Complaintsboard Is Hurtful To Business

Houston !!! We have a problem



Complaintsboard.com and it’s affiliated sites as listed below represents a present and imminent threat to “US”
we who are THE GENUINE CONSUMER REPORTING and SCAM FIGHTING ORGANIZATIONS. WE HAVE THE BADGE TO PROVE OUR MISSION FOCUS WORK.”

The practices of manufacturing complaints are UNACCEPTABLE AND just plain outright unethically. THESE JERKS SHOULD BE STOP.

ScamFraudAlert.com-Forum and Blog, have observed that some of the complaints posted on complaintsboard.com are manufactured i.e. posted by commercial spammers.
The Operators of Complaintsboard.com also engage in the promotion of unapproved online pharmacy websites – promoting the sale prescription drugs online without a Doctor prescription.

  1. Complaintsboard Engages in Cybersquating
  2. Complaintsboard.com is Merareview.com
  3. Scammers Are On Complaintsboard.com
  4. ScamInformer.com
  5. Scamtracers.com
  6. Scamradar.com
  7. scamchecker.com
  8. bizclaims.com
  9. scamfound.org
  10. spamcaution.com
  11. Spaminform.com
  12. Scamchasers.com
  13. Scamadvocates.com
  14. scamfraudripoff.com
  15. ripoffonline.com
  16. ripofftalk.com
  17. http://www.buzzillions.com
  18. www.topconsumerreviews.com
  19. http://www.iripoff.com
  20. http://complaintcenter.com

As a business owner, it pains me to see all sorts of businesses being slammed on this website called ComplaintsBoard.com . Sure, it has become a really popular avenue for consumers to vent their frustrations on businesses who have done them wrong.

But… the scary part is that vicious competitors are now using this vehicle to slander other legitimate businesses.

I have seen so many fake-sounding complaints about businesses on this website. Where is their sense of decency?

Here’s to you Complaintsboard.com :

How would you like your competitors to slander your site and post fake complaints about you?

And you, Elizabeth Arden, are you getting richer and richer everyday while these businesses are hurting? I hope that you sleep really well tonight?

Complaints Board

W 110th St Ste 400
Overland Park, KS 66210-2407
(240) 764-48637500
http://www.complaintsboard.com


United States Court of Appeals
FOR THE EIGHTH CIRCUIT
___________

No. 09-2601
___________

Susan Johnson; Robert Johnson; *
Cozy Kittens Cattery LLC, *
*
Appellants, *
* Appeal from the United States
v. * District Court for the
* Western District of Missouri.
Elizabeth Arden, dba *
ComplaintsBoard.com; Michelle *
Reitenger; ComplaintsBoard.com, *
InMotion Hosting Inc.; Melanie *
Lowry; Kathleen Heineman, *
*
Appellees. *
___________

Submitted: February 10, 2010
Filed: August 4, 2010
___________

Before RILEY, Chief Judge,1 SMITH and SHEPHERD, Circuit Judges.
___________

SMITH, Circuit Judge.

Susan and Robert Johnson filed a state civil suit making multiple claims against
several defendants as a result of allegedly defamatory statements posted on an internet
discussion board. The defendants removed the case to federal court. The original

1. The Honorable William Jay Riley became Chief Judge of the United States
Court of Appeals for the Eighth Circuit on April 1, 2010.
complaint included six defendants; however, the Johnsons located and served only
InMotion Hosting, Inc. (“InMotion”), Melanie Lowry, and Kathleen Heineman.

The district court2 dismissed the claims against InMotion with prejudice,
finding that the Communications Decency Act (CDA) of 1996, 47 U.S.C. § 230(c)(1)
and (e)(3) protects InMotion. The court dismissed the claims against Lowry and
Heineman without prejudice, finding that Lowry and Heineman had insufficient
contacts with the State of Missouri to be subjected to personal jurisdiction in Missouri.
Finally, the district court set aside a state court default judgment against Lowry under
Federal Rule of Civil Procedure 60(b). On appeal, the Johnsons argue that the district
court erred in dismissing the claims against InMotion, Heineman, and Lowry and
erred in setting aside the default judgment against Lowry. For the reasons stated
below, we disagree and affirm.

I. Background
The Johnsons reside in Unionville, Missouri, where they own and operate the
exotic cat breeding business known as the Cozy Kitten Cattery. The Cozy Kitten
Cattery is a Missouri limited liability company formed in 2007. Its principal office and
place of business is located in Missouri, and the Johnsons are its sole members.
Around December 2004, the Johnsons obtained a registered federal trademark and
service mark for “Cozy Kitten Cattery.” The Johnsons operate their cat breeding
business under that trademark and licensed the use of that trademark and service mark
to Cozy Kitten Cattery, LLC. The Johnsons advertise their business on the internet and
have a website with the web address http://www.CozyKittens.com.

Someone posted several allegedly defamatory statements about the Cozy Kitten
Cattery on the interactive website http://www.ComplaintsBoard.com. In response, the

2. The Honorable Dean Whipple, United States District Judge for the Western
District of Missouri.
Johnsons and Cozy Kittens Cattery filed suit against Elizabeth Arden d/b/a
http://www.ComplaintsBoard.com, Michelle Reitenger, http://www.ComplaintsBoard.com,
InMotion, Lowry, and Heineman in Putnam County, Missouri. Counts I, II and III allege that all six defendants conspired to use http://www.ComplaintsBoard.com to post false statements about the Johnsons, including statements that the Johnsons kill cats, the Johnsons “rip off” cat breeders, the Johnsons steal kittens, the Johnsons’ cats and kittens are infected, and the Johnsons are con artists. The Johnsons assert that they requested all defendants to remove the statements but that the statements were not removed for more than 48 hours.

The Johnsons assert that they suffered lost sales of kittens and cats, lost revenue and lost goodwill and will continue to suffer damages because of the statements posted on the interactive website.

The Johnsons assert that InMotion, Lowry, and Heineman were all served with
the Summons and Petition/Complaint, although all three dispute service. The Johnsons
were unable to locate or serve defendants Elizabeth Arden d/b/a
http://www.ComplaintsBoard.com, Michelle Reitenger or http://www.ComplaintsBoard.com.

Heineman, Lowry, and InMotion moved in district court to dismiss the action
based on lack of personal jurisdiction and insufficient service of process. Heineman and InMotion also asserted improper venue as an additional ground for dismissal.

A. Kathleen Heineman
Heineman is a resident of the State of Colorado and has been since 1981.
Heineman is a cat breeder and also works as an accountant. In both capacities, she works out of her home in Colorado. She maintains no offices in Missouri, owns no property in Missouri and does not pay taxes in Missouri. She also alleges that she does not own any domain name registrations and does not own or operate any website.
However, the website, http://www.BoutiqueKittens.com, and the related cat breeding and selling business are licensed by the State of Colorado to Heineman, and thus for the purpose of this appeal, we will assume that Heineman owns the website in question.
The Johnsons assert that Heineman sells cats and kittens throughout the United States, including the State of Missouri, while advertising on the internet using the web address http://www.BoutiqueKittens.com. The Johnsons allege that Heineman advertises and sells cats and kittens under the name “Cozy Kittens and Cuddly Cats.”

Heineman had a limited business relationship with the Johnsons, which ended
in March 2006. The Johnsons never employed Heineman or paid her a salary. She provided administrative assistance to the Johnsons from her home office in Colorado, including proofreading services and other miscellaneous work on an intermittent basis, such as helping them to acquire cats.

Between 2002 and 2006, the Johnsons contend that Heineman purchased about 16 cats for them from breeders throughout the United States. Heineman did not profit from the purchase of these cats. Some of these cats were shipped to Heineman in Colorado and then eventually shipped to Susan Johnson in Missouri; other cats were picked up from the sellers directly by the Johnsons or their relatives.

In 2002, Heineman twice delivered cats to the Johnsons in Missouri. During the course of their relationship, the Johnsons contend that they shipped seven cats to Heineman and charged her only for their out-of-pocket expenses.

In the course of their relationship, Heineman also purchased advertising space
from the Johnsons on http://www.CozyKittens.com for a fee of $100 per kitten advertised.
The Johnsons’ website then listed Heineman’s email address as the contact email for persons interested in those cats. These advertisements were not targeted to Missouri residents, and Heineman did not place any cats or kittens or do any other business in Missouri. Heineman advertised approximately 50 cats in this manner. Heineman asserts that she has not posted or authorized anyone else to post anything about the Johnsons on ww.ComplaintsBoard.com or on any other website.
B. InMotion Hosting, Inc. – InMotion is a California corporation and maintains its principal place of business there. InMotion, as an internet service provider (ISP), only hosted the http://www.ComplaintsBoard.com website. InMotion does not operate http://www.ComplaintsBoard.com or create any of its content. InMotion does not monitor or control the content of its customer’s websites, including
http://www.ComplaintsBoard.com.

The website http://www.ComplaintsBoard.com is published worldwide on the
internet. The website is interactive, permitting and encouraging individuals to post complaints about businesses and business owners. Individuals seeking to post complaints on the website are required to register with the website and provide identifying information, such as their name and email address.

C. Melanie Lowry
Lowry resides in California and does not own any property in Missouri, does
not have any bank accounts or telephone listings in Missouri, has never paid taxes in Missouri, and has never transacted business in Missouri. Lowry asserts that she has never done business with the Johnsons, does not know them, and has only spoken to Susan Johnson one time on the telephone—a call initiated by Susan Johnson.

The Johnsons assert that Lowry’s postings on http://www.ComplaintsBoard.com
included statements that Susan and Robert Johnson had sold a breeder cat without providing the papers, offered a refund but refused to pay it, stolen money from their customers, and fed their cats Tylenol, causing them to suffer horrible deaths and pre-death injuries.

The record contains one alleged posting by Lowry on http://www.ComplaintsBoard.com. That alleged posting does not mention Missouri, and there is no other evidence in the record indicating that the focal point of this particular posting, or any of Lowry’s other postings, was Missouri.

The Johnsons filed a state court complaint against Lowry, who they assert was
properly served on July 17, 2008. Lowry did not respond or file a pleading. A
Missouri default judgment was filed against Lowry on September 22, 2008. Lowry filed a motion to set aside the judgment on November 12, 2008.

D. Procedural History
The defendants removed the case to federal court based on diversity of
citizenship. Heineman filed a motion to dismiss contending that she was not properly served and that the district court had improper venue and lacked personal jurisdiction under Federal Rule of Civil Procedure 12(b)(2). The district court granted Heineman’s motion for lack of personal jurisdiction. The Johnsons then filed a motion for an order of default against InMotion, which had not yet filed any pleadings in the district court.
The district court denied the motion.

InMotion then filed its motion to dismiss under Rule 12(b), contending that it
was not properly served, the district court did not have venue, the complaint failed to state a claim for relief, it had insufficient contacts with Missouri to be sued there, and Missouri was an inconvenient forum. InMotion did not raise the CDA as a defense.
The district court raised the CDA sua sponte in its order granting InMotion’s motion to dismiss.

Finally, Lowry, pro se, filed a two-page letter/motion moving to dismiss the
complaint against her, claiming that she was not properly served and that the district court lacked personal jurisdiction because she had insufficient contacts with the State of Missouri. In the same motion Lowry moved to set aside the default judgment on liability pending against her.
The district court entered an order dismissing the claims against InMotion with
prejudice and dismissing the claims against Lowry and Heineman without prejudice.
The district court found that Lowry and Heineman had insufficient contacts with the State of Missouri to be subjected to personal jurisdiction there and that the CDA barred claims against InMotion. The district court also set aside the state court default judgment against Lowry under Federal Rule of Civil Procedure 60(b) but made no specific finding in support of that ruling.

II. Discussion

On appeal, the Johnsons argue that the district court erred in

(1) dismissing the
claims against InMotion, after finding that InMotion was immune from suit under the CDA;

(2) dismissing the claims against Heineman for lack of personal jurisdiction;
(3) dismissing the claims against Lowry for lack of personal jurisdiction; and (4) abused its discretion in setting aside the default judgment against Lowry.

A. Communications Decency Act

The Johnsons first argue that the district court erroneously dismissed their
claims after concluding InMotion is immune under the CDA. The Johnsons contend that 47 U.S.C. § 230(c)(1) and (e)(3) merely provide that a provider of internet services shall not be treated as the publisher or speaker of information on the internet provided by another party but does not immunize a provider from suit. The Johnsons assert that Missouri law provides for joint liability where a wrong is done by concert of action and common intent and purpose. According to the Johnsons, the CDA would only bar actions against website operators deemed to be the “publisher or speaker” of defamatory material.

InMotion responds that the district court correctly found that InMotion was
immune from suit under the CDA. Additionally, InMotion asserts that it maintained no control and had no influence over the content that the Johnsons alleged was posted on http://www.ComplaintsBoard.com by unrelated third parties. Because of this, InMotion maintains, it could not have “acted in concert” or “intentionally inflicted emotional distress” in a manner that caused any damage to the Johnsons.

This case presents an issue of first impression for this court, as we have not
previously interpreted § 230(c). “Statutory interpretation is a question of law that we
review de novo.” Minn. Supply Co. v. Raymond Corp., 472 F.3d 524, 537 (8th Cir.
2006). The CDA states that “[n]o provider or user of an interactive computer service
shall be treated as the publisher or speaker of any information provided by another
information content provider,” 47 U.S.C. § 230(c)(1), and expressly preempts any
state law to the contrary, id. § 230(e)(3).3 The CDA defines an “information content
provider” as “any person or entity that is responsible, in whole or in part, for the
creation or development of information provided through the internet or any other
interactive computer service.” Id. at § 230(f)(3).

