CUOMO 2South, Mineola, NY 11501/Tel: (516) 7413222/Fax: (516) 7413223 | 200 Old Country Road, Sui Squarespace, Inc. January 10, 2017 224 Varick Street NY.NY 10014. VIAEMAIL ‘To: Squarespace (abuse@squarespace.com) Re: VoicesofJupiterFlorida.com I write on behalf of my client, Robert Krausanisas, host and author of Copyright- ‘Trolls.com, regarding VoicesofupiterFlorida.com (“VOIP”), « disturbing blog written by an anonymous writer hosted by the Squarespace platform, ‘Asa lawyer who is familiar with and represents blogger's rights, I recognize and support that bloggers have the right to anonymously post legitimate criticisms and commentary. I understand that Internet Service Providers such as Squarespace are not directly liable or responsible for what any blogger may post as I have represented many clients over my 30 years of experience in claims regarding Section 230 of the Communications Decency Act; The First Amendment to the United States Constitution; and copyright infringement, However, many remarks on VOJF are false and defamatory. Furthermore, the Squarespace blog hs been used within anonymous emails directed at my client's customers and tortuously interfering with his business. The scope of this harassment has now escalated to where his wife’s employer and members of a not-for-profit board on which she sits have received these harassing emails Reading over Squarespace's Terms of Serviee, it appears to my client that this, "anonymous" blogger is falsely representing and impersonating themselves asa group of concerned citizens and parents of Jupiter Florida in an apparent effort to create false weight and false credibility to the false, deceptive, and harmful content being written. My client believes that most, if not all, the comments are being "faked.” Again, the issue is not whether anyone can post a comment anonymously or whether fake comments are impermissible per se, The issue is that the whole site is someone impersonating themselves as a concemed resident or residents of Jupiter, Florida and has created alleged, fake commenters for the purpose to harass and abuse my client and his family. The blog goes far beyond criticizing my elient, his business, o his blog. The writer has ‘embarked on a singular campaign of personal and defamatory attacks against my client and his family. The blog pointedly identifies my client's home address; his wife; her employer; their son's name; and makes many references to his minor daughter. I would like to emphasize that my client brings these matters up as a matter of potential violations of Squarespace's Terms of Service and Acceptable Use Policy, not as an attempt to stifle legitimate speech. In fact, the VOJF blog is an attempt to stifle Mr. Krausankas’ right to free speech. We believe that the perpetrator of this campaign of harassment is either Joel Albrizio, the subject of a negative article written by my client on his website Copyright-trolls.com, or someone connected WWW.CUOMOLLE.COM,CUOMO to Mr, Albrizio. I have no direct proof of this, but the circumstances surrounding the timing of the Krausankas article and the creation of VOJF and dissemination of the harassment campaign provide a strong temporal proximity between the two, Further, I have previously communicated with Mr. Albrizio when he made verbal threats upon my client to “destroy” him and “ruin his life", We believe VOJF is, in fect, being used as an instrument to carry out that promise. I have attached a copy of that letter for your reference, Attachment Two shows an email we have obtained that points to an IP address originating from Pawtucket, Rhode Island I would add that having known Mr. Krausankas personally and professionally for a number of years, [ am personally aware that he and his family enjoy an excellent reputation in ‘the Jupiter community so that it would be extremely unlikely that this negative campaign generated spontaneously from someone in Jupiter at the same time as the negative article was published, ‘The blog is being further used as an instrument of tortious interference because an alias named "Jessica Langston has been actively posting and emailing links of this blog in a campaign to damage my client’s personal and business relationships. This is not a case where someone legitimately or organically finds the blog on their own or through a legitimate referral. Quite simply, the Squarespace blog is being used as an instrument in a personal, tortious smear ‘campaign, For example, attached! are recent Facebook posts clearly taking advantage of the false, defamatory