Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 1 of 24
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`JULIEN SWANSON (SBN 193957)
`AUSTIN LAW GROUP
`584 Castro Street #2126
`San Francisco, California 94114
`Tel: (415) 282.4511
`Fax: (415) 282.4536
`swanson@austinlawgroup.com
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`Attorneys for Plaintiff TIR CONSULTING LLC
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`Case No. 3:22-cv-09010
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`PLAINTIFF’S COMPLAINT FOR
`DAMAGES AND INJUNCTIVE RELIEF and
`DEMAND FOR JURY TRIAL
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`TIR CONSULTING LLC, A California
`limited liability company;
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`Plaintiff,
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`v.
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`CLOUDFLARE, INC., a Delaware
`corporation; NAMESILO, LLC, an Arizona
`Limited Liability Company; and DOES 1-
`100
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` Defendants.
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`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
`Page 1
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 2 of 24
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`INTRODUCTION
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`1.
`This action stems from the knowing, unauthorized and ongoing infringement of
`Plaintiff's intellectual property by these named Defendants, and their unknown customers, named
`here as Doe defendants as a result.
`2.
`Plaintiff, TIR Consulting LLC ("TIR"), is a California-based adult entertainment
`company that has produced and owns a substantial library of original works, all of which are
`branded with its registered "Mistress Harley" family of trademarks ("Original Works").
`3.
`Since 2015, TIR's Original Works have been available for purchase around the
`world on its website at www.mistressharley.com, as well as through authorized third parties
`pursuant to license agreements for which it is paid and accounted.
`4.
`One of the most significant business threats faced by TIR is the widespread and
`unabated infringement of its Original Works on the web.
`5.
`Counterfeit and pirate websites like https.mistress-harley.com, and a myriad of
`others like it, have an effective assortment of tools at their disposal to accomplish their pirating
`and counterfeiting without detection and for great profit for everyone involved except the lawful
`owner of the content.
`6.
`One such tool is to redirect traffic from authentic sites, like TIR's
`www.mistressharley.com, without permission, to third party servers like CloudFlare, who will
`house the information for their client, and protect the privacy of the infringer (who has paid for
`both the housing services and the guarantee that CloudFlare will do nothing to interfere with
`their anonymity and their cyber-theft).
`7.
`From there, the pirates and counterfeiters are free to make the stolen works
`available for purchase, again without permission or accounting, on domain sites that are hosted
`by companies that sell and host domains, while guaranteeing the anonymity of the domain
`owner, like the Defendant NameSilo.
`8.
`This is precisely how TIR's intellectual property remains available for unauthorized
`purchase on pirate sites around the web.
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`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
`Page 2
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 3 of 24
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`9.
`If the owner of the pirate site https.mistress-harley.com was known or
`discoverable, the owners would be sent a cease and desist and the site would be susceptible to
`shut down and /or brought to Court to account for the piracy, like it is supposed to work.
`10. However, with the help of companies like these Defendants, who blatantly
`advertise that part of the service they sell is to shield and redact the true identity of the website’s
`owners and hosts (like NameSilo and CloudFlare), who provide an anonymous shelter for the
`diverted, stolen traffic and illegal websites, making these pirate and counterfeit sites impossible
`to police or shut down.
`11.
`Plaintiff is far from alone – other content owners who spend the time and money to
`secure registrations and seek to police their intellectual property, have raised similar complaints
`against these Defendants. After providing proof of infringement, these third party providers still
`refuse to disclose which persons or companies directly own, control or host the pirate sites – thus
`they are making a profit by knowingly shielding their customers despite knowing these
`customers are breaking the law.
`12.
`The Defendants named herein are listed as owners and/or hosts of domains that
`have and that continue to directly infringe upon TIR's copyrights and trademarks – despite
`repeated complaints by TIR and its attorneys of infringement on those very websites.
`13.
`The Defendants named herein therefore have, with actual knowledge of their
`customers' direct infringements of TIR's Original Works, materially contributed to or aided in
`such infringement.
`14.
