2019-04-25 Suburban Express

Case: 1:18-cv-02861 Document #: 106 Filed: 04/25/19 Page 1 of 9 PagelD #:1135
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
PEOPLE OF THE STATE OF ILLINOIS

ex rel. KWAME RAOUL, Attorney General
of the State of Illinois, No. 1:18-cv-2861
Plaintiff, Judge Andrea R. Wood
v.
SUBURBAN EXPRESS, INC.; ALLERTON

CHARTER COACH, INC.; and DENNIS
TOEPPEN, individually and in his official
capacity as owner,
Defendants.
PLAINTIFF'S SUPPLEMENTAL FILING IN SUPPORT OF ITS MOTION TO

ENFORCE CONSENT DECREE
Defendant Dennis Toeppen's ("Toeppen") April 24, 2019 submission to the
Court asserts that he has removed two webpages attacking Defendants' customers,
and removed text from Defendants' websites that diminishes the content of the anti-
discrimination policy language required by the Consent Decree. Despite these tardy
attempts to comply with this Court's judgment, there is additional evidence that
Toeppen, and the defendants he controls, continue to violate the requirements of the
Consent Decree, breaching their duty of good faith and fair dealing in the process.
These violations, explained in full below, show that Toeppen's representation to the
Court that he will comply with the Consent Decree is, at best, disingenuous. Rather
Case: 1:18-cv-02861 Document #: 106 Filed: 04/25/19 Page 2 of 9 Pagel D #:1136
than comply, Toeppen continues to seek ways to harass Defendants' customers,
contravening both the letter and spirit of the Consent Decree.
Racist Public Commentary
As the State described in open court on April 23, 2019, Toeppen admittedly
made sanctionable racist public statements about the allegations in the State's
complaint that cannot be cured. On April 18, 2019, one day after the State filed its
motion to enforce the Consent Decree, Toeppen said the following in emails to a
reporter (see Toeppen Sub. at 22): "[T]he AG's lawsuit had a great deal of MSG
sprinkled on it." That statement was then widely published in the media. See Ex. A
at 4 (emphasis added). As Toeppen is well aware, the State's complaint focused
largely on Defendants' discriminatory actions against individuals of Asian origin; the
injunctive relief required by the Consent Decree is in place to remedy such conduct.
And as Toeppen is also aware, MSG (or monosodium glutamate) is a seasoning'
prevalent in food of Asian origin and a source of racist commentary.
Indeed, Toeppen's own submission to the Court—a Wikipedia page about
MSG—discusses the "popular misconception" that MSG causes a sickness called
"Chinese restaurant syndrome." Toeppen Sub. at 24. Had Toeppen included more
than the first page of the Wikipedia article, the Court would have learned that "[t]he
perpetuation of the negative image of MSG through the so-called Chinese Restaurant
Syndrome has been attributed to xenophobic or racist biases, with people specifically
targeting Asian cuisine." See Ex. B at 2.
2
Toeppen's description of the State's complaint as "sprinkled" with MSG was
not, as he contends, an innocent reference to "an enhancer to make [the complaint]
seem better than it is." Toeppen Sub. at 19. It was a dog whistle that he emailed to a
reporter knowing full well that it would be published. And it is a comment with a
direct line to his December 2, 2017 marketing ploy, in which he advertised that riders
on Suburban Express would encounter "fcJustomers like you. You won't feel like
you're in China when you're on our buses." Complaint [Dkt. 1] ¶ 25 (emphasis
added).
The "MSG" comment violates Paragraph 4(a)(iii) of the Consent Decree, which
requires defendants not to "circulate or distribute communications that Defendants
know are to the effect that ... any person is unwelcome, objectionable, or unacceptable
because of race." And it is a communication that Toeppen is unable to cure, given its
publication on the Internet by a major news organization—the fact of which made it
far more widely circulated than any of Toeppen's own webpages. This communication
by Toeppen exemplifies his bad faith violation of the Consent Decree, justifying
sanctions.
Additional Attack Webpages
After the State filed its complaint, Defendants removed many public attacks
against their customers from their various websites. Rather than continue to refrain
from such conduct, shortly after the Consent Decree was entered on April 9, Toeppen
returned to the strategy of posting webpages that single out Defendants' customers
for vicious scorn. Multiple pages that Toeppen reposted violate the Consent Decree's
3
command against penalizing individual customers for their online commentary about
the Defendants. Puzzlingly, Toeppen includes a copy of his Suburban Express
"Response Page" in his April 24 submission to the Court—a webpage containing links
to multiple other webpages that violate the Consent Decree. See Toeppen Sub. at 26.
1. Toeppen and the corporate defendants reposted two attack pages about
a single individual, one of which explicitly insults the person for being "a pushy little
Chinese engineering student with a fragile ego." See Ex. C at 2 (emphasis
added). The page goes on to say this: "If I were a guest in another country, I would
certainly not act like [the individual]. I would be humble and polite." Id. This webpage
is a communication that Toeppen, and the Defendants, know is to the effect that a
person is unwelcome, objectionable, or unacceptable because of the person's race and
national origin, violating Paragraph 4(a)(iii) of the Consent Decree. On another page
about the same person, Defendants refer to the individual as a "LITTLE WEASEL"
and an "idiotic" "little guy," all based solely on the individual's activity on Yelp.com.
See Ex. D. In other words, Defendants are punishing the individual for his online
commentary about Suburban Express and Toeppen—a violation of the Consent
Decree's command in Paragraph 4(c)(iii) that the defendants not "penalize customers
based solely on online comments about any Defendant, including reviews."1
2. Toeppen and the corporate defendants reposted a page attacking
another person for a Yelp commentary about Suburban Express and Toeppen. See
1 Toeppen's submission to the Court lacks any definition of "penalize" as used in the Consent Decree
or in 815 ILCS 505/2UUU. In its motion to enforce, the State defined the term in its ordinary
meaning—to "punish" or to "treat unfairly," see Dkt. 99 at 2, which is precisely what an attack webpage
does to an individual who dares to speak out against Defendants.
4
Ex. E. First, Defendants reprint what they purport to be a response Toeppen posted
to a Yelp review from a customer who requested accommodation for multiple
wheelchairs on a Suburban Express bus. Defendants go on to write that the person
was "so erratic. Was she living in a mental hospital, we wondered? So we googled her
address and found that her yard was full of bizarre decorative junk." Following this
commentary, Toeppen and the corporate defendants post an image represented as
the person's home and mock the person for accusing Defendants of "stalking her." All
this attack page cites as the basis for its content is the person's Yelp activities. This
conduct, too, violates Paragraph 4(c)(iii) of the Consent Decree because it penalizes a
person for her online commentary about the Defendants.
3. Toeppen and the corporate defendants reposted what they call a "Page
of Shame" on the Suburban Express website, on which they purport to "review what
we consider to be bad customers." See Ex. F at 1. After a long list of individuals that
Defendants assert "have given us payments which ultimately were not honored,"
including the individuals' home and email addresses and phone numbers, Defendants
display a list of "permanently banned" customers. This list indicates Defendants have
banned at least three customers from service for their online commentary about
Suburban Express, representing additional efforts to penalize customers, violating
Paragraph 4(c)(iii) of the Consent Decree. See id. at 4-5. Two of the individuals have
written for the Daily Illini, the student newspaper of the University of Illinois at
Urbana-Champaign. See Exs. G, H. Defendants write on their "Page of Shame" that
one of these individuals "[i]dentified herself as an employee of an entity whose

employees are not welcome on Suburban Express." The other individual, Defendants
write, "is morally and ethically challenged, in our opinion." What the individuals have
in common is that they both wrote articles about Toeppen and Suburban Express for
the Daily Illini, which constitute online commentary and thus fall under the Consent
Decree.
Also listed on this Page of Shame is an individual who was the subject of one
of the attack webpages that Toeppen represented to the Court that he had removed
from his website. See Toeppen Sub. at 25. Nonetheless, her name still appears on this
Page of Shame; Defendants states that the individual "is mentally unstable based on
her activities as reddit user [username]." Ex. F at 5. The username Toeppen lists is
the same one on the attack page that was an exhibit to the State's motion to enforce
the Consent Decree—the page on which Defendants viciously attacked the individual
for her online commentary about Suburban Express. See Toeppen Sub. at 30. Thus,
while removing one page about the individual, Toeppen and the corporate defendants
still attack the individual for that same online commentary, just on a different page
of the Suburban Express website—complete with a reference to the person being
"mentally unstable."
Failure to Post Anti-Discrimination Language
Toeppen asserts in his April 24 submission that "[t]he allertoncharter.com
website has been removed." Toeppen Sub. at 1. Not true. The Consent Decree in
Paragraph 4(a)(iv) requires Defendants to post specific anti-discrimination policy
language "on the main page of any Defendant's website." A website exists at
Case: 1:18-cv-02861 Document #: 106 Filed: 04/25/19 Page 7 of 9 Pagel D #:1141
allertoncharter.com. See Ex. I. The main page now consists of a website that says,
"This website no longer exists," yet a website informing the world that it is not a
website is still a website. Defendants have not removed the website of Allerton
Charter, despite having removed the main page entirely of the suburbs.com website,
which returns a "403 Forbidden error" page as of April 25, 2019. See Ex. J. So long as
Toeppen and the Defendants maintain allertoncharter.com, they must post the
required anti-discrimination policy language on its main page.
Misrepresentation to the Court
In addition to travel photographs and graphs of water levels, Toeppen includes
in his submission to the Court an assertion that he was engaged in "a dawn to dusk
endeavor" from the evening of April 1 through April 16, 2019 "taking photographs at
various sites" on a vacation. Toeppen Sub. at 38. Only after he arrived in Urbana
"late afternoon on 4/17," Toeppen says, could he "immediately commence[
compliance activities which I could not undertake remotely." Id. Yet on April 11,
Toeppen inserted a statement on the main page and University of Illinois page of
suburbanexpress.com offering his thoughts about the Consent Decree. See Exs. K, L.
This commentary asserted that "Suburban Express felt that it was being extorted by
the state, but chose a $100k payment to state [sic] rather than spending $250k-$500k
defeating the lawsuit," and goes onto argue that a press release from the State "on
the matter is false and defamatory in the extreme." Exs. K, L.
Toeppen informed the Court at a hearing on April 23, 2019, and again in his
submission of April 24, 2019, that he was unable to comply with the Consent Decree
7
prior to April 17. This cannot be true. Toeppen was able to post his commentary about
the Consent Decree and the State's press release on April 11 in the precise space
where he later posted the required anti-discrimination policy language. Compare Exs.
K & L with Toeppen Sub. at 2, 6. Toeppen has not explained to the Court how or why
he was able to post this commentary, but not the required anti-discrimination policy
language, during a time in which he has informed the Court he could not "undertake
remotely" any web posting. (Toeppen also apparently had time to post this statement
on Facebook on April 11. See Ex. M.)
This conduct also relates to a separate statement Toeppen made to the media,
where he said the Consent Decree "gives us 30 days to cure any breach, whether
intentional or accidental." Toeppen Sub. at 21 (emphasis added); see also Ex. A at 3.
As the State informed the Court at a hearing on April 23, 2019, this language
evidences Toeppen's belief that the Defendants can "intentionally" flout the
requirements of the Consent Decree so long as they correct those violations within 30
days after the State notices and warns them about these violations. That mode of
conduct in no way complies with the spirit of the Consent Decree.
Requested Relief
Given the Defendants' past, new, and ongoing violations of the Consent Decree
and misrepresentations to the Court, the State revises its request for relief in its
Motion to Enforce Consent Decree. The State requests that in order to deter further
violations of the Consent Decree the Court enter a monetary judgment against each
defendant in the amount of $20,000, or any other amount the Court deems just and
appropriate. In addition, the State requests that the Court order the Defendants to
remove the webpages that violate the Consent Decree as discussed above within 24
hours, and remove any bans on customers for their online commentary about
Defendants, including the bans described above.
Date: April 25, 2019 Respectfully submitted,
By: /s/ Jeff VanDam
KWAME RAOUL
Attorney General of Illinois
Jeanne Witherspoon
Matthew V. Chimienti
Alison V. Hill
Jeff VanDam
Thomas J. Verticchio
Assistant Attorneys General
Civil Rights & Special Litigation
Bureaus
100 W. Randolph Street, 11th floor
Chicago, IL 60601
Tel.: (312) 814-1188
jwitherspoon@atg.state.il.us
mchimienti@txtg.state.il.us
ahill@atg.state.il.us
jvandam@atg.state.il.us
tverticchio@atg.state.aus
9
Case: 1:18-cv-02861 Document #: 106-1 Filed: 04/25/19 Page 1 of 49 PagelD #:1144
Exhibit A
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CULTURE (/CULTURE)
Bus Company Faces New Fine

