Thursday, January 24, 2013

Chill Free Speech, First Amendment Legal Threat, Free Speech Threat, Central District of California SLAPP Suit 2:12-cv-02484-GW-SH, MANWIN LICENSING INTERNATIONAL SARL V. NICHOLAS BULGIN. Domainers, Citizen Journalists, Bloggers, Whistleblowers: FIGHT BACK, Know your Rights.

Nicholas Bulgin;  FIGHT BACK, Know your Rights.  
Manwin, Counter Defendant in State of Nevada Case 2:12-cv-02040-GMN-PA is Going after Manwin Sucks Site. Investigative Blogger Crystal Cox Alleges, this is in Criminal and Civil Conspiracy with Co-Conspirators and Counter Defendants of District of Nevada 
Case 2:12-cv-02040-GMN-PAL.

Below is Research Tips for ALL Victims of SLAPP Suits, Free Speech Legal Threats, First Amendment Legal Threats, Intellectual Property Legal Threats 

 Central California 2:12-cv-02484-GW-SH

2:12-cv-02484-GW-SH -  Manwin Unconstitutionally V. Nicholas Bulgin

NOTE: First Amendment Rights TRUMP Trademark Laws

"Manwin Seeks $400K, Domain Transfers in Trademark Suit"

"LOS ANGELES — Manwin has filed court papers spelling out what the adult entertainment conglomerate is seeking in its suit against Nicholas Bulgin.

The company is demanding $400,000 in damages from Bulgin, described in court papers as a "professional cybersquatter," for violating its trademarks — the statutory maximum for four websites Bulgin allegedly registered (,, and

Manwin, in its motion for a default judgment, also is asking for approval to transfer the domains at the heart of the suit. Currently, the company does not own,, and

The requests to the court, which is slated to hear Manwin's default motion on Feb. 21, go further.

Manwin wants a permanent injunction requiring Bulgin to cease registering more Manwin variant websites, as well as Twitter accounts or blogs, and cease from disseminating statements falsely accusing Manwin reps or even its managing partner, Fabian Thylmann. It also seeks $11,600 in attorneys fees."

Source and Full Article
hey have you seen the Case?

This is the Exact Same Case Merits. They are using Trademark as the New Way to Suppress Free Speech, and you know who is behind it all. The Co-Conspirators and Counter Defendants of State of Nevada Case 2:12-cv-02040-GMN-PAL. Can you Say RICO?

These Guys are in Criminal and Civil Conspiracy. You have a Free Speech Right to Parody them, to have a Sucks Sites. 

Research Links

"Trademark use in a fictional work to describe or identify products or services. Some examples would be, "shopping for books at Walmart", "playing a Playstation game", and "wearing Oakley sunglasses." Trademark law allows an author of a non-fiction work to use trademarks in a way that is critical of the owner's products or services such as "rolling over in my Ford". In this situation, the author uses the trademark to describe Ford's vehicles and is careful not to confuse the reader as to the owner of the trademark. Ford has yet to file a trademark infringement lawsuit against the individual. Another website, is a website that Ford heavily targeted to get removed from the Internet and as with many other corporations, FAILED MISERABLY to get it removed. Ford has seemingly given up on it, maybe they are finally more focused about their failing dynasty.

The above-referenced situations are considered non-confusing and "nominative use" based on the following requirements:

the owner's product and service cannot be easily identifiable without the use trademark
the author uses as little of the trademark as possible to identify the trademark owner's products or services the author does nothing that suggests to the reader sponsorship or endorsement by the trademark owner."


Research ALL Documents in the, 

as to Parody, Satire, Trademark.

Research the Goldman Sachs V. Mike Morgan Case

A Bit on the Trademark and Domain Names

"Sprint Nextel is run by Dan Hesse. Sprint gouged Allen Harkleroad's company for tens of thousands of dollars for dedicated Internet connectivity. Sprint refused to rectify the situation and ignored Mr. Harkleroad's attempts to settle the matter. was started to give people a place to vent their frustration with Sprint. Sprint has not filed a SLAPP against Harkleroad, because they know they would be wasting the money they ripped Harkleroad off for. Allan's redesign of the Sprint logo with the transparent word of SUCKS on top of it was absolutely brilliant and fully protected under trademark law. He could have gone one step further by adding a rubber stamp just above the 'sucks' to show his seal of approval.

