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	B. The Internet Confederates 47. At the time P&G became a behind the scenes sponsor of the Schwartz site, Mr. Schwartz was in regular contact with Internet confederates who shared a common purpose with Schwartz and P&G, namely, to damage or destroy Amway's business. Schwartz was also providing links on his web page to the web pages of his Internet confederates at that time. P&G knew or should have known that its secret sponsorship of the Schwartz site would amplify the impact of not only Schwartz's site but also the sites of Schwartz's Internet confederates. 48. Many of these Internet confederates identified themselves as an anti-Amway "ring" and explicitly welcomed others to join the "ring." According to one confederate: "All anti-MLM and anti-Amway pages are welcome to join the ring." 49. Schwartz provides links to many of the sites that make up this ring. In addition, the members of the "ring" include links or other mechanisms on each site facilitating the ability of a reader to move easily from one false and misleading antiAmway site in the ring to another. Amway is continuing its investigation into the identity and role of other members of the anti-Amway ring.50. In order to facilitate his communication with other members of the ring, Schwartz set up an e-mail group called the "BLC" (or "Broke Losers' Club"), which is used as a forum to discuss plans to damage Amway's business. One participant in the group has explained that the BLC consists of "anti-Amway/AMO site authors [who are] not just 'talking"' but are functioning as "a vehicle for action" against Amway. 51. The BLC members' web sites reveal that the "action" they intend to take against Amway is to spread or assist in spreading malicious lies in an effort to damage Amway's business expectancies. For example, on a web site entitled "Amway: The Continuing Story," one member advises: "Any action you take should be directed at stopping the growth of the Amway business or stopping the flow of income. . . . Like the 'war on drugs' the best attack is to stop the inflow of new people."

B. The Internet Confederates

47. At the time P&G became a behind the scenes sponsor of the Schwartz site, Mr. Schwartz was in regular contact with Internet confederates who shared a common purpose with Schwartz and P&G, namely, to damage or destroy Amway's business. Schwartz was also providing links on his web page to the web pages of his Internet confederates at that time. P&G knew or should have known that its secret sponsorship of the Schwartz site would amplify the impact of not only Schwartz's site but also the sites of Schwartz's Internet confederates.

48. Many of these Internet confederates identified themselves as an anti-Amway "ring" and explicitly welcomed others to join the "ring." According to one confederate: "All anti-MLM and anti-Amway pages are welcome to join the ring."

49. Schwartz provides links to many of the sites that make up this ring. In addition, the members of the "ring" include links or other mechanisms on each site facilitating the ability of a reader to move easily from one false and misleading antiAmway site in the ring to another. Amway is continuing its investigation into the identity and role of other members of the anti-Amway ring.50. In order to facilitate his communication with other members of the ring, Schwartz set up an e-mail group called the "BLC" (or "Broke Losers' Club"), which is used as a forum to discuss plans to damage Amway's business. One participant in the group has explained that the BLC consists of "anti-Amway/AMO site authors [who are] not just 'talking"' but are functioning as "a vehicle for action" against Amway.

51. The BLC members' web sites reveal that the "action" they intend to take against Amway is to spread or assist in spreading malicious lies in an effort to damage Amway's business expectancies. For example, on a web site entitled "Amway: The Continuing Story," one member advises: "Any action you take should be directed at stopping the growth of the Amway business or stopping the flow of income. . . . Like the 'war on drugs' the best attack is to stop the inflow of new people."

C. Mr. Lowndes

52. Mr. Schwartz has also maintained links to the web site operated by Mr. Lowndes entitled "Lowndes for Congress." As with the P&G/Schwartz web site, the "information" contained on the Lowndes site has been false, misleading and calculated to result in damage to Amway's business, The "Lowndes for Congress" site has included the following maliciously false statements:

"The Amway Corporation stole a lot of money from my family, when it was most needed. My now eight year old son Jordan was born near the time of the theft."

"We developed a direct mail campaign involving MCI, authorized by the Amway corporation in Official literature, and then behind our backs without any of the contractually required notices, Amway proceeded to lie to our clients, convincing them to send the MCI sign-ups in to Amway, by-passing our family, even though the Corporation had no legal standing whatsoever to do so, in contract law and/or in Criminal Law."

"According to the marketing plan, how much money does Amway steal when they intentionally and wrongfully interfere with this plan and objection?"

"Can or will Amway survive running things honestly and fairly?"
"AMWAY HITS PANIC BUTTON, 'THREATENS' LOWNDES FOR CONGRESS WITH LAWSUIT!! AMWAY WANTS TO BE 'MANAGER' OF CAMPAIGN! BIG BLUFF FROM CONFESSED THEIVES (AMWAY FOUNDERS, THAT IS)!!"

The web site has contained many other false and defamatory statements, but these are typical.

53. The Lowndes site has falsely and maliciously portrayed Amway as having "[b]ought and paid for" the decisions of the Courts of the United States of America. In describing a Federal Magistrate Judge's decision upholding a discovery subpoena, Lowndes stated: "[The scope of appeal process] is up to the corporate Amway Federal Judicial System. I know, I know, you all thought that the Courts are there for We the people - sorry, but by what I encountered today, Amway already OWNS the Judges [sic] 'Decisions!' Bought and paid for, to the humble best of my limited ability to comprehend what is going on." [emphasis original]

54. Lowndes apparently has nothing but contempt for the duly issued and served discovery process of the United States. Lowndes has reported on his site that he "will publicly BURN any (constitutional First Amendment Violating Subpoena - in front of Amway HQ! - with the Full Press and Media invited to watch!"

55. The Lowndes site has also falsely and maliciously portrayed Amway as "promoting classic fascism."

56. Shortly after the Lowndes site appeared on the Internet, Schwartz, as was his practice, provided a link to the Lowndes site on the P&G/Schwartz web site. By providing this link, Schwartz enabled anyone who accessed the P&G/Schwartz web site to become aware of the Lowndes site and to obtain easy access to it. The Lowndes site frequently changed its location on the Internet, and the P&G/Schwartz site regularly updated its link to the new location of the Lowndes site.

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This page updated Jul-26-99