`The Defendants named herein, with the right and ability to control or supervise
`such infringing activity, have done nothing but allow and continue to profit from such activity.
`15.
`These Defendants continue doing business with the pirate sites even after receiving
`actual notices of infringement from content owners, including here, Plaintiff.
`16.
`For these reasons, the parties named herein should be held liable for contributory
`and vicarious copyright infringement and direct and contributory trademark infringement.
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`Plaintiff’s Complaint for Damages and Injunctive Relief
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 4 of 24
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`17.
`This suit seeks injunctive relief to (i) stop the Defendants from illegally shielding
`the identity of the owners of domains that are actively infringing on the intellectual property of
`another; (ii) command the Defendants to identify the owner of the infringing sites; and (iii) to
`award damages to Plaintiff for the infringement to date, and other illegal acts, and assess punitive
`and treble damages against the Defendants for their bad acts.
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`PARTIES
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`18.
`Plaintiff, TIR CONSULTING LLC (“TIR” or “PLAINTIFF”) is, and at all times
`mentioned herein was, a California limited liability company with its principal office in the State
`of California, in the County of Los Angeles.
`19.
`TIR is the registered and sole owner of copyrighted works, registered with the US
`Copyright Office, that are the subject of this action.
`20.
`TIR is also the registered owner of multiple trademarks containing the image and
`name "MISTRESS HARLEY" that brand the copyrighted works, all of which are registered with
`the US Patent and Trademark Office
`21. Defendant CLOUDFLARE, INC. (“CloudFlare”) is a Delaware corporation,
`registered to conduct business sin the state of California, with its principal offices at 101
`Townsend, San Francisco, CA 94107.
`22. CloudFlare provides an array of internet privacy services, including a content
`delivery network, and other services which it labels “pass-through” services, and on information.
`23. According to its own website, "Cloudflare is a large network of servers that can
`improve the security, performance, and reliability of anything connected to the Internet…by
`serving as a reverse proxy for your web traffic. All requests to and from your origin flow
`through Cloudflare and — as these requests pass through our network — we can apply various
`rules and optimizations to improve security, performance, and reliability." 1
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`1 https://developers.cloudflare.com/fundamentals/get-started/concepts/how-cloudflare-works/
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`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
`Page 4
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 5 of 24
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`24. CloudFlare provides these services to the owner and the hosts of the infringing
`website https://mistress-harley.com/ .
`25. Defendant NAMESILO LLC ("NameSilo") is an Arizona Limited Liability
`Company with its principal offices located at 8825 N. 23rd St. Suite 100, Phoenix, AZ 85021.
`26. Defendant NameSilo offers what they call "free WHOIS privacy" and act as the
`domain name registrar of the infringing sites https://mistress-harley.com/ and manyvips.com.
`27.
`Plaintiff is ignorant of the true names and capacities of defendants sued herein as
`DOES 1 through 100 inclusive, and therefore sues these defendants by such fictitious names. The
`plaintiff is informed, believes and thereupon alleges that the Defendants designated herein as
`DOES 1 through 100, inclusive, are any one of the following:
`(a)
`Parties responsible in some manner for the events and happenings herein
`referred to that caused injuries and damages proximately thereby to the Plaintiff as herein
`alleged;
`(b)
`Parties that are the agents, servants, employees and/or contractors of the
`Defendants, each or any of them acting within the course and scope of their agency,
`employment, or contract;
`(c)
`Parties that own, lease, manage, operate, secure and/or are responsible for
`the premises referred to hereinafter, and/or
`(d)
`Parties that have assumed or retained the liabilities of any of the
`Defendant(s) by virtue of an agreement, sale, transfer or otherwise.
`28.
`Plaintiff will amend this complaint to allege their true names and capacities, and
`the charging allegations, when such are ascertained.
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`JURISDICTION AND VENUE
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`29.
`The Court has jurisdiction over this action because it arises under the Copyright
`Act and Lanham Act, 28 U.S.C. § 1338(a). The Court has jurisdiction over the claim for unfair
`competition asserted herein under 28 U.S.C. §§ 1338(b) and 1367(a).
