Notes Regarding Marc Randazza having NO Legal, Ethical or Sensible Right to STEAL MarcRandazza.com . Marc Randazza is a Domain Name Thief. One May Even Call Marc Randazza a Thieving Little SHIT.
Marc Randazza secretly dropped his Czech Complaint, I had no knowledge of this matter. Then Marc Randazza filed a WIPO complaint, of which also I was not served information on. Marc Randazza uses the legal system to suppress Free Speech and to squash the First Amendment Right of Whom ever Marc Randazza pleases. And Marc Randazza flat out steals whatever Domain Name he wants to while at the same time Hypocrite Marc Randazza defends others rights to own domain names with "Other" people's name in the Domain Name.
Here are some Tidbits of my Domain FIGHT Response.
Crystal L. Cox
SavvyBroker@Yahoo.com
Pro Se Respondent
Czech Arbitration Court (CAC) Case No. 100472
(EP) D2012-1525 <marcjohnrandazza.com> et al. Notification of Panel Appointment
Complainant: Marc John Randazza
Respondent: Crystal L. Cox, in my Pro Se Capacity
Response from, Crystal L. Cox in my Pro Se Capacity to Case No. 100472 regarding disputed Domain Names marcrandazza.com, marcjrandazza.com, marcjohnrandazza.com.
First I Crystal L. Cox in my Pro Se Capacity Demand, Request that the “Panel” be a Three Party Panel, and that ALL members of the Czech Arbitration Court (CAC) having any deciding factors regarding Czech Arbitration Court (CAC) Case No. 100472, sign a Conflict of Interest Disclosure. I Crystal L. Cox in my Pro Se Capacity have a right to a fair and impartial panel, under law. It is a crime to not provide affirmation of or denial of any conflict of interest in this matter. I Crystal L. Cox in my Pro Se Capacity have attached said Conflict of Interest Form to my response to Czech Arbitration Court (CAC) Case No. 100472, (EP) D2012-1525 <marcjohnrandazza.com> et al. Notification of Panel Appointment regarding disputed Domain Names marcrandazza.com, marcjrandazza.com, marcjohnrandazza.com.
I cannot afford the 3 panel filing option, I am Pro Se, and have no money. Marc Randazza knows this. I demand that a 3 Panel.. be used in this case, as I have no money and no ability to pay
It is unfair, unjust to have a Single Panel.
I Object to Remedies sought.
The Respondent hereby responds to the statements and allegations in Czech Arbitration Court (CAC) Case No. 100472 Complaint and respectfully requests the Panel to deny the remedy
requested by the Complainant Marc J. Randazza.
I, Crystal L. Cox in my Pro Se Capacity, currently own MarcRandazza.com and purchased MarcRandazza.com on December 10th, 2011. I also purchased MarcjRandazza.com and MarcJohnRandazza.com, I currently do not own MarcjRandazza.com and MarcJohnRandazza.com as they were part of a “Remedy” to pay off a debt owed to Eliot Bernstein of iViewit Technologies. MarcjRandazza.com and MarcJohnRandazza.com were used to post information regarding current events surrounding Free Speech and First Amendment cases and to expose the activities of Randazza Legal Group as well as to poke fun at Marc Randazza himself. MarcjRandazza.com and MarcJohnRandazza.com were never used to bait and switch, to sell a service or to make any money for the domain holder.
Marc Randazza is a very experienced Lawyer in WIPO Cases, Domain Name arbritration, Domain Name Law, First Amendment Rights, and Free Speech.. Marc Randazza chose Czech Arbitration Court (CAC) as he seems to have an insider in the Czech Arbitration Court (CAC), according to rumor.
Use of Domain
MarcRandazza.com is and has been used to expose the activities of and poke fun at Marc Randazza, Randazza Legal Group and to report on cases that involve Free Speech Issues and First Amendment Rights issues. I, personally have made no revenue with MarcRandazza.com and have not used this domain name as a bait and switch to get business of any kind. MarcRandazza.com was also used to report on stories, post tips, and as a way to get more attention to the Free Speech issues that are so important to us all.
Marc Randazza emailed me Crystal L. Cox, Respondent, and said he would represent me as my attorney, then he turned around and conspired with the Plaintiff in Obsidian V. Cox to Testify directly against me.
Marc Randazza is an attorney licensed in 5 States, if Complainant, Marc Randazza had real proof of the allegation of Extortion and the Allegation of Witness Tampering then why did Complaintant, Marc Randazza bring this up in the Czech Arbitration Court and not file Criminal Charges in the U.S against Respondent Crystal Cox? For the simply reason that this is NOT true in any regard and Complaintant, Marc Randazza is flat out lying to the Czech Arbitration Court panel for personal motivation and gain and to deliberately suppress the Free Speech rights of Blogger Crystal Cox who is exposing the Truth about Attorney Marc J. Randazza.