After Agreeing to Pay $100K in
Discrimination Suit
Matt Masterson (/stories-by-author/matt masterson) I April 18,
2019 4:o1 pm
Like us f
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Follow us W
(https://twitter.com/wttw)
TRENDING
(Courtesy of Suburban Express)

1 The Week in
Review: Foes Ell
(/2019/0.4/19/week-
Faces Heat in
Smollett Case review-
Illinois' top prosecutor says the owner of a Champaign- (/2o19/04/19/we14tI2,-
based bus company that shuttles University of Illinois review-foxx- faces-
students to and from the Chicago area has violated a faces-heat- heat-
smollett-case) smollett-
consent decree in "multiple ways." The news comes just
case)
days after the owner agreed to pay a $100,000 fine to
settle a federal lawsuit that accused the company of
2 too Days In,
Gov. Pritkzcr's
discriminating against Asian customers. (/2019/04/23/too-
Biggest
Challenges Are days-
Illinois Attorney General Kwame Raoul last week
Just Ahead Boy'
announced his office had reached a three-year consent (/2019/04/23/rodsritkzers-
decree with Dennis Toeppen, owner of the Suburban days-gov- biggest-
Express bus line, which requires the company to pay the pritkzers- challenges-
biggest- are-
fine and "end its practice of discriminating and harassing challenges-are-
iust-
customers and their families." Doing so would effectively just-ahead) -
ahead)
settle a lawsuit filed by Raoul's predecessor against the
company. United Airlines
3 Trims Growth ",.','"'""7
Plan for 2019 tt 2019/ 04/19/united-
"For too long, students traveling from university campuses
(/2019/04/19/unrikkes-
to their homes have done so under the fear of being airlines-trims- truns-
subjected to discrimination and harassment by Suburban growth-plan- growth-
Express and its owner," Raoul said in a statement on April zom) plan-
9. 2019)
Aloha Poke
"This consent decree brings an end to Mr. Toeppen's 4 Claim Revives
(/2019/04/19/aloha-
reprehensible business practices and ensures that students Hawaiian
Culture poke-
receive fair and equal access to Suburban Express's
Protections claim-
services." revives-
Push
(/2019/o4/19/alohawaiian-
But just days later, Raoul's office has filed a new motion poke-claim- culture-
asking a judge to order an additional $10,000 fine, revives- protections-
claiming Toeppen already violated multiple aspects of that hawaiian-
push)
culture-
consent decree, including prohibitions against penalizing protections-
customers who post negative reviews and publishing push)
"unwelcoming communications."
New Research
5 Downplays
(/2019/04/22/new-
Importance of
Counting research-
Calories for downplays-
Weight Loss importance-
(/2019/04/22/netbunting-
research- calories-
downplays- weight-
importance-
loss)
counting-
calories-
weight-loss)
https://news.wttw.com/2019/04/18/suburban-express-bus-company-faces-consent-decree-new-fine 1/6
4/23/2019 Case: 1:18-c*1412@elrEgfeurtlentiltAleiNlefrikteQ4/23Sagiiz ttindfiitlicSgaigei10st#Y17-46
WTTW NEWS DAILY
BRIEFING
email address Subscribe
COMMENTS
• too Days In, Gov.
Pritkzer's Biggest
Document Read the new motion here.
Challenges Are Just
(https://news.wttw.com/sites/default/files/article/file- Ahead
attachments/merged_10041_-1-155360273.pdf) (https://news.wftw.corn/2019/04/22/100-
days:gov-pritkzers-
The motion claims Suburban Express harassed one biggest-challenges-are-
just-ahead)
customer who wrote a negative Yelp review by publishing
1 comment • 4 hours ago
the address of their childhood home on the company's • Developer Wants Obama
website, linking to their Linkedln account and ridiculing Presidential Center to
their mental state. Spur South Side
Regeneration
The company also allegedly attacked a person of "Asian (https://news.wnw.com/zoi9/04/22/developer-
origin" by labeling them an "insane ... spoiled child" and wants-obama-
• saying the individual reminds them of a prominent Asian- presidential-center-spur-
American who advocates against discrimination, adding south-side-regeneration)
2 comments 2 hours ago
that readers should Google that activist "for a good laugh." • A Look at the Massive
'One Central'
"Taken individually or together with the other page
Development Proposed
Defendants have posted attacking a person of Asian origin, Near Soldier Field
Defendants have circulated communications that (httPs://news.wttw.com/coi9/04/22/look-
Defendants know are to the effect that the individuals massive-one-central-
under attack are objectionable and unacceptable because development-proposed-
of their race and national origin," Raoul wrote in the near-soldier-field)
2 comments 7 hours ago
motion.
Medal of Honor
Recipient on His Path
Through the motion, Raoul has also asked a judge to order
from Bullied Victim to
Suburban Express to remove specific pages from its
War Hero
"defamatory" website within 24 hours. (https://news.waw.com/2019/04/22/medal-
honor-recipient-his-
Suburban Express also operates a notorious "Page of path-bullied-victim-war-
Shame" on its website, offering up the names, addresses hero)
and contact information of customers who, according to 2 comments • 8 hours ago
the company, write bad checks or use counterfeit tickets.

But the company's complaints against customers don't
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stop there. Others who have been banned by the company
are labeled on the site as "a danger to herself and others,"
"mentally unstable" or "generally unpleasant, if not ON-SITE
insane." X-RAY
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A screenshot of the Suburban Express "Page of Shame." Names and personal

information have been redacted.
THE 00IGTAI
As part of its agreement with the state, the company is 1 STE I IN/V;TA & SONS.
barred from discriminating against customers or refusing
service based on a person's race, national origin or
BUYER'S GUIDE
religion. Customers who purchased bus tickets dating back
to April 23, 2014 are also allowed to seek refunds from
Suburban Express between April 30 and Oct. 9, 2019.
4/23/2019 Case: 1:18-c\VANeletfeurtierilti#:AreagleVitegENSW2337/9ifaittOetillnguillgiFtitsgtHOWTIWT
View ell sponsors i/sponsers)
Reached via email Thursday, Toeppen claimed he was on
vacation in the days after the consent decree was signed
and stated he believed he had 3o days to "cure any breach"
RECURRING
of the agreement, "whether intentional or accidental."
FEATURES
Toeppen also took issue with the "refunds" outlined in the Ask Geoffrey
decree, stating that term never appears in the agreement. (/recurring-
Instead, he says his company internally is referring to segments/ask-geoffrey)
Animals and Nature
payments resulting from the decree as "Vote Purchase
(/tags/animals-nature)
Payments" and "Beer Money for Suburbanites."
Criminal Justice
(/tags/criminal-justice/)
`Passengers like you' Hedy Weiss: Theater
Reviews (/recurring-
Heading into winter break in 2017, Suburban Express
segments/hedy-weiss-
distributed an email ad telling customers they'll be able to theater-reviews)
enjoy being seated near "passengers like you" Homegrown, WTI'W's
(hn'tps://news.mtw.com/2o17/12/04/suburban-express- organic garden
bus-line-facing-blowback-offensive-bigoted-ad) on (/homegrown)
upcoming Christmas break rides. Jay's Chicago (/stories-
by-author/jay-shefsky)
"You won't feel like you're in China when you're on our The Week in Review
buses," the ad states, in an apparent reference to the (/recurring-
segments/week-in-
number of non-white students on campus.
review)
Weekend Events,
Suburban Express faced further blowback following its
(/tags/weekend-events)
initial "apology"
(https://news.wttw.com/2017/12/05/suburban-express-
issues-new-apology-grotesquely-xenophobic-ad) for that
ad, in which the company did not actually apologize. VIDEO ARCHIVE
Instead, it criticized the supposed financial
"mismanagement" within the U. of I. that forced tls
university to admit more international students, whluivin//news.wttw.com/zoi9/o4/18/trio-
turn "place(d) a variety of burdens on domestic stinikritthuchicago-productions-highlight-
language-danee?mini=2019-03)
"We agree that having a mixture of different cult-tit-el and
ethnicities is valuable," the company said at the tin-want,
ouLp,/ inews.wttw.com/2o19/o4/18/trio-
we're not comfortable with the idea of selling our superb-Chicago-productions-highlight-
university to the highest foreign bidder." language-dance?mini=2019-05)
Suburban Express later apologized for that response and

the initial ad. April
(https://news.wttw.com/archive/month/24319-
Then-Attorney General Lisa Madigan issued a subpoena to 04)
Suburban Express that same week and eventually filed a
lawsuit against the company in 2018, accusing it of racial
and religious discrimination, "vicious customer (litips://news.wttw.com/archive/day/2019-(haps.//news.wttw.corn/arehiveithy/29194
mistreatment" and other illegal business practices. 124.01 Q.492)
7
Toeppen is not required to make any admission of guilt as (laps://news.wttw.com/arehive/day/2m9-0Aps://news.wnw.com/arehive/day/2m9-(
part of this consent decree, but is required to pay 05
$100,000 to the attorney general's office within 180 days. 14 15 11
Toeppen and all Suburban Express employees must also fhttos://news.wttw.com/archivIday tt n sAvttl y/203.9-(
attend annual training sessions focusing on "laws against 9.4:25) 04,11)
discrimination on the basis of race, national origin, and 21 23
flaps://news.wttw.comLanhive/day/2 9-(https://news.wttw.com/archive/day/_2_oio,
religion."
04o23)
28 29 30
The company's website now includes a "statement of
inclusion" which says it does not discriminate "on the basis
of any individual's race, color, sex, gender identity, age,
religion, disability, national origin, ancestry, sexual
orientation, marital status, parental status, military status,
or source of income."
Read the full response from Suburban Express.
(https://www.facebook.com/SuburbanExpressEus/posts/1147144842113174)
4/23/2019 Case: 1:18-ciaL@Rffel-1reticurtlef9Iti#:406,01efritecEP*4-/ 235/19ifactigeitBnOifuitatikaffekieRvsit Y172113
Suburban Express posted a response to the consent decree
on Facebook last week, saying it felt it was being "extorted
by the state" through a lawsuit it says contained "false,
unproven, unproveable (sic) and legally inconsequential
allegations."
Additionally, the company claimed Raoul's statement on

the consent decree is "false and defamatory in the
extreme."
Toeppen reiterated Thursday there was "no finding or

admission of fault, liability, wrongdoing, etc." on his part
in the consent decree, which he says is contrary to the
language Raoul used in his April 9 statement.
"The AG's lawsuit had a great deal of MSG sprinkled on it,"

Toeppen wrote in a follow-up email to WTEW News,
apparently referencing a food additive commonly
associated with Chinese cooking.
"I'd go so far as to say the allegations were false and

misleading in the extreme ... We have never harassed
anyone. Our position has always been defensive. When
someone harasses us enough, we sometimes respond on
our website."
In that email Toeppen also included a link to his personal

website which includes a photo that appears to show him
standing at the Great Wall of China in 2017.
The company says it will consider legal action against

Raoul and Assistant Attorney General Thomas Verticchio.
A hearing in the case is scheduled in federal court next

Tuesday.
Contact Matt Masterson: @ByMattMasterson

(https://twitter.com/ByMattMasterson)
mmasterson@ulttw.com
(mailto:mmasterson@wttw.cont) I (773) 509-5431
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Suburban Express Bus Line Facing Blowbaek from

Òffensive, Bigoted' Ad
(https://news.wttw.comizot7/12/04/suburban-
express-bus-line-facing-blowback-offensive-
bigoted-ad)
Suburban Express Issues New Apology for

`Grotesquely Xenophobic' Ad
(https://news.wttw.com/2o17/12/05/suburban-
express-issues-new-apology-grotesquely-
xenophobic-ad)
Illinois Joins Lawsuit Against Trump's Emergency