Sprint also has been harshly criticized on a website that is looking for authorized dealers to bring a class action lawsuit against Nextel."


" An Example of the Difficulties in Applying Trademark Law to Domain Name Disputes"

Also Nicholas Bulginand BULLIED Defendants such as Nicholas Bulgin, Note This:

Your First Amendment Rights MUST Be Adjudicated Before they Can Seize a Domain Name or your Content.

"If a court issues an injunction prior to adjudicating the First Amendment Protection of the speech at issue, the injunction cannot pass constitutional muster."

If your Domain Names, Sites are SEIZED before the First Amendment is Adjudicated or Considered a Factor in the case and thereby "expressly skipping the essential step of adjudicating the First Amendment protections to the speech at issue.", then this is a violation of law and constitutional rights. FIGHT BACK.

Manwin is a Public Figure. (New York Times Vs. Sullivan). You have a right to a Gripe Site, Parody Site, Review Site, Sucks Site, Satire Blog / Site.

A Judicial Order that prevents free speech from occurring is unlawful. ( Erwin Chemerinsky, Constitutional Law; Principles and Policies 918 (2002) ( “The Clearest definition of prior restraint is.. a judicial order that prevents speech from occurring:).

Prior Restraints are “the most serious and least tolerable infringement on First Amendment Rights.” Neb. Press Ass’n v. Stewart, 427 U.S. 539, 559 (1976).  There is a “deep-seated American hostility to prior restraint” Id at 589 (Brennan, J. concurring).

Injunctive relief to prevent actual or threatened damage is heavily disfavored because it interferes with the First Amendment and amounts to censorship prior to a judicial determination of the lawlessness of speech. See Moore v. City Dry Cleaners & Laundry, 41 So. 2d 865, 872 (Fla. 1949). “The special vice of prior restraint,” the Supreme Court held, “is that communication will be suppressed... before an adequate determination that it is unprotected by the First Amendment”. Pittsburgh Press Co v. Pittsburg Comm’n on Human Relations, 413 U.S. 376, 390 (1973). Also se Fort Wayn Books Inc. v Indiana, 489 U.S. 46, 66 (1989); M.I.C., Ltd v Bedford Township, 463 U.S. 1341, 11343 (1983.)

Also see Post-Newswek Stations Orlando, Inc. v. Guetzlo.

“RKA sought extraordinary relief in the form of prior restraint to enjoin .. . This relief is not recognized in this State, nor anywhere else in the Country.  In addition to ignoring the First Amendment Rights and almost a century’s worth of common law, the .. court ignored virtually all procedural requirements for the issue of a preliminary injunction.” Page 5 Paragraph ii of Opening Brief Appellate Case No. 3D12-3189, Irina Chevaldina Appellant vs. R.K./FI Management Inc.;, Appellees. Attorney for Appellant Marc J. Randazza Florida Bar No. 325566, Randazza Legal Group Miami Florida. "

Research Fraud on the Courts, Judicial Cannons and ...

In the United States, when an officer of the court is found to have fraudulently presented facts to court so that the court is impaired in the impartial performance of its legal task, the act, known as "fraud upon the court", is a crime deemed so severe and fundamentally opposed to the operation of justice that it is not subject to any statute of limitation.

Officers of the court include: Lawyers, Judges, Referees, and those appointed; Guardian Ad Litem, Parenting Time Expeditors, Mediators, Rule 114 Neutrals, Evaluators, Administrators, special appointees, and any others whose influence are part of the judicial mechanism.
"Fraud upon the court" has been defined by the 7th Circuit Court of Appeals to "embrace that species of fraud which does, or attempts to, defile the court itself, or is a fraud perpetrated by officers of the court so that the judicial machinery can not perform in the usual manner its impartial task of adjudging cases that are presented for adjudication". Kenner v. C.I.R., 387 F.3d 689 (1968); 7 Moore's Federal Practice, 2d ed., p. 512, ¶ 60.23

In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated "Fraud upon the court is fraud which is directed to the judicial machinery itself and is not fraud between the parties or fraudulent documents, false statements or perjury. ... It is where the court or a member is corrupted or influenced or influence is attempted or where the judge has not performed his judicial function ‐‐‐ thus where the impartial functions of the court have been directly corrupted."

