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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`ALI AL-AHMED,
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`v.
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`Plaintiff,
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`COMPLAINT
`JURY TRIAL DEMANDED
`Index No.: ______________
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`TWITTER, INC.,
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`attorneys, Gerstman Schwartz LLP, as and for its Complaint against Defendant Twitter
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`(hereinafter, “Defendant” or “Twitter”), hereby alleges as follows:
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`Defendant.
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`Plaintiff Ali Al-Ahmed (hereinafter, “Plaintiff” or “Mr. Al-Ahmed”) by and through his
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`JURISDICTION & VENUE
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`1.
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`Jurisdiction is proper in this court because this litigation arises under federal law,
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`namely 18 U.S.C. §2701 et seq. (Violation of the Stored Communications Act). The Court has
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`jurisdiction over this action under 28 U.S.C. § 1331.
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`2.
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`The Court has supplemental jurisdiction over the state law claims asserted in this
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`case under 28 U.S.C. § 1367, and 28 U.S.C. § 1362 because there is diversity of citizenship
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`between the parties and the amount in controversy exceeds $75,000.
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`3.
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`Venue is proper in this district under 28 U.S.C. §§ 1391(b) and 1391(c) because
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`Defendant resides in this district insofar as it maintains a sprawling, 12-floor corporate
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`headquarters (its second largest office) located at 245 West 17th Street in Manhattan—a news and
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`media mecca—in deference to New York City as a global media market.
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`Case 1:20-cv-04982 Document 1 Filed 06/29/20 Page 2 of 16
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`4.
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`While venue is proper in New York, California law is applicable under New York’s
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`“interests analysis” approach insofar as a substantial part of the acts and omissions giving rise to
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`the claims asserted herein occurred in California. See Belmac Hygiene, Inc. v. Medstar, Inc., 121
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`F.3d 835, 838 (2d. Cir. 1997); Istim, Inc. v. Chemical Bank, 78 N.Y.2d 342 (1991).
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`PARTIES
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`5.
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`Plaintiff Ali Al-Ahmed is one of the leading political dissidents to the Kingdom of
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`Saudi Arabia (hereinafter “KSA”) who resides, and has been granted asylum in, the United States
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`because he faced imminent persecution were he to return to his native country, Saudi Arabia.
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`6.
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`Defendant Twitter is a Delaware corporation with its principal place of business
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`located in San Francisco, California and its second largest corporate headquarters located at 245
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`West 17th Street, New York, New York. Twitter conducts business throughout the United States,
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`including New York.
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`7.
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`In 2011, Saudi Prince Alwaleed Bin Talal (hereinafter, “Bin Talal”) purchased $300
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`million worth of stock in Twitter. In 2015, Bin Talal made an additional investment, owning 5.2%
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`of the company, more than Twitter’s founder and CEO. A January 29, 2018 article in the British
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`newspaper, The Daily Mail, reported that after being imprisoned and perhaps tortured by KSA,
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`Bin Talal signed over many of his assets to Crown Prince Mohammed Bin Salman (hereinafter,
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`“MBS”). According to The Daily Mail, a deal was allegedly made with MBS allowing MBS to
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`seize control of these assets and those of other princes, so long as the assets remained in the United
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`States.
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`8.
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`Plaintiff is informed and believes, and based thereon alleges, that since late 2017
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`or January of 2018, MBS has exercised control over more Twitter stock than is owned by Twitter’s
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`founder, Jack Dorsey. Twitter also failed to properly safeguard Plaintiff’s account, and as a result,
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`personal and highly sensitive information was disclosed to third parties including, but not limited
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`to, the KSA and its agents.
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`PRELIMINARY STATEMENT
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`9.
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`This is an action to vindicate the rights of Ali Al-Ahmed, a political refugee who
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`has been granted political asylum in the United States from the despotic regime in the Kingdom
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`of Saudi Arabia. Because of the tremendous wealth of key figures in KSA, major corporations,
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`including Twitter, Inc., have enabled, collaborated with, aided and abetted, and turned a blind eye
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`to KSA’s efforts to suppress, torture, falsely imprison, terrorize, and murder dissenters both within
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`Saudi Arabia and around the world.
