DD Support Board and Research Team

[scion]

13. The Plaintiff charges its customers a dissemination fee (advertising fee) in order for customers to gain access to its email dissemination services to its proprietary database. Upon information and belief, on or around February 18, 2011, the defendants in this case have each/or while in acting in concert by the use of an artifice or scheme, successfully hacked into Marketing Integrale’s server’s hosted at its primarily servers located in the United States at I-contact (www.icontact.com). Defendants hacked into Plaintiff’s server in order to gain access, copy, and distribute mail directly to persons on Marketing Integrale’s proprietary e-mail customer lists. By accessing and utilizing Plaintiff’s e-mail list without payment and without authorization, Defendants violated 18 U.S.C. § 2701 and 18 U.S.C. § 1030.

14. Upon information and belief, after the Defendants stole Integrale’s email lists, Defendants incorporated the use of several websites and other associated servers in order to complete their illegal activity.

Extract:
04/09/2012 5 First AMENDED COMPLAINT with JURY DEMAND against All Defendants filed by MARKETING INTEGRALE CO..(Iruke, Leonnel) (Entered: 04/09/2012)

Doc 5 PDF file
https://viewer.zoho.com/docs/aNcl3