What effect does an act of “fraud upon the court” have upon the court proceeding? “Fraud upon the court” makes void the orders and judgments of that court."

First Amendment Rights 
TRUMP Trademark Laws
Also NoteThe Information Below from Court Documents and Filings of District of Nevada Case 2:12-cv-02040-GMN-PAL - Chill Speech Case,

Reader: The Registrar in my Case is Godaddy, So Your Case May Be Different

" was one of these Domain Names SEIZED by Plaintiff / Counter Defendant Marc Randazza with no Due Process to Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox and Defendant Eliot Bernstein and no First Amendment Adjudication. was purchased by Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox as a Parody, making fun of Plaintiff / Counter Defendant Marc Randazza. was never a blog, has made ad revenue by Godaddy yet in a fraud on the court RRR claims that Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox made the ad revenue. This domain name was SEIZED, Stolen. and the “taboo” domain were both parked at Godaddy and never had blogs. Godaddy Inc., Bob Parsons had ads on the parked pages yet Plaintiff / Counter Defendant Marc Randazza claims that Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox did, knowing full well that Crystal Cox was not the one receiving ad dollars. Plaintiff / Counter Defendant Marc Randazza, with actual malice committed fraud on the court and lied regarding Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox and domain names at Godaddy. Godaddy Inc., Bob Parsons has Pattern and History in freely placing ads on Trademarked Parked Domain Names Godaddy Inc., Bob Parsons are IMMUNE from Legal Action and are able to make ad revenue hand over fist on trade names, trademarked names in a domain name, yet Godaddy Clients, Customers and Domainers are SUED by Attorneys such as Plaintiff / Counter Defendant Marc Randazza. When a company, say, for example Walmart of Ford, or an Association Say, such as “Realtor” issue a cease and desist or sue a Godaddy Clients, Customers and Domainers for Trademark Infringement, they are satisfied as long as the Godaddy Clients, Customers and Domainers moves the Domain Name to a parked page, vs a blog. They deem the blog or website as stealing their traffic and redirecting their business, however, these companies such as Ford, Walmart, Realtors, as in the example, have no issue with Godaddy Inc., Bob Parsons making that ad dollar revenue of their good name, their trademarked name. This is unlawful, hypocritical, discriminating, unconstitutional and a violation of the legal rights of the Godaddy Clients, Customers and Domainers. Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox and business partner have been Godaddy Customers since 2005, for years having over 5000 domain names. We have executive account manager, received gifts from Godaddy and constant calls. YET, when an unlawful, bully, hypocritical attorney such as Plaintiff / Counter Defendant Marc Randazza sues someone like us, a valuable Godaddy Client, Godaddy Inc., Bob Parsons not only sticks up for the attorney, Godaddy Inc., Bob Parsons breaks the laws and UDRP rules in changing servers and violating rights, conspiring with that attorney and against their own clients. Godaddy sends emails trying to get you to buy domains, yes even trademarked names and names of OTHER PEOPLE. Godaddy gets ad dollars from parked domains even when a domainer is renew them, why? Because Godaddy is “Allowed” to make ad dollar money from PARKED, Trademarked Domain Names but Domainers are NOT. Godaddy Inc., Bob Parson has been at this racketeering game for Years. Pro Se Defendant / Pro Se Counter Plaintiff Crystal L. Cox will soon be naming Godaddy, Bob Parson, WIPO, Peter L. Michaelson, along with Plaintiff / Counter Defendant Marc Randazza and other co-conspirators and counter defendants in a Federal RICO Complaint, a Criminal Complaint to the Attorney General and reporting to all authorities the activities of Godaddy, Bob Parson, WIPO, Peter L. Michaelson, along with Plaintiff / Counter Defendant Marc Randazza and other co-conspirators and counter defendants. Godaddy Inc., Bob Parson woos their clients at trade shows, sends them special gifts, emails offer non stop. And the biggest Godaddy Clients such as Investigative Blogger Defendant Crystal Cox, when our Domain Names are STOLEN, Godaddy conspires with the Intellectual Property Thieves and violates the rights of long term Godaddy Clients. Godaddy Inc. lets' buyers spend money on Trademarked Domain Names, and Godaddy Inc. Gives no refund. When Companies such as WALMART and Association such as REALTOR, send a Domainer a cease and desist, they are satisfied if the name is PARKED. Thing is the Domainer PAID for the Domain Names, renewed the Domain Name, Got the Domain Name found in the Search Engines and Godaddy GOT the Revenue from the PARKED Domain Names. The Courts, WIPO, ICANN, they all side with the Trademark Owner, and AGAINST the Smart, Internet Savvy Domainer. So the Domainer pays for the Domain Name, Gets the Domain Name in the Search, then pays to litigated the loss of the Domain Name and GODADDY gets all the MONEY with NO Liability, EVEN though GODADDY is the One Selling Trademarked Domain Names. Godaddy Auctions Sell Trademarked Names, Domain Name Leasing Sites Lease Trademarked Names and godaddy makes ad Dollars from the ads on the domain names, even the Trademarked ONES."

