»Rob Content«

Aga posted this over at the pond, and i'm just posting it here.

So this came from there.

Here we go:

NATURE OF THE ACTION
This is a proposed ?hybrid? action to brought pursuant to F.R.C.P. 23(c)(4).
Specifically, NR Media, Inc. (?NRM?) seeks damages and equitable relief on behalf of itself
and on behalf all persons and entities that operate Affiliate Programs, and that suffered harm
as a result purchasing information processing services from Too Much Media, LLC
(?TMM?) based on NATS, a software program designed for, by and owned by TMM, and/or
John Albright and/or Charles Berrebbi (collectively, the ?TMM Defendants?). In addition,
Plaintiffs seek relief based on the tortious conduct that the TMM Defendants specifically
directed at Plaintiffs and which resulted in the destruction of NRM?s profitable and popular
on-line Internet business and sabotaged NR LCC from its inception.


Defendants,
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TMM?s officers, directors, and employees, Doe Defendants 1 through
30, and any judicial official to whom this matter is assigned.
16. The Class is so numerous that joinder of all members is impracticable. While
the exact number of Class members is unknown to NRM at this time and may only be
ascertained through discovery, NRM believes there are several hundreds of members in the
proposed class.
17. The claims of NRM are typical of the claims of the members of the Class,
because NRM and all Class members sustained damages out of defendants? wrongful
conduct complained of herein.
18. NRM will fairly and adequately protect the interests of the Class. NRM has
no interests antagonistic to those of the Class, and has retained counsel and consultants
experienced in consumer class action litigation and who are further familiar with the
technical aspects of the Affiliate Program business model.
19. A class action is superior to other available methods for the fair and efficient
adjudication of the claims asserted herein, because the expense and burden of litigation, and
the power to deny members of the Class vital information-processing services that would
lead to the collapse of their business, make it virtually impossible for the Class members to
pursue individual redress for the wrongs they have suffered and continue to suffer. The
likelihood of individual members of the Class prosecuting individual, separate claims is
remote.
20. In addition, members of the Class reside in many states throughout the United
States and in foreign countries and are so numerous that it will be impracticable to join them
each individually. However, it will be highly practicable to ascertain their identities and to
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communicate with them because TMM has a list of all members of the Class.

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