Read together, these provisions bar plaintiffs from holding ISPs legally
responsible for information that third parties created and developed. See Fair Hous.
Council of San Fernando Valley v. Roommates.com, LLC, 521 F.3d 1157, 1162–64
(9th Cir. 2008) (holding that CDA immunity did not apply to website that was
designed to force subscribers to divulge protected characteristics, but that CDA
immunity did apply to the “Additional Comments” section of the website where the
information was created by third parties and not required by the website ISP).
“Congress thus established a general rule that providers of interactive computer
services are liable only for speech that is properly attributable to them.” Nemet
Chevrolet, Ltd. v. Consumeraffairs.com, Inc., 591 F.3d 250, 254 (4th Cir. 2009).

3
Section 230(e)(3) states:
(3) State law—Nothing in this section shall be construed to prevent any State
from enforcing any State law that is consistent with this section. No cause of
action may be brought and no liability may be imposed under any State or local
law that is inconsistent with this section.

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“The majority of federal circuits have interpreted the CDA to establish broad
‘federal immunity to any cause of action that would make service providers liable for
information originating with a third-party user of the service.'” Almeida v.
Amazon.com, Inc., 456 F.3d 1316, 1321 (11th Cir. 2006) (quoting Zeran v. Am.
Online, Inc., 129 F.3d 327, 330 (4th Cir. 1997)). The district court, following majority
circuit precedent, held that § 230(c)(1) blocks civil liability when web hosts and other
ISPs refrain from filtering or censoring the information that third parties created on
their sites. Green v. Am. Online, 318 F.3d 465, 471 (3d Cir. 2003) (holding that under
the CDA the defendant ISP is not liable for failing to monitor, screen, or delete
allegedly defamatory content from its site).

It is undisputed that InMotion did not originate the material that the Johnsons
deem damaging. InMotion is not a “publisher or speaker” as § 230(c)(1) uses those
terms, therefore, the district court held that InMotion cannot be liable under any
state-law theory to the persons harmed by the allegedly defamatory material. Five
circuit courts agree. See Universal Commc’n Sys., Inc. v. Lycos, Inc., 478 F.3d 413,
419 (1st Cir. 2007) (affirming dismissal of a claim brought by a public-traded
company against an internet message board operator for allegedly false and
defamatory postings by pseudonymous posters); Batzel v. Smith, 333 F.3d 1018
1032–33 (9th Cir. 2003) (holding that even if operator of internet services could have
reasonably concluded that the information was sent for internet publication, he was
immunized from liability for the defamatory speech as a “provider or user of
interactive computer services” under the CDA); Green v. Am. Online, 318 F.3d at 471;
Ben Ezra, Weinstein & Co. v. Am. Online, Inc., 206 F.3d 980, 986 (10th Cir. 2000)
(finding that defendant ISP was immune to the defamation claim under the CDA when
it made its own editorial decisions with respect to third-party information published
on its website); Zeran, 129 F.3d at 332–34 (holding that the CDA barred claims
against defendant ISP that allegedly delayed in removing defamatory messages posted
by unidentified third party, refused to post retractions of those messages, and failed
to screen for similar postings thereafter).

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District courts in this circuit have reached the same conclusion. See, e.g.,
PatentWizard, Inc. v. Kinko’s, Inc., 163 F. Supp. 2d 1069, 1072 (D.S.D. 2001)
(holding that Ҥ 230 of the Communication[s] Decency Act errs on the side of robust
communication and prevents the plaintiffs from moving forward with their claims”
that a company that allowed users to access the internet via its computers could be
held liable for the actions of one of those users).

The Johnsons cite Chicago Lawyers’ Committee for Civil Rights Under Law,
Inc. v. Craigslist, Inc., 519 F.3d 666 (7th Cir. 2008), for support. Craigslist held that
Ҥ 230(c) as a whole cannot be understood as a general prohibition of civil liability for
web-site operators and other online content hosts. . . .” Id. at 669. However, while the
Seventh Circuit construes § 230(c)(1) to permit liability for ISPs, it limited that
liability to ISPs that intentionally designed their systems to facilitate illegal acts, such
as stealing music. Id. at 670 (citing Metro-Goldwyn-Mayer Studios Inc. v. Grokster,
Ltd., 545 U.S. 913 (2005); In re Aimster Copyright Litig., 334 F.3d 643 (7th Cir.
2003)). Specifically, Craigslist held that an ISP could not be held liable for allowing
third parties to place ads in violation of the Fair Housing Act on its website if the ISP
did not induce the third party to place discriminatory ads. Id. at 671–72.

The record contains no evidence that InMotion designed its website to be a
portal for defamatory material or do anything to induce defamatory postings. We
conclude that the CDA provides ISPs like InMotion with federal immunity against
state tort defamation actions that would make service providers liable for information
originating with third-party users of the service such as the other defendants in this
case.

Therefore we decline the Johnsons’ invitation to construe § 230(c)(1) as
permitting liability against InMotion for material originating with a third party. See
Zeran, 129 F.3d at 330 (stating that Ҥ 230 precludes courts from entertaining claims
that would place a computer service provider in a publisher’s role. Thus, lawsuits

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seeking to hold a service provider liable for its exercise of a publisher’s traditional
editorial functions—such as deciding whether to publish, withdraw, postpone or alter
content—are barred”).

Because InMotion was merely an ISP host and not an information content
provider, the Johnsons’ claims against InMotion fail as a matter of law under
§ 230(c)(1), and the district court properly dismissed the claims.

B. Personal Jurisdiction
1. Kathleen Heineman
The Johnsons next argue that the district court erred by dismissing the claims
against Heineman for lack of personal jurisdiction. The Johnsons maintain that
Heineman purposefully directed internet activities at Missouri citizens. The Johnsons
also assert that the record establishes personal jurisdiction under the Missouri long
arm statute.

Heineman responds that the Johnsons cannot challenge the district court’s ruling
because they waived any opposition by not filing a timely objection. In the alternative,
Heineman argues that the district court correctly ruled it lacked personal jurisdiction
over her. According to Heineman, the record does not reflect that she had systematic
or continuous contacts with Missouri or, even if she did, that they were aimed or
purposefully directed at Missouri.

First, as a threshold question, we address whether the Johnsons may challenge
the district court’s decision to grant Heineman’s motion. Heineman contends that the
Johnsons have waived any challenge to the district court’s order dismissing her from
the lawsuit because they failed to file a timely opposition to the motion to dismiss at
the district court.

-11-
Heineman filed a motion to dismiss all counts against her, and the Johnsons did
not file a timely response. Instead, two weeks after their deadline passed, the Johnsons
filed a motion for additional time. The Johnsons then filed a response to Heineman’s
motion before the district court ruled on the Johnsons’ motion for additional time. An
affidavit from Susan Johnson was attached with the response. The district court denied
the Johnsons’ motion for additional time and struck the response from the record. The
district court subsequently granted Heineman’s motion to dismiss, finding that the
Johnsons did not respond in a timely manner, but nevertheless, “out of caution,” the
district court stated that it considered Susan Johnson’s affidavit before ruling on
Heineman’s motion to dismiss.

“It is a well-established rule that issues not raised in the trial court cannot be
considered by this court as a basis for reversal.” Edwards v. Hurtel, 724 F.2d 689, 690
(8th Cir. 1984) (per curiam). “The primary purpose of the rule is promptly to inform
the district judge of possible errors, and thus give the judge an opportunity to
reconsider the ruling and make desired changes.” Id. This rule is followed “in all but
exceptional cases where the obvious result would be a plain miscarriage of justice or
inconsistent with substantial justice.” Kelley v. Crunk, 713 F.2d 426, 427 (8th Cir.
1983) (per curiam).

In Shanklin v. Fitzgerald, a plaintiff filed certain exhibits without properly
authenticating the exhibits. 397 F.3d 596, 601 (8th Cir. 2005). The defendant made
a motion to strike the exhibits, and the plaintiff did not oppose. Id. The district court
granted the motion to strike, and on appeal the plaintiff contended that the district
court erred in striking the motion. Id. We held that “[a]bsent exceptional
circumstances, we cannot consider issues not raised in the district court.” Id.

The Johnsons distinguish Shanklin by pointing out that the district court
considered the affidavit from Susan Johnson in making a ruling on the motion to
dismiss, while the Shanklin court did not review any documents. Also, the Johnsons

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did attempt to oppose the motion to dismiss, although in an untimely fashion. In
Shanklin the plaintiff did not even attempt to file an out-of-time opposition. We find
merit in this argument, because the district court acknowledged that it considered
some opposition to the motion—Susan Johnson’s affidavit—which the Johnsons
clearly submitted for the purpose of opposing the motion to dismiss. Therefore, the
trial court had an opportunity to “reconsider” the issue of whether to dismiss knowing
that the Johnsons opposed dismissal. In fact, in the district court’s order, it specifically
stated that “out of caution, and because the Court must construe the jurisdictional facts
in the light most favorable to the Johnsons, the Court has considered the affidavit of
Sue Johnson . . . . ” Therefore, we hold that the Johnsons sufficiently preserved their
argument for appeal.

Grants of motions to dismiss for lack of personal jurisdiction under Federal
Rule of Civil Procedure 12(b)(2) are reviewed de novo. First Nat’l Bank of Lewisville,
Ark. v. First Nat’l Bank of Clinton, Ky., 258 F.3d 727, 729 (8th Cir. 2001). “If the
District Court does not hold a hearing and instead relies on pleadings and affidavits,
then we must look at the facts in the light most favorable to the nonmoving party and
resolve all factual conflicts in favor of that party.” Epps v. Stewart Info. Serv. Corp.,
327 F.3d 642, 646–47 (8th Cir. 2003).

In Missouri, to obtain personal jurisdiction over a non-resident
defendant, “the plaintiff must make a prima facie showing that (1) the
cause of action arose out of an activity covered by Missouri’s long-arm
statute, . . . and (2) the defendant had sufficient minimum contacts with
Missouri to satisfy the requirements of due process.”

Berry v. Berry (In re Marriage of Berry), 155 S.W.3d 838, 840 (Mo. Ct. App. 2005)
(quoting Wray v. Wray, 73 S.W.3d 646, 649 (Mo. Ct. App. 2002)). “The evidentiary
showing required at the prima facie stage is minimal. . . . ” Willnerd v. First Nat’l
Neb., Inc., 558 F.3d 770, 778 (8th Cir. 2009) (internal quotations and citation
omitted).

-13-
Missouri’s long-arm statute, Mo. Rev. Stat. § 506.500, confers jurisdiction to
the extent allowed by the Due Process Clause.4 State ex rel Deere and Co. v. Pinnell,
454 S.W.2d 889, 892 (Mo. 1970). Under this standard, “[p]ersonal jurisdiction exists
only if the contacts between the defendant and the forum state are sufficient to
establish that the defendant has purposefully availed himself of the benefits and
protections of the forum state.” Johnson v. Woodcock, 444 F.3d 953, 955 (8th Cir.
2006). In Aftanase v. Economy Baler Co., we set forth five factors courts must
consider when determining whether there are sufficient minimum contacts to confer
jurisdiction. 343 F.2d 187, 197 (8th Cir. 1965). These factors include: (1) the nature
and quality of the contacts with the forum state; (2) the quantity of the contacts; (3)
the relationship of the cause of action to the contacts; (4) the interest of Missouri in
providing a forum for its residents; and (5) the convenience or inconvenience to the
parties. Id. The first three factors are primary factors, and the remaining two factors
are secondary factors. Id. The third factor distinguishes whether the jurisdiction is
specific or general. Digi-Tel Holdings, Inc. v. Proteq Telecomm., Ltd., 89 F.3d 519,
523 n.4 (8th Cir. 1996). We must look at all of the factors in the aggregate and
examine the totality of the circumstances in making a personal-jurisdiction
determination. Northrup King Co. v. Compania Productora Semillas Algodoneras,
S.A., 51 F.3d 1383, 1388 (8th Cir. 1995).

4
The statutes states, in relevant part:

1. Any person . . . whether or not a citizen or resident of this state
. . . submits . . . to the jurisdiction of the courts of this state as to any
cause of action arising from the doing of any such acts:

(1) The transaction of any business within this state;
(2) The making of any contract within this state;
(3) The commission of a tortious act within this state. . . .

-14-
The minimum contacts necessary for due process may be the basis for either
“general” or “specific” jurisdiction. Davis v. Baylor Univ., 976 S.W.2d 5, 12 (Mo. Ct.
App. 1998). A court obtains general jurisdiction “against a defendant who has
‘continuous and systematic’ contacts with the forum state, even if the injuries at issue
in the lawsuit did not arise out of the defendant’s activities directed at the forum.”
Dever v. Hentzen Coatings, Inc., 380 F.3d 1070, 1073 (8th Cir. 2004) (quoting
Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 415–16 (1984)).
Specific jurisdiction over a defendant is exercised when a state asserts personal
jurisdiction over a nonresident defendant that “‘has purposefully directed [its]
activities at [Missouri] residents'” in a suit that “‘arises out of’ or ‘relates to’ these
activities.” Lakin v. Prudential Sec., Inc., 348 F.3d 704, 707 (8th Cir. 2003) (quoting
Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472 (1985)).

a. General Jurisdiction
Heineman’s contacts with the State of Missouri—which must be found to be
“continuous and systematic” before general jurisdiction is conferred—may be
summarized as follows: She purchased cats in Missouri for delivery to the Johnsons;
personally delivered cats to the Johnsons in Missouri on two separate occasions;
conducted her cat breeding and sale business with the Johnsons, using the Johnsons’
website—operated from the Johnsons’ location in Unionville, Missouri—for a period
of about four years, which ended two years before this lawsuit was initiated; and
engaged in numerous telephone conversations and email exchanges with the Johnsons
during that four-year period.