Complainant, Marc Randazza Says, Complaintant, Marc Randazza claimed to be my attorney, as seen in emails attached to this complaint, Complaintant, Marc Randazza emailed Respondent, Crystal Cox and told me that he wanted to represent me in my appeal in Obsidian V. Cox. This after Complaintant, Marc RandazzaComplaintant, Marc Randazza represent me, Respondent, Crystal Cox. Since I did not choose Marc Randazza to represent me and get in on this very big First Amendment, Free Speech, Anti-Slap, Shield Laws Case, Complaintant, Marc Randazza has since been on a rampage of revenge to punish Respondent, Crystal Cox for she, I, chose Eugen Volokh UCLA Professor of Law to represent me in this massively, globally important Free Speech case that affects Citizen’s Journalists worldwide.
Complainant Marc Randazza has no Trademark on the name Marc Randazza, Complainant Marc Randazza is not the only Complainant Marc Randazza in the entire world. Complainant Marc Randazza does not have a legal right over any other Complainant Marc Randazza nor over Respondent Crystal Cox.
Marc Randazza knows that Crystal Cox has a legal right to own MarcRandazza.com and to have past purchased marcjrandazza.com and marcjohnrandazza.com.
Marc knows this as to the fact that Marc has litigated cases such as this and one for the domain name owner of the highly controversial domain name Glen Beck WIPO Case No. D2009-1182 you see that Marc Randazza adamantly defended the rights of Respondent Isaac Eiland-Hall to own the domain name "GlennBeckRapedAndMurderedAYoungGirlIn1990.com".
Marc Randazza has had several of my blogs removed by Google and Wordpress in order to Suppress my Free Speech rights. Marc Randazza has harassed me, defamed me and incited online hate against me, all because I bought MarcRandazza.com. Marc Randazza has no legal right to own MarcRandazza.com or the question comes to mind why would a Domain Name attorney, known in media as a friend domainers, and an alleged expert in this field not own this particular dotcom?
Marc Randazza is humiliated as having not bought MarcRandazza.com as he represents major clients in defending their domain names yet never bought this particular domain name and now wants to harass Respondent Crystal Cox, so Marc Randazza has filed a domain name dispute with the Czech Arbitration Court (CAC). Even though Marc Randazza has litigated several WIPO complaints regarding this same manner and won for his clients,
Glen Beck WIPO Case No. D2009-1182 - Respondent Isaac Eiland-Hall was represented by Marc Randazza and Marc Randazza won that case. As you see in the attached PDF of Marc Randazza’s blog, Marc Randazza considered this a major win for Free Speech, and yet Marc Randazza feels he has a right to own MarcRandazza.com, Crystal Cox Repondent in my Pro Se Capacity FIRMLY disagrees.
I Crystal L. Cox in my Pro Se Capacity hereafter respond to Marc J. Randazza’s “Summary of Facts Relevant to Complaint”.
On December 10, 2011, I Crystal L. Cox registered the domain name MarcRandazza.com, (the “Disputed Domain Name”). I registered MarcRandazza.com in order to post information regarding Free Speech issues, Free Speech and First Amendment Cases, Issues regarding Marc Randazza’s cases and to also promote my own Free Speech case Obsidian Finance Group vs. Crystal L. Cox. Obsidian v. Cox is one of the most important Blogger cases of Free Speech in America. As I was stripped of my Free Speech rights in this case and am currently under appeal in the Ninth Circuit court with world renowned Constitutional Law Professor Eugene Volokh as my attorney.
On December 10th 2011, I had spoke with Marc Randazz, as he was an option for me to be my attorney on the Obsidian Vs. Cox defamation case. I chose Eugene Volokh over Marc Randazza as he had a better resume and I felt he could handle my case better and with more professionalism toward me.
I made this decisions days later. However on Dec. 10th I bought MarcRandazza.com in order to start a blog on this very important debate of Free Speech, Bloggers Rights, Shield Laws, Anti-Slapp Laws and the First Amendment rights of all Bloggers and Citizen Journalists.
I, Crystal L. Cox in my Pro Se Capacity, did not register said domain names in bad faith.
I, Crystal L. Cox in my Pro Se Capacity, had no bad faith plan what so ever. I never received any pay per click revenue, and if MarcRandazza.com was ever a pay per click, that would be something the Registrar did to profit when MarcRandazza.com was in between development stages. I had no extortion scheme what so ever and feel I had and have every legal right to own MarcRandazza.com.
Marc Randazza flat out lies about an alleged extortion scheme, as one never existed, nor was a complaint filed or charges of extortion ever issued to me, Crystal L. Cox Respondent.
Said domain names were NEVER used as Pay Per Click sites. Godaddy may have had the pages parked when the domain was not in use, that was nothing to do with Respondent Crystal Cox. Nor did I, Crystal Cox EVER receive said revenue from said domain names.