Wall Declaration
(https://news.wttw.cotnizoto/o2/21/illinois-joins-
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File Attachments:
ij merged_loo4L-1.4555602773•Pdf
(https://news.wttw.com/sites/default/files/artiele/file-
attachments/merged_mo41_-1-15556o2m.pdf)
TAGS:
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SUBURBAN EXPRESS (RAGS/SUBURBAN-EXPRESS)
MAME RAOUL VTAGS/KWAME-RAOULI
TRANSPORTATION (RAGS/TRANSPORTATION) COURTS (RAGS/COURTS)
DISCRIMINATION IRAGS/DISCRIMINATION)
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WIKTPEDIA
Monosodium glutamate
Monosodium glutamate (MSG, also known as sodium glutamate) is the sodium salt of glutamic acid, one of the most
abundant naturally occurring non-essential amino acids 12] Glutamic acid is found naturally in tomatoes, grapes, cheese, trinsnEopms.
Monosodium glutamate
and other foods.E31[41
MSG is used in the food industry as a flavor enhancer with an umami taste that intensifies the meaty, savory flavor of food, as
naturally occurring glutamate does in foods such as stews and meat soups.[5116] It was first prepared in 1908 by Japanese biochemist
Kikunae Ikeda, who was trying to isolate and duplicate the savory taste of kombu, an edible seaweed used as a base for many
Japanese soups. MSG as a flavor enhancer balances, blends, and rounds the perception of other tastes.E71181
MSG has been used for over a hundred years and today is commonly found in stock cubes (Bouillon cube), soups„ ramen, gravy,
stews, condiments, savoury snacks etc.
The U.S. Food and Drug Administration has given MSG its generally recognized as safe (GRAS) designation.E91 A popular
misconception is that MSG can cause headaches and other feelings of discomfort, known as "Chinese restaurant syndrome," but
double-blind tests fail to find evidence of such a reaction.E91[10[111 The European Union classifies it as a food additive permitted in
certain foods and subject to quantitative limits. MSG has the HS code 29224220 and the E number E621.E121
Contents
NaMes
History
IUPAC name
Use
Sodium 2-aminopentanedioate
Safety
Society and culture
identifiers
Production CAS Number 142-47-2 (http://ww
Chemical properties w.commonchemistry.

Regulations org/ChemicalDetail.a
Names spx?ref=142-47-2)
See also 3D model l Interactive image (htt
References (JSmol)
ps://chemapps.stola
External links f.edu/jmol/jmol.php?
model=%5BNa%2
B%5D.O%3DC%2
History 8%5B0-%5D%29%
5BC%40%40H%5
Glutamic acid was discovered and identified in 1866 by the German chemist Karl Heinrich Ritthausen, who treated wheat gluten (for
D%28N%29CCC%2
which it was named) with sulfuric acid.E131 Kikunae Ikeda of Tokyo Imperial University isolated glutamic acid as a taste substance in
8%300%290)
1908 from the seaweed Laminaria japonica_ (kombu) by aqueous extraction and crystallization, calling its taste umami.ME151 Ikeda
noticed that dashi, the Japanese broth of katsuobushi and kombu, had a unique taste not yet scientifically described (not sweet, salty, ChemSpider 76943 (http://www.ch
sour, or bitter).(43 To verify that ionized glutamate was responsible for umami, he studied the taste properties of glutamate salts: emspider.com/Chem
calcium, potassium, ammonium, and magnesium glutamate. All these salts elicited umami and a metallic taste due to the other ical-Structure.76943.
minerals. Of them, sodium glutamate was the most soluble, most palatable, and easiest to crystallize. Ikeda called his product html) 1
"monosodium glutamate", and submitted a patent to produce MSG;E161 the Suzuki brothers began commercial production of MSG in ECHA 100.005.035 (https://
1909 as Aji-no-moto (I*0*, "essence of taste").[171[18][191 InfoCard echa.europa.eu/subs
tance-information/-/s
Use ubstanceinfo/100.00
5.035)
Pure MSG is reported to not have a highly pleasant taste until it is combined with a savory aroma.rwl The basic sensory function of
EC Number 205-538-1
MSG is attributed to its ability to enhance savory taste-active compounds when added in the proper concentration.171 The optimum
concentration varies by food; in clear soup, the pleasure score rapidly falls with the addition of more than one gram of MSG per 100 E number 1 E621 (flavour
mL.[2 i1 I enhancer)
PubChem 85314 (https://pubch
The sodium content (in mass percent) of MSG, 12%, is about one-third of that in sodium chloride (39%), due to the greater mass of CjQ em.ncbi.nlm.nih.gov/
the glutamate counterion.[221 Although other salts of glutamate have been used in low-salt soups, they are less palatable than
compound/85314)
MSG.E231 "MSG might even promote healthy eating, (food scientist Steve Witherly) hypothesizes, by not only making kale more
delicious but also letting you get away with using less salt."[241 UNII C3C196L9FG (http
s://fdasis.nlm.nih.go
MSG is commonly used and found in stock cubes (Bouillon cube), soups, ramen, gravy, stews, condiments, savoury snacks etc. v/srs/srsdirect.jsp?re
The ribonucleotide food additives disodium inosinate (E631) and disodium guanylate (E627), as well as conventional salt are usually gno=C3C196L9FG)
I'
used with monosodium glutamate-containing ingredients as they seem to have a synergistic effect. "Super salt" is a mixture of 9 parts III
salt, to one part MSG and 0.1 parts disodium inosinate and disodium guanylate.{251 CompTox DTXSID9020906 (htt
Dashboard
ps://comptox.epa.go
(ERA)
https://en.wikipedia.org/wiki/Monosodium_glutamate 1/6
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Safety v/clashboard/DTXS I I
D9020906) 19
MSG is safe to consume.[26] A popular belief is that MSG can cause headaches and other feelings of discomfort but double-blind tests
InChI
have found no good evidence to support this.M MSG has been used for more than 100 years to season food, with a number of
studies conducted on its safety. Consumption and manufacture of high-salt and high-glutamate foods, which contain both sodium SMILES
and glutamate, stretch back far longer, with evidence of cheese manufacture as early as 5,50o BCE.E271 International and national Properties
bodies governing food additives currently consider MSG safe for human consumption as a. flavor enhancer.E281 Under normal Chemical C5H8NO4Na
conditions, humans can metabolize relatively large quantities of glutamate, which is naturally produced in the gut in the course of formula
protein hydrolysis. The median lethal dose (LD50) is between 15 and 18 g/kg body weight in rats and mice, respectively, five times the Molar mass 169.111 g/mol
LD50 of sodium chloride (3 g/kg in rats). The use of MSG as a food additive and the natural level of glutamic acid in foods are not (anhydrous),
toxicological concerns in humans.[28] 187.127 g/mol
(monohydrate)
A 1995 report from the Federation of American Societies for Experimental Biology (FASEB) for the United States Food and Drug
Administration (FDA) concluded that MSG is safe when "eaten at customary levels" and, although a subgroup of otherwise-healthy Appearance White crystalline
individuals develop an MSG symptom complex when exposed to 3 g of MSG in the absence of food, MSG as a cause has not been powder
established because the symptom reports are anecdotal129] Melting point 232 °C (450 °F;
505 K)
According to the report, no data support the role of glutamate in chronic disease. A controlled, double-blind, multiple-location
Solubility in
clinical trial failed to demonstrate a relationship between the MSG symptom complex and actual MSG consumption. No statistical
water
association has been demonstrated, and the few responses were inconsistent. No symptoms were observed when MSG was
administered with food.[3°][31][32][331
NFPA 704
Adequately controlling for experimental bias includes a double-blind, placebo-controlled experimental design (DBPC) and
administration by capsule, because of the unique aftertaste of glutamates.(32) In a study by Tarasoff and Kelly (1993), 71 fasting
participants were given 5 g of MSG and then a standard breakfast. One reaction (to the placebo, in a self-identified MSG-sensitive
individual) occurred.[3°] A study by Geha et al. (2000) tested the reaction of 130 subjects with a reported sensitivity to MSG. Multiple
Lethal doseOr
DBPC trials were performed, with subjects exhibiting at least two symptoms continuing. Two people out of the 130 responded to all
four challenges. Because of the low prevalence, the researchers concluded that a response to MSG was not reproducible.t341
15800:.rng/kg
Studies exploring MSG's role in obesity have yielded mixed results.[35)[36]
Although several studies have investigated anecdotal links between MSG and asthma, current evidence does not support a causal EidePt+ArhereotnerWiSeTioted,'data
association.bA Since glutamates are important neurotransmitters in the human brain, playing a key role in learning and memory, aie':g veri for materials ir(theif
standard atate (at 25 °C'{77 °F],
ongoing neurological studies indicate a need for further research.[38)
Food Standards Australia New Zealand (FSANZ) MSG technical report concludes, "There is no convincing evidence that MSG is a verify (what is LA
significant factor in causing systemic reactions resulting in severe illness or mortality. The studies conducted to date on Chinese Infobox refer, nc, s
restaurant syndrome (CRS) have largely failed to demonstrate a causal association with MSG. Symptoms resembling those of CRS
may be provoked in a clinical setting in small numbers of individuals by the administration of large doses of MSG without food. However, such effects are neither persistent nor
serious and are likely to be attenuated when MSG is consumed with food. In terms of more serious adverse effects such as the triggering of bronchospasm in asthmatic
individuals, the evidence does not indicate that MSG is a significant trigger factor."1391(4°1
However, the FSANZ MSG report says that although no data are available on average MSG consumption in Australia and New Zealand, "data from the United Kingdom
indicates an average intake of 590 mg/day, with extreme users (97.5th percentile consumers) consuming 2330 mg/day" (Rhodes et al. 1991). In a highly seasoned restaurant
meal, intakes as high as 5000 mg or more may be possible (Yang et al. 1997). When very large doses of MSG (>5 g MSG in a bolus dose) are ingested, plasma glutamate
concentration will significantly increase. However, the concentration typically returns to normal within two hours. In general, foods providing metabolizable carbohydrate
significantly attenuate peak plasma glutamate levels at doses up to 15o mg/kg body weight. Two earlier studies—the 1987 Joint FAO/WHO Expert Committee on Food Additives
(JECFA) and the 1995 Federation of American Societies for Experimental Biology (FASEB)—concluded, "there may be a small number of unstable asthmatics who respond to
doses of 1.5-2.5 g of MSG in the absence of food". The FASEB evaluation concluded, "sufficient evidence exists to indicate some individuals may experience manifestations of
CRS when exposed to a a3 g bolus dose of MSG in the absence of food".[39]
Society and culture

It has been suggested that a fear of MSG may reflect anti-Asian racism, with MSG being seen as an alien arrival in Western cooking, likely to be dangerous [41][42][43) Food critic
Jeffrey Steingarten argued that fear of MSG should be seen as a Western-centric mindset, lacking awareness of its common use in Far Eastern cooking without apparent
problems: "If MSG is a problem, why doesn't everyone in China have a headache?"[44451
A hypothetical MSG symptom complex, named "Chinese restaurant syndrome", attracted attention in the period after 1968, when Robert Ho Man Kwok reported symptoms he
felt after an American-Chinese meal. Kwok suggested possible reasons for his symptoms, including cooking with wine, sodiutn, and MSG; even though there is a pervasive belief
that MSG causes a variety of symptoms, there are no data to substantiate this claim.[3°1 •
The perpetuation of the negative image of MSG through the so-called Chinese Restaurant Syndrome has been attributed to xenophobic or racist biases,[461[47][48][49]15°]L51] with
people specifically targeting Asian cuisine whereas the widespread usage of MSG in western consumer goods (e.g. in processed food) doesn't generate the same stigma.[521
Production
MSG has been produced by three methods: hydrolysis of vegetable proteins with hydrochloric acid to disrupt peptide bonds (1909-1962); direct chemical synthesis with
acrylonitrile (1962-1973), and bacterial fermentation (the current method).(r ) Wheat gluten was originally used for hydrolysis because it contains more than 3o g of glutamate
and glutamine in 100 g of protein. As demand for MSG increased, chemical synthesis and fermentation were studied. The polyacrylic fiber industry began in Japan during the
mid-1950s, and acrylonitrile was adopted as a base material to synthesize MSG.E531
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Currently (2016), most global MSG is produced by bacterial fermentation in a process similar to making vinegar or yogurt. Sodium is added later, for neutralization. During
fermentation, corypfbacterium species, cultured with ammonia and carbohydrates from sugar beets, sugarcane, tapioca or molasses, excrete amino acids into a culture broth
from which L-glutamate is isolated. The Kyowa Hakko Kogyo Company developed industrial fermentation to produce L-glutamate.E543
The conversion yield and production rate (from sugars to glutamate) continues to improve in the industrial production of MSG, keeping up with demand.[171 The product, after
filtration, concentration, acidification, and crystallization, is glutamate, sodium, and water.
Chemical properties
The compound is usually available as the monohydrate, a white, odorless, crystalline powder. The solid contains separate sodium cations Na+ and glutamate anions in
zwitterionic form, - 00C-CH(NIV-(CH2)2-000- .E551 In solution it dissociates into glutamate and sodium ions.
MSG is freely soluble in water, but it is not hygroscopic and is insoluble in common organic solvents (such as ether).[561 It is generally stable under food-processing conditions.
MSG does not break down during cooking and, like other amino acids, will exhibit a MaiHard reaction (browning) in the presence of sugars at very high temperaturesP83
Regulations
United States
MSG is one of several forms of glutamic acid found in foods, in large part because glutamic acid (an amino acid) is pervasive in nature. Glutamic acid and its salts may be
present in a variety of other additives, including hydrolyzed vegetable protein, autolyzed yeast, hydrolyzed yeast, yeast extract, spy extracts, and protein isolate, which must be
specifically labeled. Since 1998, MSG cannot be included in the term "spices and flavorings". However, the term "natural flavor" is used by the food industry for glutamic acid
(chemically similar to MSG, lacking only the sodium ion). The Food and Drug Administration (FDA) does not require disclosure of components and amounts of "natural
flavor."t5A
The FDA considers labels such as "no MSG" or "no added MSG" misleading if the food has ingredients which are sources of free glutamate, such as hydrolyzedyrotein. In 1993,
it proposed adding "contains glutamate" to the common names of certain hydrolyzed proteins with substantial amounts of glutamate.
Australia and New Zealand