information and gross misrepresentations contained in the Squarespace blog, Please note how one of them is tagged with the name of my client’s wife, her employer, and a university with which she is affiliated. Thave read and respect Squarespace's Privacy Policy and understand Squarespace may not share its uscr°s account information with me. However, [do request that Squarespace independently investigate the following matters to find out if Squarespace's Terms of Se1 are being violated: Is the account owner or payer, in fact, a “concerned citizen" of Jupiter, Florida as the blog prominently claims? We believe that the user or payer may be a party related to Joel Albrizio or Adlife Marketing & Communications from Pawtucket, Rhode Island, Are the user comments on blog posts from the attached comments, in fact, from different and "real" commenters? We suspect most, if not all, the public comments are fake and may be traced to a proxy server or an IP Address from or near Pawtucket, Rhode Island, Altachment 2 is an email sent by "Jessica Langston" to one of my client's customers; the sender originated from Pawtucket, Rhode Island We believe that this account owner has flagrantly violated numerous articles of the Acceptable Use Poliey in Squarespace’s Terms of Service: tem 2.2 - Don't send altered, deceptive or false source-identifying information, including without imitation phishing or spoofing. ‘tem 3.1 ~ Don't do anything that's false, fraucluteni, inaccurate or deceiving. tem 3.2 ~ Don't impersonate another person, company or entity Item 3.3 - Don't engage in misleading or unethical marketing or advertising wwwnecvoMonLe.comCUOMO Jem 6.1 - Don't do or post anything threatening, harassing, abusive, excessively violent, offensive, sexually explicit or obscene. Tiem 6.2 - Don’t advocate bigotry or hatred against any person or group based on their race, ethnicity, nationality, religion, gender, gender identity, sexual preference, age or disability, Squarespace Paragraph: We try to ensure fair outcomes, but in all cases we reserve the right to remove ‘any content or suspend your Account or Your Sites, without any refund of any amounts paid for the Services, without notice, at any time and for any reason. We reserve the right ta enforce, or not enforce, this Acceptable Use Policy in our sole discretion. 1 ask that Squarespace exercise its right to investigate the overall matter, the account holder, payer, and take appropriate actions. I believe that the purpose and content of "Voices of Jupiter Florida” is ‘ot in keeping with the Squarespace Terms of Service or Acceptable Use Policy. 1 further belive thet this is not the type or style of blog or website that Squarespace Would want to support or promote as it is utierly false and deceptive and designed solely to give the false impression that a group of Jupiter, Florida citizens are actually concerned over the alleged behavior of one Jupiter resident, Robert Krausankas and his website which does not even discuss Jupiter Florida matters, VOIF's content is entirely devoted to smearing Mr. Krausankas and his family. Attachment 3 lists broadcast emails which refers to VOIF for the purpose of falsely smearing my client and his famnily for the purpose to compel him to takedown his website, copyright-trolis.com, Attachment 4 lists a sample of the VOJF blog posts. Among the issues I would ask you to note is the constant representation of the blog author(s) as being concerned parents of Jupiter Florida and the way the author(s) repeatedly insert my client’s wife and son’s name into the posts to increase the likelihood ‘that these posts will come up in a search engine request under their names. Attachment 5 is the letter 1 wrote to Mr. Albrizio on October 24, 2016 after he threatened Mr. Krausankes. believe the account holder has a right to anonymously criticize my elient and his blog, But the account holder does not have the right to impersonate or misrepresent itself to the public as groups of people in Jupiter Florida, or as supposedly legitimate commenters of its blog posts. I respectfully request Squarespace to fully enforce its Terms of Service and its Avceptable Use Poliey. If corrective measures, are not taken, I may be compelled to initiate legal action to force the take down of the site; uncover the ‘rue identity of the author, account holder, and/or the payer of VoicesofJupiterFlorida.com blog; and bring legal action for the continued defamation and libel of my client. ‘Thank you for your immediate attention to this matter, = Oscar Michelen WWWw.cuoMoLLc.coxe