The Registrar Makes Money, Why Can't The End User?

First Amendment Rights 
TRUMP Trademark Laws

Also Check Out this Nevada SLAPP Suit to Chill Free Speech

District of Nevada Case Number 2:12-cv-02040-GMN-PAL Chill Speech Threat

For More on District of Nevada Case Number 2:12-cv-02040-GMN-PALthis Nevada Slapp Suit, Nevada Shield Law Challenge, Free Speech Threat, Chill Speech Threat, First Amendment Threat, Intellectual Property Fraud, SLAPP Lawsuit, Violation of Due Process, Violation of Constitutional Rights, WIPO Fraud Alleged, Godaddy Inc. Civil and Criminal Conspiracy Alleged, Tonkon Torp Civil and Criminal Conspiracy Alleged, Obsidian Finance Group Civil and Criminal Conspiracy Alleged, Peter L. Michaelson Civil and Criminal Conspiracy Alleged, Liberty Media Holdings Civil and Criminal Conspiracy Alleged, Philly Law Blog Civil and Criminal Conspiracy Alleged, NPR Civil and Criminal Conspiracy Alleged, Forbes Civil and Criminal Conspiracy Alleged, Kashmir Hill Civil and Criminal Conspiracy Alleged, New York Times Civil and Criminal Conspiracy Alleged, David Carr Reporter Civil and Criminal Conspiracy Alleged, APPLE Executives Civil and Criminal Conspiracy Alleged, Intel Corp. Civil and Criminal Conspiracy Alleged, Nevada Courts Civil and Criminal Conspiracy Alleged, Free Speech Coalition Civil and Criminal Conspiracy Alleged, Diana Duke Civil and Criminal Conspiracy Alleged, Kenneth P. White Civil and Criminal Conspiracy Alleged, Brown White and Newhouse Civil and Criminal Conspiracy Alleged, J. Malcom Devoy Civil and Criminal Conspiracy Alleged, Greenberg Traurig Civil and Criminal Conspiracy Alleged, Ronald D. Green Civil and Criminal Conspiracy Alleged and many others,District of Nevada Case Number 2:12-cv-02040-GMN-PAL 

Posted Here by 
Investigative Blogger Pro Se Defendant / Pro Se Counter Plaintiff
Crystal L. Cox
Upon Knowledge and Belief

Nicholas Bulgin; FIGHT BACK, Know your Rights. Manwin, Counter Defendant in State of Nevada Case 2:12-cv-02040-GMN-PA is Going after Manwin Sucks Site, this is in Criminal and Civil Conspiracy, RICO. 2:12-cv-02484-GW-SH