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`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 6 of 24
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`30. Venue is proper in this District, in that the Defendants may be found in this
`District, 28 U.S.C. § 1400(a).
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`GENERAL ALLEGATIONS OF FACT
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`31.
`TIR Consulting LLC is a California based adult entertainment company that owns
`a large library of original content, which it brands with its family of registered "Mistress Harley"
`trademarks ("Original Works").
`32.
`It has incurred the time and expense of registering its intellectual property with the
`United States Patent and Trademark Office and the US Copyright Office, both US government
`agencies designed to give copyright and trademark owners access to the tools necessary to
`protect and police their intellectual property.
`33. Nonetheless, on December 12, 2021, a third party secured the domain
`https://mistress-harley.com/ with the intention of pirating TIR's intellectual property for its own
`profit.
`
`34.
`The third party is unknown to Plaintiff because both of the named Defendants,
`CloudFlare and NameSilo, have shielded that person or entity's information, as a matter of their
`regular business practice, and for their own profit.
`35. Both CloudFlare and NameSilo have done this despite being on notice of the
`infringement that is being perpetrated on the pirate site https://mistress-harley.com/.
`36.
`Included in the illegally available material for purchase by anyone with access to
`the internet, worldwide, at https://mistress-harley.com/ , at the time of writing this complaint,
`includes an astonishing 65 videos made, paid for, produced and owned by TIR.
`37. Also included in the pirate site's materials is TIR's family of Trademark
`registrations for Mistress Harley, including USPTO Regs. 6855999, 5333306 and 5175274, used
`to brand and sell the videos.
`38. Also included in the pirate site's materials is a group of videos owned by TIR and
`registered with the US Copyright Office, including Regs. PA0002371803 / 2022-08-19 ("Sissy
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`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 7 of 24
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`Workout Series 1: All About the Booty"); PA0002371804 / 2022-08-19 ("Rating Your Dick
`Pic"); PA0002371801 / 2022-08-19 ("Random Timer Blackmail JOI").
`39.
`Each of the above intellectual properties is presumed a valid registration and is
`statutorily protected under the law.
`40.
` Each of the above intellectual properties is available for unauthorized purchase
`from the following pirate websites.
`Pirate Site #1 – Mistress-Harley.Com
`41.
`The accountability of online domains, to include their registered owners and any
`email address to report abuse, are locatable through a WHOIS database that is available to the
`public, and is run mainly by registrars and registries.
`42. According to Internet Corporation for Assigned Names and Numbers, or ICANN
`regulations, every domain registrar is required to maintain a publicly accessible database called
`"WHOIS" containing the contact information for all registered domain names.
`43.
`The pertinent information for the WHOIS Search Results for the Domain Name
` https://mistress-harley.com/ is as follows:
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`a. Domain Name: MISTRESS-HARLEY.COM
`b. Registry Domain ID: 2662961447_DOMAIN_COM-VRSN
`c. Registrar WHOIS Server: whois.namesilo.com
`d. Registrar URL: http://www.namesilo.com
`e. Updated Date: 2021-12-22T19:13:22Z
`f. Creation Date: 2021-12-20T19:56:24Z
`g. Registry Expiry Date: 2022-12-20T19:56:24Z
`h. Registrar: NameSilo, LLC
`i. Registrar IANA ID: 1479
`j. Registrar Abuse Contact Email: abuse@namesilo.com
`k. Registrar Abuse Contact Phone: +1.4805240066
`l. Domain Status: clientTransferProhibited
`https://icann.org/epp#clientTransferProhibited
`m. Name Server: DESI.NS.CLOUDFLARE.COM
`n. Name Server: SRI.NS.CLOUDFLARE.COM
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`Plaintiff’s Complaint for Damages and Injunctive Relief
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`44. A name server is most easily defined as the actual location of a website - similar to
`a brick and mortar store's physical address.
`45. Here, the name server for the pirate site is one of the Defendant CloudFlare's
`products, while the Registrar is the Defendant NameSilo.
