DD Support Board and Research Team

[lucky, mydog]

i see he has tried this before.


COLOSSEUM COUNSEL
Attorneys at Law
3811
Airport Pulling Rd. Ste. 203
Naples, FL 34105
Tel: 239
-
631
-
8160
Fax: 239
-
529
-
2315
Vito M. Roppo, Esq.
James R. Chillemi, Esq.
August 2
9
,
2019
VIA
EMAIL
:
InvestorsHub.com, Inc.
[e-mail]
c/o Corporation Service Company
1201 Hays Street
Tallahassee, FL 32301
My Client:
Jake P. Noch
Re:
Identifying Defamatory
registered
users of iHub
To Whom It May Concern:
This
law firm represents Jake Noch, and we write with
respect to clear
-
cut violations of the
Terms of Service (“
TOS
”) of InvestorHub.com, Inc. (“
iHub
”) by certain users. The TOS imposes
the responsibility on iHub’s members to “
to bring violations of the Terms by other members to
iHub's attention.” See TOS at
§ 5.
In that regard, Mr. Noch has become
aware of unwarranted and
deragory statements
that are
derogatory to his character and reputation, especially amongst
investors
––
in violation of Section 5’s prohibition against, among other things, defamatory and
l
ibelous material
.
These libelous claims have been made as posts on your Investors Hub comments boards
by registered iHub users with impunity
and meant to portray
Mr. Noch
as being involved in illegal
and
criminal
activity
. The following users and
their
posts are
summarized
as follows:
iHub Letter.pdf
1)
A registered user by the name of “
-
Teffy
-
Trader
-
”
,
who has been a
registered member since July 29
th
, 2009 on the iHub boards
,
has made
numerous posts that disparaged Jake’s character and reputation. For
example, he
unfairl
y
questioned
my clients
investing history
,
said
his “gig
was up”
, referred to his investing plans as a “pump and dump” and that his
investments were
“not for real money to be i
n”.
2)
Another registered user with the profile name of “Crowin”, that has been
a
member of Investors Hub since February 19
th
, 2005 has also made several
disparaging comments
about my client.
“Crowin” has specifically made his
website signature to be that he “has been exposing scam stocks for 14 years”
further adding to the libelous
nature of his claims about my client.
This iHub
member posted that my client
“has no claim” to IFLM
(the company stock
in question). As well as s
pecifically referring to
m
y clients investments as a
scam in several posts.
3)
A user by the name of “Homebrew”,
who has been a registered member
since October 29, 2013 has
r
eferred to
my client and his endeavors in
various
iHub
posts as “
failure
..
crap
...
zombie
... [a]
pump and dump
”...
and as not making any financial sense. Specifically, this user referred to my
client
as
“Jake
-
the
-
snake dude scammer... as an insult to snakes
” that would
“
screw with investors
”
.
4)
“munimi”, a
member
since April 4
th
, 2017
posted that my client was a
“spoiled little brat” that got schooled
by other parties and that he was just
using his rich
parents money. In other posts he refers to my client as
“
Jake"TheBurntCake
”...
is
a
clueless
idiot
who
doesn't
know
what
he
is
doing,
and
needs
an
adult
supervision,
which
was
obvious
to
most
people
since
day
1”
. Other posts by “munimi” refer to my client
as a dog, described
him as a “desperate kid.....with embarrassingly desperate brags”, and that
his involvement will lead to a bad result for all involved.
5)
“nitwit”,
a
member since April 13
th
, 2006
referred to my client as “pretty
boring”.
6)
“nodummy”
,
a
me
mber since February 26, 2010
posted that my client was
a serial pump and dumper
, as a senseless investor,
and that his investments
amounted to nothing more than a stock manipulation scheme.
7)
“surfkast”
, a
member since June 10
th
, 2006
that
explicitly
calls
himself
a
“
scam buster
” on his member profile posted that my client was “smoking
crack” a “complete and total idiot” and that his investment claims were
beyond comical”. As well as describing my clients investments as a “proven
scam... dead in the water”
iHub Letter.pdf

8)
“
THall”,
a registered
member since October 27
th
, 2006
posted that my
clients investments will send most traders into bankruptcy and as an idiot
that will be jailed for insider trading and stock manipulation”.
9)
“Trader59”,
a
member since January 20, 2015
posted that my client was
“reckless and incompetent”, “childish and erratic [in] nature”, ridiculed his
living situation and accused him of running an illegal pump and dump
scheme.
As registered users of iHub, these people were allowed to remain anonymou
s and hide any
personally identifying information behind their screen names.
All of these posts were done within
the context of disparaging my client and his investments and had the general purpose of accusing
him of
criminal activity, including an
illegal
pump and dump scheme
,
as well as tarnishing his
name and hard
-
earned reputation amongst other 3
rd
parties and investors. This was done by them
posting these defamatory claims on iHub
posts for others to see and connect the defamatory claims
to my client in a bad light. Thus, he has asked us to pursue legal action against these users.
Prior to formally issuing a subpoena or other legal process, as contemplated in “Other
Disclosure” i
n iHub’s Privacy Policy,
we ask
that you provide
us
with the personally identifying
information that each member must provide when registering with iHub, including but not limited
to: full names, email addresses, credit card information to make any site du
es, and I.P. addresses
for when they have
accessed iHub
.
Because these derogatory claims
can be seen as libelous we
ask that your company divulge the identifying information in your records that could be used to
identify all of the iHub members listed abov
e.
My client aim
s
to stress
their
intention to resolve
this matter harmoniously and avoid any need for
costly
litigation.
My client
merely wants
to
identify the people behind these defamatory claims and pursue litigation against them.
Unless
you
respon
d to our requests to identify these iHub members
within the next
ten (10)
days,
we will be forced to file legal action against you
as
well as filing a complaint
with the Better Business Bureau. Please contact my office to correspond with me about
the
best
means
for
transmitting the proper identify
ing information within 10 days.
Kind regards,
/s/ Vito M. Roppo, Esq.
Vito M. Roppo, Esq.
Fla. Bar No.: 112153
Attorneys for
Jake Noch
Colosseum Counsel, PLLC
3811 Airport Pulling Road, Ste. 203
Naples, Florida 34105
Phone:(239)
-
631
-
8160
E
-
Mail:
[e-mail]
https://www.dropbox.com/s/heyly8v5nq2v90g/iHub%20Letter.pdf?e=3&dl=0