Heineman is a citizen and resident of Colorado who sells cats and kittens
throughout the United States, and advertises her business on the website
http://www.BoutiqueKittens.com. The Johnsons and Heineman first made contact when
Heineman purchased a cat from the Johnsons in late 2001 or early 2002. Around April
2002, they began a business relationship that lasted until March 2006. During this
time, Heineman provided the Johnsons administrative assistance with their website,

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http://www.CozyKittens.com. She also purchased advertising space for cats she sold from
Colorado on the Johnsons’ website, advertising approximately 50 cats thereon.
Between 2002 and 2006, Heineman purchased about 16 cats for the Johnsons from
breeders throughout the United States. These cats were generally shipped to Colorado,
then eventually shipped to Missouri. Heineman never worked as an employee of the
Johnsons.

Applying the Aftanase factors, see Lakin, 348 F.3d at 711, we do not find
sufficient contacts between Heineman and Missouri to support general jurisdiction.
Heineman did business almost exclusively from her Colorado home, except for
infrequent trips to Missouri to deliver cats. See Johnson, 444 F.3d at 956–57 (holding
that evidence that nonresident party collaborated with a resident and had a publishing
relationship with another did not establish general jurisdiction); see also Helicopteros,
466 U.S. at 418 (“[W]e hold that mere purchases, even if occurring at regular
intervals, are not enough to warrant a State’s assertion of in personam jurisdiction over
a nonresident [party] in a cause of action not related to those purchase transactions.”).
Heineman’s contact with Missouri was neither continuous nor systematic.

With the Johnsons unable to establish that Heineman had continuous and
systematic contacts with Missouri, we turn to the question of specific jurisdiction.

b. Specific Jurisdiction
Specific jurisdiction is proper “only if the injury giving rise to the lawsuit
occurred within or had some connection to the forum state, meaning that the defendant
purposely directed its activities at the forum state and the claim arose out of or relates
to those activities.” Steinbuch v. Cutler, 518 F.3d 580, 586 (8th Cir. 2008) (citing
Burger King Corp., 471 U.S. at 472).

The Johnsons’ primary support for specific jurisdiction are two sets of actions
that Heineman allegedly undertook—posting defamatory statements on

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http://www.ComplaintsBoard.com and using the trademark “Cozy Kittens” on the website
http://www.BoutiqueKittens.com. The trademark claim will be discussed under a Lanham
Act analysis. See infra. The question for both sets of actions is whether Heineman
“purposefully directed” her internet activities at the State of Missouri.

When considering the sufficiency of internet contacts under a specific
jurisdiction analysis, we have found the Zippo test instructive. Lakin, 348 F.3d at
710–11. In Zippo Mfg. Co. v. Zippo Dot Com, Inc., the court examined the issue of
whether a website could provide sufficient contacts for specific personal jurisdiction.
952 F. Supp. 1119, 1124 (W.D. Pa. 1997). The court created a “sliding scale” to
measure the likelihood of personal jurisdiction. Id. The scale runs from active contract
formation and repeated transmission of computer files to mere posting of information
on a website. Id. The http://www.ComplaintBoards.com site lands on the “mere posting” end
of the scale. Although InMotion represents http://www.ComplaintsBoard.com as an
“interactive” website, users may actually only post information. There is no interaction
between users and a host computer; the site merely makes information available to
other people. The website’s accessibility in Missouri alone is insufficient to confer
personal jurisdiction.

There are other ways the Johnsons can obtain specific jurisdiction, including
employing the Calder effects test. See Calder v. Jones, 465 U.S. 783 (1984). “To
sustain [their] argument, [the Johnsons] would have to show that [Heineman] knew
that ‘the brunt of the injury would be felt by [them] in the State in which [they] live
[ ] and work[ ]’ and intentionally targeted the forum state.” Steinbuch, 518 F.3d at 586
(quoting Calder, 465 U.S. at 789–90).

The “effects” test, therefore, provides that

a defendant’s tortious acts can serve as a source of personal jurisdiction
only where the plaintiff makes a prima facie showing that the defendant’s acts (1) were intentional, (2) were uniquely or expressly aimed at the forum state, and (3) caused harm, the brunt of which was suffered—and which the defendant knew was likely to be suffered—[in the forum state].

Lindgren v. GDT, LLC, 312 F. Supp. 2d 1125, 1132 (S.D. Iowa 2004) (internal quotations and citation omitted). We have stated that this test “allows the assertion of personal jurisdiction over non-resident defendants whose acts are performed for the very purpose of having their consequences felt in the forum state.” Dakota Indus., Inc.
v. Dakota Sportswear, Inc., 946 F.2d 1384, 1390–91 (8th Cir. 1991) (internal quotations and citation omitted). Heineman’s alleged acts were not so performed.

The Johnsons allege that Heineman stated on http://www.ComplaintBoards.com that “Sue Johnson and Cozy Kittens operated from Unionville, Missouri, where they killed cats, sold infected cats and kittens, brutally killed and tortured unwanted cats andoperated a ‘kitten mill’ in Unionville, Missouri.” Although we accept this allegation as true,5 alone, it fails to show that Heineman uniquely or expressly aimed her statements at Missouri. The statements were aimed at the Johnsons; the inclusion of “Missouri” in the posting was incidental and not “performed for the very purpose of having their consequences” felt in Missouri. There is no evidence that the http://www.ComplaintsBoard.com website specifically targets Missouri, or that the content of Heineman’s alleged postings specifically targeted Missouri.

Additionally, even if the effect of Heineman’s alleged statement was felt in Missouri, we have used the Calder test merely as an additional factor to consider when evaluating a defendant’s relevant contacts with the forum state. In Dakota, we

5
There is no copy of any post from Heineman, defamatory or otherwise, in the record, although at this summary judgment stage we construe the evidence in the light most favorable to the Johnsons. Semple v. Federal Exp. Corp., 566 F.3d 788, 791 (8th Cir. 2009).

-18-
declined to grant personal jurisdiction solely on the basis of forum state effects from an intentional tort. Id. at 1391 (“In relying on Calder, we do not abandon the five-part [Aftanase] test . . . . We simply note that Calder requires the consideration of additional factors when an intentional tort is alleged.”). We therefore construe the Calder effects test narrowly, and hold that, absent additional contacts, mere effects inthe forum state are insufficient to confer personal jurisdiction. See Hicklin Eng’g, Inc.
v. Aidco, Inc., 959 F.2d 738, 739 (8th Cir. 1992) (per curiam). As explained, supra, there are no additional contacts between Heineman and Missouri to justify conferringpersonal jurisdiction.

Posting on the internet from Colorado an allegedly defamatory statement including the name “Missouri” in its factual assertion does not create the type of substantial connection between Heineman and Missouri necessary to confer specific personal jurisdiction.

c. Lanham Act Claims
The Johnsons also challenge the district court’s denial of jurisdiction for the
Johnsons’ Lanham Act claim. The Johnsons allege that Heineman violated the Lanham
Act, 15 U.S.C. § 1051 et seq.,6 by using the words “Cozy Kittens and Cuddly Cats”
to advertise her cat breeding business on http://www.BoutiqueKittens.com. As noted,
Heineman denies ownership of this website, but for purposes of our review of adismissed count, we assume that Heineman owns the site in question.

Here, we do not decide the viability of the Johnsons’ Lanham Act claim on the merits, only whether the district court had jurisdiction to decide the claim. The

6 The Lanham Act governs the use of federal trademarks. Davis v. Walt Disney Co., 430 F.3d 901, 903 (8th Cir. 2005) (“The Lanham Act prohibits the use of a mark in connection with goods or services in a manner that is likely to cause confusion as to the source or sponsorship of the goods or services.”)

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Missouri long-arm statute confers jurisdiction to Missouri courts for torts committed within Missouri. See Mo. Rev. Stat. § 506.500.

Infringing upon a trademark, as a tort, may be grounds for personal jurisdiction under Missouri’s long-arm statute. Uncle Sam’s Safari Outfitters, Inc. v. Uncle Sam’s Army Navy Outfitters-Manhattan, Inc., 96 F. Supp. 2d 919, 921 (E.D. Mo. 2000).
However, the same “minimum contacts” analysis applies to determine if the allegedly tortious act was committed within Missouri. Id. Heineman, as discussed, does not have sufficient contacts to grant general personal jurisdiction. The Johnsons argue that
Heineman sells cats and kittens throughout the United States, including in the State of Missouri via advertising on http://www.BoutiqueKittens.com, thus creating specific personal jurisdiction. However, under Zippo, whether specific personal jurisdiction could be conferred on the basis of an interactive website depends not just on the nature of the website but also on evidence that individuals in the forum state accessed the website in doing business with the defendant. Zippo, 952 F. Supp. at 1125–26.
Although http://www.BoutiqueKittens.com may be characterized as interactive, there is no evidence in the record that Heineman engaged in any transaction or exchange of information with a Missouri resident via ww.BoutiqueKittens.com, or that a Missouri resident ever accessed the website. We decline to confer personal jurisdiction based on only the possibility that a Missouri resident had contact with Heineman through http://www.BoutiqueKittens.com.

Similarly, the Johnsons have failed to prove that http://www.BoutiqueKittens.com is uniquely or expressly aimed at Missouri; thus Calder provides no support for their Lanham Act claim. For these reasons, as well as the reasons stated supra, Part II.B.1, we hold that Heineman does not have sufficient minimum contacts with Missouri and affirm the district court’s decision to dismiss the Lanham Act claims against Heineman for lack of personal jurisdiction.

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Because we find there was no personal jurisdiction, we do not reach Heineman’s other issues related to service and venue.

2. Melanie Lowry
a. Personal Jurisdiction
The Johnsons also contend that the district court erred by dismissing their claims against Melanie Lowry for lack of personal jurisdiction because the web activities of Lowry were purposefully directed at the citizens of the State of Missouri.
We address this issue with an analysis similar to the one completed above for Heineman.

The only evidence in the record relating to Lowry is an affidavit she attached to her motion to dismiss. In it, Lowry claimed that she has never been to Missouri, does not own any property in Missouri, does not have any bank accounts or telephone listings in Missouri, has never paid taxes in Missouri nor insured a risk in Missouri, and has never knowingly, regularly or continuously transacted business in the State of Missouri. Her affidavit also states that she has never done business with the Johnsons, does not know them, and has only spoken to Susan Johnson one time on the telephone—a call that Johnson initiated. The evidence supporting systematic and continuous contacts between Lowry and Missouri is thus even weaker than that for Heineman. Again applying the Aftanase factors we hold that the district court did not have general jurisdiction over Lowry.

The court also did not have specific jurisdiction over Lowry. Lowry’s alleged activities related to http://www.ComplaintsBoard.com are similar to Heineman’s, except that Lowry did not include any statement related to or mentioning the State of Missouri.
No statement of any kind by Lowry was purposefully directed at Missouri. We affirm the district court’s decision to dismiss the Johnsons’ claims against Lowry for lack of personal jurisdiction.

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b. Default Judgment
Finally, the Johnsons argue that the district court abused its discretion or erred by vacating the Missouri state court default judgment against Lowry under Federal Rule of Civil Procedure 60(b). The Johnsons specifically challenge the district court’s lack of a showing of good cause.

The district court, “for good cause shown,” “set aside” the default judgment against Lowry as part of its order granting Lowry’s motion to dismiss for lack of personal jurisdiction. Thus, while no findings were made or specific reasons given for setting aside the judgment, it is reasonable to surmise that the district court set aside the default judgment as void because the district court found that Missouri courts
lacked personal jurisdiction over Lowry.

The default judgment was filed on September 22, 2008, and Lowry filed a motion to set aside the judgment on November 12, 2008. Lowry did not reference a rule of civil procedure in her motion, but Lowry is a pro se litigant and therefore we construe her pleadings broadly. See Smith v. Hundley, 190 F.3d 852, 855 n.7 (8th Cir. 1999) (holding that pro se pleadings are afforded a liberal construction). Because Lowry specifically stated that “this is my motion to set aside the default judgment” and in the same motion argued that the court did not have personal jurisdiction, we will view her motion as a Rule 60(b)(4) motion. See Baldwin v. Credit Based Asset Servicing and Securitization, 516 F.3d 734, 737 (8th Cir. 2008) (characterizing a pro se motion that did not specify a particular rule of civil procedure as a Rule 60(b)(4) motion because the motion stated that the court did not have personal jurisdiction).

“The court may set aside an entry of default for good cause, and it may set aside a default judgment under Rule 60(b).” Fed. R. Civ. P. 55(c). Rule 60(b)(4) provides in relevant part that “the court may relieve a party . . . from a final judgment [if] . . . the judgment is void[.]” Fed. R. Civ. P. 60(b)(4). “A judgment is void if the rendering court lacked jurisdiction or acted in a manner inconsistent with due

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process.” Baldwin, 516 F.3d at 737 (internal quotations and citation omitted).
“Although we have sometimes said that relief from a judgment under Rule 60(b) is an extraordinary remedy left to the discretion of the district court, relief from a judgment that is void under Rule 60(b)(4) is not discretionary.” United States v. Three Hundred Fifty-Three Thousand Six Hundred Dollars, in United States Currency, 463 F.3d 812,
813 (8th Cir. 2006). “Thus, while Rule 60(b) dispositions are generally reviewed for an abuse of discretion . . . an order [granting] relief pursuant to Rule 60(b)(4) is reviewed de novo.” Id. (internal citation omitted).

