Linhardt

RESPONSE to Motion to Dismiss

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

E360INSIGHT, LLC,
Plaintiff,

v.

COMCAST CORPORATION,
Defendant.

COMCAST CORPORATION,
Counterclaimant,

v.

E360INSIGHT, LLC,
Counterdefendant,
DAVID LINHARDT,
MAVERICK DIRECT MARKETING
SOLUTIONS, INC.,
BARGAIN DEPOT ENTERPRISES, LLC,
d/b/a bargaindepot.net and
bargainshoppecorp.com,

MOTION to Dismiss

04/24/2008 - 10:15
America/Chicago

David Linhardt, and his various sock puppets, are now trying to dismiss Comcast's countersuit and 3rd party complaints. Among the complaints he makes is that Comcast did not attach even one single email to the complaint. That strikes me as a dangerous demand to make. I think that he could end up with reams of paper as a result. But, we'll have to wait and see.

Status Report

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

E360INSIGHT, LLC, an Illinois Limited
Liability Company, and DAVID LINHARDT,
an individual,
Plaintiffs,

v.

MARK JAMES FERGUSON, an individual,
SUSAN WILSON A.K.A. SUSAN GUNN, an
individual, and KELLY CHIEN, an individual,
Defendants.

JOINT STATUS REPORT

Counterclaim and Third Party Complaint

The bar for this was pretty low, and so, to no one's surprise, it was granted. Thus, we have a repeat document. The Counterclaim and 3rd Party Complaint is no longer a proposed document. Comcast is now officially counter-suing e360Insight as well as David Linhardt and all of the socks in his drawers.

===============================
UNITED STATES DISTRICT COURT

Complaint

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

E360INSIGHT, LLC, an Illinois Limited
Liability Company, and DAVID LINHARDT,
an individual,
Plaintiffs,
v.

MARK JAMES FERGUSON, an individual,
SUSAN WILSON A.K.A. SUSAN GUNN, an
individual, and KELLY CHIEN, an individual,
Defendants.

e360Insight LLC, et al. v. Ferguson, et al. (III)

Not content to only launch a goofball suit against Comcast last week, David Linhardt, by and through e360Insight LLC, is suing Mark Ferguson, Susan Wilson, and Kelly Chien for a third time.

Suit was filed on January 18, 2008.

This lawsuit alleges defamation, tortious interference with a prospective business advantage, and tortious interference with a contract.

In other words: "WAAAAAAA! THEY SAID MEAN THINGS ABOUT ME IN PUBLIC!"

Motion to Dismiss

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION

JOHN W. FERRON,
Plaintiff,

vs.

e360Insight, L.L.C., el al.,
Defendants,

MOTION OF DEFENDANTS TO DISMISS COMPLAINT

NOW COME DEFENDANTS, e360lnsight, LLC and David Linhardt, by and through counsel, and, pursuant to Fed. R. Civ. Proc. 12(b)(2) move this Court to dismiss Plaintiff's Complaint against them. The reasons for this Motion are set forth in the accompanying Memorandum in Support.

-2-
MEMORANDUM IN SUPPORT
I. INTRODUCTION

Complaint

IN COURTOF COMMON PLEAS
FRANKLIN COUNTY

JOHN W. FE'RRON,
Plaintiff,

vs

E360INSIGHT LLC.
And
DAVID LINHARDT
Defendants.

COMPLAINT FOR MONEY DAMAGES, DECLARATORY
JUDGMENT AND INJUNCTIVE RELIEF
JURY DEMAND ENDORSED HEREON
NOW COMIES PLAINTIFF JOHN W. FERRON, by and through his undersigned counsel, and makes the fiillowing allegations and claims against DEFENDANTS e360INSIGHT, I.LC and DAVID LINHARDT.

The Parties

Ferron v. e360Insight LLC, et al.

On September 21, 2007, John Ferron, an Ohio attorney, filed suit against e360Insight LLC, and David Linhardt, alleging violations of the CAN-SPAM Act, the Ohio Electronic Mail Advertisement Act, and the Ohio Consumer Sales Practices Act.

The case was removed to federal court by e360 and Linhardt.

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