I, Crystal L. Cox in my Pro Se Capacity did not buy nor use said domain names to target Complainant’s name in order to redirect. It is obvious to any reasonable reader that the site is owned by me Crystal L. Cox and that I am NO friend of Marc Randazza. I, Crystal Cox clearly labeled the top of the blog that I am an Enemy of Marc Randazza, and have been mistreated by Marc Randazza and my civil and constitutional rights violated. No reasonable reader would EVER confuse my blog with anything having been posted by Marc Randazza nor Randazza Legal Group, thereby I was not attempting to confusing readers, web users, blog viewers in any way.
MarcjRandazza.com, MarcJohnRandazza.com were transferred to Eliot Bernstein in a large amount of Domain Names in order to satisfy a Debt owed by myself Crystal L. Cox to Eliot Bernstein owner of iViewit Technologies.
Complaintant, Marc Randazza did not “Challenge” said domain name. Complaintant, Marc Randazza demanded that Respondent Crystal Cox give him the domain name MarcRandazza.com, if I did not cooperate Complainant, Marc Randazza would thereafter contact the Plaintiff in Obsidian V. Cox and gang up on me, Crystal Cox, per say in effort to set me up for the crime of extortion though no extortion charges were filed, nor was I charged with extortion in any court.
When Complaintant, Marc Randazza’s threats to Respondent Crystal Cox, me, were challenged and I did not succomb to his threats Complaintant, Marc Randazza contacted the Plaintiff in Obsidian V. Cox and assisted them in harassing me, Crystal Cox. Complaintant, Marc Randazza even went so far as to recommend a “Receiver” in order to steal mass amounts of Domain Names. And Complaintant, Marc Randazza made arrangement to fly to Portland Oregon to be deposed and give testimony against me, Respondent Crystal Cox. All this after Complaintant, Marc Randazza emailed Respondent Crystal Cox the he would represent me, Crystal Cox as my Attorney in my appeal of Obsidian V. Cox.
Respondent Crystal Cox did NOT offer to clean up Marc Randazza’s reputation nor had Respondent Crystal Cox even went as far as to poke fun at Complaintant, Marc Randazza on her blogs until after Complaintant, Marc Randazza contacted the Plaintiff in Obsidian Vs. Crystal Cox in order to harm, defame, harass and threaten Respondent Crystal Cox. After Complaintant, Marc Randazza threatened me and demanded that I turn over MarcRandazza.com and after Complaintant, Marc Randazza contacted the Plaintiff who was suing me and the very same Plaintiff that weeks early Complaintant, Marc Randazza, who is an attorney, offered to represent me in defending me against this same Plaintiff.
Then, and only then did I start to poke fun at, criticize Complaintant, Marc Randazza in regard to his double standards, his WIPO domain name dispute cases, his Free Speech cases, his defending Rush Limbaugh AGAINST women’s rights and the over all hypocrisy of Marc Randazza, then I began to poke fun. I did not offer to clean this up for a fee. That is simply a flat out LIE by Complainant, Marc Randazza.
Complainant, Marc Randazza flat out lies saying that I had anything negative only when we discussed him working for me or me working for him, that is simply NOT True.
Complainant, Marc Randazza has no Legal Grounds to transfer said domain names, period.
In response to registering Complainant’s wife’s name, this is totally irrelevant to this complaint, however in response yes I had a blog on said domain name, this same blog is now at JenniferRandazza.blogspot.com, I gave JenniferRandazza.com to Alex Melody to further the cause of protecting women in the porn industry, of which one of Marc Randazza’s attorneys is connected to a stalker that was threatening Alex Melody’s family. Complainant, Marc Randazza stole this name out of Alex Melody’s account with the alleged help of Godaddy employee.
The registering of “Complainant’s 3-year-old daughter” is also irrelevant as to the right or lack of right to Complainant transfering MarcRandazza.com to Complainant, however I will Respond. This domain name was purchased by me in order to poke fun at how Ignorant Complainant, Marc Randazza, Domain Name Law expert is at Domain Name Law. It was NEVER, EVER pointed to a blog, nor did I ever publish that I owned this domain name. Complainant, Marc Randazza himself posted that I owned the name and accused me of harassment, stalking and all kinds of lies. Complainant, Marc Randazza even went so far as to file for a protective order against me. This was filed in Las Vegas Nevada, I was a Montana Resident. Complaintant, Marc Randazza even told Forbes, a big media company that I had the domain name and they posted a picture of the child. Complainant, Marc Randazza exploited his own child to seek revenge against me for registering the domain name MarcRandazza.com.
As far as Complainant, Marc Randazza claiming that Crystal Cox Respondent made up “news” articles that were barely literate and paranoid rant” Well this is his Opinion, and his Free Speech right to claim, though absolutely irrelevant to where Complainant, Marc Randazza has a legal right to steal MarcRandazza.com or not. Seems to me that Complainant, Marc Randazza is the one on a paranoid rant. And that Complainant, Marc Randazza is out to destroy Crystal Cox Respondent’s reputation and livlihood, endanger her, my life and deliberately paint Crystal Cox Respondent, me in False Light.