This is not a case where Lowry lost on the merits, failed to appeal, and belatedly attempted to avoid the judgment with a Rule 60(b)(4) motion. Cf. Kocher v. Dow Chem. Co., 132 F.3d 1225, 1229 (8th Cir. 1997) (“A party may not use a Rule 60(b)(4) motion as a substitute for a timely appeal. In other words, if a party fails to
appeal an adverse judgment and then files a Rule 60(b)(4) motion after the time permitted for an ordinary appeal has expired, the motion will not succeed merely because the same argument would have succeeded on appeal.”) (internal citations omitted). Rather, Lowry challenged jurisdiction from the inception of this case. The district court found that Lowry could not be subjected to personal jurisdiction in Missouri. Although we reviewed that decision on the merits in this opinion, see supra, Part II.B.2.a, for purposes of review of the district court’s decision to set aside the default judgment, we do not consider the underlying decision; we are confined to determining only whether the district court erred in granting Lowry’s Rule 60(b)(4) motion. See Three Hundred Fifty-Three Thousand six Hundred Dollars, in UnitedStates Currency, 463 F.3d at 814. Because the district court did not err in granting Lowry’s Rule 60(b)(4) motion when it found personal jurisdiction lacking we affirm
the court’s decision to set aside Lowry’s adverse judgment.

III. Conclusion
Accordingly, we affirm the judgment of the district court.


Accents Of Salado
Posted: 2010-09-28 by terrawest

Quality
Complaint Rating: 100 % with 2 votes
Company information:
Nevada
United States

I had purchased 3 urns for $289.00… It was nothing like the actual picture… The picture looks like the the tops are bronzed like almost fauxed and smooth… Just beautiful was real excited to get them in…What I got was 3 pieces of ceramic that looks as if someone took them in the back alley and spray painted them and forgot to dust them off. I had to put them on top of my kitchen cabinets up far so you could not see all the imperfections and just the poor quality…I was very disappointed… Well one day I had went to the furniture show where they sell wholesale and I actually went into a show room that sells the same exact stuff and found out thats where they order alot of there stuff and all of it was junk… I was amazed this company stays in business. I give them an A plus on the website because everything looks so beautiful but they obviously photo shop those pictures… On top of that the whole sale price was 90 dollars and they sell it for 289.00 that is such a ripoff…

Anyways be careful what you buy because honestly the quality is very poor…


I have read the FAQs and checked for similar issues: YES
My site’s URL (web address) is: http://www.accentsofsalado.com
Description (including timeline of any changes made):

RIP OFF REPORTS and COMPLAINTS BOARD are currently attempting to extort payment from my company to remove negative reviews of my ecommerce business. Complaints Board posted a false complaint on 9-28-2010 about an invented product that I do not sell and used my unique company name along with a state location (Nevada) where my company is not located.

http://www.complaintsboard.com/complaints/accents-of-salado-c377553.html#comment
Google picked up my company name within hours of the posting and ranked this invented complaint #6 out of 4,180 results. Google ranks Rip Off Reports and Complaints Board pages even higher than my Google Blogspot blog. Curiously I received an email this morning 9-29-2010 from a Reactive Online Reputation Management company offering to remove this complaint. The email reads:

Hello,
Good day, hope you are doing well. My name is Janette Adams and I am a Search Engine Reputation Management (SERM) consultant at BrandRevitalize, a leading reputation management company.

I am writing to inform you that your online reputation may be at risk.
While i was doing my daily research concerning your niche, i noticed that your company, together with other companies, has a listing on Ripoffreport.com http://www.ripoffreport.com/specialty-stores/accents-of-salado/accents-of-salado-poor-qualit-699f6.htm

The above negative listing may put your brand equity and customer loyalty you’ve built at risk. Who you are online is as important as who you are offline. Imagine how frustrating it is to build rapport with a potential client, only to lose the deal when they Google your company name—accentsofsalado.com. BrandRevitalize preserves your marketing investments, customer trust and revenues by eliminating potentially fraudulent use of your brand online. Our company makes sure your online reputation is free from false malicious associations and libelous accusations. We make sure CONTROL is delivered back to you, where it belongs.

In line with this, i am hoping we can schedule a time to discuss your Reactive Online Reputation Management and the amount of time needed to eliminate your negative listings in Google’s Search Engine Results Page (SERP). Are you free for a quick discussion today or tomorrow?

Kindly please let me know so we can schedule a call.
You may also visit our processes’ page for more information

http://brandrevitalize.com/our-process.php
Regards,
Janette Adams
BrandRevitalize – Protect. Repair. Reinforce.
8 Maiden Lane, Streetsville,
ONT, Canada L5M 1W8
1-877-878-4108


THIS FRAUDULENT AND LIBELOUS ACTION IS EXTORTION PURE AND SIMPLE.

I have looked at both Rip Off Report and Complaints Board HTML code. There is no reason that the web site HTML Meta Tags and lack of supporting text would propel these two sites to the top 10 Google search results within hours or even at all. My company has received repeated emails and phone calls that have attempted to extort payment for complaint removal services.

MY QUESTIONS:
1. Does Google give ranking preference to these extortionists?
2. Does Google have a special relationship with these complaint web sites?
3. Google has the ability to remove these web sites from their search results. Why has Google not done so?
4. Is there a Google contact email address?

All replies would be greatly appreciated as it is impossible to find Google contact information anywhere on the Google site. It is impossible to report abuse to Google if Google doesn’t provide Google contact information for these serious matters.


Address lookup
canonical name ripoffonline.com.
aliases
addresses 174.120.7.253
Domain Whois record

Queried whois.internic.net with “dom ripoffonline.com”…

Domain Name: RIPOFFONLINE.COM
Registrar: GODADDY.COM, LLC
Whois Server: whois.godaddy.com
Referral URL: http://registrar.godaddy.com
Name Server: NS1629.HOSTGATOR.COM
Name Server: NS1630.HOSTGATOR.COM
Status: clientDeleteProhibited
Status: clientRenewProhibited
Status: clientTransferProhibited
Status: clientUpdateProhibited
Updated Date: 01-jul-2011
Creation Date: 25-aug-2010
Expiration Date: 25-aug-2012

>>> Last update of whois database: Sat, 04 Feb 2012 18:10:48 UTC <<<

Queried whois.godaddy.com with “ripoffonline.com”…

Registrant:
Domains By Proxy, LLC
DomainsByProxy.com
15111 N. Hayden Rd., Ste 160, PMB 353
Scottsdale, Arizona 85260
United States

Registered through: Go Daddy
Domain Name: RIPOFFONLINE.COM
Created on: 25-Aug-10
Expires on: 25-Aug-12
Last Updated on: 01-Jul-11

Administrative Contact:
Private, Registration RIPOFFONLINE.COM@domainsbyproxy.com
Domains By Proxy, LLC
DomainsByProxy.com
15111 N. Hayden Rd., Ste 160, PMB 353
Scottsdale, Arizona 85260
United States
(480) 624-2599 Fax — (480) 624-2598

Technical Contact:
Private, Registration RIPOFFONLINE.COM@domainsbyproxy.com
Domains By Proxy, LLC
DomainsByProxy.com
15111 N. Hayden Rd., Ste 160, PMB 353
Scottsdale, Arizona 85260
United States
(480) 624-2599 Fax — (480) 624-2598

Domain servers in listed order:
NS1629.HOSTGATOR.COM
NS1630.HOSTGATOR.COM

Network Whois record

Queried rwhois.theplanet.com with “174.120.7.253”…

%rwhois V-1.5:003eff:00 whois.theplanet.com (by Network Solutions, Inc. V-1.5.9.5)
network:Class-Name:network
network:ID:NETBLK-THEPLANET-BLK-16
network:Auth-Area:174.120.0.0/14
network:Network-Name:TPIS-BLK-174-120-7-0
network:IP-Network:174.120.7.224/27
network:IP-Network-Block:174.120.7.224 – 174.120.7.255
network:Organization-Name:WebsiteWelcome
network:Organization-City:Boca Raton
network:Organization-State:FL
network:Organization-Zip:33496
network:Organization-Country:USA
network:Description-Usage:customer
network:Server-Pri:ns1.theplanet.com
network:Server-Sec:ns2.theplanet.com
network:Tech-Contact;I:abuse@theplanet.com
network:Admin-Contact;I:abuse@theplanet.com
network:Created:20090410
network:Updated:20090422

%ok

Queried whois.arin.net with “n 174.120.7.253″…

NetRange: 174.120.0.0 – 174.123.255.255
CIDR: 174.120.0.0/14
OriginAS: AS36420, AS30315, AS13749, AS21844
NetName: NETBLK-THEPLANET-BLK-16
NetHandle: NET-174-120-0-0-1
Parent: NET-174-0-0-0-0
NetType: Direct Allocation
RegDate: 2009-03-23
Updated: 2009-03-23
Ref: http://whois.arin.net/rest/net/NET-174-120-0-0-1

OrgName: ThePlanet.com Internet Services, Inc.
OrgId: TPCM
Address: 315 Capitol
Address: Suite 205
City: Houston
StateProv: TX
PostalCode: 77002
Country: US
RegDate: 1999-08-31
Updated: 2010-10-13
Ref: http://whois.arin.net/rest/org/TPCM

ReferralServer: rwhois://rwhois.theplanet.com:4321

OrgTechHandle: TECHN33-ARIN
OrgTechName: Technical Support
OrgTechPhone: +1-214-782-7800
OrgTechEmail: admins@theplanet.com
OrgTechRef: http://whois.arin.net/rest/poc/TECHN33-ARIN

OrgNOCHandle: THEPL-ARIN
OrgNOCName: The Planet NOC
OrgNOCPhone: +1-281-822-4204
OrgNOCEmail: noc@theplanet.com
OrgNOCRef: http://whois.arin.net/rest/poc/THEPL-ARIN

OrgAbuseHandle: ABUSE271-ARIN
OrgAbuseName: The Planet Abuse
OrgAbusePhone: +1-281-714-3560
OrgAbuseEmail: abuse@theplanet.com
OrgAbuseRef: http://whois.arin.net/rest/poc/ABUSE271-ARIN

RAbuseHandle: ABUSE271-ARIN
RAbuseName: The Planet Abuse
RAbusePhone: +1-281-714-3560
RAbuseEmail: abuse@theplanet.com
RAbuseRef: http://whois.arin.net/rest/poc/ABUSE271-ARIN

RNOCHandle: THEPL-ARIN
RNOCName: The Planet NOC
RNOCPhone: +1-281-822-4204
RNOCEmail: noc@theplanet.com
RNOCRef: http://whois.arin.net/rest/poc/THEPL-ARIN

RTechHandle: TECHN33-ARIN
RTechName: Technical Support
RTechPhone: +1-214-782-7800
RTechEmail: admins@theplanet.com
RTechRef: http://whois.arin.net/rest/poc/TECHN33-ARIN

DNS records
name class type data time to live
ripoffonline.com IN TXT v=spf1 ip4:174.120.7.226 a mx include:websitewelcome.com ~all 14400s (04:00:00)
ripoffonline.com IN MX
preference: 0
exchange: ripoffonline.com
14400s (04:00:00)
ripoffonline.com IN SOA
server: ns1629.hostgator.com
email: dnsadmin.gator815.hostgator.com
serial: 2011050802
refresh: 86400
retry: 7200
expire: 3600000
minimum ttl: 86400
86400s (1.00:00:00)
ripoffonline.com IN NS ns1630.hostgator.com 86400s (1.00:00:00)
ripoffonline.com IN NS ns1629.hostgator.com 86400s (1.00:00:00)
ripoffonline.com IN A 174.120.7.253 14400s (04:00:00)
253.7.120.174.in-addr.arpa IN PTR fd.7.78ae.static.theplanet.com 86400s (1.00:00:00)

— end —

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14 thoughts on “Complaintsboard Is Hurtful To Business

  1. Scrub says:

    TO:
    ALL THE FAKE POSTINGS FROM ALL THE FAKE ID CRETEF FOR THE SOLE PURPOSE OF DAMAGING OUR GOOD REPUTATION

    THESE RA ESOME OF THE IDS: PISSEDCUSTONER, MARY M, LENNEY UK, IPURCHASED, AGENT WHATEVER, JIMMY BLACKESTER, JOSE M, AND ALL THE OTHER ID’S THAT ARE BEING CREATED ALMOST EVERY DAY

    These are all aliases created between starting 5 2011 and continuing for the sole purpose of slandering our good name.

    You are publishing lies about our company, making false allegations, pretending like you were ever a customer that lost money to a scan when you know this to be a complete lie and fabrication on your part.

    You do not give your real name nor a proper way to contact you in order to verify any of the things that you are saying. Instead. Instead, you hide behind fake names and make multiple complaints under those bogus IDs to make it look like many people are complaining, when it is just you making false allegations and lying through your teeth. Striking like a thief in the night !

    All these (identical) postings that you made (under false pretenses and using fake IDs) were made with malicious intent and that makes you a liar.

    For Your Information: No customer of ours has ever lost money on our account, and to the best of our knowledge and belief, all of our clients have been happy with the result of our work. There are plenty of testimonials on our website to support this claim, and if you had ever dealt with us, you would know better than to publish lies about our company.

    I do not know who you are, or what your motives are. What I do know is that you are a liar and up to no good. I suggest you do something positive with your life instead of publishing lies about other people.

    You just opened this new alias just like the other ones just to slander us.. Here is your file as I was able to cut and paste it from “Complaintsboard”

    Lonney uk
    Member since Nov 10, 2011
    Saltburn, Cleveland, England
    United Kingdom

    Your postings are lies, and fabrications with no truth in them whatsoever.

    If you are for real, then why do you hide behind so many fake names?

    What is your real name and where are you really from?
    Princeton Partners

    TO ALL READERS OF THIS AND/OR ANY OTHER BOGUS COMPLAINTS ABOUT PRINCETON PARTNERS:

    Some slanderous, malicious, false and libelous statements have been made about Princeton Partners (and some other companies mentioned in a recent posting ) and now we are being asked for money to be paid in order for these postings to be removed.

