IN THE SUPERIOR COURT
OF THE STATE OF RIDGEWAY
DAVIDLCLARKE;
NOTSFEELINGS,
Plaintiff,
v.
THE MILTON DAILY, a Ridgeway
corporation;
SUPRAMQRK5, a representative,
Defendants.
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Case No. RSC-CV-2696
Complaint in a Civil Action
Hon. Judge koala4life
COMES NOW Plaintiffs DavidLClarke and notsfeelings, seeking all available relief
against the above-mentioned defendants, by and through the undersigned attorneys, hereby files
this civil action and alleges, for their complaint against the defendants, as follows:
PARTIES
I. Plaintiffs
1. Clarke, Feelings & Associates is a limited liability partnership organized and existing
under the laws of the State of Ridgeway, with its principal office located at Suite 6020,
652 Palmer Boulevard, Palmer, RW 19457.
2. Plaintiff DavidLClarke is a resident of the State of Ridgeway. He is a partner of the firm
Clarke, Feelings & Associates jointly with Plaintiff notsfeelings.
3. Plaintiff Notsfeelings is a resident of the State of Ridgeway. He is a partner of the firm
Clarke, Feelings & Associates jointly with Plaintiff DavidLClarke.
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II. Defendants
4. Defendant The Milton Daily is a corporation organized and existing under the laws of the
State of Ridgeway.
5. Defendant supramqrk5 is a resident of the State of Ridgeway. He is the Chairman and
President of The Milton Daily, and an author for news articles thereof.
JURISDICTION AND VENUE
6. Plaintiff invokes the jurisdiction of the Superior Court contained in Article V, Section IV
of the state Constitution, giving jurisdiction for “all civil or criminal cases.”
7. Venue is proper as the actions involved herein occurred over Discord which is an external
communications platform subject to the laws of the State of Ridgeway.
FACTUAL ALLEGATIONS
I. Background of Clarke, Feelings & Associates
8. Clarke, Feelings & Associates (hereinafter the “Firm”, or “CFA”, “CF&A”, “CA”,
“C&A) is a law firm registered, licensed, and authorized to provide legal services by the
Ridgeway State Bar.
9. When a prospective client opens a ticket for consultation, the prospective client must
agree to the Terms of Engagement, which is a contractual agreement which requires both
the firm and prospective client to fulfill various obligations, such as the firm “assess[ing]
[the] case free-of-charge and decid[ing] whether or not [it] can and will represent [the
client] in [their] matter.” Terms of Engagement, at § I.
II. Terms of Engagement
10. Upon opening a ticket for consultation, Defendant Supramqrk5 signed a contractual
agreement with the firm, with which required the Defendant to fulfill various obligations,
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including, in pertinent part, “[t]hat the services provided are for [the client] and may not
be disclosed to any other party or referred to in public, except as a partner of the firm
may authorize or as may be authorized by law.” Terms of Engagement, at § III(d).
11. The firm emphasizes to prospective clients that they expressly consent to the terms of
engagement when they open a ticket for consultation. The firm displays a notification in
bold lettering stating, “BY OPENING A TICKET, YOU AGREE TO OUR TERMS
OF ENGAGEMENT,” accompanied with a hyperlink on the phrase “TERMS OF
ENGAGEMENT,” directing prospective clients to the terms.1
12. The firm utilizes an automated bot named “Tickets”, which allows prospective clients to
open a ticket—a private channel—for legal assistance.
13. Further emphasizing the agreement and consent to the terms of engagement, when
creating a ticket, prospective clients are prompted with “Do you agree to our Terms of
Engagement?” Additionally, the prompt also states to “not open a ticket if you do not
agree” before a response to the question is entered.
III. Background of The Milton Daily
14. The Milton Daily is a news network licensed in the State of Ridgeway operated by
supramqrk5.
15. The Milton Daily has a press pass from the Ridgeway Department of State since March
10th, 2024.
16. The Milton Daily releases news to about forty subscribers using a channel called “#news”
which is available to anybody in The Milton Daily’s Discord communications server.
1 Tickets#6981, "BY OPENING A TICKET, YOU AGREE TO OUR TERMS OF ENGAGEMENT," March
24, 2024, https://discord.com/channels/1178885785567633518/1179160406170816563/1221655156819755109
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Using their press pass, they can publish news to the greater Ridgeway population through
the “#newsfeed” channel in the State of Ridgeway Discord server.
IV. News Article
17. On or about the date of April 21, 2024, Defendant supramrqk5 published a news article
beginning with the headline “LAW FIRM CLARKE L & ASSOCIATES IS LGBTQIA+
PHOBIC!”
18. The contents of this article is that the firm (and employees thereof) are homophobic on
the basis that service was refused to Defendant supramrqk5 who requested document
proof-reading services from the firm.
19. The document that the defendant requested to be reviewed was written in multi-color
text, with multi-color highlighting, making the entire document unreadable without
extreme eye strain and mental effort.