Also Complainant, Marc Randazza statements of “Respondent then peppered each blog article with hyperlinks to her other commercial websites, attempting to manipulate the page ranking of Respondent’s sites when indexed by search engines in order to interfere with the Complainant’s legitimate blogging endeavors and law practice and to gain money for herself.”
Well my, Crystal Cox’s, methods of Internet Search is absolutely irrelevant and is protect Free Speech in and of itself, See Eugene Volokh’s, UCLA Law Professor’s white paper on this issue, commissioned by Google, attached to this document. Crystal Cox Respondent was not interfering with with Complainant, Marc Randazza alleged “legitimate blogging endeavors”. And again this is absolutely irrelevant as to the right to own said domains or not. Complainant, Marc Randazza flat out lies that I received any money gained for myself in regard to said domain names, for I received no money in any way regarding said domain names.
Also Complainant, Marc Randazza statements of “Upon being made aware of the disputed status of the domain names, Respondent Cox engaged in a scheme to continuously “cyberfly” the domain names from one registrant to another in an attempt to evade any action to seize them. Cox transferred registration of the domain names in question to other parties—Eliot Bernstein and Alex Melody Mayers, and then to a Diana Grandmaison, after Cox realized she would face a UDRP dispute or other legal action regarding her improper registration and use of the Disputed Domain Names and other domain names affiliated with Complainant. (See Annex L). Cox has since transferred <marcrandazza.com> back to her name” This is absolutely false. I was not engaged in a scheme to “Cyberfly”. I registered MarcRandazza.com, and after I made a deal with Eliot Bernstein to transfer domain names in lieu of a Debt Owed, I then still owned MarcRandazza.com, JenniferRandazza.com and NataliaRandazza.com. I deleted NataliaRandazza.com as my point was made in regard that Marc Randazza, so called Domain Law Expert and Internet Law Expert was too ignorant to buy his own daughters name as a dotcom. Alex Melody is a Porn Industry News expert and had been exposing stalkers and issues within the porn industry that was harming those within the Porn Industry. Complainant, Marc Randazza is one of the biggest Porn Attorneys out there and I had recently aware that Alex Melody had connected a Randazza Legal Group attorney, J. M. Devoy with a Stalker whom had allegedly harassed and threatened many women within the porn industry and Alex Melody for exposing what they were up to and Alex’s family was threatened. There had been many women and children threatened harm and Alex Melody had proven a connection to Randazza Legal Group. I wanted to help expose this serious situation and therefor gave Alex Melody the domain names MarcRandazza.com and JenniferRandazza.com.
Complainant, Marc Randazza immediatley emailed Alex Melody and made offers for the domain names. Then when Alex refused to give Complainant, Marc Randazza the domain names, Complainant, Marc Randazza got very mad and posted online that Alex Melody should drive over a cliff and even gave the year and make of Alex’s car in order to intimidate and threaten Alex Melody. Complainant, Marc Randazza emailed Alex Melody, threatened Alex Melody and made Alex Melody in fear of their life and livlihood.
Complainant, Marc Randazza then proceed to push for the transfer of JenniferRandazza.com and Alex Melody refused, so Complainant, Marc Randazza in conspiracy with a Godaddy Employee and stole the domain name JenniferRandazza.com out of Alex Melody’s Godaddy Account.
Alex Melody fought for the domain name and Godaddy conspired with Complainant, Marc Randazza and Alex lost all rights to JenniferRandazza.com.
After this Alex Melody was discouraged as to any legal rights and the fact that Complainant, Marc Randazza was seemingly above the law and acting with insiders in conspiracy to steal domain names. So at this point, June 4th of 2012, I offered to take the domain name back in order to protect the life and livelihood of Alex Melody. On June 20th I went into Godaddy to Check the Domain Name and it was LOCKED, I could not even change the server, all my rights STRIPPED.
Crystal Cox Respondent, I was made aware of Czech Arbitration Court (CAC) Case No. 100472 on June 20th when I went into my godaddy account and noticed that the domain name MarcRandazza.com was on hold, I then emailed Godaddy as records show, Godaddy told me that a complaint had been filed with Czech Arbitration Court , as email records with Godaddy will show. I then emailed the Czech Arbitration Court and asked if I could get a copy of said complaint, and June 22nd I received said complaint copy. Complainant, Marc Randazza flat out lies in saying this: “Upon being made aware of the disputed status of the domain names, Respondent Cox engaged in a scheme to continuously “cyberfly” the domain names from one registrant to another in an attempt to evade any action to seize them.” That statement from Complainant, Marc Randazza is in no way true.
MarcRandazza.com was given to Alex Melody by me, Crystal L. Cox, period. And then transferred back out of deathly fear.