    Here are some words published March 3, 2009 on the subject of online slander, bogus negative reports, etc, by Matt Cutts (Senior Google Employee):

    Matt Cutts March 3, 2009 at 10:36 am

    “Reliable sources have reported that ROR’s business model is to make up negative reports and then ask the targeted business to pay high fees for “reputation management” services.”

    If this is a common practice and reliable sources have documented it then people should have no difficulty at all in getting a court to agree with that as a statement of fact. I said my piece about ROR at Vegas PubCon, which is that they don’t meet the bar for webspam that we’d remove a site for, so I’d want to see a court agree with you before we took action. I really don’t want Google acting as the truth police, and in general I think many people would agree that’s a slippery slope.

    I will now show you an email Princeton Partners received on November 10 2011 (Just a few days after the recent postings) asking for money:

    From: Eden Williams
    Subject: Remove Complaints Against: KwickDegree.com
    Date: November 10, 2011 3:16:03 AM GMT+09:00
    To: Service@princetonpartners.co.uk

    Hello,

    We noticed your company’s site is listed on http://www.complaintsboard.com

    If you haven’t seen it already, I included a link below.

    http://www.complaintsboard.com/complaints/kwickdegreecom-c516630.html

    You may know who this complaint is from. Unfortunately, whether the complaint is justified or not, a listing on a powerful website like http://www.complaintsboard.com is eventually going to show up on the front page of Google when searching for your company name, or your personal name, and can be devastating to your business. In some industries, up to 70% of potential customers do an internet search on a company before deciding whether or not to purchase. Because most companies have very few positive reviews on external websites, a complaint can unfairly give people a bad impression of your company, and cost you tens of thousands of dollars in sales.

    Our competitors will offer to remove this complaint, but when questioned, what they really mean is that they will try to hide the complaint, or move it down Google’s rankings over a period of months, so that less people see it. The complaint will still exist. We, on the other hand, erase the complaint completely. It is our guarantee, and you don’t pay us until the complaint is gone from http://www.complaintsboard.com and the search engine. This process usually takes 1-2 days. Our organization has been in business for over three years and we have helped hundreds of clients protect their business from complaints. Prices are likely less than you think.

    If you have any questions, you can contact us at 1.877.414.2272, or just reply to this e-mail.

    Thanks!

    Sincerely,

    Eden Williams MBA
    ORM Consultant
    http://www.OnlineProtection.us

    1.877.414.2272

    New York Office
    25 East 21st Street
    B/W Park Avenue South & Broadway
    Suite 6R
    New York, NY 10010

    This whole thing amounts to slander, sabotage, perhaps even extortion of a perfectly good, serious, reliable and reputable company such as Princeton Partners ( and other companies mentioned in the fake slanderous reports) by person, or persons unknown with malicious intent. I am not sure where the email asking for money in order for the postings to be removed comes from, but it strikes me as mildly curious, don’t you think?

    Now if you as a consumer, are looking to get a Really Good Graphic Reproduction or The Best Printing Job that can be made, you will carefully evaluate everything that I have told you in these responses and ignore the poisoned tongues of those who try to hurt is for their own selfish gain.

    Bear in mind that if you believe these lies that are being told about us and decide do not order from us, you will not be getting the best.
    We continue to make the best replicas for our customers and we are the best at what we do.

    Yours Truly

    Princeton Partners
    13th of Nov, 2011 by Princeton Partners 0 Votes
    TO:
    THE AUTHOR OD ALL THE FAKE POSTINGS USING FAKE IDs CRETED FOR THE SOLE PURPOSE OF DAMAGING OUR GOOD REPUTATION
    AND TO WHOM IT MAY CONCERN.

    THESE ARE SOME OF TO ALIEASES (HOLLOW, EMPTY SHELLS) CREATED FOR THE PURPOSE OF THESE MALICIOUS POSTINGS.
    WITH MORE BEING ADDED ALL THE TIME:

    Pissedcustoner
    Member since Nov 5, 2011
    Braswik, Humberside, England
    United Kingdom

    Jose M.
    Member since Nov 6, 2011
    Phoenix, Arizona
    United States

    Ipurchased
    Member since Nov 9, 2011
    Davidstow, Cornwall, England
    United Kingdom

    Micheal 336
    Member since Nov 10, 2011
    Glossop, Derbyshire, England
    United Kingdom

    Agent Beck
    Member since Nov 10, 2011
    Abington, Cambridgeshire, England
    United Kingdom

    Marry M
    Member since Nov 10, 2011
    Dartmouth, Devon, England
    United Kingdom

    Becky M.
    Member since Nov 11, 2011
    Falmouth, Cornwall, England
    United Kingdom

    Abbi Sar
    Member since Nov 11, 2011
    United Arab Emirates

    Rodger Stevens
    Member since Nov 11, 2011
    West Covina, California
    United States

    Violation
    Member since Nov 11, 2011
    Dronfield, Derbyshire, England
    United Kingdom

    Joe Fontane
    Member since Nov 12, 2011
    Caledonia, Illinois
    United States

    ladybug2
    Member since Nov 12, 2011
    San Diego, California
    United States

    Alex BBB
    Member since Nov 12, 2011
    Pelican, Alaska
    United States

    Joe Fontane
    Member since Nov 12, 2011
    Caledonia, Illinois
    United States

    These are all aliases created starting 5 2011 and continuing for the sole purpose of slandering our good name.

    You are publishing lies about our company, making false allegations, pretending like you were ever a customer that lost money to a scan when you know this to be a complete lie and fabrication on your part.

    You do not give your real name nor a proper way to contact you in order to verify any of the things that you are saying. Instead. Instead, you hide behind fake names and make multiple complaints under those bogus IDs to make it look like many people are complaining, when it is just you making false allegations and lying through your teeth. Striking like a thief in the night !

    All these postings that you are making (under false pretenses and using fake IDs) were made with malicious intent and that makes you a liar.

    For Your Information: No customer of ours has ever lost money on our account, and to the best of our knowledge and belief, all of our clients have been happy with the result of our work. There are plenty of testimonials on our website to support this claim, and if you had ever dealt with us, you would know better than to publish lies about our company.

    I do not know who you are, or what your motives are, but we mean to find out.

    Your postings are lies, and fabrications with no truth in them whatsoever, as you already know.

    You would not be hiding behind fake names if you were for real instead of a saboteur of our company.

    What is your real name and where are you really from?
    Apparently you do not know, so I will tell you that “Domains By Proxy” is part of Godaddy.com the internet service provider and they probably have over a million domain names listed under that name.
    Princeton Partners

    TO ALL READERS OF THIS AND/OR ANY OTHER BOGUS COMPLAINTS ABOUT PRINCETON PARTNERS:
    If you haven’t deal with us before and do not already know how efficiently and well we work for all out customers, I am sure you will be a little bit concerned by this sudden onslaught of poisoned pen postings.
    The fact of life is that is often people who are bad at doing good things, are quite good at doing bad things. Please read the following statement and feel free to email us if you have any questions.

    On November 5th 2011 Princeton Partners (and other companies listed above) became victims malicious postings, making false reports from fake IDs posing as past clients, who lost their money through gross misconduct on our part. This is NOT TRUE as all of our real customers already know.
    Now we are being asked for money to be paid in order for these postings to be removed. This all sounds more than a little strange.

    Here are some words published March 3, 2009 on the subject of online slander and extorsion, bogus negative reports, etc, by Matt Cutts (Senior Google Employee):

    Matt Cutts March 3, 2009 at 10:36 am

    “Reliable sources have reported that ROR’s business model is to make up negative reports and then ask the targeted business to pay high fees for “reputation management” services.”

    If this is a common practice and reliable sources have documented it then people should have no difficulty at all in getting a court to agree with that as a statement of fact. I said my piece about ROR at Vegas PubCon, which is that they don’t meet the bar for webspam that we’d remove a site for, so I’d want to see a court agree with you before we took action. I really don’t want Google acting as the truth police, and in general I think many people would agree that’s a slippery slope.

    I will now show you an email Princeton Partners received on November 10 2011 (Just a few days after the recent postings) asking for money:

    From: Eden Williams
    Subject: Remove Complaints Against: KwickDegree.com
    Date: November 10, 2011 3:16:03 AM GMT+09:00
    To: Service@princetonpartners.co.uk

    Hello,

    We noticed your company’s site is listed on http://www.complaintsboard.com

    If you haven’t seen it already, I included a link below.

    http://www.complaintsboard.com/complaints/kwickdegreecom-c516630.html

    You may know who this complaint is from. Unfortunately, whether the complaint is justified or not, a listing on a powerful website like http://www.complaintsboard.com is eventually going to show up on the front page of Google when searching for your company name, or your personal name, and can be devastating to your business. In some industries, up to 70% of potential customers do an internet search on a company before deciding whether or not to purchase. Because most companies have very few positive reviews on external websites, a complaint can unfairly give people a bad impression of your company, and cost you tens of thousands of dollars in sales.

    Our competitors will offer to remove this complaint, but when questioned, what they really mean is that they will try to hide the complaint, or move it down Google’s rankings over a period of months, so that less people see it. The complaint will still exist. We, on the other hand, erase the complaint completely. It is our guarantee, and you don’t pay us until the complaint is gone from http://www.complaintsboard.com and the search engine. This process usually takes 1-2 days. Our organization has been in business for over three years and we have helped hundreds of clients protect their business from complaints. Prices are likely less than you think.

    If you have any questions, you can contact us at 1.877.414.2272, or just reply to this e-mail.

    Thanks!

    Sincerely,

    Eden Williams MBA
    ORM Consultant
    http://www.OnlineProtection.us

    1.877.414.2272

    New York Office
    25 East 21st Street
    B/W Park Avenue South & Broadway
    Suite 6R
    New York, NY 10010

    This whole thing amounts to slander, sabotage, perhaps even extortion of a perfectly good, serious, reliable and reputable company such as Princeton Partners ( and other companies mentioned in the fake slanderous reports) by person, or persons unknown with malicious intent. I am not sure where the email asking for money in order for the postings to be removed comes from, but it strikes me as mildly curious, don’t you think?

    Now if you as a consumer are looking to get a Really Good Graphic Reproduction or The Best Printing Job that can be made, you will carefully evaluate everything that I have told you in these responses and ignore the poisoned tongues of those who try to hurt is for their own selfish gain.

    Bear in mind that if you believe these lies that are being told about us and decide do not order from us, you will not be getting the best.
    We continue to make the best replicas for our customers and we are the best at what we do.

    IF YOU ARE READING THESE POSTINGS AND STILL HAVE QUESTIONS JUST VISIT OUR WEBSITE AND EMAIL OUR COMPANY

    Kind Regards
    Princeton Partners

    Complaintsboard.com

  2. Scrub says:

    This scam concerns http://www.complaintsboard.com and http://www.onlineprotection.us

    A few weeks ago I came across a posting by Sherlock_Holmes on this forum where he expressed his opinion on a number of companies. I responded as a customer having purchased from one of them and been very pleased with the outcome and not having experienced any of the issues raised in his/her remarks. Sometime later I received the following message:

    Hello,

    We noticed your company’s site is listed on http://www.complaintsboard.com

    If you haven’t seen it already, I included a link below.

    http://www.complaintsboard.com/compl…g-c516708.html

    You may know who this complaint is from. Unfortunately, whether the complaint is justified or not, a listing on a powerful website like http://www.complaintsboard.com is eventually going to show up on the front page of Google when searching for your company name, or your personal name, and can be devastating to your business. In some industries, up to 70% of potential customers do an internet search on a company before deciding whether or not to purchase. Because most companies have very few positive reviews on external websites, a complaint can unfairly give people a bad impression of your company, and cost you tens of thousands of dollars in sales.

    Our competitors will offer to remove this complaint, but when questioned, what they really mean is that they will try to hide the complaint, or move it down Google’s rankings over a period of months, so that less people see it. The complaint will still exist. We, on the other hand, erase the complaint completely. It is our guarantee, and you don’t pay us until the complaint is gone from complaintsboard.com and the search engine. This process usually takes 1-2 days. Our organization has been in business for over three years and we have helped hundreds of clients protect their business from complaints. Prices are likely less than you think.

    If you have any questions, you can contact us at 1.877.414.2272, or just reply to this e-mail.

    Thanks!

    Sincerely,

    Eden Williams MBA
    ORM Consultant
    http://www.OnlineProtection.us

    1.877.414.2272

    New York Office
    25 East 21st Street
    B/W Park Avenue South & Broadway
    Suite 6R
    New York, NY 10010

    And this was my response:

    Dear Eden Williams,

    I was surprised to receive this email from you as I have nothing to do with fake-diploma-watchdog.

    I was a customer of budgetdiploma.com and I responded a few months back to a thread, which I enclose:

    http://www.scam.com/showthread.php?t=138479

    I simply stated that I was a happy customer of one of the companies mentioned, which is true. But I believe the individual that made the initial claim somehow believes that because I didn’t agree with his view I must clearly be part of the company and that is an erroneous assumption.

    It does strike me that the individual making these claims must be a competitor of those companies he’s complaining about as a way to boost traffic away from them. And, furthermore, the existence of enterprises like your own add credibility to claims that in the real world would be give rise to a case for libel damages. This is compounded by your seeking remuneration to make the issue go away, something that could easily be construed as extortion.

    In any event, this has nothing to do with me so please remove my email address from your database.

    Regards,

    Billy Ray

    Needless to say they haven’t responded.

    My argument is that there is no credibility to this medium whatsoever. This is an open forum for anonymous cowards, hiding behind multiple fictitious email addresses (gmail being a particular favorite of these chicken sh*t stirrers) with replicated usernames who often spam the medium with untruths and may also be part of a wider scam to profiteer by asking for money to remove the offending postings. If these forums were serious at all they would turn the current system away from the Kangaroo court that it is now into something credible and not offer to remove postings for ANY amount of cash.

