Jared S. Adam Richard S. Fry Linda M. Kirsch Caitlin L.

Slessor Of Counsel
Constance M. Alt Richard C. Garberson Diane Kutzko Marty L. Stoll John M. Bickel
Jeffrey M. Beatty Vincent S. Geis Jonathan C. Landon Gary J. Streit William R. Shuttleworth
Brian D. Bergstrom Allison M. Heffern Michael O. McDermott Mark L. Zaiger
Jace T. Bisgard William S. Hochstetler Dennis J. McMenimen Retired
Kevin J. Caster Tricia Hoffman-Simanek Joseph M. Miller Registered Patent Lawyers Thomas M. Collins
Kelly A. Cwiertny Robert D. Houghton Dana L. Oxley Tim Klima
William J. Daly Mark P.A. Hudson Steven J. Pace Caroline M. Nash * V.C. Shuttleworth 1900-1965
Theresa C. Davis Wesley B. Huisinga Nancy J. Penner James C. Nemmers T.M. Ingersoll 1902-1972
Laurie L. Dawley Stephen B. Jackson Sr. William P. Prowell Brett D. Papendick
John H. Ehrhart Donald L. Johnson Jennifer E. Rinden Jason R. Sytsma
Dean R. Einck Samuel E. Jones Kristen A. Shaffer Marlana K. Titus **
Kerry A. Finley Desire A. Kilburg Kristymarie Shipley
* Admitted In DC, MD and VA only
**Admitted In DC and MD only

July 18, 2017

VIA FED EX AND EMAIL

Jesse Nickles jesse@littlebizzy.com

CollegeTimes info@littlebizzy.com
848 N. Rainbow Blvd. #4064 info@collegetimes.co
Las Vegas, NV 89107 info@collegetimes.tv

Re: Maharishi University of Management and CollegeTimes.co

Dear Mr. Nickles:

Our firm represents Maharishi University of Management (MUM). I am writing to you

regarding false statements published by you about MUM on your website
www.collegetimes.co.1

CollegeTimes page regarding MUM falsely states that MUM lacks accreditation. See
Screen shot at the bottom of this letter. MUM has been accredited by the Higher Learning
Commission since May 2, 1980. See HLC Print-Out, attached as Exhibit 1, also accessible
through the Higher Learning Commissions Directory of Institutions at
http://www.hlcommission.org/Directory-of-HLC-Institutions.html. The Higher Learning
Commission is a federally-recognized accrediting agency required to assure that all its member
institutions are meeting their Title IV program responsibilities as well as complying with the
expectations of specific regulations accreditors must enforce as a part of their recognition by the
U.S. Department of Education.

The above statements constitute libel per se under Nevada law. By negligently or
maliciously communicating to a third party false and defamatory statements, you are liable for
defamation. Lubin v. Kunin, 17 P.3d 422, 425 (Nev. 2001) (quoting PETA v. Boby Berosini, 895
P2d 1269, 1272 (Nev. 1995). Because the statements impute a lack of fair dealing or business
ability, it is defamation per se. Cohen v. Hansen, 2015 WL 3609689, at *4 (D. Nev. June 9,

1
https://collegetimes.co/maharishi-university-of-management/

Shuttleworth & Ingersoll, P.L.C.

115 3rd Street SE, Suite 500 Cedar Rapids, IA 52401 PO Box 2107 Cedar Rapids, IA 52406-2107
ph (319) 365-9461 fax (319) 365-8443 www.shuttleworthlaw.com
Shuttleworth & Ingersoll, P.L.C.
July 18, 2017
Page 2

2015) (quoting Talbot v. Mack, 169 P. 25, 30 (Nev. 1917)). As such, Nevada common and
statutory law entitles MUM to general damages. See Nev. Ind. Broad. V. Allen, 664 P.2d 337,
346 (Nev. 1983) (citing N.R.S. 41.334). Your failure to correct the libelous statements on
CollegeTimes.co could also entitle MUM to special damages. See N.R.S. 41.337. Furthermore,
your irresponsible publication of this false accreditation information endangers the very service
your website claims to provide to a number of unsuspecting potential students. I am confident
that the courts would look favorably on a request for exemplary damages, as outlined in N.R.S.
41.333, given the circumstances.

Your statement that MUM lacks accreditation is not protected by Section 230 of the
Communications Decency Act, because this is a statement by you and not some third party
commenters on your site. Section 230 only states that No provider or user of an interactive
computer service shall be treated as the publisher or speaker of any information provided by
another information content provider. Since this statement was made by you at the top of the
webpage and not by another in the comments on this page, Section 230 does not relieve you from
liability.

If you fail to address and correct the libelous statements published on your website within
the next 20 days, MUM will be forced to bring immediate legal action against you and seek
damages general, special and exemplary in court for libel per se and business
disparagement.

Govern yourself accordingly.

Sincerely,

JASON R. SYTSMA
jrs@shuttleworthlaw.com

JRS:kji
Enclosure

Shuttleworth & Ingersoll, P.L.C.

115 3rd Street SE, Suite 500 Cedar Rapids, IA 52401 PO Box 2107 Cedar Rapids, IA 52406-2107
ph (319) 365-9461 fax (319) 365-8443 www.shuttleworthlaw.com
Shuttleworth & Ingersoll, P.L.C.
July 18, 2017
Page 3

Shuttleworth & Ingersoll, P.L.C.

