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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF PENNSYLVANIA
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`19-CV-4034
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`KAREN HEPP,
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`v.
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`Plaintiff,
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`FACEBOOK, INC.; IMGUR, INC.,
`REDDIT, INC., GIPHY, INC.; WGCZ
`S.R.O., and DOES 1-10,
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`Defendants.
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`MOTION OF DEFENDANT IMGUR, INC. TO DISMISS
`THE FIRST AMENDED COMPLAINT
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`Defendant Imgur, Inc. (“Imgur”) moves, pursuant to Federal Rule of Civil Procedure
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`12(b)(2), to dismiss all claims against it because this Court lacks jurisdiction over Imgur. Imgur also
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`moves, pursuant to Fed.R.Civ.P. 12(b)(6), to dismiss all claims against it because the purported
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`claims are not actionable under Pennsylvania state law, and are pre-empted by Section 230(c) of the
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`Communications Decency Act, which immunizes Imgur from all claims raised in this lawsuit. The
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`grounds for this Motion are set forth in the accompanying Memorandum of Law, and the Declaration
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`of Alan Schaaf, both of which are incorporated by reference.
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`Respectfully submitted,
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`/s/ Michael LiPuma
`Michael LiPuma, Esq.
`325 Chestnut Street, Suite 1109
`Philadelphia, PA 19106
`(215) 922-2126
`Attorney for Defendant Imgur, Inc.
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`Dated: March 2, 2020
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`Case 2:19-cv-04034-JMY Document 53 Filed 03/02/20 Page 2 of 2
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`CERTIFICATE OF SERVICE
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`I certify that on March 2, 2020, I caused a copy of the foregoing document, together with all
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`supporting papers, to be served by ECF upon all counsel of record.
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`/s Michael LiPuma
`Michael LiPuma, Esq.
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