    So, I would be interested to find out whether the likes of complaintsboard.com and onlineprotection.us et al actually go round posting libellous statements, or pay others to do so, only to come round later and offer the salvation. This strikes me of racketeering, which is perhaps not surprising given the fact that the company who runs complaintsboard.com is based in Riga, Latvia. As far as onlineprotection.us goes guess what! They are also another gmail contact outfit who, in exchange for money can totally and completely remove such postings.

    If you have been conned, scammed, shortchanged, cheated or whatever, stop using this medium and approach the courts who would have no trouble adjudicating in your favour or go straight to the feds. You can find them here: http://www.ic3.gov/default.aspx

    Until such a time as validated email addresses of the cheated, offended or scammed parties are published on such sites to enable the supposedly defrauded and the fraudsters to communicate directly one can only treat such postings as malicious and libelous.

    Source: Scam.com

  3. Scrub says:

    Address lookup

    canonical name world-online-auctions.com.
    aliases
    addresses 64.13.192.80
    Domain Whois record

    Queried whois.internic.net with “dom world-online-auctions.com”…

    Domain Name: WORLD-ONLINE-AUCTIONS.COM
    Registrar: GODADDY.COM, INC.
    Whois Server: whois.godaddy.com
    Referral URL: http://registrar.godaddy.com
    Name Server: NS1.MEDIATEMPLE.NET
    Name Server: NS2.MEDIATEMPLE.NET
    Status: clientDeleteProhibited
    Status: clientRenewProhibited
    Status: clientTransferProhibited
    Status: clientUpdateProhibited
    Updated Date: 12-jan-2011
    Creation Date: 11-apr-2005
    Expiration Date: 11-apr-2013

    >>> Last update of whois database: Sat, 24 Sep 2011 02:30:05 UTC <<<
    Queried whois.godaddy.com with "world-online-auctions.com"…

    Registrant:
    Oliver Witt
    Brivibas
    Riga LV-1076
    Latvia

    Registered through: GoDaddy.com, Inc. (http://www.godaddy.com)
    Domain Name: WORLD-ONLINE-AUCTIONS.COM
    Created on: 11-Apr-05
    Expires on: 11-Apr-13
    Last Updated on: 12-Jan-11

    Administrative Contact:
    Witt, Oliver auktionportal@gmail.com
    Brivibas
    Riga LV-1076
    Latvia
    +371.27808931 Fax —

    Technical Contact:
    Witt, Oliver auktionportal@gmail.com
    Brivibas
    Riga LV-1076
    Latvia
    +371.27808931 Fax —

    Domain servers in listed order:
    NS1.MEDIATEMPLE.NET
    NS2.MEDIATEMPLE.NET
    Network Whois record

    Queried whois.arin.net with "n ! NET-64-13-192-0-1"…

    NetRange: 64.13.192.0 – 64.13.255.255
    CIDR: 64.13.192.0/18
    OriginAS:
    NetName: MEDIATEMPLE-103
    NetHandle: NET-64-13-192-0-1
    Parent: NET-64-0-0-0-0
    NetType: Direct Allocation
    RegDate: 2006-06-26
    Updated: 2007-01-11
    Ref: http://whois.arin.net/rest/net/NET-64-13-192-0-1

    OrgName: Media Temple, Inc.
    OrgId: MEDIAT-10
    Address: 8520 National Blvd.
    Address: Building B
    City: Culver City
    StateProv: CA
    PostalCode: 90232
    Country: US
    RegDate: 2001-05-15
    Updated: 2010-06-29
    Ref: http://whois.arin.net/rest/org/MEDIAT-10

    OrgTechHandle: NA230-ARIN
    OrgTechName: NOC Hosting Operations
    OrgTechPhone: +1-877-578-4000
    OrgTechEmail: dnsadmin@mediatemple.net
    OrgTechRef: http://whois.arin.net/rest/poc/NA230-ARIN

    OrgAbuseHandle: ABUSE418-ARIN
    OrgAbuseName: Abuse Desk
    OrgAbusePhone: +1-877-578-4000
    OrgAbuseEmail: abuse@mediatemple.net
    OrgAbuseRef: http://whois.arin.net/rest/poc/ABUSE418-ARIN

    RTechHandle: NA230-ARIN
    RTechName: NOC Hosting Operations
    RTechPhone: +1-877-578-4000
    RTechEmail: dnsadmin@mediatemple.net
    RTechRef: http://whois.arin.net/rest/poc/NA230-ARIN
    DNS records

    name class type data time to live
    world-online-auctions.com IN MX
    preference: 10
    exchange: mail.world-online-auctions.com
    43200s (12:00:00)
    world-online-auctions.com IN SOA
    server: ns1.mediatemple.net
    email: dnsadmin.mediatemple.net
    serial: 2007080301
    refresh: 10800
    retry: 3600
    expire: 1209600
    minimum ttl: 43200
    43200s (12:00:00)
    world-online-auctions.com IN NS ns2.mediatemple.net 43200s (12:00:00)
    world-online-auctions.com IN NS ns1.mediatemple.net 43200s (12:00:00)
    world-online-auctions.com IN A 64.13.192.80 43200s (12:00:00)
    80.192.13.64.in-addr.arpa IN PTR acmkokecgk.gs01.gridserver.com 43200s (12:00:00)
    — end —

  4. Scrub says:

    Complaintsboard.com
    Commercial Scam Posters

    8th of Aug, 2011
    by KarissaD

    ComplaintsBoard.com is filled with commercial scammers. These are people that get paid to write negative posts or comments about other people or businesses. They are not real consumers and have no first hand knowledge of the business or person about which they are writing or commenting. They are watering down this site making http://www.ComplaintsBoard.com have no credibility whatsoever.

    I am calling on the moderators of this website to please change this in order to prevent commercial spammers and posters from participating on this board. There are posters here who have been members for just a week or a month and have posted hundreds or even thousands of posts and comments on topics. There is no way possible that they could have had negative interactions with that many people or businesses in such a short time span. In addition, it appears that certain “members/posters” are working in collaboration with each other as the same handful of posters coincidentally comment on the same topics over and over again. This is not good and is destroying the credibility of what once had the potential of being a very helpful site.

    For public information, here are some ids of what appear to be commercial spammers:

    http://www.complaintsboard.com/panel.php?action=profile&id=739647
    http://www.complaintsboard.com/panel.php?action=profile&id=746897
    http://www.complaintsboard.com/panel.php?action=profile&id=605423
    http://www.complaintsboard.com/panel.php?action=profile&id=780607
    http://www.complaintsboard.com/panel.php?action=profile&id=743890
    http://www.complaintsboard.com/panel.php?action=profile&id=754596

    **Brenda**
    ILC3
    DV8
    Ramelle

    Source: Scaminformer.com / Scamtracer.com

  5. Scrub says:

    Address lookup

    canonical name fairfieldcommunities.com.
    aliases
    addresses 69.64.147.243
    Domain Whois record

    Queried whois.internic.net with “dom fairfieldcommunities.com”…

    Domain Name: FAIRFIELDCOMMUNITIES.COM
    Registrar: NETWORK SOLUTIONS, LLC.
    Whois Server: whois.networksolutions.com
    Referral URL: http://www.networksolutions.com
    Name Server: DNS1.NAME-SERVICES.COM
    Name Server: DNS2.NAME-SERVICES.COM
    Name Server: DNS3.NAME-SERVICES.COM
    Name Server: DNS4.NAME-SERVICES.COM
    Name Server: DNS5.NAME-SERVICES.COM
    Status: clientTransferProhibited
    Updated Date: 31-jan-2011
    Creation Date: 05-nov-2010
    Expiration Date: 05-nov-2012

    >>> Last update of whois database: Sat, 27 Aug 2011 18:39:07 UTC <<<
    Queried whois.networksolutions.com with "fairfieldcommunities.com"…

    Registrant:
    Wyndham Vacation Ownership, Inc.
    8427 South Park Circle
    Orlando, FL 32819
    US

    Domain Name: FAIRFIELDCOMMUNITIES.COM

    ————————————————————————
    Promote your business to millions of viewers for only $1 a month
    Learn how you can get an Enhanced Business Listing here for your domain name.
    Learn more at http://www.NetworkSolutions.com/
    ————————————————————————

    Administrative Contact:
    Wyndham Worldwide – Domain Admin domain.admin@wyn.com
    7 Sylvan Way
    Parsippany, NJ 07054
    US
    973-753-7360

    Technical Contact:
    Wyndham Vacation Ownership, Inc. Hostmaster-admin@wyndhamvo.com
    8427 S. Park Circle
    Orlando, FL 32819
    US
    1+407.370.5200

    Record expires on 05-Nov-2012.
    Record created on 31-Jan-2011.
    Database last updated on 27-Aug-2011 14:35:10 EDT.

    Domain servers in listed order:

    DNS1.NAME-SERVICES.COM 63.251.163.102
    DNS2.NAME-SERVICES.COM 216.52.184.230
    DNS3.NAME-SERVICES.COM 63.251.83.36
    DNS4.NAME-SERVICES.COM 64.74.96.242
    DNS5.NAME-SERVICES.COM 212.118.243.118
    Network Whois record

    Queried whois.arin.net with "n ! NET-69-64-144-0-1"…

    NetRange: 69.64.144.0 – 69.64.159.255
    CIDR: 69.64.144.0/20
    OriginAS: AS21740
    NetName: ENOM-BLOCK
    NetHandle: NET-69-64-144-0-1
    Parent: NET-69-0-0-0-0
    NetType: Direct Assignment
    RegDate: 2007-07-25
    Updated: 2010-04-08
    Ref: http://whois.arin.net/rest/net/NET-69-64-144-0-1

    OrgName: eNom, Incorporated
    OrgId: ENOM
    Address: 5808 Lake Washington Blvd. Suite 300
    City: Kirkland
    StateProv: WA
    PostalCode: 98033
    Country: US
    RegDate: 2001-06-15
    Updated: 2011-08-12
    Comment: Domain Related inquiries please contact our helpdesk at 425-274-4500 (http://www.enom.com/help/).
    Ref: http://whois.arin.net/rest/org/ENOM

    OrgTechHandle: RSI80-ARIN
    OrgTechName: Singh, Raj
    OrgTechPhone: +1-425-274-4500
    OrgTechEmail: raj.singh@demandmedia.com
    OrgTechRef: http://whois.arin.net/rest/poc/RSI80-ARIN

    OrgNOCHandle: DEMAN-ARIN
    OrgNOCName: DemandMedia NOC
    OrgNOCPhone: +1-425-274-4500
    OrgNOCEmail: dmnoc@demandmedia.com
    OrgNOCRef: http://whois.arin.net/rest/poc/DEMAN-ARIN

    OrgAbuseHandle: DEMAN-ARIN
    OrgAbuseName: DemandMedia NOC
    OrgAbusePhone: +1-425-274-4500
    OrgAbuseEmail: dmnoc@demandmedia.com
    OrgAbuseRef: http://whois.arin.net/rest/poc/DEMAN-ARIN

    RTechHandle: RSI80-ARIN
    RTechName: Singh, Raj
    RTechPhone: +1-425-274-4500
    RTechEmail: raj.singh@demandmedia.com
    RTechRef: http://whois.arin.net/rest/poc/RSI80-ARIN

    RNOCHandle: DEMAN-ARIN
    RNOCName: DemandMedia NOC
    RNOCPhone: +1-425-274-4500
    RNOCEmail: dmnoc@demandmedia.com
    RNOCRef: http://whois.arin.net/rest/poc/DEMAN-ARIN

    RAbuseHandle: DEMAN-ARIN
    RAbuseName: DemandMedia NOC
    RAbusePhone: +1-425-274-4500
    RAbuseEmail: dmnoc@demandmedia.com
    RAbuseRef: http://whois.arin.net/rest/poc/DEMAN-ARIN
    DNS records

    name class type data time to live
    fairfieldcommunities.com IN A 69.64.147.243 3600s (01:00:00)
    fairfieldcommunities.com IN MX
    preference: 10
    exchange: p.nsm.ctmail.com
    3600s (01:00:00)
    fairfieldcommunities.com IN SOA
    server: dns1.name-services.com
    email: info.name-services.com
    serial: 2002050701
    refresh: 10001
    retry: 1801
    expire: 604801
    minimum ttl: 181
    3600s (01:00:00)
    fairfieldcommunities.com IN NS dns1.name-services.com 3600s (01:00:00)
    fairfieldcommunities.com IN NS dns2.name-services.com 3600s (01:00:00)
    fairfieldcommunities.com IN NS dns3.name-services.com 3600s (01:00:00)
    fairfieldcommunities.com IN NS dns4.name-services.com 3600s (01:00:00)
    fairfieldcommunities.com IN NS dns5.name-services.com 3600s (01:00:00)
    243.147.64.69.in-addr.arpa IN PTR ash.parking.local 900s (00:15:00)
    — end —

  6. Jayson Harvey says:

    It is unlikely that decent people would take the, time to complain against a business unless that business hurt or damaged them in some way. Individuals need to be more vocal against unethical business practices. The courts are expensive, slow and often times slanted in favor of business. The system is at fault here however complaints on the web level the playing field. Keep your customers loyal and you’ll have a thriving business. Violate standard of moral and ethical behavior and get slammed.

    • Scrub says:

      In our opinion:

      Jayson,
      We at SFA whole heartedly agreed with your statement about keeping your customers happy. We also agreed with the costs associated with a legal proceedings. What we value at SFA is transparency and fairness. We are hopeful that http://Complaintsboard.com would become more transparent as to who the owners are so that all players are known and a level playing field is available to everyone.