Standard 1.2.4 of the Australia and New Zealand Food Standards Code requires MSG to be labeled in packaged foods. The label must have the food-additive class name (e.g.
"flavour enhancer"), followed by the name of the additive ("MSG") or its International Numbering System (INS) number, 621.[581
Pakistan
The Punjab Food Authority banned Chinese salt, which contains MSG, from being used in food products in the Punjab Province of Pakistan in January 2018 [591
Names
The following are alternative names for MSG:LiHooKon
Chemical names and identifiers
• Monosodium glutamate or sodium glutamate

• Sodium 2-a minopentanedioate
• Glutamic acid, monosodium salt, monohydrate
• L-Glutamic acid, monosodium salt, monohydrate
• L-Monosodium glutamate monohydrate
• Monosodium L-glutamate monohydrate
• MSG monohydrate
• Sodium glutamate monohydrate
• UNII-W81N5U6R6U
On packaging
• Flavour enhancer E621
Trade names
• Accent, produced by B&G Foods Inc., Parsippany, New Jersey, US[6203]

• AJI-NO-MOTO, produced by Ajinomoto, 26 countries, head office Japan[641(651
• Tasting Powder
• Ve-Tsin by Tien Chu Ve-Tsin
• SazOn, distributed by Goya Foods, Jersey City, NJ[661
See also
• Acceptable daily intake • Disodium glutamate .• Glutamate flavoring
• Adenosine monophosphate • Disodium inosinate • Glutamic acid
• Ajinornoto • Garum • Guanosine monophosphate
4/24/2019 Case: 1:18-cv-02861 Document #: 101ckftwoli:094/239/191fOettje 12 of 49 PagelD #:1155
• Hypoxanthine-guanine phosphoribosyltransferase • Monopotassium glutamate • Tien Chu Ve-Tsin
• Inosinic acid • Murri (condiment) • Umami
• Kikunae Ikeda • Ribonucleoside
References
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Technical Committee, Umami Manufacturers Association of Japan. (1998). "What
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August 11, 2014.
doi:10.1080/87559129809541155.(https://doLorg/10.1080%2F8755912980954115
2. Ninomiya K, Technical Committee, Umami Manufacturers Association of Japan
(1998). "Natural occurrence", Food Reviews international. 14 (2 & 3): 177-211.
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dot10.1080/87559129809541157 htt s://doi.or /10.1080%2F8755912980954115
as a basic taste (umami)?". The American Journal of Clinical Nutrition. 90 (3):
7/. 719S-7225. dot:10.3945/429.2009.27462D (https://doi.org/10.3945%2Fajcp.200
3. "FDA Q&A on MSG" (http://www.fda.gov/Food/IngredientsPackagtagLabeling/Foo 9.27462Dj. PMID 19640953 (9ps://www.ncbi.nlm.nih.gov/pubmed/19640953),
dAdditivesIngredients/ucm328728.htm). fcia,gov. Retrieved 5 March 2016.
20. Rolls, Edmund T., Oxford Centre for Computational Neuroscience. United
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afen/health-canada/servicesifood-nutrition/food-safety/food-additives/monosodium International Glutamate Technical Committee, a nongovernmental organization
7glutamate-questions-answers.html). Government of Canada. Retrieved 20 May funded by industrial producers and users of glutamate in food, (September 2009).
2018. "Functional neuroimaging of umami taste: what makes umami pleasant?". The
5. Ikeda K (November 2002). "New seasonings". Chem Senses. 27 (9): 847-849. American Journal of Clinical Nutrition. 90 (3): 8045-8135.
doi:10.1093/chemse/27.9.847 (hltps://doLorg/10.1093%2Fchemse%2F27.9.847). doi:10.39451on.2009.27462R (https://doi.org/10,3945%2Fajon,2009,274621K.
PMID 12438213 (https://www.ncbi.nlm.nih.gov/pubmed/12438213). PMID 19571217 (Liftps://www.ncbi.nlm.nih.gov/pubmed/19571217).
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-84b2-00144feabdc0.html#axzz424XCO). Financial Times. Nikkei. Retrieved Dekker Inc.
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7. Loliper J (April 2000). "Function and importance of Glutamate for Savory Foods". Takahashi, Chikahlto, Central Research Laboratories, Ajinomoto Co., Japan.
Journal of Nutrition. 130 (4s Suppl): 915s-920s. doi:10.1093/jn/130.4.915S (http (January 1984). "Interactions of monosodium glutamate and sodium chloride on
s://doLorg/10.1093%2Fjn%2F130.4.915S). PMID 10736352 (https://www.ncbi.n1 saltiness and palatability of a clear soup". Journal of Food Science. 49 (1): 82-85.
rn.nih.goyfpubmed/10736352). doi:10.1111/1.1365-2621.1984.tb13675.x(https://doi.org/10.1111%25,4305-2621.1
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physlology & Behavior. 49 (5): 833-841. doi:10.1016/0031-9384(91)90192-Q (htt 23. Ball P, Woodward 0, Beard T, Shoobridge A, Ferrier M. Sponsorship: We
ps://doi.org/10.1016%2F0031-9384%2891%2990192-Q). PMID 1679557 (httpsy acknowledge the financial support of the International Glutamate Technical
www.ncbi.nlm.nih.gov/pubmed/1679557). Committee (IGTC), a nongovernmental organization funded by industrial
9. "Questions and Answers on Monosodium glutamattyspy(riftp://www.fda.gov/f producers and users of glutamate in food. (June 2002). "Calcium digiutamate
pod/ingrodientspeckaginglabeling/foodadditivesingredients/ucm328728.htm). U.S. improves taste characteristics of lower-salt soup". Eur J Cirri Nulr. 56 (6): 519-23.
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ih.gov/prric/articies/PMC4970486). The Journal of Headache and Pain. 17: 54. (https://www.businessinsider.com/cooking-with-msg-supersalt-2017-2). Business
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PMID 27189588 (https://www.ncbi.nim.nih.gov/pubmed/27189588). 26. Barry-Jester, Anna Maria (8 January 2016). "How MSG Got A Bad Rap: Flawed
11. Wei, Wit (16 June 2014). The Truth Behind Notorious Flavor Enhancer MSG (htt • Science And Xenophobia" (https://fivethirtyeight.com/features/howrinsg: got: arbad
p://www.businessinsider.com/msg-ingredients-side-effects-2014-6). Business -rap-flawed-science-and-xenophobia/).
Insider (Podcast). Retrieved 13 November 2017. 27. "Art of cheese-making is 7,500 years old" (http://www.nature.com/news/art-of-che
12. "Current EU approved additives and their E Numbers" (http://www.food.gov.uldsaf ese-making-is-7-500-years-old-1.12020). Nature. December 12,2012.
ereatingtchemsafe/additivesbranch/enumberlist). Food.gov.uk. 2010-11-26, 28. Walker R, Lupien JR, School of Biological Sciences, University of Surrey, UK, and
Retrieved 2012-01-30. Food and Nutrition Division, FAO of the United Nations, Italy. (April 2000). "The
13. R.H.A. Plimmer (1912) (1908). R.H.A. Plimmer; F.G. Hopkins (eds.). The safety evaluation of monosodium glutamate". Journal of Nutrition. 130 (4S Suppl):
Chemical Constitution of the Proteinihttps://books.poogle.com/?id=7JM8AAAAIA 1049S-52S. doi:10.10931p/130.4.1049S (https://doi.org/10.1093%2FjoN2F130.4.
AJ8pg.PA1141 Monographs on biochemistry. Part I. Analysis (2nd ed.). London: 1049S). PMID 10736380 (https://www.ncbi.nlm.nih.gov/pubmed/10736380).
Longmans, Green and Co. p. 114. Retrieved June 3,2092. 29. Rotten DJ. Talbot JM, Fisher KD (1996). "Executive Summary from the Report:
14. Lindemann, Bernd, Universitat des Saarlandes, Medical Faculty, Physiology, Analysis of Adverse Reactions to Monosodium Glutamate (MSG) -no summary
Germany; Ogiwara Yoko, Ajinomoto Co., Inc., European Head Office, France; available, 8111/2014". Journal of Nutrition, 125 (6): 28915-29085.
Ninomiya, Yuzo, Section Oral Function and Neurobiology, Department of doi:10.1093/jn/125.11.2891S (https://doLorg/10.1093%2Fjn%2F125.11.2891S).
Regulatory Oral Science, Kyushu University Graduate School, Japan. (November PMID 7472671 (https://www.ncbi.nlm.nih.gov/pubmed/7472671).
2002). "The discovery of umami". Chern Senses. 27 (9): 843-4. 30. Freeman, Matthew, CNP. mph, Clinical Instructor (Adult Nurse Practitioner), Ohio
doi:10.1093/chemse/27.9.843 (https://doLorg/10.1093%2Fchemse%2F27.9.843). State University. He reviewed 40 years of documents on PubMed, Medline, Lexis-
PMID 12438211 htt s://www.ncbi.nlm.nih. ov/ ubmed/12438211 Nexus, and Infotrac, and concluded there is no consistent clinical data to support
15. Renton, Alex (10 July 2005). "If MSG is so bad for you, why doesn't everyone in the belief that MSG can elicit a headache, and there is no consistent evidence to
Asia have a headache?" (https://www.theguardian.com/lifeandsVle/2005/jul/10/fo suggest that individuals may be uniquely sensitive to MSG. (2006).
odanddrinkjeatures3), the Guardian. "Reconsidering the effects of monosodium glutamate: A literature review'. Journal
16. Ikeda K (1908). "A production method.of seasoning mainly consists of salt of L- of the American Academy of Nurse Practitioners. 18 (10): 482-6.
glutamic acid". Japanese Patent 14804. doi:10.1111/j.1745-7599.2006.00160.x (https://doi.org/10.1111%2Fj.1745-7599.20
'17. Sane, Chiaki, Technology and Engineering Center, Ajinomoto Co, Japan. 06.00160,20. PMID 16999713 (https://www.ncbi.nlm.ne,gov/pubmed/16999713),
(September 2009). "History of glutamate production". The American Journal of 31. Geha RS. Beiser A, Ren C, et al. (April 2000). "Review of alleged reaction to
Clinical Nutrition. 90 (3): 728S-732S, doi:10.39451ajcn.2009.27462F1https://doLor monosodium glutamate and outcome of a multicenter double-blindpiacebo-,
g/10.3945%2Fajcn.2009.27462F), PMIC19640955.(hyps://y ricbi.nlm.nifigov/ controlled study" (https://web.archive.org/web/20120114164740/httpArputrition.o
pubmed/19640955). ro/content/130/4/1058.1ong). J. Nair. 130 (43 Suppl): 10585-625.
doi:10.1093/jn/130.4.1058S(hftps://doi.org/10.1093%2Fjn%2F130.4.105EI5).
PMID 10736382 (https://www.ncbi.nlm.nih.gov/pubmed/10736382). Archived from
the original (hftp://in,nutrition.org/content/130/4/1058.1ong) on 2012-01-14.
4/24/2019 Case: 1:18-cv-02861 Document #: 1064010F066:011/1WIRIReatje 13 of 49 PagelD #:1156
32. Tarasoff L.: Kelly M.E (1993). "Monosodium L-glutamate: a double-blind study and 49. "Why Do People Freak Out About MSG in Chinese Food?" (https://www.youtube.c
review". Food Chem. Toxicoi. 31 (12): 1019-35. doL10.1016/0278- . ondwatch?v=Sm8Yx-gWIMs). AJ+ (on YouTube). AI Jazeera Media Network, 14
6915(93)90012eN ffittps://doLorg/10.1016%2F0278-6915%2893%2990012-19. August 2018.