20. On that same day, following the publishing of the news article, The Milton Daily
(operated by supramrqk5) republished this article to its Discord server.
21. On the same day, supramrqk5 brought attention to the news article published by The
Milton Daily in the State of Ridgeway Discord server. The Ridgeway Discord server
amasses over 12,000 participants
COUNT 1
1 R. Stat. § 3107 - Breach of Contract
Against supramqrk5
22. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
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23. Defendant supramqrk5 agreed to the Terms of Engagement published by Clarke, Feelings
& Associates as a condition of receiving legal advice in the consultation ticket created by
him.
24. The Terms of Engagement create a legally binding agreement where there is an offer of
legal services in consideration of payment to be made when those services are complete.
25. Defendant supramqrk5 had the legal capacity to enter into a legally binding contract at
the time that he agreed to the Terms of Engagement.
26. Defendant, having accepted an offer and agreeing to pay consideration accordingly, and
then breaching a term of that offer, has breached his contract with Plaintiffs and is liable
for compensatory and punitive damages.
COUNT 2
Common Law - Defamation
Against supramqrk5 for DavidLClarke
27. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
28. Common law jurisdiction is invoked and the Restatement (2d) of Torts is consulted for
the elements of defamation, which include:
a. a false and defamatory statement concerning another;
b. an unprivileged publication to a third party;
c. fault amounting to, at least, negligence on the part of the publisher; and
d. special harm caused by the publication.
29. Defendant supramqrk5 made a false and defamatory statement concerning DavidLClarke
as an owner of Clarke, Feelings & Associates, alleging that he is homophobic.
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30. DavidLClarke is not homophobic.
31. Defendant supramqrk5 published this false statement to his newspaper, The Milton Daily
in a news article titled “LAW FIRM CLARKE L & ASSOCIATES IS LGBTQIA+
PHOBIC!”
32. Defendant supramqrk5 spread this news article and a short excerpt in the
“#general-chatroom” channel of the State of Ridgeway Discord server.
33. Defendant supramqrk5 intentionally falsely represented the actions taken by plaintiffs,
amounting to actual malice (surpassing the negligence requirement).
34. Plaintiff DavidLClarke suffered reputation harm as a result of the publication.
COUNT 3
Common Law - Defamation
Against supramqrk5 for notsfeelings
35. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
36. Common law jurisdiction is invoked and the Restatement (2d) of Torts is consulted for
the elements of defamation, which include:
a. a false and defamatory statement concerning another;
b. an unprivileged publication to a third party;
c. fault amounting to, at least, negligence on the part of the publisher; and
d. special harm caused by the publication.
37. Defendant supramqrk5 made a false and defamatory statement concerning notsfeelings as
an owner of Clarke, Feelings & Associates, alleging that he is homophobic.
38. notsfeelings is not homophobic.
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39. Defendant supramqrk5 published this false statement to his newspaper, The Milton Daily
in a news article titled “LAW FIRM CLARKE L & ASSOCIATES IS LGBTQIA+
PHOBIC!”
40. Defendant supramqrk5 spread this news article and a short excerpt in the
“#general-chatroom” channel of the State of Ridgeway Discord server.
41. Defendant supramqrk5 intentionally falsely represented the actions taken by plaintiffs,
amounting to actual malice (surpassing the negligence requirement).
42. Plaintiff notsfeelings suffered reputation harm as a result of the publication.
COUNT 4
Common Law - Defamation
Against The Milton Daily for DavidLClarke
43. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
44. The Milton Daily, in republishing and spreading the news article to its Discord server, is
liable as a republisher of that information in the same way that the original publisher is.
Restatement (2d) of Torts § 578.
COUNT 5
Common Law - Defamation
Against The Milton Daily for notsfeelings
45. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
46. The Milton Daily, in republishing and spreading the news article to its Discord server, is
liable as a republisher of that information in the same way that the original publisher is.
Restatement (2d) of Torts § 578.
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PRAYER FOR RELIEF
WHEREFORE, Plaintiff requests the court to grant relief to redress the injury as follows:
a. Declaratory relief declaring that Defendants defamed the Plaintiff.
b. Declaratory relief declaring the Defendant supramqrk5 is in breach of his contractual
agreements with the plaintiffs.
c. Injunctive relief enjoining the further publishing of defamatory statements about
Plaintiffs by Defendant.
d. Compensatory damages that the court finds just and proper for the damage done to the
reputations of Plaintiffs.
e. Punitive damages that the court finds just and proper for each count.
f. Granting Plaintiffs such other further relief as the court finds just and proper.
DATED: April 21, 2024 Respectfully submitted,
______________________________
Derogatoryyy
R. Bar No. 19119
D: racoontimes
Counsel of Record
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APPENDIX A
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APPENDIX B
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APPENDIX C
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APPENDIX D
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APPENDIX E
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