I, Crystal L. Cox, Respondent, in my Pro Se Capacity have NOT used said Domain Names for any form of cybersquatting, nor have I been charged with or committed acts of extortion in any way. I, Crystal L. Cox, Respondent, in my Pro Se Capacity have NOT used said domain names for pay per click revenue, the Registrar may have but I have NOT. I have also received no revenue for advertising for the Complainant’s name in any way.
I, Crystal L. Cox, Respondent, in my Pro Se Capacity have never offered Marc Randazza the service of cleaning up anything that I have posted. Marc Randazza offered in emailing what do I want.. I did not respond to this email. I had not poked fun at, made a parody of Marc Randazza in any way what so ever until he got VERY mad that I bought and owed MarcRandazza.com, and then he threatened me, gave false information to Forbes and NPR, Conspired with a Federal Judge to deny me a new trial in Obsidian V. Cox by Flat Out Lying about Extortion, and conspiring with the Plaintiff in my case Obsidian v. Cox. All this after emailing me, Crystal Cox Respondent that he, Complainant, Marc Randazza would represent me in my appeal AGAINST this same Plaintiff.
I, Crystal L. Cox, Respondent, in my Pro Se Capacity have NOT used MarcRandazza.com in bad faith. I have used MarcRandazza.com to report on important issues in Internet Law, Anti-Slapp Laws, Free Speech Law and Cases, First Amendment Rights Laws and Cases, and to poke fun at Marc Randazza himself for being an alleged expert in Domain Name Law and not buying MarcRandazza.com himself.
I, Crystal L. Cox, Respondent, in my Pro Se Capacity say that the above-referenced domains should NOT be transferred to the complainant.
Complainant, Marc Randazza does not have Trademark Rights to MarcRandazza.com
Complainant, Marc Randazza never sent a Cease and Desist to Crystal L. Cox, Respondent.
I, Crystal L. Cox, Respondent, in my Pro Se Capacity never falsely or deliberate mislead anyone with said domain names.
I, Crystal L. Cox, Respondent, in my Pro Se Capacity did not hold said domain name to sell or rent, in fact email records show that Complainant, Marc Randazza offered to buy said domain name and I, Crystal L. Cox, Respondent flatly rejected this offer at ANY price.
I, Crystal L. Cox, Respondent, in my Pro Se Capacity Response To: “IV. Legal basis” Section of Complaint Filed by Complainant, Marc Randazza.
There is no “proxy registrant” to said domain names. Said Domain Names are still pointed to my blogs in the registrar only because the new owner has not yet changed said servers. My blogs are independent of the domain names they are on, this is a technical FACT.
I, Crystal L. Cox, Respondent, in my Pro Se Capacity was NOT aware of any UDRP or Legal Dispute. Complainant, Marc Randazza claiming this in section “IV. Legal basis” of this complaint is pure nonsense. As I had transferred domain names for reasons of prior debt and gave names to Alex Melody to further the cause of victims of the porn industry. I had NO FEAR of a UDRP Dispute, as in the summer of 2011 I, Crystal L. Cox, Respondent, in my Pro Se Capacity had represented myself in a WIPO dispute against one of the world’s biggest law firms, Proskauer Rose Law Firm out of New York. I won the right to own 4 domain names in that dispute, those names were JosephLecesse.com, AllenFagin.com, GreggMashberg.com and ProskauerLawFirm.com .
The Purpose of my blogs regarding Complainant, Marc Randazza has been and will continue to FOREVER be about defending Free Speech Rights, Citizen Journalists rights and exposing the hypocrisy of Domain Name / Free Speech Attorney Marc Randazza.
Just because Marc Randazza is a lawyer does not mean he has a legal right these domain names.
Respondent Crystal Cox has every legal right to own MarcRandazza.com
Complaintant, Marc Randazza has no Trademark
Being a lawyer alone does not allow Complainant, Marc Randazza to own said domains any more then Glen Beck has a right to own the WIPO Case he lost, nor Jerry Falwell or Anna Nicole Smith, or the Annex C WIPO cases, that I myself Won regarding this same matter. Certainly Glen Beck is more renowned then Marc Randazza yet Complainant, Marc Randazza defended the right of his client Hall in buying and owning, and blogging on the domain name with Glen Beck Named, as in Annex E.
Complainant, Marc Randazza has provided no documents to prove that Complainant, Marc Randazza has a Trademark on the name Marc Randazza.
Google owns all blog content and can remove at any time, Marc Randazza has had many of my blogs removed, via Google and Wordpress and not through proper legal channels.