PMID 8282275.(https://www.ncbi.nlm.nilleov/pubmed/8282275), 50. Blythman, Joanna (21 May 2018), "Chinese restaurant syndrome: has MSG been
33. Walker R (October 1999). "The significance of excursions above the ADJ. Case unfairly demonised?" (hffpe://www.theooardian.com/lifeandstyle/2018/mey/21/chin
study: monosodium glutamate'', Regal. Toxicol, Pharmaco/, 30 (2 Pt 2): 8119-21. ese-restaurant-syndrome-has-msg-been-unfairly-demonised), The Guardian.
doi:10.1006/rtph.1999.1337 (https://deLorg/10.1006°/02Frtph.1999.1337). • "Although Chang doesn't use MSG in his kitchens, he has defended its use, telling
PMID 10597625 (hffps://www.ncbi.nlm.nkgov/pubmed/10597625). a high-level meeting of top chefs that Chinese restaurant syndrome Is nothing
34. Williams, A. N. VVoessner, K.M. (2009). "Monosodium glutamate 'allergy': menace more than a "cultural construct". That is a polite way of saying that avoidance of
or myth?". Clinical & Experimental Allergy. 39 (5): 640-6. doi:10.1111/1365- MSG is an expression of western ignorance, or worse, racism, drawing on
2222.2009.03221.x (https://doi.org/10.1111%2Fj.1365-2222.2009.03221.x. stereotypes of Asian countries as dangerous or dirty."
PMID 19389112(hffpe://www.ncbi.nlm.nitegov/pobmed/19389112), 51. Gelling, Natasha (8 November 2013). "It's1ffeUmeni,Stopid,Why the Truth
35. Shi, Z; Luscombe-Marsh, ND; Witted, GA; Yuan, B; Dai, Y; Pan, X; Taylor, AW About MSG is So Easy, to Swallow"(https://www.smithsonianmag.com/arts-cultur
(2010). "Monosodium glutamate is not associated with obesity or a greater ents-the-umami-stupid-why-the-truth-about-msg-is-so-eaey-to-swallow-18094762
prevalence of weight gain over 5 years: Findings from the Jiangsu Nutrition Study 6/). Smithsonian. "Everyone knows this connection, and probably associates MSG
of Chinese adults". The British Journal of Nutrition. 104 (3): 457-63. use in America most heavily with Chinese restaurants-thanks in large part to the
doi:10.1017/S0007114510000760 (https://doi.org/10.1017%2FS00071145100007 absurdly racist name for MSG sensitivity "Chinese Restaurant Syndrome.'"
p.MIp...?9.Fp.9.11.(https://www.ncbi.nlmmih.eov/pubmed/203709,11). 52. "Why Do People Freak Out About MSG in Chinese Food?"(https://www.youtube.c
36. Nicholas bakalar (August 25, 2008). "Nutrition: MSG Use Is Linked to Obesity"(htt om/watch?v=Sm8Yx-gWIMs). AJ+ (on YouTube). Al Jazeera Media Network. 14
ps://viavw.nytimes.com/2008/08/26/health/nutrition/26nutr.html), The New York August 2018. Event occurs at 0:00-1:00m and 5:20-8:30m.
Times. Retrieved 2010-11-10. "Consumption of monosodium glutamate, or MSG, 53. Yoshida T, Ajinomoto Co., Planning and Development Department, Japan. (1970).
the widely used food additive, may increase the likelihood of being overweight, a "Industrial manufacture of optically active glutamic acid through total synthesis".
new study says." Chern log Tech, 42 (9-10); 641-644. doi:10.1002/cite.33042091_2(httoe://doLereL
37. Stevenson, D. D. (2000). "Monosodium glutamate and asthma". J. Nutr. 130 (4S 10.1002%2Fcite.330420912).
Supply 1067S-73S. doi:10.10930/130.4.1067S (https://doLorg/10.1093%2Fjoy2 54. Kinoshita Shukuo, Tokyo Research Laboratory, Kyowa Fermentation Industry
F130.4.1067S). PMID 10736384 (httpeei/www.ncbi.nlm.nitLgev/popmed/1073638 Company; Udaka, Shigezo; Shimamoto, tv1asakazu. (1957), "Studies on amino
acid fermentation. Part I. Production of L-glutamic acid by various
38. Nicholas J. Maragakis, MD; Jeffrey D. Rothstein. MD (March 2001). "Glutamate microorganisms" (https://wvoiv.jstagejst.go.jp/article/jgam1955/3/3/3 3 193/_pdf).
Transporters in Neurologic Disease"(http://archneurjamanetwork,com/article,asp J Gen Appl Microbial, 3 (3): 193-205, doi:10.2323/jearn.3.193 (https://doi.org/10.2
x?articleid=778622). 58 (3). pp. 365-370. Retrieved 2015-01-17. 323%2Fjoarn.3.193).
39. MONOSODIUM GLUTAMATE, A Safety Assessment, TECHNICAL REPORT 55. Chiaki SAND, Nobuya NAGASHIMA, Tetsuya KAWAKITA, Yoichl IITAKA (1989),
SERIES NO. 20Ahttp://www.foodstandards,9ov.au/publications/Documents/MS "Crystal and Molecular Structures of Monosodium L-Glutamate Monohydrate".
G%20Technical%20Report.doc). FoodStandards.gov.au. Food Standards Analytical Sciences, volume 5, issue 1, pages 121-122. dol:10.2116/analsci.5.121
Australia New Zealand, Health Minister Chair, Peter Dutton MP. June 2003, (htips://doLerg/10.2116%2Fanalsci.5.121)
ISBN 978-0642345202. ISSN 1448-3017(httpe://veivw.worldcatorg/issn/1448-301 56. Win. C., ed. (1995). Principles of Biochemistry. Boston, MA: Brown Pub Co.
7), Retrieved January '17, 2015 57. "CFR - Code of Federal Regulations Title 21, Vol 6, Part 501, Subpart B-
40. "Monosodium glutamate search" (Ittp://www.foodstandards.gov.au/Search/pages/ Specific Animal Food Labeling Requirements" (http:11www.accessdata.fda.gov/scri
results.aspx?k=Monosodium+glutamate). FoodStandards.gov.au. Food Standards pts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=501.22). FDA.gov. U.S. Food and Drug
Australia New Zealand, Health Minister Chair, Peter Dutton MP. Retrieved Administration. Retrieved August 13, 2014.
August 13, 2014, 58. "Standard 1.2.4 Labelling of Ingredients" (https://web.archive.org/web/201008211
41. Mahoney, John. "The Notorious MSG's Unlikely Formula For Success" (https://ww 30741/http://www.foodstandards. ov.auffoodstandardsffoodstandardscode/standa
w.buzzfeed.com/johnmahoney/the-notorious-msgs-unlikely-formula-for-succese). rd1241abellee4231.cfmj. Food Standards Code. Food Standards Australia New
BuzzFeed. Retrieved 12 November 2014. Zealand. Archived from the original (http://www.foodstandards.gov.auffoodstandar
42, Dickerman, Sarah. "Could MSG make a comeback?" (http://www.slate.com/article ds/foodstandardscode/standard1241abelling4231.cfm) on 2010-08-21. Retrieved
s/lifeffood/2006/05/coulteesgmake a comeback.htmq. Slate magazine. May 15, 2010.
43. Mange, Imaeyen. "China food scare: a dash of racism" (http://abcnews.go.com/G 59. "Punjab Food Authority bans Chinese salt after scientific panel finds it hazardous
MA/Health/story?id=3413105). ABC News. Retrieved 12 November 2014. for health" (https://www.dawn.com/news/1383111/peejeb-food-authority-bans-chin
ese-salt-after-scientific -finds-it-hazardous-for-health). Dawn, Retrieved
44. Haber, Barbara. "Life on the Culinary Edge" (http://harvardmagazine.com/2003/0
15 January 2018.
1/life-on-the-culinaryeeedg.html). Harvard Magazine. Retrieved 12 November 2014.
60. Singh, K. K.; Desai, Pinakin, Director. "Glutamate Chemical" (http://www.triveniinte
45. Renton, Alex, "If MSG is so bad for ybu, why, doesn't everyone in Asia have a
rchem.com/glutareete.html) TriveniinterChem.com. Riveni InterChem of Triveni
headache?" (https://www.theguardian.comffifeandstyle/2005/jul/10/foodanddrinki
Chemicals, manufacturer & supplier of industrial chemicals, India. Retrieved
eatures3). The Guardian. Retrieved 12 November 2014.
August 11, 2014.
46. LeMesurier, Jennifer L. (8 February 2017), "Uptaking Race: Genre, MSG, arid
61. Desmo Exports Limited, Chemical Manufacturers and Importers of India (2011),
Chinese Dinner", Portal. 12 (2). doi:10.13008/2151-2957.1253 htt s://doi.or /10.1
"Monosodium Glutamate (MSG)" (htt ://desmoex orts.com/ roducts/ms .htm
3008%2F2151-2957.1253). "Introduction; 'Chinese Restaurant Syndrome' as
DesmoExports.corn. Desmo Exports. Retrieved August 11, 2014.
Rhetorical [...] Finally, I trace how the journalistic uptakes of this discussion, in
only taking up certain medical phrases and terms, reproduce the tacit racism of 62. "Accent Flavor Enhancer" (httpy/www.accentflavorcom/products/becent-flavor-en
this boundary policing while avowing the neutrality of medical authority." hancer/), AccentFlayorcorri. B&G Foods, Inc. Retrieved August 11, 2014.
47. DeJesus, Erin (16 October 2016). "Recapping Anthony Bourdain 'Parts Unknown' 63. "B&G Foods, Incorporated" ffittp://wwwerocery.com/bg-foods-incorperetecyl.
in Sichuan"(https://www.eater.com/2016/10/16/13278532/anthony-bourdaieeparts- Grocery.corn. Retrieved August 13, 2014.
unknown-sichuan-china-recap) Eater. Vox Media. See also "Bourdain, off the 64. "Monosodium glutamatelMSGnhyp://www.ajinomoto.comffeatures/eji-no-mete/e
cuff: Sichuan" (https://explorepartsunknown.com/sichuan/bourdain-off-the-cuff-sic n/truth/). Umami Global Website, AJINOMOTO CO., INC. Retrieved 30 Oct 2016.
huan/), Explore Parts Unknown, CNN, Retrieved 14 December 2018. "[On MSG]: 65. "To Greet the Next 100 Years (Corporate Guide)" (http://www.ajinornoto.com/en/a
"You know what causes Chinese-restaurant syndrome? Racism. 'Ooh, I have a bouttie/pdffejiponoteprofile.pdf?scid=ay_etpc comeheadbp_aboutes_ejipomot
headache, must have been the Chinese guy.""' en,,proffie) (PDF). AJINOMOTO CO., INC. Retrieved 13 Aug 2014.
48. Barry-Jester,-Anna Maria (8 January 2016). :How MSG Got A Bad Rap: Flawed 66. §.. .K99,..§!9pp199;...§001y1e, Ingredients, Eqpivalentslhttp;//www.gourmetsleut
Science And Xenophobia" (https://fivethirtyeieht.com/features/how-ms - of-a-bad h.conyinoredigets/cletaii/sazon7seasoninel GourmetSleuth, Retrieved on 2016-
-rap-flawed-science-and-xenophobia/). FiveThirtyEight. hat MSG causes health 11-04.
problems may have thrived on racially charged biases from the outset. Ian Mosby,
a food historian, wrote in a 2009 paper titled "'That Won-Ton Soup Headache':
The Chinese Restaurant Syndrome. MSG and the Making of American Food,
1968-1980" that fear of MSG in Chinese food is part of the U.S's long history of
viewing the "exotic" cuisine of Asia as dangerous or dirty."
4/24/2019 Case: 1:18-cv-02861 Document #: 106140Filled:g04/23311,919tartle 14 of 49 PagelD #:1157
External links
• The Facts on Monosodium GiutamateiEUFICAhdp://www.eufic.org/enifood-todaVarticle/the-facts-on-monosodium-glutamate)
Retrieved from "https://en.wikipedia.org/w/index.php?title=Monosodium glutamate&oldid=893766078"
This page was last edited on 23 April 2019, at 12:59 (OTC).