`Pirate Site #2 - ManyVIPS.com
`46.
`Each and every of the 65 Infringing Links, backlinks to another website,
`www.manyvips.com, and each of the thumbnail images of the video clips similarly backlinks to
`www.manyvips.com.
`47.
`The pertinent information for the WHOIS Search Results for the Domain Name
`manyvips.com is as follows:
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`a. Domain Name: MANYVIPS.COM
`b. Registry Domain ID: 2199018318_DOMAIN_COM-VRSN
`c. Registrar WHOIS Server: whois.namesilo.com
`d. Registrar URL: http://www.namesilo.com
`e. Updated Date: 2022-01-04T22:02:12Z
`f. Creation Date: 2017-12-12T08:14:37Z
`g. Registry Expiry Date: 2023-12-12T08:14:37Z
`h. Registrar: NameSilo, LLC
`i. Registrar IANA ID: 1479
`j. Registrar Abuse Contact Email: abuse@namesilo.com
`k. Registrar Abuse Contact Phone: +1.4805240066
`l. Domain Status: clientTransferProhibited
`https://icann.org/epp#clientTransferProhibited
`m. Name Server: ARYANNA.NS.CLOUDFLARE.COM
`n. Name Server: ROCCO.NS.CLOUDFLARE.COM
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`48. Here again, the name server for the pirate site is one of the Defendant CloudFlare's
`products, while the Registrar is the Defendant NameSilo.
`Cloudflare - a Favored Tool for Infringers
`49. CloudFlare boasts that it "…provide[s] security and performance for millions of
`Internet properties" and that its "services run silently in the background, keeping many of the
`websites and services you depend on up and running."
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`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
`Page 8
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 9 of 24
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`50. CloudFlare explains that its service converts a domain name search into the IP
`address for the website associated with that domain name, so that the user can connect to the
`website they are trying to reach. Without CloudFlare, a user could still get to the domain if the
`user had the actual IP address for the website associated with that domain name, or find a
`comparable service on their own or from a third party.
`51. CloudFlare also “optimizes the delivery of customers' websites from the customers'
`origin server to visitors' browsers. This gives visitors to a customer's website faster page load
`times and better performance, while blocking threats and abusive bots and crawlers from
`attacking the websites.” CloudFlare provides what it calls a transparency report, wherein it
`admits "Cloudflare has never modified customer content at the request of law enforcement or
`another third party."
`52. Based on CloudFlare's own admissions, it caches customer content across its vast
`global network, for the purpose of bringing the materials physically closer to users, enabling fast
`access and avoiding overburdened servers. CloudFlare’s Service is offered as a platform to
`"cache and serve web pages and websites.”
`53. CloudFlare admits that it does not copy client websites without modification,
`rather, it admits that it "may modify" that content.
`54.
`Sec. 2.5.3 of its terms of use provides that "Cloudflare may modify certain
`components of Customer Content… Cloudflare may: (i) intercept requests…(ii) add cookies to
`your domain to track visitors… (iii) add scripts to your page… (iv) add firewall rules to your
`website; (v) scan your infrastructure …and (vi) make other changes."
`55. CloudFlare's terms of use at section 2.5.4, requires its customers to "represent and
`warrant that Customer Content does not infringe, violate, or misappropriate any third-party right,
`including any copyright, trademark, patent, trade secret, moral right, privacy right, right of
`publicity, or any other intellectual property or proprietary right."
`https://www.cloudflare.com/terms/
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`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
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`56. CloudFlare and its customers therefore mutually understand and agree that a user is
`prohibited from infringement, and CloudFlare has the right to terminate its relationship with any
`customer that infringes on a third party's copyright and/or trademark rights.
`57. According to CloudFlare's own pledge "It is Cloudflare's overriding privacy
`principle that any personal information you provide to us is just that: personal and private. We
`will not sell, rent, or give away any of your personal information without your consent. Our
`respect for our customers' privacy applies with equal force to commercial requests and to
`government or law enforcement requests."
`58. CloudFlare also readily admits it "…has never modified the intended destination of
`DNS responses at the request of law enforcement or another third party."
