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
"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
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
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.