1 3.

Plaintiff is informed and believes, and thereon alleges, that Defendant Bell is an
2 individual resident in the County of Los Angeles, California.
3 4. Plaintiff is ignorant of the true names and capacities of the Defendants sued herein as
4 Does 1 through 10, inclusive, and therefore sues these Defendants by such fictitious names. Plaintiff
5 will amend this Complaint to allege their true names and capacities when ascertained.
6 5. At all times relevant herein, and at the time of the transactions complained of, each of
7 the Defendants were the agent and employee of each of the remaining Defendants, and in doing the
8 things hereinafter alleged, was acting within the scope of such agency.
9 JURISDICTION
10 6. This Court has jurisdiction over Defendants, and each of them, because each Defendant
11 does business in this State; specifically, each Defendant is either a resident of this State, and/or has its
12 principal place of business in this State, and/or has purposefully availed of the marketplace in
13 California entering into agreements governing activities in this State.
14 VENUE
15 7. Venue is proper in this County because some or all of the Defendants are resident in
16 this County.
17 FACTUAL ALLEGATIONS
18 8. Lin is the founder of Scope Day, which is a social media website focused on
19 technology, art, music, culture and social good. Tech, Art, Music, Culture, and Social Good.
20 9. Lin produces events on Twitter, Inc.’s live video streaming app, Periscope.
21 10. Bell is a self-proclaimed “digital storyteller” and an active user of Periscope.
22 11. On or about February 10, 2016, Bell posted a 12-minute long video stream about Lin on
23 Periscope. The video stream was posted by Bell in an effort to vex and harass Lin, and harm Lin’s
24 reputation.
25 12. In the video stream, Bell made a large number of false statements about Lin, including
26 but not limited to, that Lin: Lin: “is a felon,” “is mentally disturbed,” “extremely racist,” a
27 “psychopath,” a “sociopath”, is “not allowed in America,” “a lot of [sex bots] are him,” “uses
28 “[LinkedIn] information to gain [persons’] mortgage information,” “used [LinkedIn] privileges to get

Complaint – Page 2
1 phone numbers and make threats to women in our community”, “has run away to Taiwan, so that he
2 will not be committed for being a danger to his own family” and is “hiding out in Taiwan, in his
3 parents’ basement.” Said statements are collectively referred to herein as the “Defamatory
4 Statements.”
5 13. Bell also sought to destroy Lin’s business, Scope Day, by encouraging persons to delete
6 or block Lin’s Scope Day account.
7 14. Bell’s defamatory statements had their intended effect, and Lin has suffered harm to his
8 business and reputation, as well as extreme mental distress.
9 FIRST CAUSE OF ACTION
10 SLANDER PER SE
11 15. Plaintiff incorporates and realleges the foregoing allegations of this Complaint as
12 though fully set forth herein.
13 16. In the past year, Defendants caused to be made the oral Defamatory Statements to third
14 persons.
15 17. Defendants’ oral Defamatory Statements were reasonably understood by persons to be
16 about Lin, and were understood to mean that Lin was a criminal mentally ill, violent, dishonest and
17 lacked integrity. The oral Defamatory Statements have a natural tendency to adversely impact Lin’s
18 reputation, goodwill, and business profits.
19 18. The oral Defamatory Statements were false.
20 19. Defendants knew that the oral Defamatory Statements were false, and/or failed to use
21 reasonable care to determine the truth or falsity of the statements.
22 20. Defendants’ oral Defamatory Statements have been a substantial factor in causing harm
23 to Lin’s professional reputation, and have caused Lin to feel ashamed and mortified.
24 21. Defendants made the oral Defamatory Statements with malice for the purpose of
25 harming Lin, and Lin is entitled to recover punitive damages as a result of Defendants’ oppressive,
26 fraudulent, and malicious conduct.
27
SECOND CAUSE OF ACTION
28
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

Complaint – Page 3
1 22. Plaintiff incorporates and realleges the foregoing allegations of this Complaint as
2 though fully set forth herein.
3 23. Defendants’ conduct, including making the Defamatory Statements, and engaging in
4 harassing conduct toward Lin was outrageous.
5 24. Defendants intended for their conduct to cause Lin emotional distress or acted with
6 reckless disregard of the probability that Lin would suffer emotional distress.
7 25. Lin suffered severe mental distress including major depression and anxiety.
8 26. Defendants’ conduct was a substantial factor in causing Lin’s emotional distress.
9 27. Defendants’ conduct was done with the intent to harm Lin, and Lin is entitled to
10 recover punitive damages as a result of Defendants’ oppressive, fraudulent, and malicious conduct.
11 PRAYER
12 WHEREFORE, Lin prays for judgment against Defendants, and each of them, as set
13 forth below:
14 1. For damages according to proof, but in an amount of no less than $1,000,000;
15 2. For punitive and exemplary damages;
16 3. For pre-judgment and post-judgment interest;
17 4. For an order enjoining Defendants from making further defamatory statements
18 regarding Lin;
19 5. For costs of suit; and
20 6. For such other and further relief as the court may deem just and proper.
21 DEMAND FOR TRIAL BY JURY
22 Plaintiff Mike Lin demands a trial by jury on all claims so triable.
23 Dated: November 10, 2016 LAW OFFICES OF SETH W. WIENER
24

25

26
By:______________________________________
Seth W. Wiener
27 Attorneys for Plaintiff
Mike Lin
28

Complaint – Page 4