1. This action arises out of the vindictive and mendacious conduct of defendant Benjamin Wey (the self-described "Saint of Wall Street, Journalist, Financier") and the defendant companies he controls, which, because Defendant Wey disagreed with a decision rendered by the Financial Industry Regulatory Authority, Inc. ("FINRA"), have been waging a retaliatory internet defamation campaign against FINRA, the FINRA panelists who issued the decision, and members of the advisory cowlcil that upheld FINRA's decision on appeal. 

Plaintiff Christopher Brummer, a Professor of Law at Georgetown University Law Center, served on that advisory council.

2. One of many weapons in defendants' arsenal of defamatory internet publications is "TheBlot Magazine" ("TheBlot"),¹ a digital magazine published by Defendant Wey that purportedly "brings traditional journalism to the modern day" but that Defendant Wey, in fact, utilizes to maliciously defame, harass, and intimidate private individuals under the guise of legitimate investigative journalism. Here, Defendant Wey has used TheBlot to sling knowingly false information in various articles about Professor Brummer specifically intended to blot Professor Brummer's character, destroy his reputation, harass and intimidate him, and incite others to harass him (e.g., by publishing his telephone number and email address). Defendant Wey has also spewed falsehoods about Professor Brummer that seep into each category of the cause of action for defamation per se except for the "loathsome disease" category (e.g., "Chris Brummer, charged with regulatory abuses, FINRA's 'Uncle Tom,'" "Chris Brummer, caught in multiple fraud," "Georgetown Law School Chris Brummer caught lying, exaggerated biography," and "In December 2014, Brummer was caught messing with another man's wife"). In an effort to inflict maximum damage on his victims, Defendant Wey has even gone to such outrageous lengths as to perform internet search engine optimization to increase the exposure of his defamatory articles and to create phony names for reporters and post sham comments about their articles to intensify the illusion of legitimate journalism and thereby lend an air of credibility to his knowing and malicious libel. 

3. Professor Brummer accordingly seeks, among other things, compensatory and punitive damages and an order enjoining defendants from continuing their deliberate and relentless campaign of defamation, harassment, and intimidation, and from further tarring Professor Brummer's reputation.

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¹ Blot (blot) n. An association of disgrace with one's character or reputation. See The American Heritage Dictionary of the English Language, Houghton Mifflin Harcourt Publishing Company (Slh ed. 20 14).  

Defendant Wey's Retaliation for a FINRA Decision that Punished His Associates For Acts of Fraud 

24. In August 20 13, after a fully-litigated proceeding, a FINRA hearing panel found that two of Defendant Wey's business associates (William Scholander and Talman Harris) had violated Section 1 O(b) of the Securities Exchange Act of 1934, SEC Rule 10b-5, and FINRA Rules 2020 and 2010. This decision (the "Hearing Panel Decision") prohibited the patties from associating with any FINRA finn in any capacity. This Hearing Panel Decision was appealed to the NAC and ultimately affirmed on December 29,2014. Professor Brummer served on the NAC panel that issued this decision (the "NAC Decision"). 

25. The Hearing Panel Decision that was issued in August 2013 referred to Defendant Wey's involvement in the activities of Scholander and Harris. On August 29, 2013, Defendant Wey's legal counsel wrote a letter to FINRA demanding that Defendant Wey's name be removed from the Hearing Panel Decision. FINRA accommodated that request. 

26. On or about September 24,2013, Defendant Wey emailed one of the FINRA hearing panelists, falsely accusing the panelist of participating in a racist, baseless, and vindictive decision. Defendant Wey wrote, "Read this media story, it is disgusting" and provided a link to an article he had written for TheBlot under a fake name falsely maligning FINRA. Defendant Wey threatened to "start talking to the New York times (sic) and other media organizations" and to tell those organizations that the FINRA panelist was racist and had called Defendant Wey a "Chinese negro," which Defendant Wey well knew to be false. 

