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. legal@investorshub.com 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: vito@fightforme.com https://www.dropbox.com/s/heyly8v5nq2v90g/iHub%20Letter.pdf?e=3&dl=0