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Here is Linhardt's amazing response to John Ferron's response to Linhardt's motion to dismiss.

Among other amazing tidbits to be found in this document is a disavowal of his connection to BargainDepot.net (Reply at 1-2, Linhardt Affidavit at paragraph 4). Unless he's got an evil twin, then he's got problems. Possibly with perjury.

This is more or less of a document dump. I don't have the time currently to OCR these documents, but they need public disclosure.

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

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

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.