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`FACTS
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`Facts In Common to All Causes of Action
`10. Mr. Al-Ahmed is a leading voice of dissent casting an evidently unwanted
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`magnifying glass upon the acts and omissions, policies and, at times, alleged crimes conducted on
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`behalf of, or with the knowledge and consent of, the Kingdom of Saudi Arabia (“KSA”) or
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`elements within the KSA. Mr. Al-Ahmed is also one of the most active and courageous journalists
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`within the United States covering the KSA. Through his prominent social media presence, and
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`persistent critique of the KSA, Mr. Al-Ahmed has brought broad awareness to issues of social and
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`political concern including allegations of KSA human rights violations, KSA links to international
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`terrorism, and KSA corruption within the Kingdom.
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`11.
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`It would not be an overstatement to suggest that Mr. Al-Ahmed has become a thorn
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`in the side of the KSA. Indeed, he would not dispute that he has made it his life’s work to counter
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`KSA propaganda and expose systemic corruption, violence, and police state tactics within the
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`KSA, and to counter KSA efforts to miscast itself as a modern nation. As a result, Mr. Al-Ahmed
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`attests that the KSA has consistently attempted to—quite literally—silence his voice, even going
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`so far as to attempt to kidnap and kill him on multiple occasions. The KSA has also formally
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`stripped Mr. Al-Ahmed of his Saudi nationality and has kept him under vigilant surveillance.
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`12.
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`He has been invited to speak by institutions including Princeton University,
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`Amnesty International, the Hudson Institute, American Enterprise Institute, and Meridian
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`International Center and has testified before Congress on several occasions on the issue of civil
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`rights and religious freedom in the Middle East. He has authored reports on Saudi Arabia regarding
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`religious freedom, torture, press freedom, and religious curriculum.
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`13.
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`Although Mr. Al-Ahmed usually disseminates information via social media, Al-
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`Ahmed is a frequent consultant to major international broadcast media on issues including Saudi
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`political affairs, terrorism, Sunni-Shi’a relations, Wahhabi Islam, political and religious
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`oppression, human and women’s rights in Saudi Arabia, and the Saudi-U.S. relationship. He has
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`been a regular guest on CBS News, CNN, PBS, Fox News, and Al-Jazeera. He has written for, and
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`has been quoted in, the Washington Post, Associated Press, The Times, Reuters, the Wall Street
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`Journal, USA Today and the Boston Globe. In short, he is a leading Saudi voice for KSA reform
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`and democratization.
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`14. With the passage of time, Mr. Al-Ahmed has become such an influential voice
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`that multiple prominent Saudi officials have followed his Arabic Twitter, his largest verifiable
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`social media account, which has over 36,000 followers worldwide (although, as will be described
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`in further detail herein, it has since been suspended).
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`Alzabarah’s and Abouammo’s Unauthorized and Unlawful Access of Mr. Al-
`Ahmed’s Private Information
`In or around August 2013, until in or around December 2015, Ali Hamad Alzabarah
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`15.
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`(hereinafter, “Alzabarah “) and Ahmad Abouammo (hereinafter, “Abouammo”), Twitter
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`employees charged by the United States government with being KSA spies,1 accessed the
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`company’s information on an array of Saudi dissidents including Mr. Al-Ahmed.
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`16.
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`Through use of both Alzabarah and Abouammo, the KSA was successful in using
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`Twitter’s internal resources to identify Mr. Al-Ahmed as a critic of the government and ultimately
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`silence him.
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`17.
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`On numerous occasions, Alzabarah and Abouammo mined Twitter’s internal
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`systems for, inter alia, personal information regarding Mr. Al-Ahmed, email addresses, contacts,
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`phone numbers, birth dates, and internet protocol (“IP”) addresses.
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`18.