`59. As a natural consequence, Defendant CloudFlare is a safe holding space for
`website owners who are offering illegal content, and both sides know exactly what is being
`bought and sold.
`60. According to a submission to a US government report on copyright, the Recording
`Industry Association Of America stated that: “[Piracy] sites are increasingly turning to
`Cloudflare, because routing their site through Cloudflare obfuscates the IP address of the actual
`hosting provider, masking the location of the site.”
`61.
`In 2015, New York District Court Judge Alison J. Nathan issued a preliminary
`injunction ("TRO") against CloudFlare, ordering that “[u]pon receipt of notice from Plaintiffs or
`if CloudFlare otherwise has knowledge of an infringement on the part of one of its customers,
`CloudFlare shall cease providing its services to that customer as soon as possible, but no later
`than 48 hours after receiving such notice or obtaining such knowledge.” Arista Recs., LLC v.
`Tkach, No. 15-CV-3701 AJN (S.D.N.Y. July 9, 2015) (emphasis added).
`62. CloudFlare claimed the TRO did not apply to it because it was only a "passive"
`service, and was not necessary for the operation of the website alleged to be infringing, an
`argument to which the Court did not agree.
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`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
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`63.
`In October of 2021, a Northern District Court held that insofar as
`Cloudflare's provision of services makes it more difficult for a third party to report incidents of
`infringement to the web host as part of an effort to get the underlying content taken down, it
`could be liable for contributory infringement.
`64.
`This is precisely the basis for the claims here.
`NameSilo
`65. NameSilo advertises itself as being "…proud to offer FREE WHOIS Privacy
`Protection for all of our domain holders without limitation!"
`66. NameSilo describes that it is unlike its competitors in this manner, because "Unlike
`many of our competitors who offer Free WHOIS Privacy for a limited time, we provide WHOIS
`Privacy for free at all times, no exceptions!"
`67. NameSilo partners with PrivacyGuardian.org to offer its customers what it calls
`"complete protection for your information" while complying with ICANN requirements.
`68. As a result, it explains that on accessing the WHOIS database, "Instead of seeing
`your personal data, all contact information will be replaced with the PrivacyGuardian.org
`defaults."
`69.
`There is no question that this is not just an attractive service, but a necessary
`service for a pirate that wants to set up a site with illegal downloads.
`DMCA
`70.
`In 1998, The Digital Millennium Copyright Act ("DMCA") amended Title 17 of
`the United States Code, extending the reach of copyright and limiting the liability of the
`providers of online services for copyright infringement by their users.
`71. DMCA heightens the penalties for internet copyright infringement, but creates
`a safe harbor for online service providers (OSPs and ISPs) against liability if they adhere to and
`qualify for specific safe harbor guidelines, and either promptly block access to alleged infringing
`material or remove such material from their systems on notification of an infringement
`claim from a copyright holder or the copyright holder's agent (a "notice and takedown" process).
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`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
`Page 11
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 12 of 24
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`72. As an example of doing business legally, TIR publishes on its website an email
`address where intellectual property based complaints can be directed, so any DMCA complaints
`are received and responded to within the parameters of the law.
`73. However, the pirates and counterfeiters utilize yet another tool in their scheme,
`offered by companies like NameSilo and CloudFlare, who both serve as gatekeepers for any such
`DMCA and third party complaints. Instead of acting on the complaints, CloudFlare and
`NameSilo simply disclaim liability and point to each other as registrar or as host.
`74. Of course this is a dead end loop, if the hosting company and the registrar are both
`paid by the owner of the site to shield its identity.
`75.
`It is thus companies like these very Defendants, who protect and insulate the
`pirates and make the infringement not only possible but enable it to thrives, all while the legal
`content owners are left without viable recourse outside of costly and time intensive litigation like
`this.
`
`76. Attempting to enforce copyright laws against pirate sites can be taxing if not
`impossible, as the owners and initial infringers purposely register their web domains with a
`private registry, thus masking their identity – and undermining the entire point of policing
`original content.