Complainant Marc Randazza says, “The Respondent’s sole purpose for operating the domains using the Complainant’s name is to “Google bomb” the Complainant in order to ensure that her sites, containing fabricated stories and barely legible rants, will appear near the top when his name is searched for on Google.com and other Internet search engines. “
Respondent asks is this illegal? Is an alleged Google Bomb illegal? If so then Google is the one participating in the google bomb as the publisher right?
http://www.volokh.com/wp-content/uploads/2012/05/SearchEngineFirstAmendment.pdf
Complainant Marc Randazza Says “The Respondent registered the Disputed Domain Name to prevent the Complainant from using his personal name as a domain name, to profit from Complainant’s name, and to harass Complainant and his family members.” This is in no way true. Crystal Cox Respondent registered MarcRandazza.com for the above stated reasons of Free Speech Issues and promoting cases regarding these issues of First Amendment Rights, Anti-Slapp Laws, Shield Laws, Bloggers Rights and other domain name issues, blogger’s rights issues, defamation issues, issues of chilling free speech online, and the rights of whistle blowers and citizen journalists worldwide.
Complainant Marc Randazza says “The Respondent has engaged in this conduct previously, thus establishing a pattern of such bad faith conduct. See Obsidian Finance Group v. Cox, No.
CV-11-57-HZ, (D. Ore. Jan. 23, 2012), In that suit, brought in U.S. federal district court, a jury found that the Respondent had registered several domain names using the plaintiff’s business name and personal name to besmirch the reputation of the individual plaintiff and the business plaintiff by constructing the sites in such a manner that they would appear near the top of Google searches. The jury awarded the plaintiffs in that case a total $2.5 million in damages.
The Obsidian case is not the only time that the Respondent has engaged in this behavior. In fact, Respondent has engaged in a pattern of registering the domain names of attorneys for the purpose of “Google bombing.” Respondent is a serial cybersquatter, and has registered
numerous domain names. See Annex X. Here, as the Respondent did previously in Obsidian, by registering the domains, the Respondent intended to disrupt and interfere with Complainant’s business. The Respondent registered multiple domain names using Complainant’s name or
similar variations in order to achieve this effect. In so doing, the Respondent registered and used the disputed domain names in bad faith.”
My alleged past conduct has no relevance on the Complainant right to steal my Intellectual Property. Yes I, Respondent Crystal Cox have registered the name of Attorneys in the past in order to expose them. And such Attorneys filed WIPO complaints against me and I won, See attached Annex C. Complainant Marc Randazza is falsely accusing me of cybersquatting when I have every legal right to own the domain names I have past purchased, this proven by Annex C, as Well As Annex J and K.
This domain name dispute has nothing to do with Obsidian Finance Group v. Cox, other then that is how I first came across Marc Randazza, as he was going to represent me in my appeal in Obsidian Finance Group v. Cox. Marc Randazza said he would represent me on appeal and then turned on me after I gave him privileged information regarding my case. This UDRP Panel is no place for Marc Randazza to whine about my alleged activity in a U.S. Legal Case.
Marc Randazza, Complainant should be ashamed, as an Attorney in 5 States, Marc Randazza flat out lies about the details of Obsidian Finance Group v. Cox, as he says this “a jury found that the Respondent had registered several domain names using the plaintiff’s business name and personal name to besmirch the reputation of the individual plaintiff and the business plaintiff by constructing the sites in such a manner that they would appear near the top of Google searches. The jury awarded the plaintiffs in that case a total $2.5 million in damages.”
Obsidian Finance Group v. Cox, as the records plainly show was in regard to ONE blog post on a blog that was published on the Domain Name BankruptcyCorruption.com, this was not a personal person’s name, it was not an attorney’s name, nor was it a company name. Marc Randazza has again lied about Respondent Crystal Cox and painted me in false and defamatory light. This statement simply is not based in fact.
The Jury did award $2.5 Million to the Plaintiff, simply for the reason that I refused to give up my source, and the courts stripped my rights to actual malice, shield laws, anti-slapp laws, retraction laws and more, in order to protect over $50 million dollars that went through the accounts of Portland Oregon Attorneys and I was exposing them, along with the Bankruptcy Judge, Judge Randall Dunn and the Dept. of Justice Trustee Pamela Griffith in conspiracy with Steven Hedberg of Perkins Coie Law Firm and Leon Simson of Tonkon Torp Law Firm as well as those at Obsidian Finance Group whom violated U.S. Bankruptcy Laws.
I am a Whistle Blower and I was getting the story found in the search engines. The Story of the Summit $40 Million Bankruptcy out of Bend Oregon with victims in 5 States and involving an IRS Tax Based 1031 Exchange Company. My case is on appeal, and was nothing to do with a Domain Name dispute.
I never benefited monetarily from said domain names, period. Marc Randazza is lying to this domain dispute panel.
How can Marc Randazza possibly have the right to own MarcRandazza.com yet allege that Glen Beck had no right, and Marc Randazza won that case for his client Respondent Isaac Eiland-Hall ? (See Annex E)
Marc Randazza claims that silencing Rush Limbaugh is un-American, (see Annex G) Yet Marc Randazza has done everything in his power to silence Investigative Blogger Crystal Cox, me. Marc Randazza has doubled standards at best, as you look at Marc Randazza’s history of cases, his videos and what he speaks for, it sure seems hypocritical to attempt to silence my Free Speech rights for the very same issues.