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`According to the Twitter “Playbook,” which outlines the policies Twitter
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`employees must abide by, Alzabarah and Abouammo were prohibited from engaging in outside
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`employment or consulting “or other business activity that would create a conflict of interest with
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`the company.” 2 Certainly, acting as spies, foreign agents and purveyors of assignation would be
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`prohibited. Twitter’s Employee Invention Assignment and Confidentiality Agreements with both
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`Alzabarah and Abouammo reinforced “a relationship of confidence and trust” between Twitter and
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`each of them with respect to any information of a confidential nature or secret nature that may be
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`disclosed over the course of their employment with the company. 3
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`19.
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`Neither Alzabarah nor Abouammo’s job duties included a need to access Mr. Al-
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`Ahmed’s private information. The fact that they did so was a serious and reportable violation of
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`the Twitter Playbook polices regarding safeguarding user data. Although Twitter belatedly
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`attempted to remedy their indefensible security practices, the damage to Mr. Al-Ahmed and his
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`1 https://www.justice.gov/usao-ndca/press-release/file/1215976/download
`UNITED STATES v. AHMED ALMUTAIRI, a/k/a AHMED ALJBREEN; and ALI ALZABARAH, November 2019.
`2 https://www.sec.gov/Archives/edgar/data/1418091/000156459017013336/twtr-ex101_6.htm
`3 Id.
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`5
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`followers had already been done. Twitters’ subsequent efforts to enhance their security protocols
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`does not undo the damage done to Mr. Al-Ahmed and his followers as a result of Twitter’s slip
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`shot practices which have made Mr. Al-Ahmed and many of his followers targets for the brutal
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`KSA, jeopardizing the very lives of his followers living within the confines of the KSA and its
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`surrounding environs.
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`20.
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`Indeed, several Twitter users, who either followed Mr. Al-Ahmed’s Twitter
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`account and/or had direct contact with him through the use of private messaging, have disappeared,
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`been arrested, or have been executed. One such example is Abdullah al-Hamid, a Saudi Dissident
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`and follower of Mr. Al-Ahmed’s Twitter account, who was jailed and ultimately died in custody.4
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`21.
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`On the heels of all this death and skullduggery, on or about May 2018, the KSA
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`managed to fully silenced Mr. Al-Ahmed when they had their embedded Twitter agents or others
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`within Twitter suspend Mr. Al-Ahmed’s Arabic Twitter account, “@AliAlahmed,” without
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`explanation or warning. Despite the above-noted Justice Department criminal complaint exposing
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`these Twitter KSA agents’ activities in November of 2019, Mr. Al-Ahmed’s repeated attempt to
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`appeal this suspension have been to no avail.
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`22.
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`Inexplicably, Twitter has upheld this suspension and kept his account inaccessible
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`including Mr. Al-Ahmed’s access to his approximately 36,000 followers’ contact information. The
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`genesis of this suspension having been clearly exposed, Twitter continues to bar Mr. Al-Ahmed
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`from access or use presumably because Twitter is in league with the KSA; preferring access to the
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`KSA over human rights, freedom and abiding by the terms of its owner agreements made with
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`4 https://www.nytimes.com/2020/05/21/world/middleeast/abdullah-al-hamid-saudi-dissident-dies-in-detention-at-
`69.html
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`6
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`Twitter subscribers, and in contravention of its public representation that Twitter is committed to
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`protecting Twitter uses.5
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`23. Mr. Al-Ahmed spent many years of time and effort cultivating, developing and
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`curating his expansive list of Twitter followers, which effectively amounted to valuable intellectual
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`and proprietary property—particularly insofar as it earned him credibility, career nods and
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`income—reflecting a huge number of persons interested in unvarnished coverage of KSA activities
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`provided from a pro-democracy and pro-human rights vantage point. Upon information and belief,
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`some of Mr. Al-Ahmed’s followers’ accounts have also been shut down as a result of protesting
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`his account suspension. This is not only immoral, it is undemocratic.
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`In pertinent part, Twitter, in its “Twitter Rules,” states that,
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`Twitter’s purpose is to serve the public conversation. Violence,
`harassment and other similar types of behavior discourage people
`from expressing themselves, and ultimately diminish the value of
`global public conversation. Our rules are to ensure all people can
`participate in the public conversation freely and safely…Safety -
`Violence: You may not threaten violence against an individual or a
`group of people. We also prohibit the glorification of violence.