`77. A lawful content owner cannot stop these pirate sites, despite filing complaints and
`alerting the named domain hosts of the infringement – the complaints of infringement are simply
`ignored, and the pirate sites flourish.
`78. And when contacted, companies like and including the Defendants here, refuse to
`disclose the identity of the host or site owner while ignoring the requests and complaints.
`79.
`The effort and expense of identifying or bringing owners of pirate sites into Court
`may be for not, as it is cheaper and easier to disappear and resume services anonymously on
`some other website under some other entity's privacy shield.
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`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
`Page 12
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 13 of 24
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`80.
`The pirate sites would be unable to accomplish their goals if the Defendants did not
`act as third party service providers, to include hosts, content delivery networks, advertising
`networks and affiliate programs, all the while protecting the identity of the actual pirate.
`TIR and Reports of Infringement
`81.
`TIR, on its own behalf and through its attorneys, repeatedly complained to
`CloudFlare of the infringement and abuse, and was told that CloudFlare was a pass-through and
`would do nothing. "Cloudflare offers network service solutions including pass-through security
`services, a content distribution network (CDN) and registrar services. Due to the pass-through
`nature of our services, our IP addresses appear in WHOIS and DNS records for websites using
`Cloudflare. Cloudflare cannot remove material from the Internet that is hosted by others."
`82. CloudFlare admitted that the accepted 65 URL(s) for the DMCA report on
`mistress-harley.com included:
`1) https://mistress-harley.com/
`2) https://mistress-harley.com/mistress-harley-10-minute-joi-game_6.html
`3) https://mistress-harley.com/mistress-harley-alpha-males-become-weak-sluts-for-
`me_607.html
`4) https://mistress-harley.com/mistress-harley-ass-cleaning-slave_384.html
`5) https://mistress-harley.com/mistress-harley-ass-cleaning-slave_614.html
`6) https://mistress-harley.com/mistress-harley-ass-owns-you-mesmerize_594.html
`7) https://mistress-harley.com/mistress-harley-ass-stroke-zombie_581.html
`8) https://mistress-harley.com/mistress-harley-bap3zed-in-cum-for-harley_591.html
`9) https://mistress-harley.com/mistress-harley-bap3zed-in-cum-for-mistress-
`harley_615.html
`10) https://mistress-harley.com/mistress-harley-become-my-favorite-slave_10.html
`11) https://mistress-harley.com/mistress-harley-big-3ts-control-you_577.html
`12) https://mistress-harley.com/mistress-harley-blackmailed-into-my-
`control_578.html
`13) https://mistress-harley.com/mistress-harley-blue-balls-edging-game_20.html
`14) https://mistress-harley.com/mistress-harley-cant-abuse-the-willing_572.html
`15) https://mistress-harley.com/mistress-harley-cleavage-makes-you-weak_599.html
`16) https://mistress-harley.com/mistress-harley-cock-shrinking-mesmerize_589.html
`17) https://mistress-harley.com/mistress-harley-craving-mistress-harley_590.html
`18) https://mistress-harley.com/mistress-harley-debt-contract-slave-rules_94.html
`19) https://mistress-harley.com/mistress-harley-domina3ng-weak-wimpy-
`boys_601.html
`20) https://mistress-harley.com/mistress-harley-dumb-boys-empty-wallets_30.html
`
`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
`Page 13
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 14 of 24
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`21) https://mistress-harley.com/mistress-harley-ear-cleaning-fe3sh_11.html
`22) https://mistress-harley.com/mistress-harley-enslaved-by-femdom_32.html