  7. Josh says:

    Cybersquatting
    Complaintsboard is a Corrupt Bogus Consumer complaint and Scam Fighting Site Whose Operators Are Unknown
    It is a widespread believe amongst scam fighting sites that the Operators of Complaintsboard are partly owners of several Canadian Pharmacy Websites

    Some Consumer Complaints Posted On Complaintsboard

    ARE MANUFACTURE BY COMPLAINTSBOARD OPERATORS
    google
    pub ID -7643816519439245
    ca-pub-3499251668624688
    The operators of complaintsboard.com have engaged in a massive program of STEALING/DUPLICATIING COMPETITOR’S sites. They have created sites that mirrors other scam fighting sites with the sole purpose of
    Stealing Traffic.
    Putting the competitor out of business.
    Discreating the other site work.
    Lawsuits – Ripoff Report.com
    canonical name ripoffreport.cc = This Domain is now own by Xcentric Ventures, llc aka Ripoffreport.com aka ED Magedson.
    aliases Ripoff Report | Scams, reviews, complaints, lawsuits and frauds. File a report, post your review. Consumers educating consumers.

    addresses 72.52.210.60
    Domain Whois record
    Queried whois.nic.cc with “dom ripoffreport.cc”…

    Domain Name: RIPOFFREPORT.CC
    Registrar: WILD WEST DOMAINS, INC.
    Whois Server: whois.wildwestdomains.com
    Referral URL: Wild West Domains

    Name Server: NS1.WEBHOSTING4INDIA.COM
    Name Server: NS2.WEBHOSTING4INDIA.COM
    Status: CLIENT-RENEW-PROHIBITED
    Status: CLIENT-XFER-PROHIBITED
    Status: CLIENT-UPDATE-PROHIBITED
    Status: CLIENT-DELETE-PROHIBITED
    Updated Date: 01-aug-2010
    Creation Date: 18-jun-2009
    Expiration Date: 18-jun-2011

    Last update of whois database: Sat, 8 Jan 2011 08:02:37 EST
    Queried whois.wildwestdomains.com with “ripoffreport.cc”…

    Registrant:
    Domains by Proxy, Inc.
    DomainsByProxy.com
    15111 N. Hayden Rd., Ste 160, PMB 353
    Scottsdale, Arizona 85260
    United States

    Registered through: GoDaddy.com, Inc. (Domain Names, Web Hosting and SSL Certificates – Go Daddy)
    Domain Name: RIPOFFREPORT.CC
    Created on: 18-Jun-09
    Expires on: 18-Jun-11
    Last Updated on: 01-Aug-10

    Administrative Contact:
    Private, Registration RIPOFFREPORT.CC@domainsbyproxy.com
    Domains by Proxy, Inc.
    DomainsByProxy.com
    15111 N. Hayden Rd., Ste 160, PMB 353
    Scottsdale, Arizona 85260
    United States
    (480) 624-2599 Fax — (480) 624-2598

    Technical Contact:
    Private, Registration RIPOFFREPORT.CC@domainsbyproxy.com
    Domains by Proxy, Inc.
    DomainsByProxy.com
    15111 N. Hayden Rd., Ste 160, PMB 353
    Scottsdale, Arizona 85260
    United States
    (480) 624-2599 Fax — (480) 624-2598

    Domain servers in listed order:
    NS1.WEBHOSTING4INDIA.COM
    NS2.WEBHOSTING4INDIA.COM
    Network Whois record

    Queried rwhois.liquidweb.com with “72.52.210.60″…

    whois V-1.5:003eff:00 rwhois.liquidweb.com (by Network Solutions, Inc. V-1.5.7.4)
    network:Class-Name:network
    network:ID:NETBLK-SOURCEDNS.72.52.128.0/17
    network:Auth-Area:72.52.128.0/17
    network:Network-Name:SOURCEDNS-72.52.128.0
    network:IP-Network:72.52.128.0/17
    network:IP-Network-Block:72.52.128.0 – 72.52.171.255
    network:Organization;I:SOURCEDNS
    network:Org-Name:SourceDNS
    network:Street-Address:4210 Creyts Rd.
    network:City:Lansing
    network:State:MI
    network:Postal-Code:48917
    network:Country-Code:US
    network:Tech-Contact;I:admin@sourcedns.com
    network:Created:20040212
    network:Updated:20060327
    network:Updated-By:admin@sourcedns.com
    network:Abuse:abuse@sourcedns.com

    ok
    Queried whois.arin.net with “n 72.52.210.60″…

    NetRange: 72.52.128.0 – 72.52.255.255
    CIDR: 72.52.128.0/17
    OriginAS:
    NetName: LIQUIDWEB-6
    NetHandle: NET-72-52-128-0-1
    Parent: NET-72-0-0-0-0
    NetType: Direct Allocation
    NameServer: NS.LIQUIDWEB.COM
    NameServer: NS1.LIQUIDWEB.COM
    RegDate: 2006-08-03
    Updated: 2007-03-26
    Ref: http://whois.arin.net/rest/net/NET-72-52-128-0-1

    OrgName: Liquid Web, Inc.
    OrgId: LQWB
    Address: 4210 Creyts Rd.
    City: Lansing
    StateProv: MI
    PostalCode: 48917
    Country: US
    RegDate: 2001-07-20
    Updated: 2008-12-19
    Ref: http://whois.arin.net/rest/org/LQWB

    ReferralServer: rwhois://rwhois.liquidweb.com:4321

    OrgAbuseHandle: ABUSE551-ARIN
    OrgAbuseName: Abuse
    OrgAbusePhone: +1-800-580-4985
    OrgAbuseEmail: abuse@liquidweb.com
    OrgAbuseRef: http://whois.arin.net/rest/poc/ABUSE551-ARIN

    OrgTechHandle: IPADM47-ARIN
    OrgTechName: IP Administrator
    OrgTechPhone: +1-800-580-4985
    OrgTechEmail: ipadmin@liquidweb.com
    OrgTechRef: http://whois.arin.net/rest/poc/IPADM47-ARIN
    DNS records

    name class type data time to live
    Ripoff Report | Scams, reviews, complaints, lawsuits and frauds. File a report, post your review. Consumers educating consumers. IN CNAME ripoffreport.cc 14400s (04:00:00)
    ripoffreport.cc IN MX
    preference: 0
    exchange: ripoffreport.cc
    14400s (04:00:00)
    ripoffreport.cc IN SOA
    server: ns1.webhosting4india.com
    email: chirs.roberts.gmail.com
    serial: 2010080400
    refresh: 86400
    retry: 7200
    expire: 3600000
    minimum ttl: 86400
    86400s (1.00:00:00)
    ripoffreport.cc IN NS ns2.webhosting4india.com 86400s (1.00:00:00)
    ripoffreport.cc IN NS ns1.webhosting4india.com 86400s (1.00:00:00)
    ripoffreport.cc IN A 72.52.210.60 14400s (04:00:00)
    60.210.52.72.in-addr.arpa IN PTR host.webhosting4india.com 300s (00:05:00)
    – end –

    5663 Balboa Avenue Suite 477
    San Diego, CA 92111. USA

  8. Scrub says:

    Read what people are saying – comments posted at Consumer Motion

    Complaints Board allows ‘anyone’ to post ‘anything’ to their board but they do not do anything to validate the content of the message posted. I was recently informed that someone had posted derogatory and damaging information about my company that was neither genuine nor accurate. Without validation and investigation, Complaints Board is subjecting themselves to civil action for contributing to defamation and libel.
    ‘THIS’ victim of Complaints Board is considering legal action.

    JOhn Pippin June 17, 2011
    Unfair
    The complaints board website is a joke. They let people post anonymously without even a real name. This obviously makes it so any competitor of any company can post negative comments that appear to be legitimate when they are not. There is no responsibility or even a touch of effort to verify that any claim made here is true or false. This site will begin to be attacked by honest hard working companies that refuse to be slander by nameless, faceless people hiding behind their computers. COMPLAINTSBOARD.COM IS A SCAM! Don’t waste your time with anything said on this site, form your own opinion by asking someone with some credibility and actual knowledge of a company you are thinking of using. Unfair practices like this only cause honest companies to spend more money defending unfounded lies. DON’T USE COMPLAINTS BOARD. You might as well as a 4 year old, you’ll get better informed information.

  9. Scrub says:

    69.64.87.242 is in Overland Park Kansas United States
    Map data ©2011 Google – Terms of Use
    50 mi100 km
    We have 1 complaints about 69.64.87.242 Is 69.64.87.242 misbehaving (engaging in SPAM, brute-force, DOS attack, phishing, or other fraud? Report the abuser now!

    ComplaintsBoard.com is owned by Dzianis Beltyukov, in Riga, Latvia. Beltyukov is Russian, and beyond the reach of U.S. Courts. He is a criminal. Numerous legitimate merchants have tried to get the FBI to close the site due to egregious death threats and false legal information posted on the site. The site is hosted on a private dedicated server leased in Overland Park, Kansas City, IP address 69-64-87-242.dedicated.abac.net. We have multiple violations in process for legal processing. Please disengage from hosting this account to offset legal problems.

    [Querying whois.arin.net]
    [whois.arin.net]

    # Query terms are ambiguous. The query is assumed to be:
    # “n 69.64.87.242”
    # Use “?” to get help.

    The following results may also be obtained via:
    http://whois.arin.net/rest/nets;q=69…showARIN=false

    NetRange: 69.64.64.0 – 69.64.95.255
    CIDR: 69.64.64.0/19
    OriginAS: AS10316
    NetName: CODERO2006A
    NetHandle: NET-69-64-64-0-1
    Parent: NET-69-0-0-0-0
    NetType: Direct Allocation
    RegDate: 2006-08-04
    Updated: 2009-07-31
    Ref: http://whois.arin.net/rest/net/NET-69-64-64-0-1

    OrgName: Codero
    OrgId: APHIN
    Address: 7500 W 110th St., Suite 400
    City: Overland Park
    StateProv: KS
    PostalCode: 66210
    Country: US
    RegDate: 2009-07-21
    Updated: 2009-07-21
    Ref: http://whois.arin.net/rest/org/APHIN

    OrgTechHandle: ADA108-ARIN
    OrgTechName: APH DNS Administrator
    OrgTechPhone: +1-877-275-8763
    OrgTechEmail: dns@codero.com
    OrgTechRef: http://whois.arin.net/rest/poc/ADA108-ARIN

    OrgAbuseHandle: APHAB-ARIN
    OrgAbuseName: APH Abuse
    OrgAbusePhone: +1-877-275-8763
    OrgAbuseEmail: abuse@codero.com
    OrgAbuseRef: http://whois.arin.net/rest/poc/APHAB-ARIN

    #
    # ARIN WHOIS data and services are subject to the Terms of Use
    # available at: https://www.arin.net/whois_tou.html

    Complaints Board Criminal Wanted: 69.64.87.242 Overland Park Kansas United States IP Tracer and IP Tracker and other DNS Tools.

    http://www.ipillion.com/ip/69.64.87.242

  10. Scrub says:

    Address lookup

    canonical name http://www.zprotect.net.
    aliases
    addresses 69.64.87.242
    Domain Whois record

    Queried whois.internic.net with “dom zprotect.net”…

    Domain Name: ZPROTECT.NET
    Registrar: NAME.COM LLC
    Whois Server: whois.name.com
    Referral URL: http://www.name.com
    Name Server: NS1.NAME.COM
    Name Server: NS2.NAME.COM
    Name Server: NS3.NAME.COM
    Name Server: NS4.NAME.COM
    Status: clientTransferProhibited
    Updated Date: 20-dec-2010
    Creation Date: 28-feb-2008
    Expiration Date: 28-feb-2012

    >>> Last update of whois database: Sat, 09 Jul 2011 00:58:43 UTC <<<
    Queried whois.name.com with "zprotect.net"…

    Visit AboutUs.org for more information about zprotect.net
    AboutUs: zprotect.net

    Domain Name: zprotect.net
    Registrar: Name.com LLC

    Expiration Date: 2012-02-28 18:55:02
    Creation Date: 2008-02-28 11:54:53

    Name Servers:
    NS1.NAME.COM
    NS2.NAME.COM
    NS3.NAME.COM
    NS4.NAME.COM

    REGISTRANT CONTACT INFO
    bnet
    Denis Beltyukov
    ICC, Route de Pré-Bois 20
    Geneva
    none
    1215
    SZ
    Phone: +371.28314947
    Email Address: adele.zprotect@gmail.com

    ADMINISTRATIVE CONTACT INFO
    bnet
    Denis Beltyukov
    ICC, Route de Pré-Bois 20
    Geneva
    none
    1215
    SZ
    Phone: +371.28314947
    Email Address: adele.zprotect@gmail.com

    TECHNICAL CONTACT INFO
    bnet
    Denis Beltyukov
    ICC, Route de Pré-Bois 20
    Geneva
    none
    1215
    SZ
    Phone: +371.28314947
    Email Address: adele.zprotect@gmail.com

    BILLING CONTACT INFO
    bnet
    Denis Beltyukov
    ICC, Route de Pré-Bois 20
    Geneva
    none
    1215
    SZ
    Phone: +371.28314947
    Email Address: adele.zprotect@gmail.com

    Timestamp: 1310173149.0255

    The Data in the Name.com LLC WHOIS database is provided by Name.com LLC for information purposes, and to assist persons in obtaining information about or related to a domain name registration record. Name.com LLC does not guarantee its accuracy. By submitting a WHOIS query, you agree that you will use this Data only for lawful purposes and that, under no circumstances will you use this Data to: (1) allow, enable, or otherwise support the transmission of mass unsolicited, commercial advertising or solicitations via e-mail (spam); or (2) enable high volume, automated, electronic processes that apply to Name.com LLC (or its systems). Name.com LLC reserves the right to modify these terms at any time. By submitting this query, you agree to abide by this policy.