`Learn more about our violent threat and glorification of violence
`policies…
`Terrorism/violent extremism: You may not threaten or promote
`terrorism or violent extremism. There is no place on Twitter for
`terrorist organizations or violent extremist groups and individuals
`who affiliate with and promote their illicit activities. The violence
`that these groups engage in and/or promote jeopardizes the physical
`safety and well-being of those targeted. Our assessments in this
`context are informed by national and international terrorism
`designations. We also assess organizations under our violent
`extremist group criteria. Violent extremist groups are those that
`meet all of the below criteria: identify through their stated purpose,
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`5https://help.Twitter.com/en/safety-and-security/public-and-protected-tweets “About public and protected Tweets –
`Should you choose to protect your Tweets, you can do so through your account settings…If you protect your Tweets,
`you’ll receive a request when new people want to follow you, which you can approve or deny…Protected Tweets:
`Only visible to your Twitter followers. Please keep in mind, your followers may still capture images of your Tweets
`and share them.” Twitter thus created an illusion of security and safety relied upon by Plaintiff, and, according to
`Plaintiff, by those who were “disappeared,” arrested or eliminated.
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`7
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`Case 1:20-cv-04982 Document 1 Filed 06/29/20 Page 8 of 16
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`publications, or actions as an extremist group; have engaged in, or
`currently engage in, violence and/or the promotion of violence as a
`means to further their cause; and target civilians in their acts and/or
`promotion of violence. We examine a group’s activities both on and
`off Twitter to determine whether they engage in and/or promote
`violence against civilians to advance a political, religious and/or
`social cause.
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`What is in violation of this policy? Under this policy, you can’t
`affiliate with and promote the illicit activities of a terrorist
`organization or violent extremist group. Examples of the types of
`content that violate this policy include, but are not limited to:
`engaging in or promoting acts on behalf of a terrorist organization
`or violent extremist group; recruiting for a terrorist organization or
`violent extremist group; providing or distributing services (e.g.,
`financial, media/propaganda) to further a terrorist organization’s or
`violent extremist group’s stated goals; and using the insignia or
`symbols of terrorist organizations or violent extremist groups to
`promote them. What is not a violation of this policy? We may make
`limited exceptions for groups that have reformed or are currently
`engaging in a peaceful resolution process, as well as groups with
`representatives who have been elected to public office through
`democratic elections. We may also make exceptions related to the
`discussion of terrorism or extremism for clearly educational or
`documentary purposes. This policy also doesn’t apply to military or
`government entities.6
`Between Twitter’s holding out that one can protect their Tweets, the above-
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`24.
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`referenced affirmative corporate and global commitment to “serve the public conversation,” and
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`Twitter’s supposed opposition to violence and terrorism, Twitter’s failure to screen and supervise
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`its employees, thereby allowing KSA spies to embed in Twitter, makes a mockery of this so-called
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`“commitment.” It is a crying shame that individuals like the Plaintiff have detrimentally relied on
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`same to their undying personal prejudice, particularly in the face of those who how have been
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`6 https://help.twitter.com/en/rules-and-policies/twitter-rules
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`8
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`“disappeared,” arrested or otherwise subject to KSA extreme sanction—perhaps for having
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`followed Plaintiff or “liked” a posting while believing their identity was “protected.”
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`25.
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`Now Plaintiff cannot even access the list of over 36,000 pro-democracy leaning
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`followers who have had enough of the KSA’s police state antics, perversely turning Twitter’s
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`“commitment” on its head by silencing critics of terrorism and violence, and positioning Twitter
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`to continue to carry the KSA’s water by doing violence to truth and free speech, and by denying
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`Plaintiff access to his proprietary list of followers, research and other intellectual property, even
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`after Twitter’s slip shod adherence to its protocols and negligence in its hiring and supervision of
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`embedded spies was roundly exposed by the Department of Justice’s November 2019 Criminal
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`Complaint.7
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`26.
