According to the
lawsuit, the false and defamatory information includes
but is not limited to the following:
a. Claims that the
search engine giant Google has banned and is banning
from its search engine listings websites of
Traffic-Power.com clients because of the search engine
optimization strategies used by Plaintiff.
b. Claims that
clients of Traffic-Power.com run the risk of being
banned from Google search engine listings if they use
Traffic-Power.com services;
c. Claims that
Traffic-Power.com plagiarizes its web page optimization
work;
d. Claims that
Plaintiff has started several new businesses under
different names to hide its identity;
e. Claims that two
new businesses started by Plaintiff are under
investigation by several agencies;
f. Claims that
and/or innuendo that Plaintiff is engaged in extortion
of its clients because of the techniques used by
Plaintiff in optimizing search engine listings;
g. Claims that
Plaintiff's business constitutes a scam and that clients
of Plaintiff are "victims;"
h. Claims that
Plaintiff stole from defendants;
i. Claims that the
business practices of Plaintiff constituted some kind of
actionable violation of the rights of its clients and
that the filing of a class action lawsuit against
Plaintiff by its clients was imminent; and
j. Claims that
Plaintiff formed and operates fake Internet forums on
search engine optimization to promote its services.