    Cached on: 2011-07-08T18:59:09-06:00
    Network Whois record

    Queried whois.arin.net with “n ! NET-69-64-64-0-1″…

    NetRange: 69.64.64.0 – 69.64.95.255
    CIDR: 69.64.64.0/19
    OriginAS: AS10316
    NetName: CODERO2006A
    NetHandle: NET-69-64-64-0-1
    Parent: NET-69-0-0-0-0
    NetType: Direct Allocation
    RegDate: 2006-08-04
    Updated: 2009-07-31
    Ref: http://whois.arin.net/rest/net/NET-69-64-64-0-1

    OrgName: Codero
    OrgId: APHIN
    Address: 7500 W 110th St., Suite 400
    City: Overland Park
    StateProv: KS
    PostalCode: 66210
    Country: US
    RegDate: 2009-07-21
    Updated: 2011-06-08
    Ref: http://whois.arin.net/rest/org/APHIN

    OrgAbuseHandle: APHAB-ARIN
    OrgAbuseName: APH Abuse
    OrgAbusePhone: +1-877-275-8763
    OrgAbuseEmail: abuse@codero.com
    OrgAbuseRef: http://whois.arin.net/rest/poc/APHAB-ARIN

    OrgTechHandle: ADA108-ARIN
    OrgTechName: APH DNS Administrator
    OrgTechPhone: +1-877-275-8763
    OrgTechEmail: dns@codero.com
    OrgTechRef: http://whois.arin.net/rest/poc/ADA108-ARIN
    DNS records

    name class type data time to live
    http://www.zprotect.net IN A 69.64.87.242 300s (00:05:00)
    zprotect.net IN A 69.64.87.242 300s (00:05:00)
    zprotect.net IN NS ns2.name.com 300s (00:05:00)
    zprotect.net IN SOA
    server: ns1.name.com
    email: support.name.com
    serial: 1
    refresh: 10800
    retry: 3600
    expire: 604800
    minimum ttl: 3600
    300s (00:05:00)
    zprotect.net IN NS ns4.name.com 300s (00:05:00)
    zprotect.net IN NS ns3.name.com 300s (00:05:00)
    zprotect.net IN NS ns1.name.com 300s (00:05:00)
    242.87.64.69.in-addr.arpa IN PTR 69-64-87-242.dedicated.abac.net 43200s (12:00:00)
    — end —

  11. Just a good man says:

    MY QUESTIONS:

    – 1. Does Google give ranking preference to these extortionists?
    No, those sites just expoit google’s ranking policy, creating hundreds of pages on a simple complaint – i.e sorted by popularity, categories, etc. All those pages vote for the complaint’s page letting it stay on the top of the google search result. There are more tacticts like switching the major voting page from time to time, therefore google search engine recognizes it as a new post and gives it a better rank, etc.

    – 2. Does Google have a special relationship with these complaint web sites?

    It is possible, but not confirmed. However Google provides to those racketeers email addresses, free phone numbers with google voice, alows them to use AdSense and AdWords. Ironically in Google AdWords analytics they are named as Google’s PARTNERS (extraction from the source – front page of complaintsboard/com):
    script type=”text/javascript” src=”http://[b]partner.googleadservices.com[/b]/gampad/google_service.js”
    /script
    script type=”text/javascript”
    GS_googleAddAdSenseService(“ca-pub-7643816519439245”);

    Therefore somehow they ARE Google’s PARTNERS.

    – 3. Google has the ability to remove these web sites from their search results. Why has Google not done so?

    There is no legal base to do so. It US Congress allows such crap, why Google will remove it?

    http://www.rexxfield.com/abuseofintenetfreespeech.php

    Neither complaintsboard, ripoffreport nor Google care about moral side, all they want is money.

    – 4. Is there a Google contact email address?
    No reason to send anything to them, you will get no response anyway. However you can mail your post to their Legal Department, the head of which is

    David C. Drummond
    Legal Department
    1600 Amphitheatre Parkway
    Mountain View, CA 94043
    (650) 253-0000

    You can also try:

    Google Legal Investigations Support
    1600 Amphitheater Parkway
    Mountain View, CA 94043
    USA
    Phone Number: 650-253-3425
    Fax Number: 650-649-2939
    E-mail: legal-support@google.com
    Custodian of Records Fax: 650-249-3429

    Posted by: Just a good man

  12. Just a good man says:

    MY QUESTIONS:

    – 1. Does Google give ranking preference to these extortionists?
    No, those sites just expoit google’s ranking policy, creating hundreds of pages on a simple complaint – i.e sorted by popularity, categories, etc. All those pages vote for the complaint’s page letting it stay on the top of the google search result. There are more tacticts like switching the major voting page from time to time, therefore google search engine recognizes it as a new post and gives it a better rank, etc.

    – 2. Does Google have a special relationship with these complaint web sites?

    It is possible, but not confirmed. However Google provides to those racketeers email addresses, free phone numbers with google voice, alows them to use AdSense and AdWords. Ironically in Google AdWords analitics their named as Google’s PARTNERS (extraction from the source – frotn page of complaintsboard/com):

    GS_googleAddAdSenseService(“ca-pub-7643816519439245”);

    Therefore somehow they ARE Google’s PARTNERS.

    – 3. Google has the ability to remove these web sites from their search results. Why has Google not done so?

    There is no legal base to do so. It US Congress allows such crap, why Google will remove it?
    http://www.rexxfield.com/abuseofintenetfreespeech.php

    Neither complaintsboard, ripoffreport nor Google care about moral side, all they want is money.

    – 4. Is there a Google contact email address?
    No reason to send anything to them, you will get no response anyway. However you can mail your post to their Legal Department, the head of which is

    David C. Drummond
    Legal Department
    1600 Amphitheatre Parkway
    Mountain View, CA 94043
    (650) 253-0000

    You can also try:

    Google Legal Investigations Support
    1600 Amphitheater Parkway
    Mountain View, CA 94043
    USA
    Phone Number: 650-253-3425
    Fax Number: 650-649-2939
    E-mail: legal-support@google.com
    Custodian of Records Fax: 650-249-3429

  13. Scrub says:

    Address lookup
    canonical name complaints-india.com.
    aliases
    addresses 69.72.135.61
    Domain Whois record

    Queried whois.internic.net with “dom complaints-india.com”…

    Domain Name: COMPLAINTS-INDIA.COM
    Registrar: ENOM, INC.
    Whois Server: whois.enom.com
    Referral URL: http://www.enom.com
    Name Server: NS1.EXCLVEN.ARVIXEVPS.COM
    Name Server: NS2.EXCLVEN.ARVIXEVPS.COM
    Status: clientTransferProhibited
    Updated Date: 02-jan-2011
    Creation Date: 11-jan-2010
    Expiration Date: 11-jan-2012

    >>> Last update of whois database: Sun, 30 Jan 2011 19:03:45 UTC <<<

    Queried whois.enom.com with "complaints-india.com"…

    Visit AboutUs.org for more information about complaints-india.com
    AboutUs: complaints-india.com

    Registration Service Provided By: Arvixe, LLC
    Contact: domains@arvixe.com
    Visit: http://www.arvixe.com

    Domain name: complaints-india.com

    Registrant Contact:
    By Arvixe
    Private Registration ()

    Fax:
    PO BOX 14738
    San Luis Obispo, CA 93406
    US

    Administrative Contact:
    By Arvixe
    Private Registration (domains@arvixe.com)
    +1.8882784939
    Fax:
    PO BOX 14738
    San Luis Obispo, CA 93406
    US

    Technical Contact:
    By Arvixe
    Private Registration (domains@arvixe.com)
    +1.8882784939
    Fax:
    PO BOX 14738
    San Luis Obispo, CA 93406
    US

    Status: Locked

    Name Servers:
    ns1.exclven.arvixevps.com
    ns2.exclven.arvixevps.com

    Creation date: 11 Jan 2010 16:01:00
    Expiration date: 11 Jan 2012 16:01:00

    Get Noticed on the Internet! Increase visibility for this domain name by listing it at http://www.whoisbusinesslistings.com

    Network Whois record

    Queried rwhois.fortressitx.com with “69.72.135.61”…

    NetRange: 69.72.135.0-69.72.135.64
    CIDR: 69.72.135.0/26
    NetName: FORTR-5-ORG-2266
    Parent: 69.72.128.0/17
    NameServer: NS1.PWEBTECH.COM
    NameServer: NS2.PWEBTECH.COM

    OrgName: FortressITX
    OrgID: FORTR-5
    Address: 100 Delawanna Ave
    City: Clifton
    StateProv: NJ
    PostalCode: 07014
    Country: US
    RegDate: 2006-05-12
    Updated: 2009-09-27
    Ref: http://whois.arin.net/rest/org/FORTR-5

    OrgAbuseHandle: FIAD-ARIN
    OrgAbuseName: Fortress ITX Abuse
    OrgAbusePhone: +1-973-572-1070
    OrgAbuseEmail: abuse@fortressitx.com
    OrgAbuseRef: http://whois.arin.net/rest/poc/FIAD-ARIN

    OrgTechHandle: FIH2-ARIN
    OrgTechName: Fortress ITX Hostmaster
    OrgTechPhone: +1-973-572-1070
    OrgTechEmail: hostmaster@fortressitx.com
    OrgTechRef: http://whois.arin.net/rest/poc/FIH2-ARIN

    # # # # # # # # # # # # # # # # # # # # # # # # #
    # FIMS 2.0 WHOIS SERVER #
    # Managed Core i7 920 / 12GB DDR3 / 1000GB HD #
    # 6000GB Bandwidth / Cpanel – ONLY $275 #
    # DEDICATEDNOW.COM – MANAGED DYNAMIC HOSTING #
    # HELPDESK – https://SUPPORT.DEDICATEDNOW.COM/ #
    # # # # # # # # # # # # # # # # # # # # # # # # #

    Queried whois.arin.net with “n 69.72.135.61″…

    NetRange: 69.72.128.0 – 69.72.255.255
    CIDR: 69.72.128.0/17
    OriginAS:
    NetName: FORTRESSITX
    NetHandle: NET-69-72-128-0-1
    Parent: NET-69-0-0-0-0
    NetType: Direct Allocation
    NameServer: NS2.PWEBTECH.COM
    NameServer: NS1.PWEBTECH.COM
    RegDate: 2003-09-03
    Updated: 2006-05-17
    Ref: http://whois.arin.net/rest/net/NET-69-72-128-0-1

    OrgName: FortressITX
    OrgId: FORTR-5
    Address: 100 Delawanna Ave
    City: Clifton
    StateProv: NJ
    PostalCode: 07014
    Country: US
    RegDate: 2006-05-12
    Updated: 2010-12-08
    Ref: http://whois.arin.net/rest/org/FORTR-5

    ReferralServer: rwhois://rwhois.fortressitx.com:4443

    OrgAbuseHandle: FIAD-ARIN
    OrgAbuseName: Fortress ITX Abuse Dept
    OrgAbusePhone: +1-973-572-1070
    OrgAbuseEmail: abuse@fortressitx.com
    OrgAbuseRef: http://whois.arin.net/rest/poc/FIAD-ARIN

    OrgTechHandle: FIH2-ARIN
    OrgTechName: Fortress ITX Hostmaster
    OrgTechPhone: +1-973-572-1070
    OrgTechEmail: hostmaster@fortressitx.com
    OrgTechRef: http://whois.arin.net/rest/poc/FIH2-ARIN

    DNS records

    DNS query for 61.135.72.69.in-addr.arpa returned an error from the server: NameError
    name class type data time to live
    http://www.complaints-india.com IN CNAME complaints-india.com 14400s (04:00:00)
    complaints-india.com IN MX
    preference: 0
    exchange: complaints-india.com
    14400s (04:00:00)
    complaints-india.com IN SOA
    server: ns1.exclven.arvixevps.com
    email: exclhyd.sify.com
    serial: 2010112203
    refresh: 86400
    retry: 7200
    expire: 3600000
    minimum ttl: 86400
    86400s (1.00:00:00)
    complaints-india.com IN NS ns2.exclven.arvixevps.com 86400s (1.00:00:00)
    complaints-india.com IN NS ns1.exclven.arvixevps.com 86400s (1.00:00:00)
    complaints-india.com IN A 69.72.135.61 14400s (04:00:00)
    Traceroute

    Tracing route to http://www.complaints-india.com [69.72.135.61]…
    hop rtt rtt rtt ip address fully qualified domain name
    1 51 1 1 70.84.211.97 61.d3.5446.static.theplanet.com
    2 1 1 1 70.87.254.5 po101.dsr02.dllstx5.networklayer.com
    3 1 1 1 70.85.127.109 po52.dsr02.dllstx3.networklayer.com
    4 0 1 0 70.87.255.41 e4-4.ibr04.dllstx3.networklayer.com
    5 1 0 1 4.59.32.29 xe-8-1-0.edge4.dallas3.level3.net
    6 14 1 1 4.69.145.180 ae-83-80.ebr3.dallas1.level3.net
    7 21 21 22 4.69.151.178 ae-41-41.ebr3.atlanta2.level3.net
    8 * * 21 4.69.148.254 ae-73-73.csw2.atlanta2.level3.net
    9 21 21 31 4.69.148.245 ae-71-71.ebr1.atlanta2.level3.net
    10 34 35 35 4.69.148.106 ae-6-6.ebr1.washington12.level3.net
    11 33 34 34 4.69.143.214 ae-1-100.ebr2.washington12.level3.net
    12 34 34 34 4.69.143.221 ae-5-5.ebr2.washington1.level3.net
    13 48 39 50 4.69.132.102 ae-4-4.ebr2.newark1.level3.net
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    16 39 38 39 208.116.63.253
    17 39 39 39 69.72.135.61

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