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`Despite its commitment to “serve the public conversation,” Twitter’s conduct
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`amounts to silencing Lech Walęsa to preserve its reach and market share in the USSR. To make
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`matters worse, Twitter did so after hiring KGB agents to oversee internal operations. The
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`ramifications of this kind of willful blindness cannot be overstated.
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`CLAIMS FOR RELIEF
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`FIRST CAUSE OF ACTION
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`(Violation of the Stored Communications Act, 18 U.S.C. § 2701, et. seq.)
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`Plaintiff hereby incorporates by reference each and every allegation contained in
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`27.
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`the foregoing paragraphs as though fully set forth herein.
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`7 https://www.justice.gov/usao-ndca/press-release/file/1215976/download
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`9
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`28.
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`In infiltrating and accessing Plaintiff’s confidential Twitter information, Alzabarah
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`and Abouammo intentionally exceeded their authorization to access that facility and thereby
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`authorized access to electronic communication while it was in electronic storage.
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`29.
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`Plaintiff is informed and believes, and based thereon alleges, that one or more of
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`Twitter’s managing agents ratified this conduct by, inter alia, concealing from Plaintiff the fact
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`that Alzabarah and Abouammo, while acting as agents for KSA, had wrongly obtained access to
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`this information.
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`30.
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`Twitter’s Chairman, Jack Dorsey, ratified this conduct by holding a cordial meeting
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`and posing for publicity photographs with MBS seven months after Dorsey learned that KSA had
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`recruited at least two of Twitter’s employees to steal the private and confidential information of
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`thousands of Twitter users.
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`31.
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`As a direct result of Twitter’s violation of 18 U.S.C. § 2701, Plaintiff has suffered
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`loss of property and has incurred out-of-pocket expenses in excess of $75,000.
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`32.
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`As a direct result of Twitter’s violation of 18 U.S.C. § 2701, Plaintiff has also
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`suffered stress, anxiety, emotional distress, pain and suffering, inconvenience, mental anguish, loss
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`of enjoyment, and damage to his personal and professional reputation.
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`33.
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`Twitter’s unlawful actions were intentional, willful, and/or were taken in willful
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`disregard of Plaintiff’s rights.
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`34.
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`In addition to general and economic damages, Plaintiff seeks punitive damages in
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`an amount sufficient to punish Twitter and to protect future Twitter users from Defendant’s
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`wrongful practices described herein.
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`SECOND CAUSE OF ACTION
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`(Breach of Contract)
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`35.
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`Plaintiff hereby incorporates by reference each and every allegation contained in
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`the foregoing paragraphs as though fully set forth herein.
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`36.
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`In or about 2009, Mr. Al-Ahmed entered into a contractual relationship with Twitter
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`when he created a Twitter user account.
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`37.
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`Both Mr. Al-Ahmed and Twitter agreed to abide by the terms of Twitter’s user
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`agreement (the “Contract”).
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`38.
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`Pursuant to the Contract, Twitter further implicitly agreed to take all necessary
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`measures in order to properly and effectively safeguard Mr. Al-Ahmed’s account.
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`39.
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`As more fully alleged above, without any justification, in or around 2018, Twitter
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`breached its Contract with Mr. Al-Ahmed by failing to adhere to the procedures and protections
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`set forth in Twitter’s policies in ways including, but not limited to, the following:
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`a. Failing to ensure that all necessary measures were being taken in order to
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`properly and effectively safeguard Mr. Al-Ahmed’s account and personal
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`information;
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`b. Failing to follow its own procedures;
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`c. Disclosing sensitive confidential information to the KSA in violation of their
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`policies, Federal Law, and the applicable New York regulations;
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`d. Prematurely suspending Mr. Al-Ahmed’s Twitter account without any
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`justification;
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`e. Preventing Mr. Al-Ahmed from continuing to use his Twitter account; and
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`f. Failing to adequately or meaningfully address and consider Mr. Al-Ahmed’s
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`appeal from the suspension of his account.
