Counter Defendant / Plaintiff Marc

Randazza and Counter Defendants, Investigative Blogger Counter Plaintiff / Defendant Crystal’s

purpose was ALWAYS, SOLELY to expose corruption, parody corruption, provide “speech

critical” of those I alleged participated in these corrupt activities and to try and make the world a

better place doing what I could to help give justice to victims of corruption.

Counter Defendant / Plaintiff Marc Randazza has no trademark on the name Marc Randazza

and has no right to MarcRandazza.com or any of the Domain Names he stole from Counter

Plaintiff / Defendant Crystal Cox Counter Defendant / Plaintiff Marc Randazza is not entitled to a Summary Judgement as his allegations are all FALSE and Defamatory.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Marco Randazza is the Plaintiffs “Handle”, “Persona” Online, NOT Marc Randazza.

It is unlawful and unconstitutional to ban an investigative blogger, a journalist from writing a last

name on her online media. Marc Randazza, is not the only Marc Randazza in the world, nor

does he have an exclusive right on the use of “Randazza”

There are many people with that last name. Plaintiff has no right to exclude ANY blogger,

journalist, to not use his name or last name. That would be like me saying no one can utter can’t

the last name Cox on anything ever. It is ridiculous, and unconstitutional, as well as selective

prosecution.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Plaintiff Marc Randazza has no Trademark on the name “Marc Randazza”.

Plaintiff Marc Randazza uses the Trade Name, Marco Randazza as his Twitter and

YouTube User Name, as well as his username on his own blog, and many other forums,

blogs, news sites and social networks, NOT Marc but MARCO, .

Plaintiff Marc Randazza uses the Trade Name, Marco Randazza on Best Tweets, in Penn.

News Articles, on Flickr, in Gloucester Times, on multiple YouTube accounts, on the Legal

Satyricon as his username on his own blog, on the DNF forum, on yFrog, and many other

sites and sources.

Plaintiff Marc Randazza had / has no ™ posted at his blog regarding the name Marc

Randazza as being trademarked and Plaintiff Attorney Marc Randazza had no Trademark

when Defendant Crystal L. Cox purchased MarcRandazza.com to use as PR for Defendant

Crystal Cox’s highly public First Amendment Case, that will set a precendence that is a

“Game Changer” for ALL New Media, Bloggers, and Citizen Journalist.

Defendant Crystal L. Cox “actions” as Plaintiff calls it, were a “legitimate purpose” and that

purpose was originally to provide PR for her own court case of which Plaintiff Marc

Randazza was, at that time to be her attorney and acted on her behalf in negotiations with

Opposing Counsel, David S. Aman of Tonkon Torp Law Firm. Obsidian Finance Group vs.

Crystal Cox is the biggest Free Speech case any one, independent blogger has ever seen,

Obsidian V. Cox. Which is the only case of it’s kind to distinguish the rights of bloggers vs.

the rights of traditional media. Obsidian V. Cox will hopefully end the “Monopoly on Free

Speech” in which according to Plaintiff Marc Randazza to Defendant Crystal Cox that “Big

Media” told him, they make more money with a Monopoly on Free Speech.

Counter Defendant / Plaintiff Marc Randazza is not entitled to a Summary Judgement as

his allegations are all FALSE and Defamatory.

There never was an Extortion Scheme. Counter Defendant / Plaintiff Marc Randazza has simply

used his money, power and influence to ruin the life of and bankrupt a female blogger who he did

not agree with.

I, Counter Plaintiff / Defendant Crystal Cox OBJECT to Plaintiff’s Motion for Summary

Judgement in it’s Entirety.

For More Detailed Information on these Objections, and Reasons why Please See Memorandum

to Defendant Crystal Cox’s OBJECTION to Plaintiff’s MOTION FOR SUMMARY JUDGMENT,

submitted to this court with this Objection to Plaintiff’s MOTION FOR SUMMARY JUDGMENT.

Source and Full Court Filing

http://ia601205.us.archive.org/2/items/gov.uscourts.nvd.91330/gov.uscourts.nvd.91330.80.0.pdf