Text is available under the Creative Commons Attribution-ShareAlike License; additional terms may apply. By using this site, you agree to the Terms of Use and Privacy Policy.
WikipedialD is a registered trademark of the Wikimedia Foundation, Inc., a non-profit organization.
https://en.wikipedia.org/wiki/Monosodium_glutamate, 6/6
Exhibit C
4/25/2019 Case: 1:18-cv-02861 Document #PXOgululuiterdmrgetaatiOdRapJèli3FOf 49 PagelD #:1159
Suburban Express - Champaign, IL Yelp
Yelp Kind of Sucks
The Yelp Commandments
Thou shalt not criticize Yelp on Yelp:
FEB 09, 2015 1 11:36AM PST

Hi,
We wanted to let you know your Specialties section on

http://www.yelp.com/biz/suburban-express-champaign falls outside our Content
Guidelines because it contained displaced content. We encourage you to use the
Specialties section to name a few of the things your business does best or makes your
business unique.
We've removed the following:
"We are the worst bus company ever -- just read the reviews! We can't figure out why
nearly 120,000, passengers rode us last year since we're so bad. Yelp is a pretty
worthless tool if your goal is to gather objective information. Negative reviews here
are typically posted by immature teens who are angry that they were held responsible
for their actions -- perhaps for the first time in their lives. Non-refundable
tickets are non-refundable. Buses leave on time, with or without you. The bus won't
come looking for you, so you have to figure out the bus stop location in advance.
Welcome to the real world."
Feel free to resubmit content that complies with our Content Guidelines
(http://www.yelp.com/guidelines). We hope you will continue to participate on Yelp
while keeping our Content Guidelines in mind.
Thanks for using Yelp!
Regards,
Penny
Yelp User Support
Yelp Official Blog 1 http://officialblog.yelp.com

Yelp Support Center 1 http://www.yelp-support.com
Yelp for Business Owners 1 https://biz.yelp.com.
For your reference this is Case 0: 3219832
Thou shalt not mention reviewer's name in response to a review which divulges
your own personal information:
JAN 26, 2015 1 12:04PM PST

Hi,
Your public comment in response to s review of your business Suburban Express

was flagged by the community on the group s that it wasn't appropriate for the forum.
We took a close look and decided to remove your comment because it discloses private
information (e.g., last names, personal information, etc.).
Please visit our Content Guidelines (http://www.yelp.com/guidelines) for more

information, and thank you for your interest in Yelp.
Removed Content: I don't know who

seems to be a pushy little ******* International studentJM"
is, but I do know
ego - and he
has been permanently banned from Suburban Express. Here he is, trying to blame his
problems on others. If I were a guest in another country, I would certainly not act
like.. I would be humble and polite.
As for bizarre claims - a quick visit to the Illinois Secretary of State's

Corp/LLC search reveals that Suburban Express, Inc and Allerton Charter Coach, Inc.
and Green River Lines, Inc. are all separate legal entities, contrary to s
"theories." apparently cannot wrap his brain around the subcontrac or
relationship w ere multiple companies work for one company to achieve a common goal
providing speedy, reliable service at a reasonable price.
Regards,
Reuben
Yelp Support
San Francisco, California

suburbanexpress.com/yelp/ 1/3
4/25/2019 Case: 1:18-cv-02861 Document #P1:0@uluirkrdP@4/2atlit9aRaNY1E7Fbf 49 PagelD #:1160
Yelp for Business Owners 1 https://biz.yelp.com
For your reference this is Case #: 3168406
YELP JAN 29, 2015 1 07:59PM UTC We love hearing from you, whether you're sharing an
awesome idea or have a problem to report. We want to make sure your Yelp experience
is great; and we're looking forward to doing what we can to help! For now, we just
wanted to let you know that we've received your message. One of our agents will take
a look and respond to your inquiry, typically within 5 business days.
Please do not submit multiple inquiries about the same issue- this will slow down our ability to respond.
-The Yelp Support Team
Original Message:
Additional Information:
Dear Idiots,
Please remove the last name "Toeppen" from the review of Suburban Express, Champaign,
IL written by This disclosure violates your own terms of service.
We do not appreciate that"lave repeatedly deleted our response containing a

symmetric disclosure - of 's last name.
You need to apply your policies consistently.
Thou shalt not attempt to use the Internet to sidestep Almighty Yelp:
Hi,
Your public comment in response to 's review of your business Suburban

Express was flagged by the community on the grounds that it wasn't appropriate for
the forum.
We took a close look and decided to remove your comment because it still discloses
private information (e.g., last names, personal information, etc.).

Removed Content: I don't know who is, but I do know

seems to be a pushy little Chinese engineering student with a fragile ego an e
has been ermanentl banned from Suburban Express. You can find him online by
Googling . Here he is, trying to blame his problems on
others. If I were a guest in another country, I would certainly not act liken.. I
would be humble and polite.
As forillips bizarre claims - a quick visit to the Illinois Secretary of State's

Corp/LLC search reveals that Suburban Express, Inc and Allerton Charter Coach Inc.
and Green River Lines, Inc. are all separate legal entities, contrary toll's
"theories."111111apparently cannot wrap his brain around the subcontractor
relationship where multiple companies work for one company to achieve a common goal -
pr6iding speedy, reliable service at a reasonable price.
About the asterisks - Yelp will not allow this idiot's last name in our response, but
they are happy to allow a last name in the review. Yelp is hilarious. We'll post our
full response at http://www.suburbanexpress.com/responsepage
Regards,
Ruby
Yelp Support

Thou Simply Shalt Not:
The Yelp gripe doesn't even match the "Removed Content":
Hi,
Your public comment in response to 's 1.11= review of your business

Suburban Express was flagged by the community...
We took a close look and decided to remove your comment because it discloses private
information (e.g., last names, personal information, etc.).
4/25/2019 Case: 1:18-cv-02861 Document #P1:064.ufBitet1T0412atigarga§dìnFbf 49 PagelD #:1161
Removed Content:
Further proof that Yelp is for whiney losers.
Regards,
Reuben
Yelp Support

Yelp isn't pro free speech - Yelp is pro Yelp clicks.
Exhibit D
4/25/2019 Case: 1:18-cv-028611111 41itietkit2.061411=1111111MIEM bri)(41931:Eaget0 #:1163
Back to the Suburban Express Response Page
Suburban Express responds to s Yelp Activities
seems to be having trouble coping with the world around him. He's taken to
Yelp to share his bizarre theories regarding Suburban Express. When we tried to
communicate with him, we found that he has blocked us from communicating with him via
Yelp. It's hard to address a reviewer's concerns when he puts his fingers in his ears
and hums.
responded to contact attempts by revealing employee personal information in his

review of Suburban Express. When he didn't like our response to this idiotic behavior,
he went whining to Yelp and had them remove our response on the basis that it revealed
his last name. In other words, IIIIIIwants to spew his venom anonymously.
All we can say is, WHAT A LITTLE WEASEL. If you're thinking of hiring
we'd recommend that you think if you're going to go aft.. .line,
expect that your anonymity may be pierced.
Illill just loves to hear himself talk. He actually reviewed a gas station:
Super Pantry
Gas & Service Stations
810 W Green St
Urbana, IL 61801
Share review
Compliment
2.0 star rating 9/19/2014
First to Review
Careless and impolite employees.
Someone needs to explain to this little guy that careless and rude are the defining
characteristics of. virlay every gas station attendant - partly due to having to
deal with people like no doubt.
The above is purely our opinion. We reserve the right to call out anonymous online
detractors.
Our other friends:
suburbanexpress.comMill 1/1
Exhibit E
4/25/2019 Case: 1:18-cv-02861 Docu ivritectr.o@ tumi 6#495PagelD #:1165
Suburban Express responds to 's Yelp Activities
The short version will have to do for now.
You are a legend here at Suburban Express for your lunacy. You are not being truthful
with Yelp readers. Shame on you.
We are happy to accommodate wheelchair passengers. When you requested a wheelchair

bus, we provided one. The problem is that your passengers had more than one
wheelchair per person -- in spite of the fact that we repeatedly told you that we
could NOT accommodate multiple wheelchairs per passenger.
Before the return trip, we contacted you and advised you that the excess items would
need to be shipped, or you would need to find another mode of transportation. The
return trip was full and other passengers would not have been able to put their bags
on if we had accommodated your two pssengers' extra wheelchairs.
Contrary to your claim above, we were willing to accommodate the two disabled
passengers and one wheelchair per passenger.
We do our best to accommodate everyone. But some customers have needs and
expectations which are simply unreasonable. We're glad you were able to find a
solution which works for you.
Thank you for helping demonstrate that customers sometimes use Yelp to "get even"
with businesses who they imagine have slighted them.
Best Wishes,
Suburban Express
When we posted the above response tol s Yelp review, she went into full attack
mode. We were curious about her situation ecause her behavior was so erratic. Was
she living in a mental hospital, we wondered? So we googled her address and found
that her yard was full of bizarre decorative junk. You've seen places like this - too
many plastic animals, weird stuff like that... We thought it was rather odd. Have a
look for yourself:
We decided that she's related to Willy Wonka.
In response to us asking her what's with all the crap in your yard, she accused us of
stalking her, as if looking someone up on google constitutes stalking them, and
feighned fear that we were somehow going to appear at her doorstep 2300 miles away. If
anything, we'd head east to get further from this psycho.
wvvw.suburbanexpress.com 1/2
4/25/2019 Case: 1:18-cv-02861 DocullillMivigittcfr00 6#49sPagelD #:1166
Some Links:
on Gay Marriage
on Linkedln
Coming soon: Recordings of phone calls from this lunatic, if they are still stored in our
phone system.
The above is purely our opinion. We reserve the right to call out anonymous online
detractors.
Our other friends:
www.suburbanexpress.com 2/2
Exhibit F
4/25/2019 case:stlArBareN)Nellogoust.WiefltcktkdleMelq*kro@kickMic9d1760ec28nufg4grPaiptMsitala8s Not LEX
n xpres
Direct Weekend Bus Service to the Chicago Area
Pick Your The Page of Shame

University
Think of this as a review site, where we review what we consider to
I Go be bad customers. Other merchants: We think you should think twice
before doing business with these individuals -- or at least require cash
Home payment. But that's just our opinion.
Itlini Shuttle Dishonored Payments

Order Online
Back when people paid for most purchases by check, merchants
Stop Locations
often pinned up returned checks for others to see. People don't pay
Policies by check anymore, but people still fail to pay for things they purchase.
Customer Service This is a list of Suburban Express customers who have given us
payments which ultimately were not honored. Some people might call
Office Hours these folks deadbeats, but we're too polite do to that.
Just for Fun
Archived dishonored payments are here.
How to stay off this list: Don't lie to your credit card company. If you
do, we will come after you.
Name Address
City, State Phone
Email Date Added
December, 2017
November, 2017
ovem er, 2017
October, 2017
Octo er, 201
October, 2017
c o er, 2017—
Septem er, 2017
September, 2017
1111M11111
July, 2017
Ju y, 2017
March, 2017
www.suburbanexpress.com/dishonoredpmts.html 1/5
4/25/2019 Case:s1 1?9_0ticW2s86101Dte661 A tckittrcrleedie ildrc014'26140§dFria0ec2431124g49rpaijelVIIVOeM s Not LEX
May, 2017
Marc n, 2017
arc ,
MIN
MEL
Fe ruary, 2017
January, 2017
W 1 .,
il21611111111
1,1 111 111M 1
une, 2016
3 un
e, 2016
June, 2016
June, 2016
ai nGi 6
1111
A ril 2016
Made multiple separate purchases at erent atetimes

(ie 2014-11-06 18:15 and 2014-11-06 17:59) then
apparently lied to credit card company and told them he
had not made multiple purchases.
February, 2016
111
Aece11.1 11
February, 2015
4/25/2019 Cas e:s1481reCe*NelorDbettiViefitcWdli@Ocleff iVEPT°31025;(facipFtoec2a7nufg4grpalpicomsiIgpMs Not LEX
Au ust 2015 --
February, 2014
June, 2015
December, 2014
September, 2014
c o er,
August, 2011
c o er,
November, 1012
Decem er, 2012
4/25/2019 Case:sitArgire iNgt31012Motiffiefitc10/501004eidittOrc@i4P2614c9dPialgec2"eleitg49Pagletil)11#iIIPTels Not LEX
INPF
November, 2009
Fare Cheaters
We take a very dim view of people who alter tickets, try to cheat us by
passing off a cheap ticket for an expensive ride, and so forth. Here
are a few people who we consider "Fare Cheaters". You should avoid
engaging in business transactions with these people, in our opinion.
Archived fare cheaters are here.
September, 2017
September, 2017
March, 2017
January, 2017
March, 2014
Banned
Sometimes, customers do ridiculous things which get them banned.