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`40. Mr. Al-Ahmed has suffered damages as a direct and proximate result of Twitter’s
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`breach of the user agreement and Twitter’s policies including, but not limited to, the following:
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`a. Long-term injury to his professional reputation and career;
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`b. Loss of compensation and wages; and
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`c. Loss of opportunity of employment, interviews, and events at other institutions.
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`41.
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`As a direct and legal result of Twitter’s breach of the Contract, Mr. Al-Ahmed has
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`been damaged in an amount to be determined at trial but which is in excess of $75,000.
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`THIRD CAUSE OF ACTION
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`(Interference with Prospective Economic Advantage)
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`Plaintiff hereby incorporates by reference each and every allegation contained in
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`42.
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`the foregoing paragraphs as though fully set forth herein.
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`43. Mr. Al-Ahmed had invested substantial time and effort to develop and maintain his
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`Twitter platform, as well his prospective business partners and relationships.
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`44. Mr. Al-Ahmed had a reasonable expectancy of employment and career
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`opportunities he received through Twitter.
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`45.
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`Through communications between Twitter and Mr. Al-Ahmed, Twitter knew and
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`understood that Mr. Al-Ahmed used Twitter as a means to network, and secure other employment
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`and career opportunities including, but not limited to, interviews with media companies and news
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`networks, and writing and reporting opportunities.
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`46.
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`Twitter interfered with, and suspended Mr. Al-Ahmed’s account with the
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`understanding that, doing so would impede his ability to secure gainful employment and career
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`opportunities elsewhere.
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`47.
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`As a direct and proximate result of Twitter’s interreference, Mr. Al-Ahmed suffered
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`adverse consequences. Mr. Al-Ahmed was further caused to suffer lost past and future wages,
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`professional opportunities and other valuable benefits and emoluments of employment all to his
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`detriment. Twitter’s wrongful con duct damages Mr. Al-Ahmed’s expected business, proximately
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`resulting in substantial lost revenues and other damages to Mr. Al-Ahmed, in an amount to be
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`determined according to proof at trial but which is in excess of $75,000.
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`48.
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`In committing the foregoing wrongful acts, Defendant acted with malice,
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`oppression, fraud, an intent to injure, and a conscious disregard of Mr. Al-Ahmed’s rights, entitling
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`him to punitive damages in amount to be determined at trial.
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`FOURTH CAUSE OF ACTION
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`(Tortious Invasion of Privacy – Public Disclosure of Private Facts)
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`Plaintiff hereby incorporates by reference each and every allegation contained in
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`49.
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`the foregoing paragraphs as though fully set forth herein.
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`50.
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`As described herein, Twitter improperly disclosed confidential and personal
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`information between and concerning, inter alia, Mr. Al-Ahmed’s private relationships with other
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`Saudi dissidents including the foregoing individuals’ email addresses, contacts, phone numbers,
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`birth dates, and internet protocol (“IP”) addresses.
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`51.
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`The confidentiality of the disclosed information is protected by the Twitter user
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`agreement.
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`52.
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`Furthermore, as alleged above, Twitter jeopardized the safety and wellbeing of both
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`Mr. Al-Ahmed and his followers by disclosing said confidential information to the KSA.
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`53.
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`The information disclosed concerns the private life, career, and reputation of Mr.
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`Al-Ahmed, as well as that of his followers.
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`Case 1:20-cv-04982 Document 1 Filed 06/29/20 Page 14 of 16
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`54.
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`55.
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`The disclosure of this information would be highly offensive to a reasonable person.
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`Furthermore, Twitter acted with evil motive, actual malice, or with intent to injure,
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`or in willful disregard for the rights of Mr. Al-Ahmed.
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`56.
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`Twitter’s conduct was outrageous, grossly fraudulent, or reckless toward the
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`reputation of Mr. Al-Ahmed.
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`57.
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`Twitter’s actions injured Mr. Al-Ahmed in numerous ways, including, but not
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`limited to, the following:
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`a. Long-term injury to Mr. Al-Ahmed’s professional reputation and career; and
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`b. Loss of employment at, inter alia, news stations and media companies.
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`58.