27. In furtherance of their retaliation against the Hearing Panel Decision, defendants, via TheBlot, began publishing vicious, defamatory, and false stories about FINRA and individuals associated with FINRA, such as: 

• "FINRA REGULATORS JEFFREY P. BLOOM, LUCINDA O. MCCONATHY IMPLICATED IN RONEN ZAKAI FELONY"² 
• "OP-ED: SEX, LIES AND IMPOTENT FINRA REGULATOR JEFFREY BLOOM MISSED NEW BERNIE MADOFF"³ 
• "MYLES EDWARDS, DISGRACED CONSTELLATION WEALTH ADVISOR LAWYER IMPLICATED IN RONEN ZAKAI FELONY CONVICTION."⁴ 
• "CAPTURED: FACEBOOK CRIMINAL RONEN ZAKAI, THE NEW BERNIE MADOFF FRAUD." ⁵
• "AEGIS CAP IT AL FIGHTS BACK AT FINRA BLACKMAIL, RACISM" ⁶

These articles falsely and maliciously accused various FINRA employees and associates with making false statements, being implicated in various frauds, and making racist and bigoted comments. 

28. On or about January 9, 2014, Defendant Wey created a fake email in an effort to impersonate Michael Dixon, a FINRA enforcement attorney, and make it appear as if Mr. Dixon were sending one of the articles above to another FINRA enforcement attorney, Jeffrey Bloom, with the question, "Is this true?" 

29. On or about February 11,2014, February 27, 2014, and March 8, 2014, Defendant Wey created further fake emails to Jeffrey Bloom that he falsely attributed to Maureen Gearty, a witness whose testimony was cited in the Hearing Panel Decision. In these emails, Defendant Wey made it appear as if Ms. Gearty were writing such things as: (i) "I have lied many times. Sorry that you were duped also. Maureen"; (ii) "Jeffrey, I have run out of money. Could you pay me again? Sorry that I have lied many times to you and duped FINRA. Maureen"; and (iii) "Jeffrey, you have screwed me so bad. Then you left me alone in the cold. You are an evil person." 

30. By fabricating these emails, Defendant Wey manufactured evidence that a witness had lied during her testimony about Scholander and Harris and that FINRA's employees had engaged in wrongdoing by paying for this false testimony. Defendant Wey fabricated this evidence for the purpose of obstructing FINRA's adjudicatory process and any appeal of FINRA's decision-making to the SEC. Upon information and belief, Defendant Wey has manufactured other kinds of false evidence in order to undermine these and other proceedings. 

31. Defendant Wey's associates, Scholander and Harris, appealed the NAC decision to the SEC in January 2015. FINRA submitted a brief concerning the circumstances of the 10 disciplinary action to the SEC. On February 27, 20 15, Defendant Wey called Michael Garawski, Associate General Counsel at FINRA, and left a threatening voicemail, transcribed here: "Hey, Michael, hi, this is Benjamin Wey from New York. I'm calling regarding a publicly-available document, searchable on the SEC website regarding FINRA v. Talman Harris. My name is mentioned as a stock promoter. What is the basis for that mentioning? I'm an investigative reporter. I'm investigating you, and your patties involved. Remove my name or you will face litigation. Okay? Call me back. Be a man, not a coward. 212-566-0499. This is 2:37 pm, Friday, February 27th " 

32. This voicemail is but one more example of defendants' using the power of TheBlot to spread falsehoods about FINRA and its employees and affiliates in retaliation for the enforcement actions against Scholander and Harris and as unlawful leverage to attempt to get FINRA to abandon and/or rescind the sanctions against them.

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² http://www.theblot.com/finra-regulators-jeffrey-p-bloom-lucinda-o-mcconathy-implicated-ronen-zakai-felony-777110 

³ http://www.theblot.com/op-ed-sex-lies-impotent-finra-regulator-jeffrey-bloom-missed-new-bemie-madoff-774216 

⁴ http://www.theblot.com/myles-edwards-disgraced-constellation-wealth-advisor-lawyer-implicated-ronen-zakai-felony-conviction-777695

⁵  http://www.theblot.com/captured-facebook-criminal-ronen-zakai-new-bemie-madoff-fraud-771524 

⁶ http://www.theblot.com/aegis-capital-fights-back-at-fima-blackmail-7728404 

• http://www.theblot.com/finra-regulators-jeffrey-p-bloom-lucinda-o-mcconathy-implicated-ronen-zakai-felony-777110
  
  
• http://www.theblot.com/op-ed-sex-lies-impotent-finra-regulator-jeffrey-bloom-missed-new-bernie-madoff-774216
  
  
• http://www.theblot.com/myles-edwards-disgraced-constellation-wealth-advisor-lawyer-implicated-ronen-zakai-felony-conviction-777695
  
  
• http://www.theblot.com/captured-facebook-criminal-ronen-zakai-new-bemie-madoff-fraud-771524
   
• http://www.theblot.com/aegis-capital-fights-back-at-finra-blackmail-7728404