115 3rd Street SE, Suite 500 Cedar Rapids, IA 52401 PO Box 2107 Cedar Rapids, IA 52406-2107
ph (319) 365-9461 fax (319) 365-8443 www.shuttleworthlaw.com
Higher Learning Commission https://www.hlcommission.org/component/directory/?Action=ShowBasi...

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Find Accredited Institutions

About HLC Accreditation Policies Publications HLC Institutions Peer Review Programs & Events Home

Statement of Accreditation Status

as of July 14, 2017

Maharishi University of Management

1000 N. 4th Street
Fairfield, IA 52557
(641) 472-7000
www.mum.edu
*Previous names: Maharishi International University to Maharishi University of Management (1995)

The information on this page describes the accreditation relationship between this institution and the Higher Learning Commission. General
information about the Commission and the accreditation process is provided at the end of this document. In addition, links to definitions are
provided for many of the terms used.

Accreditation Information
Current status: Accredited
Candidacy date(s): 07/24/1975 - 05/01/1980
Accreditation granted: 05/02/1980

Most recent reaffirmation of accreditation: 2009 - 2010

Next reaffirmation of accreditation: 2019 - 2020

Upcoming or In-Progress Reviews

2019 - 2020: Comprehensive Evaluation

Most Recent History with the Commission

10/30/2013: Focused Visit Affirmed findings of Focused Evaluation Team

General Institutional Information

This section provides brief, general information about the institutions organization and scope. The information is self-reported by the
institution through the annual Institutional Update to the Commission. Additional information can be found at nces.ed.gov/collegenavigator/ or
on the institutions web site noted above.
Control: Private NFP
Degree programs (number in each category): Bachelors (12), Masters (7), Doctoral (3)
Certificate programs (number offered): 9
Off-Campus Activities (This listing was last updated: 10/24/2014; the information may not be current.) The institutions accreditation includes
courses and programs at:

In-State: Campuses: None.

Additional Maharishi Vedic City - Maharishi Vedic City, IA;

Locations:

Out-of-State: Campuses: None.

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Higher Learning Commission https://www.hlcommission.org/component/directory/?Action=ShowBasi...

Additional None.
Locations:

Out-of-U.S.: Campuses: None.

Additional None.
Locations:

About HLC and Accreditation

Institutions of higher education in the United States seek accreditation through two types of accreditation agencies, institutional and
specialized. Institutional accreditation agencies are classified as regional and national.
National accreditation associations focus on certain types of colleges such as trade and technical institutions, or religious colleges such as
seminaries and bible colleges.
Regional accreditation agencies are recognized by the U.S. Department of Education to accredit degree granting colleges and universities.
There are six regions of the U.S. in which regional agencies operate. The regional accreditation agencies have similar standards for
accrediting colleges and universities.
Regional accreditation validates the quality of an institution as a whole and evaluates multiple aspects of an institution ranging from its
academic offerings, governance and administration, mission, finances, and resources.
The Higher Learning Commission is a regional accreditation agency that accredits degree granting institutions of higher education that are
based in the 19-state North Central region of the United States. Institutions that HLC accredits are evaluated against HLCs Criteria for
Accreditation, a set of standards that institutions must meet to receive and/or maintain accredited status.
HLCs Criteria for Accreditation reflect a set of guiding values. The accreditation process is based on a system of peer review. Approximately
1,300 educators from institutions of higher education serve as peer reviewers conducting accreditation evaluations for other institutions. Peer
reviewers also serve on committees that make up the decision-making bodies of the accreditation process.
Evaluation Process
HLC accreditation assures quality by verifying that an institution (1) meets standards and (2) is engaged in continuous improvement. In
addition, all institutions are required to complete an annual filing of the Institutional Update, undergo annual monitoring of financial and non-
financial indicators, and adhere to HLC policies and practices on institutional change.
Peer reviewers trained in HLCs standards evaluate institutions demonstration of whether they meet the Criteria for Accreditation and make
recommendations to HLCs decision-making bodies.
Institutional Actions Council (Decision-Making Body)
The Board of Trustees appoints and authorizes members of the Institutional Actions Council (IAC) to conduct reviews and take actions on the
majority of accreditation recommendations. IAC members consist of representatives of academic institutions accredited by HLC, as well as
members of the public. Detailed information on IAC processes is found in HLCs policies on decision-making.
Public Information
In the interest of being transparent, HLC is committed to providing information to the public regarding accreditation decisions made regarding
individual institutions.
Actions that are taken by HLC regarding an institutions accreditation status are disclosed to the public. Beginning July 2013, in all cases of
issuing continued accreditation, placing an institution on or resolving a sanction, or withdrawing accreditation, the Action Letter issued to the
institution is made available for viewing and the institutions status in HLCs online directory is updated. Public Disclosure Notices are also
issued in cases of sanction to provide the public more detail of the issues leading to sanction.
Complaints Against HLC Accredited Institutions
Each year, HLC receives a number of complaints about institutions from faculty, students, and other parties. HLC has established a clear
distinction between individual grievances and complaints that appear to involve broad institutional practices. Where a complaint does raise
issues regarding the institutions ongoing ability to meet the Criteria of Accreditation, HLC forwards the complaint to the institution and
requests a formal response.
Complainants with specific claims related to the Americans with Disabilities Act or employment discrimination should seek prior review of
such claims by the appropriate federal agencies. HLC may ask for the report or record of such review in determining whether it can proceed
to consider the claim as a complaint related to compliance with the Criteria for Accreditation.

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