As you look at the details of the Glen Beck WIPO Case No. D2009-1182 you see that Marc Randazza adamantly defended the rights of Respondent Isaac Eiland-Hall to own the domain name "GlennBeckRapedAndMurderedAYoungGirlIn1990.com", yet Marc Randazza claims a right to own MarcRandazza.com.
As you see in the following quotes, I have attached full document to my response, the Title of the Document is Marc J. Randazza, First Amendment * Trademark * Copyright * Domain Name Law * Internet Law. Marc Randazza claims to be an expert in those areas of expertise, however Marc Randazza did not own the dotcom in dispute? Why? I bought the domain name, not only to present information regarding First Amendment and Free Speech issues as discussed elsewhere in this response but also to poke fun at, to parody the fact that Marc Randazza did not buy the domain name and is not what he proclaims to be.
Here is a quotes from a Letter from Marc Randazza to Glen Beck’s Attorney Matthew A. Kaplan regarding the Glen Beck domain name dispute.
“Re: Proposed Stipulation in WIPO Case No. D2009-1182
Dear Mr. Kaplan,
As you may be aware, from reading our Response in this case, there is a split of authority in the WIPO decisions as to how criticism sites should be examined. See “WIPO Overview of WIPO Panel Views on Selected UDRP Questions,” at Paragraph 2.4.
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 non-commercial.”
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. ..
On March 30, 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.
I hate to presume anything about anyone, but I presume that Mr. Beck will agree to this
stipulation. It would be an interesting day indeed if Mr. Beck preferred to risk that a panelist would apply French law to a case between two Americans over a matter of public discourse.
I recall that Beck publicly called Harold Koh, the Dean of Yale Law School, a “threat to
American democracy” for his views on transnational law. Beck said of Koh: he wants to subordinate the American Constitution to foreign and international rules. We see that in his attack on First Amendment free speech principles, which he finds opprobrious.
Similarly, Mr. Beck said it best when he warned of the dangers of allowing international legal principles to trump our cherished constitutional rights:
Once we sign our rights over to international law, the Constitution is officially dead.
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.
I have attached a proposed stipulation for your review.
Sincerely,
Marc John Randazza “
Source of Letter from Marc Randazza to Opposing Counsel Regarding his client Respondent Isaac Eiland-Hall owning the domain name in dispute, "GlennBeckRapedAndMurderedAYoungGirlIn1990.com"
http://randazza.files.wordpress.com/2009/09/ct_oc_re_stipulation_proposed_final_xmt.pdf
Note: I have also attached a PDF to this Response to the the Czech Arbitration Court (CAC)
Notes Regarding the Above Letter Sent by Marc J. Randazza, Domain Name Attorney
As Complainant Marc J. Randazza says to Attorney Matthew A. Kaplan regarding the Glen Beck domain name dispute, WIPO Case No. D2009-1182
there is a split of authority in the WIPO decisions as to how criticism sites should be examined. See “WIPO Overview of WIPO Panel Views on Selected UDRP Questions,” …
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 non-commercial.”
Respondent Crystal Cox has these same rights. My sites are critisizing Marc Randazza and he does not like it. My Blogs are non-commercial and do not divert his intended commercial clients.
In that same letter Complainant Marc J. Randazza is quoted as saying, “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.” yet Complainant Marc J. Randazza does not want these same Constitutional rights for Respondent Crystal Cox.
In that same letter Complainant Marc J. Randazza goes on to say “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. ..” Yet Complainant Marc J. Randazza has ISSUE with Respondent Crystal Cox buying a domain name with his name there in, I find this Puzzling at best.
In that same letter Complainant Marc J. Randazza complains about Glen Beck allegedly saying this “On March 30, 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.” Yet in Czech Arbitration Court (CAC) Case No. 100472 that is exactly what Complainant Marc J. Randazza does, he takes the case to an international level. Talk about double standards. Complainant Marc J. Randazza is quoted as saying “we respect his creativity in seeking an alternate avenue where his claims might have a chance of success.” in this same case.
In that same letter Complainant Marc J. Randazza goes on to say “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.” Yet Complainant Marc J. Randazza wishes to deny Respondent Crystal Cox these same rights.
In that same letter Complainant Marc J. Randazza goes on to say to Mr. Kapplan “Once we sign our rights over to international law, the Constitution is officially dead.” Yet that is exactly what Complainant Marc J. Randazza has done in Czech Arbitration Court (CAC) Case No. 100472, Marc J. Randazza Vs. Reverend Crystal Cox.