Cutting off a bus so you can get on will get you banned every time.
Delaying a bus will get you banned. And so on. Here is a list of
people who have been permanently banned for various reasons:
Name, Reason
We believe is a danger to herself and others.
@dailyillini.com
Identified herself as an employee of an entity whose

employees are not welcome on Suburban Express.
March, 2017
is morally and ethically challenged,

in our opinion.
kin.
‘. 11.1111
■
is morally and ethically challenged, in our opinion.
Cut off a rolling bus with a car in order to board it
4/25/2019 CaSe:STArgsueVxfatIgelorguscdteplgitcWcy*dielp4sko914250NdpIdgyECNipAgl.grpalptlyillti gp7e2s Not LEX
Caused a bus to be delayed
, and the entire...Family

of e ind them to be generally
unpleasant, if not insane, people and we do not want
them anywhere near our buses or offices.
of area
We believe customer is mental/ unstable based on

her activities as reddit user
Suburban Express) (217) 3444500 714 S Sixth Street. Champaign, IL 81829

Images & Text copyright 1983-2017 Suburban Express Inc
Exhibit G
-pf 49 PagelD #:1174
ONLINE CLASSES
ENROLL TODAY!
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THE DAILY ILLIM

The independent student newspaper at the University of Illinois
(https://dailyillini.com)
News Sports Opinions Life & Culture Special Sections Photo & Video Multimedia Salary Guide Housing
Students on the Suburban Express Top Stories

`Page of Shame' speak out (https://dailyillini.com/featured/?
list)
001
- . . Teammates double as roommates
(https://dailyillini.com/sports/2019/04118/teammai
double-as-roommates/)
•hit ih - College culture augments
environmental impact
en :11-.Jilnie;111
(Mips nions/20 1 9/04/1 8/collq
culturc-augments-environmental-impact/)
rnrrr = ."r1,,ti!‘,11 Parkland Pathway provides cheaper

higher education
c eaper-
(https://datlyillini.com/features/2019/04/1.8/parkla
pathway-provides-cheaper-higher-education!)
' •11 ' Team aims for national title

BY OLIVIA WELSHANS
(HTTPS://DAILYILLINI.COM/STAFF/?WRITER=OLIVIA%2OWELSHANS),
CONTRIBUTING WRITER
1101
_, , , ,:,',1,
(hups://dailyill ini.com/sports/2019104/1 8/gymnast

(W.TOBER preview!)
Filed under Around Campus (https://dailyillini.com/news/around-campus/), Champaign- Families spend mealtimes distracted,
study finds
Urbana (https://dailyillini.com/news/champaign-urbana/), News
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(littps://dailyi I I i ni.corninews./2019/04/1 Wenn lies-
spend-mealtimes-distracted-study-finds/)
Transit company Suburban. Express has a page on its website entitled "Page of Shame
(http://www.suburbanexpress.com/dishonoredpmts.html)." Personal information of Sponsored
certain customers is listed, including their name, email, phone number and address.
(https://dailyillini.com/sponsoredr.
Entries on the list date as early as 2009.
The web page says, "think of this as a review site, where we review what we consider to list)
be bad customers." (https://dailyil Fun things to do in Champaign.
The "Page of Shame" is divided into three sections: "dishonored payments," "fare
champaign/tti
cheaters," and "banned," with each division having infringed on a different policy of (https://dailyillini.com/sponsored/2019/03/19ffun-
Suburban Express or having been found guilty of conduct of which the company things-to-do-in-champai gni)
1:18-cv-02861 Document #: 106-1 Filed: 04/25/19 Page 32 of 49 PagelD #:1175
According to the Chicago Tribune DI Social
(http://www.chicagotribune.cominews/local/breaking/et-bus-owner-harassment-charges-
met-20140806-story.html), in 2013, the company's owner Dennis Toeppen filed over 120
lawsuits against students for various violations of his company's policy. However,
charges were later dropped.
Kevin Thompson, sophomore in Engineering, said he chose to take Suburban Express

back to his home in the suburbs despite what he heard about the company.
"I knew that they had had records and sued students and stuff. I didn't think that I'd have
a problem with it, so I just bought tickets anyway," he said.
Thompson said he had no trouble on the bus ride to his home, but, as he was trying to
board the bus to return to the University, he found he had bought a ticket for the next
weekend.
Krannert Center for the Performing Arts
Instead of saying that he could not ride, Thompson said that the overseers of the bus f Follow
discussed the situation and decided to allow him to ride.
Compagnia Tpo returns to Krannert Center on Sunday,
April 28 with its imrnersive new production, Panda's
"They ended up saying we're not going to kick you off, just don't tell anyone we let you Home. Young audience... (Compagnia TPO: Panda's
Home)
sit," he said.
Despite being allowed to ride the bus, Thompson is now labeled a "fare cheater" by the
company. A "fare cheater," as described by the "Page of Shame," is anyone who alters a
ticket or "tries to cheat us by passing off a cheap ticket for an expensive ride."
Mick Wright, senior in ACES, is listed under "dishonored payments" after an incident Daily Newsletter
that happened his freshman year at the University.
Start each morning with an
easy-to-digest roundup
Wright said he did not experience any difficulties the first time he rode with Suburban of Illinois news, sports
Express, but, as he tried to board the bus on his second trip, he was told that he was no and more.
longer able to use the company.
"As I'm walking away from the bus driver h.e says, 'Wait, you have to get off this bus,
You're banned.' And I'm like, 'Wait, what?'," Wright said.
(https://visifor.r20.constantcontact.com/d.jsp?
In the process of buying the ticket for his first trip, Wright said he noticed he had clicked 11r=6m157cab&p=oi&m=11026302742058sit=rqkiulieb&f=22b
the wrong destination. He was not completely through the checkout process, so he said 5170-4ca0-9677-0a9c16ccaf75)
he went back to change the destination before paying for and printing out the correct
ticket.
Social Media
Wright said he found out his mother's credit card was charged for two tickets,
(https://facebook.com/thedailyillini)
presumably the correct and incorrect tickets. His mother canceled the payment for the
incorrect ticket, and this action is what Wright says caused him to be on the list. (https://twater.com/thedailyillini)
All parties said they received a letter from Suburban Express a few weeks after their
(https://instagram.comithedailyilhni)
experience with the company.
In Wright's case, he said he sent a letter of complaint to the company and received a (https://snapchat.com/addithedailyillini)
reply two months later. (https://youtube.comithedailyillini)
"I was not the most polite in my letter to them, but their letter was ridiculous. They
addressed it calling me a `scumbag,"' he said. "They threatened to push criminal charges
against me. It was really weird."
Thompson said he received a letter that asked him to pay a fine.
"They sent a letter to my house in the suburbs saying that I had broken their rules and
fined me $50. They said if I did not pay them they would sue me in Ford County," he
said.
ease: ,18-cv-02„.„. uocumen
11101110S011 bZ1191.1.11.11G taws.u.sh o Kair ukt;
information o tne weosite ana aia not want to risklegal Invo..vement.

- Prucrbt25/19
e. Page 33 of 49 PagelD #:1176
When a customer agrees to Suburban Express's terms and conditions, they agree "that no
refunds will be given for duplicate or incorrect reservations." They also say that if the
company refuses a customer's future business they will receive no advance notice and the
"driver will simply turn you away at the bus."
Nowhere in Suburban Express's terms and conditions does the customer forfeit their
personal information to be posted on the company's "Page of Shame" if they are found in
violation of the company's conditions.
Two attempts to reach Suburban Express did not result in a comment on the "Page of
Shame."
Faye Jones, University professor of law, said there are several things students can do if
the company posts something "suggesting they are a financial deadbeat or that they
engaged in any kind of bad conduct on the bus."
One option she said is students could sue Toeppen for defamation. She said, in this case,
it "may be in the per se category where actual damages do not have to be proven."
They could also ask police to arrest him for a.violation of Illinois' harassment through
electronic communication act.
Neither Wright nor Thompson ended up pursuing legal action against Suburban Express.
"For some random person to just buy a bus ticket, stumble on the page and see my name
in a bad light, that doesn't feel good," Wright said.
okw2@dailyillini.com
Correction: An earlier version of this article inaccurately stated the number of times the
reporter reached out for comment. It was two attempts, not several, and the attempts did
not result in a comment. The Daily Illini regrets the error.
Leave a Comment
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THE DAILY ILLINI

The independent student newspaper at the University of Illinois
(https://dailyillini.com)
News Sports Opinions Life & Culture Special Sections Photo & Video Multimedia Salary Guide Housing
Suburban Express breaking University Top Stories

policy with some classroom ads
(https://dailyillini.com/featured/?
list)
Teammates double as roommates
ailyillini.com/sports/20 19/04/18/teantrnai
double-as-roommates/) •
College culture augments

environmental impact
lutps://dat lyi II inileom/opinions/20 1 9/04/1 8/collei

culture-augments-environmental-impact!)
thifnc-ffrIair Parkland Pathway provides cheaper
higher education
cneaper-
(https://dailyillirii.com/features/20 19/04/1 8/parkla
pathway-provides-cheaper-higher-education/)
PHOTO COURTESY OF BEN C. .A.P.Nb Team aims for national title •
BY AARON NAVARRO (HTTPS://DAILYILLINI.COM/STAFF/?

WRITER=AARON%2ONAVARRO), ON-AIR NEWS EDITOR (https://dailyillini.com/sports/2019/04/1 8/gymnast
MARCH 27r. .111) 1 7 preview!)
41 Families spend mealtimes distracted,