`23) https://mistress-harley.com/mistress-harley-exposed-sissy-shauna_1.html
`24) https://mistress-harley.com/mistress-harley-exposed-sissybb_23.html
`25) https://mistress-harley.com/mistress-harley-falling-into-my-trap_580.html
`26) https://mistress-harley.com/mistress-harley-findom-foot-fe3sh_588.html
`27) https://mistress-harley.com/mistress-harley-fucking-men-over_595.html
`28) https://mistress-harley.com/mistress-harley-gay-test_606.html
`29) https://mistress-harley.com/mistress-harley-girlfriend-homewreck_592.html
`30) https://mistress-harley.com/mistress-harley-gooner-mind-fuck-
`mesmerize_613.html
`31) https://mistress-harley.com/mistress-harley-goth-goddess-foot-
`worship_596.html
`32) https://mistress-harley.com/mistress-harley-harley-girlfriend-
`experience_574.html
`33) https://mistress-harley.com/mistress-harley-helpless-foot-sniffer_597.html
`34) https://mistress-harley.com/mistress-harley-homewrecker-advice_343.html
`35) https://mistress-harley.com/mistress-harley-homewrecker-aroma-blackmail-
`bitch_609.html
`36) https://mistress-harley.com/mistress-harley-hotter-than-your-wife-
`homewrecker_611.html
`37) https://mistress-harley.com/mistress-harley-humilia3on-joi-cei-cam-
`session_604.html
`38) https://mistress-harley.com/mistress-harley-learn-to-please-your-perfect-
`mistress_19.html
`39) https://mistress-harley.com/mistress-harley-limpdick-humilia3on_612.html
`40) https:/mistress-harley.com/mistress-harley-make-me-a-millionaire-with-
`1_579.html
`41) https://mistress-harley.com/mistress-harley-mesmerize-dream-of-harley-audio-
`mp3_608.html
`42) https://mistress-harley.com/mistress-harley-mesmerize-gooner-brainwash-
`joi_583.html
`43) https://mistress-harley.com/mistress-harley-mesmerize-joi-to-own-you_584.html
`44) https://mistress-harley.com/mistress-harley-mesmerize-you-belong-to-
`me_586.html
`45) https://mistress-harley.com/mistress-harley-my-bikini-is-too-small_582.html
`46) https://mistress-harley.com/mistress-harley-pay-for-huge-3ts_593.html
`47) https://mistress-harley.com/mistress-harley-pay-my-expensive-lips_22.html
`48) https://mistress-harley.com/mistress-harley-poppers-slut-joi_575.html
`49) https://mistress-harley.com/mistress-harley-porn-addic3on-is-good-for-
`you_587.html
`
`
`Plaintiff’s Complaint for Damages and Injunctive Relief
`TIR Consulting LLC v. Cloudfare et al, Case No. 3:22-cv-09010
`Page 14
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`Case 3:22-cv-09010-TLT Document 2 Filed 12/20/22 Page 15 of 24
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`50) https:/mistress-harley.com/mistress-harley-porn-addic3on-stroke-
`training_290.html
`51) https://mistress-harley.com/mistress-harley-prove-youre-not-gay_51.html
`52) https://mistress-harley.com/mistress-harley-random-3mer-blackmail_517.html
`53) https://mistress-harley.com/mistress-harley-ra3ng-your-dick-pic_392.html
`54) https://mistress-harley.com/mistress-harley-ra3ng-your-dick-pic_598.html
`55) https://mistress-harley.com/mistress-harley-sissy-workout-series-1-
`booty_600.html
`56) https://mistress-harley.com/mistress-harley-top-5-gayest-sissies_585.html
`57) https://mistress-harley.com/mistress-harley-ul3mate-rip-off_602.html
`58) https://mistress-harley.com/mistress-harley-verbal-humilia3on-and-abuse-for-
`losers_576.html
`59) https://mistress-harley.com/mistress-harley-you-exist-for-my-pleasure_610.html
`60) https://mistress-harley.com/mistress-harley-your-mean-girlfriend_603.html
`61) https://mistress-harley.com/mistress-harley-smoking-is-hotter-than-
`pindicks_9.html
`62) https://mistress-harley.com/mistress-harley-ache-for-me_13.html
`63) https://mistress-harley.com/mistress-harley-brainwashing-mesmerise-joi_24.html
`64) https://mistress-harley.com/mistress-harley-homewrecker-mind-fuck-joi-for-
`losers_27.html
`65) https://mistress-harley.com/mi