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`As a direct and proximate result of Twitter’s interreference, Mr. Al-Ahmed suffered
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`adverse consequences, proximately resulting in substantial lost revenues and other damages to Mr.
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`Al-Ahmed, in an amount to be determined according to proof at trial but which is in excess of
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`$75,000. Plaintiff has also suffered stress, anxiety, emotional distress, pain and suffering,
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`inconvenience, mental anguish, loss of enjoyment, and damage to his personal and professional
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`reputation.
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`59.
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`In committing the foregoing wrongful acts, Defendant acted with malice,
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`oppression, fraud, an intent to injure, and a conscious disregard of Mr. Al-Ahmed’s rights, entitling
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`him to punitive damages in amount to be determined at trial.
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`FIFTH CAUSE OF ACTION
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`(Negligence - Negligent Hiring, Training, and Supervision)
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`Plaintiff hereby incorporates by reference each and every allegation contained in
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`60.
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`the foregoing paragraphs as though fully set forth herein.
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`Case 1:20-cv-04982 Document 1 Filed 06/29/20 Page 15 of 16
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`61.
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`Twitter had a duty to use reasonable care to select, train and supervise employees
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`who were competent and fit to perform the duties of a Twitter employee.
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`62.
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`If the Twitter employees had been properly hired, trained, and supervised, the
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`confidential information regarding Mr. Al-Ahmed and his followers would not have been
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`disclosed.
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`63.
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`Twitter failed to take reasonable measures to select, train, and supervise their
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`employees to prevent them from gaining access to Mr. Al-Ahmed’s account, and disclosing
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`confidential and sensitive information to third parties, including, but not limited to, the KSA. These
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`Defendant may have been otherwise negligent.
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`64.
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`As a direct and proximate cause of Defendant’s negligence, Plaintiff Mr. Al-Ahmed
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`was put in significant danger and lost access to his Twitter account, and its corresponding social
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`and professional networking opportunities, resulting in lost revenues, lost professional and
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`economic opportunities, and other damages to Mr. Al-Ahmed, in an amount to be determined
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`according to proof at trial but which is in excess of $75,000.
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`65. Mr. Al-Ahmed has sustained and will continue to sustain permanent impairment of
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`his current and future earning capacity, stress, anxiety, emotional distress, pain and suffering,
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`inconvenience, mental anguish, loss of enjoyment, and damage to his personal and professional
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`reputation.
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`66.
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`In committing the foregoing wrongful acts, Defendant acted with malice,
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`oppression, fraud, an intent to injure, and a conscious disregard of Mr. Al-Ahmed’s rights, entitling
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`him to punitive damages in amount to be determined at trial.
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`PRAYER FOR RELIEF
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`Case 1:20-cv-04982 Document 1 Filed 06/29/20 Page 16 of 16
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`WHEREFORE, upon all of the facts and circumstances herein alleged, Plaintiffs
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`respectfully request that this Court:
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`A. Grant judgment against the Defendant on each and every cause of action as alleged and
`delineated herein;
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`B. Grant compensatory damages against the Defendant in the amount to be determined at
`trial;
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`C. Grant punitive damages against the Defendant in the amount to be determined at trial;
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`D. Grant any other damages permitted to be recovered by law pursuant to the above causes
`of action;
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`E. Grant an award of reasonable attorney’s fees and costs expended in connection with the
`prosecution of this action pursuant to 42 U.S.C. § 1988; and
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`F. Grant any such further relief as this Court may deem just, proper, and equitable.
`JURY DEMAND
`Plaintiffs hereby demand a trial by jury as to all issues so triable.
`Dated: Garden City, New York
` June 29, 2020
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`GERSTMAN SCHWARTZ, LLP
`By: /s/ David M. Schwartz
`David M. Schwartz, Esq.
`Randy E. Kleinman, Esq.
`1399 Franklin Avenue, Suite 200
`Garden City, New York 11530
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`Tel. No.: (516) 880 – 8170
`dschwartz@gerstmanschwartz.com
`rkleinman@gerstmanschwartz.com
`Attorneys for Plaintiffs
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