Complainant Marc J. Randazza ends that letter to Mr. Kapplan, attorney for Glen Beck, by Saying this: “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 Complainant Marc J. Randazza, in a hypocritical double standard in all his arrogance and above the law demeanor wants to take these same First Amendment Rights away from me, Blogger, Respondent Crystal Cox.
In the Glen Beck WIPO Case No. D2009-1182 Case, Citizen Media Law Project assistant director Sam Bayard said of the WIPO arbitrator's decision, "It's good to see that this WIPO arbitrator had no interest in allowing Beck to circumvent the guarantees of the U.S. Constitution."
The Order Deny New Trial and other Documents Annexed as Exhibits to this Complaint are NOT relevant as to Complaintant’s right to own, steal, transfer said domain names.
Annex E4 - Internet Meme
"An Internet meme is an idea that is propagated through the World Wide Web. The idea may take the form of a hyperlink, video, picture, website, hashtag, or just a word or phrase, such as intentionally misspelling the word "more" as "moar" or "the" as "teh". The meme may spread from person to person via social networks, blogs, direct email, news sources, or other web-based services. An Internet meme may stay the same or may evolve over time, by chance or through commentary, imitations, parody, or by incorporating news accounts about itself."
http://en.wikipedia.org/wiki/Internet_meme
Conclusion
Marc Randazza is deliberately painting blogger Crystal L. Cox in false Light. Marc Randazza is defaming and harassing blogger Crystal L. Cox.
Marc Randazza’s legal name is said to be Marco Randazza
Marc Randazza of Randazza Legal Group is not the only Marc Randazza in the world. Why should Marc Randazza of Randazza Legal Group be entitled to MarcRandazza.com vs other Marc Randazza’s of the world? Shouldn’t domain names be first come first serve, and why is a self proclaimed First Amendment, Free Speech expert using this panel to suppress the Free Speech rights of a blogger who is criticizing him?
Complainant, Marc Randazza is a dangerous man. Complainant, Marc Randazza is a bully and an unethical attorney who betrays his own clients. Complainant, Marc Randazza told me he represented me, I have emails to prove it, then Complainant, Marc Randazza turns on me in a rage over a domain name.
Complainant, Marc Randazza is above the law that others have to follow. Complainant, Marc Randazza has serious anger management issues. Complainant, Marc Randazza is involved in stalking, harassing and gathering hundreds of bloggers to bully these people on line. Complainant, Marc Randazza condones his attorneys at Randazza Legal Group who threaten, berate, and put in danger those who speak out against the porn industry.
Marc Randazza is believed to have an insider at the Czech Arbitration Court (CAC) that is said to be able to seize this domain name for Marc Randazza of Randazza Legal Group. Why else file with the Czech Arbitration Court (CAC) instead of WIPO.
I once told Marc Randazza of the major WIPO Cases that I won last summer (See Annex C ) and Marc Randazza said to me that he did not care about WIPO. That is also in email records.
Over the last 6 months Marc Randazza has harassed me, and even tried to get a protective order against me out of Las Vegas, though I am a Montana Resident. Marc Randazza did this to intimidate and harass me. Marc Randazza has gathered many bloggers, attorneys, web site owners together to specifically target me and my reputation online. All seemingly because I did not choose Marc Randazza to be my attorney in a very high profile First Amendment Free Speech Case.
Marc Randazza went so far as to conspire with the Plaintiff in my case to set me up for Extortion, after Marc Randazza had agreed to represent me. Those emails are attached to this response and can be forwarded, investigated in any way upon demand.
If Complainant believes that it is his inalienable right to own MarcRandazza.com, then why did he never purchase MarcRandazza.com? And why should Blogger Crystal Cox, me, have to pay the price of losing this valuable asset that I have built up in the search engines, simply because Marc Randazza was not smart enough, per say to buy said domain name?
There was NO witness Tampering, I exposed Marc Randazza for his criminal activity in conspiracy to set me up with extortion, I fought back, I did not tamper with a witness. Marc Randazza called Plaintiff and set up his own Subpoena. Request phone records, email records and you will find that Marc Randazza offered to give testimoney and was not a witness. If Marc Randazza believes I tampered with a witness then the UDRP Arbritration is not the place for that Complaint.
Respondent Signature Page
Case No. : 100472
Covenants
Respondent objects to the applicable Mutual Jurisdiction as specified in this complaint.
Respondent, Crystal Cox in now way waves remedies against any panelist or decision making in this decision process.
Respondent, Crystal Cox certifies that the information contained in this Complaint is to the best of Respondent, Crystal Cox's knowledge complete and accurate, that this
Respondent, Crystal Cox claims that this complaint is being used for improper purpose, harassment, defamation, slander, and that the assertions in this Complaint are NOT warranted under these Rules and under applicable law.
Crystal L. Cox
Pro Se Respondent
SavvyBroker@Yahoo.com
No comments:
Post a Comment
Note: Only a member of this blog may post a comment.