Filed under Campus Life (https://dailyillini.com/news/campus-life/), News
Study finds
(https://dailyillini.com/news/)
is ac e
(https://dailyillini.corninews/201 9/04/18/fam it les-
spend-mealtimes-distracted-study-finds/)
Transport company Suburban Express has recently been advertising its services around
University classrooms and students are beginning to take notice. A thread was posted in
the UIUC subreddit (https://www.reddit.com/r/UIUC/) asking if these commercial Sponsored
advertisements are allowed in classrooms.
(https://dailyillini.com/sponsoreU
AccOrding to-campus spokeswoman Robin Kaler, these commercial advertisements are •
not.
list)
(https://dailyil Fun things to do in Champaign
Kaler said that advertising businesses is not allowed in classrooms, and that the fliers are
removed by building service workers when they are noticed. She said that the Facilities champaign/#i
& Services department reaches out to companies posting these advertisements and • • (https://dailyillini.comisponsored/201 9/03/19/fun-
• things-to-do-in-champaign/)
informs them that they are in violation of University policy.
College of ACES student Ben Chapman said he has seen three instances of Suburban
DI Social
Express' advertising in lecture halls at Gregory Hall as well as one in David Kinley Hall.
Illinois Football
Chapman said that he's seen them on the lecterns as well as stapled to the tops of
ft Follow
blackboards. He said the staples can still be seen in the cork board from a removed flyer
We want to wish #1111n1 great Scott
inside the second floor Gregory Hall lecture hall. Studwell a happy retirement after 42
years in the @Vikings organization as a
player arid scout...
The general University Property and Facilities policy
(http://studentcode.illinois.edu/article2_part4_2-407.html) deals with the posting and
distribution of handout materials. It prohibits the advertising of information associated
with solicitation for profit, such as coupons, discounts and commercial advertisements.
When it comes to distribution, the policy notes that this should only be done in "common
areas," which does not include the interiors of classrooms, auditoriums or lecture halls.
Distribution of flyers and similar items are allowed inside the common areas of
University educational buildings, provided that they do not disrupt "University business,"
such as classes, labs or meetings.
Registered student organizations have to apply to get their flyers posted in "non-free-
will" spaces in residential halls, where approval is then granted by the Office for
Residential Life.
r F-meeet
According to the Illini Union Office of Registered Organizations, only registered Illinois
organizations can advertise functions or activities on campus. However, it does note that
when the advertisement deals with something that is in great interest to Illinois students,
small commercial notices can be posted if authorized. Daily Newsletter
Its handbook on marketing and advertising for registered student organizations also states$t6rt, 00( itbrm ing:vcrit h all
AOsy -to-digest roundup
(https://publicaffairsillinois.eduJeventplanning/Marketing%20and%20Advertising%20Hai tifill inois :news, sports
that any organization not complying with these policies may lose their posting privileges WIttniriFe,
for a period of time and that the organization may be charged the cost for the removal of
posters in unauthorized locations.
Chapman said that all the ads he has seen in classrooms have been tom down.
(httpslivisitors20.constantcontact.comid.jsp?
"SubEx is seemingly trying very hard to appear to be the 'official' transport system of 11r=6erf57cab&p=oi&m=1102630274205&sit=rqkiujjeb&f=22b
UIUC. They're posting ads free of charge in public places," Chapman said. "Most of 5170-4ca0-9677-0a9c16ccaf75)
them are rather harmless, and simply require a janitor or a student to pull them down, but
as made clear by the stapled ad, SubEx doesn't care about damaging property in order to
Social Media
get their free propaganda space."
(https://facebook.com/thedailyillini)
Kaler believes that the Facilities & Services department already has, or will reach out to
Suburban Express.
(https://twittencom/thedailyillini)
The Suburban Express office was closed when calls were madefor comment and did not
(https://instagram.conythedailyillini)
provide a response.
alnavar2@illinimedia.com (https://snapchat.com/addithedailyillini)
(https://youtube.cornithedailyiIlini)
Correction: A previous version of this article included a non-factual quote incorrectly
identifying a cork board as wood. The quote has since been removed. The Daily Illini
regrets the error.
Leave a Comment
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Exhibit I
4/25/2019 Case: 1:18-cv-02861 Document #: 106-1 FiltketPe*S5419 Page 40 of 49 PagelD #:1183
This website no longer exists.
allertoncharter.com 1/1
Exhibit J
4/25/2019 Case: 1:18-cv-02861 Document #: 106-1 Fil 6416219 Page 42 of 49 PagelD #:1185
Forbidden
You don't have permission to access / on this server.
Additionally, a 403 Forbidden error was encountered while trying to use an ErrorDocument to handle the request.
Apache/2.4.18 (Ubuntu) Server at suburbs.com Port 80
suburbs.com 1/1
Exhibit K
e. =Lk-
x src 410ILOLI/1161,1 LP16111
irmaLift.
'Express
Direct Weekend Bus Service to the Chip:Jo° Arecs
Pick Your
University
Welcome to
i•Old Or char;I
iWoorifivla
Go Suburban Express!
k t t In re
FAST, DIRECT Service to the Suburbs
Suburban Express specializes in

weekend transportation for college
students. Because we focus on a niche
market, we provide the best possible
service for college students travelling Chicago
home for the weekend. 4.e v et
Suburban On April 9, 2019 Suburban Express
Express and Attorney General Kwame Raoul
reached a truce in nearly year old
(217) 344 - 5500
litigation brought by former Attorney '
PO Box 17221 Tmley Pa
Urbana, IL 61803 General Lisa Madigan. Madigan's •
lawsuit contained numerous false,
unproven, and unproveable allegations. Suburban Express felt that it
was being extorted by the state, but chose a $100k payment to state
rather than spending $250k-$500k defeating the lawsuit. Attorney
General Kwame Raoul and Suburban Express agreed to a path out of
the litigation that is a COMPROMISE, meaning that neither side won.
The resultant consent decree makes it clear that there is no finding of
fact, and that none of the allegations made by Lisa Madigan are valid
or truthful. The consent decree does impose some minor
requirements on Suburban Express, and it does recite statutes which
apply to all businesses in Illinois. It does not contain any admission of
wrongdoing, finding of wrongoing, or anything of the sort. Attorney
General Kwame Raoul's press release on the matter is false and
defamatory.in the extreme, in that it claims his office proved the
various false and unproven allegations. Suburban Express is
considering legal action against Kwame Raoul and Assistant Attorney
General Thomas Verticchio at this time.
• QUICK, DIRECT TRIPS, often with no Chicago-area stops other than your stop.
• Virtually all of our customers are college students. No riff-raff!
• Suburban Express runs at all the right times.
• We've been serving U of I since 1983! Other companies come and go.
Images & Text copyright 1983-2010 Subutban Express LTD

Last update: November 15, 2010
UIUC I ISU EIU I Purdue I Iowa I Indiana I
Exhibit L
4/11/2019 ca§dD.uliqgxe,s012€80TYINJOi1 4elitt4tIIMMIerlierttPO4/26/4412 111€061a49)414§getilD*1118gark Champa...
Direct Weekend Bus Service to the Chicago. Area
Pick Your Special Weekend Coach

University
uiuc Service Between U of 1 and
Go Chicago Area!
Home Fast, Routes

RUM Shuttle Speedy, Reliable Service
Order Online
Suburban Express specializes in
Stop Locations weekend transportation for college
Policies students. Because we focus on a small
market niche, we provide the best
Customer Service
possible service for college students
Office Hours travelling home for the weekend.
Just for Fun
On April 9, 2019 Suburban Express
and Attorney General Kwame Raoul
N ) reached a truce in nearly year old
litigation brought by former Attorney
General Lisa Madigan. Madigan's lawsuit contained numerous false,
unproven, and unproveable allegations. Suburban Express felt that it
was being extorted by the state, but chose a $100k payment to state
rather than spending $250k-8500k defeating the lawsuit. Attorney
General Kwame Raoul and Suburban Express agreed to a path out of
the litigation that is a COMPROMISE, meaning that neither side won.
The resultant consent decree makes it clear that there is no finding of

fact, and that none of the allegations made by Lisa Madigan are valid
or truthful. The consent decree does impose some minor
requirements on Suburban Express, and it does recite statutes which
apply to all businesses in Illinois. It does not contain any admission of
wrongdoing, finding of wrongoing, or anything of the sort.
Attorney General Kwame Raoul's press release on the matter is false

and defamatory in the extreme, in that it claims his office proved the
various false and unproven allegations. Suburban Express is
considering legal action against Kwame Raoul and Assistant Attorney
General Thomas Verticchio at this time.
o Tickets can now be returned for standby credit after trip has occurred.
Tickets can also be refunded up until 4 hours before first departure time.
Click the Customer Service tab for details
• Virtually all of our customers are college students. Virtually no "townies".
• We've been serving U of I since 1983! Other companies come and go -- some
with more drama than others.
• Is competitor Peoria Charter Unsafe? Perhaps.'
O Funny video about Yelp Reviews
Statement of Inclusion: All persons are welcome to ride Suburban

Express. We do not discriminate on the basis of any individual's race,
color, sex, gender identity, age, religion, disability, national origin,
ancestry, sexual orientation, marital status, parental status, military
status, or source of income. You are welcome here.
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Exhibit M
4/24/2019 Case: 1:18-cv-02861 Doc§t9pW1t P110614. ifele1114/251I93ftagex4etifF4bikittgelD #:1191
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April 11 at 10:37 AM •
On April 9, 2019 Suburban Express and Attorney General Kwame Raoul Anchor towing
reached a truce in nearly year old litigation brought by former Attorney Emergency Roadside Service
General Lisa Madigan. Madigan's lawsuit contained numerous false,
unproven, unprovable and legally inconsequential allegations. Suburban
Express felt that it was being extorted by the state, but chose a $100k American Walks
payment to state rather than spending $250k-$500k defeating the lawsuit. Tour Agency
Attorney General Kwame Raoul and Suburban Express agreed to a path out
of the litigation that is a COMPROMISE, meaning that neither side won.
City Coffee
The resultant consent decree makes it clear that there is no finding of fact,
Coffee Shop
and that none of the allegations made by Lisa Madigan are valid or truthful.
The consent decree does impose some minor requirements on Suburban
Express, and it does recite statutes which apply to all businesses in Illinois. It
Travel Midwest
does not contain any admission of wrongdoing, finding of wrongoing, or
anything of the sort. Public & Government Service
Attorney General Kwame Raoul's press release on the matter is false and
defamatory in the extreme, in that it claims his office proved the various false Krannert Center for the Performi...
and unproven allegations. Suburban Express is considering legal action Performance Art Theatre
against Kwame Raoul and Assistant Attorney General Thomas Verticchio at
this time.
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April 11 at 10:37 AM
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Case: 1:18-cv-02861 Document #: 106 Filed: 04/25/19 Page 1 of 9 PagelD #:1135

UNITED STATES DISTRICT COURT

PEOPLE OF THE STATE OF ILLINOIS

Plaintiff, Judge Andrea R. Wood

SUBURBAN EXPRESS, INC.; ALLERTON

PLAINTIFF'S SUPPLEMENTAL FILING IN SUPPORT OF ITS MOTION TO

Defendant Dennis Toeppen's ("Toeppen") April 24, 2019 submission to the

than comply, Toeppen continues to seek ways to harass Defendants' customers,

contravening both the letter and spirit of the Consent Decree.

Racist Public Commentary

at 4 (emphasis added). As Toeppen is well aware, the State's complaint focused

largely on Defendants' discriminatory actions against individuals of Asian origin; the

And as Toeppen is also aware, MSG (or monosodium glutamate) is a seasoning'

prevalent in food of Asian origin and a source of racist commentary.

Indeed, Toeppen's own submission to the Court—a Wikipedia page about

MSG—discusses the "popular misconception" that MSG causes a sickness called

targeting Asian cuisine." See Ex. B at 2.

Toeppen's description of the State's complaint as "sprinkled" with MSG was

not, as he contends, an innocent reference to "an enhancer to make [the complaint]

you're in China when you're on our buses." Complaint [Dkt. 1] ¶ 25 (emphasis

requires defendants not to "circulate or distribute communications that Defendants

publication on the Internet by a major news organization—the fact of which made it

Additional Attack Webpages

the Defendants. Puzzlingly, Toeppen includes a copy of his Suburban Express

Chinese engineering student with a fragile ego." See Ex. C at 2 (emphasis

person is unwelcome, objectionable, or unacceptable because of the person's race and

commentary about Suburban Express and Toeppen—a violation of the Consent

based solely on online comments about any Defendant, including reviews."1

2. Toeppen and the corporate defendants reposted a page attacking

to a Yelp review from a customer who requested accommodation for multiple

wheelchairs on a Suburban Express bus. Defendants go on to write that the person

commentary, Toeppen and the corporate defendants post an image represented as

person for her online commentary about the Defendants.

Suburban Express, representing additional efforts to penalize customers, violating

Urbana-Champaign. See Exs. G, H. Defendants write on their "Page of Shame" that

one of these individuals "[i]dentified herself as an employee of an entity whose

of the Suburban Express website—complete with a reference to the person being

Failure to Post Anti-Discrimination Language

Toeppen asserts in his April 24 submission that "[t]he allertoncharter.com

Paragraph 4(a)(iv) requires Defendants to post specific anti-discrimination policy

required anti-discrimination policy language on its main page.

Misrepresentation to the Court

In addition to travel photographs and graphs of water levels, Toeppen includes

"late afternoon on 4/17," Toeppen says, could he "immediately commence[

the matter is false and defamatory in the extreme." Exs. K, L.

on Facebook on April 11. See Ex. M.)

intentional or accidental." Toeppen Sub. at 21 (emphasis added); see also Ex. A at 3.

conduct in no way complies with the spirit of the Consent Decree.

Defendants, including the bans described above.

Date: April 25, 2019 Respectfully submitted,

By: /s/ Jeff VanDam

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Bus Company Faces New Fine

(Courtesy of Suburban Express)

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A screenshot of the Suburban Express "Page of Shame." Names and personal

Suburban Express later apologized for that response and

Read the full response from Suburban Express.

Additionally, the company claimed Raoul's statement on