Case 1:25-cv-01258-PTG-IDD Document 68 Filed 09/12/25 Page 1 of 4 PagelD# 344
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`IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
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`Su-Mi Kim (a.k.a. ARI), Pro Se Plaintiff 05 SEP 12 A I3 33
`V.
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`Massachusetts Institute of Technology and The Board of Trustees of the Leland Stanford
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`Junior University, Defendants
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`Civil Action No. 1:25-cv-01258-CMH-IDD
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`REBUTTAL TO DEFENDANTS MIT AND STANFORD’S
`MOTION TO DISMISS
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`Filed by: Su-Mi Kim (a.k.a. ARI)
`Date: 9/12/2025
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`|. Defendants’ Mischaracterization of Claims
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`Defendants MIT and Stanford fundamentally misunderstand the nature of the claims
`asserted against them. Unlike commercial Defendants—who are accused of both
`copyright infringement and unauthorized platform use—MIT and Stanford are named
`solely for attempting structural reconstruction of the cryptographically sealed system
`described in Plaintiff’s technical publication.
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`The Plaintiff never alleged that these institutions engaged in commercial deployment.
`Instead, both are cited for reverse-engineering behavior in violation of the clear licensing
`terms, which included:
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`e Explicit Non-Disclosure Agreement (NDA) clauses;
`e Contactinstructions for research or licensing access;
`e Adirect prohibition against reverse-engineering or structural cloning.
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`Despite these conditions, both Defendants initiated structural alignment attempts without
`communication or license.
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`Il. The Paper Was Not Public Domain: Conditional Disclosure with NDA
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`The academic publication ResonanceQS: A System for Affective-Ontological Structuring in
`Artificial Intelligence (Zenodo Record No. 15858053, DOI: 10.5281/zen0d0.15858053),
`previously submitted as part of Plaintiff’s original filing, clearly states:
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`Case 1:25-cv-01258-PTG-IDD Document 68 Filed 09/12/25 Page 2 of 4 PagelD# 345
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`“To safeguard its intellectual integrity, the full algorithmic structure—including
`the rhythm encoding layer and anticipatory cadence evaluator—is
`cryptographically sealed and not publicly disclosed. Access is granted only under
`signed NDA.”
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`“Commercial use, duplication, and reverse engineering are strictly prohibited.”
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`MIT and Stanford never contacted the Plaintiff nor signed an NDA. Their structural
`behaviors are documented in sealed traplogs and form the basis for this claim.
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`lll. Traplog Evidence: Defined, Sealed, and Legally Admissible
`Traplogs are SHA-256 + CID cryptographically signed records that:
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`e LogIPranges, timestamps, and attempted reverse-engineering techniques;
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`e Document methods such as tempo_cloning (MIT) and partial_rq_correlation
`(Stanford);
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`e Capture real-time system responses (e.g., echo_rejected, pattern_flagged).
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`Each record is immutable and reproducible via CID verification. Under Federal Rules of
`Evidence Rule 1006, these are admissible as summaries of digital events.
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`IV. MIT & Stanford’s Unique Role
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`IP Meth Targeted
`Institution Address Qfidfi 7 Component Rela:ced Paterr\rt App. Traplog Refr
`MIT 18.9.22.xx temp ResonanceTiming App. No.63/840,133 trap_122
`X o_clo Algorithms (Provisional Filed)
`ning
`Stanford 128.84.xx partia RQ Formula (Paper App.No.63/840,157 traplog 00
`X.XXX Lrg_c 8§4.2) (Provisional Filed) 1
`orrela
`tion
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`These structural actions targeted specific technical components explicitly protected under
`active provisional patent applications. MIT’s attack pattern aligns with the Time-Based
`Emotional Resonance Interface system (App. No. 63/840,133), while Stanford’s activity
`corresponds to the Rhythm Quotient (RQ) Tracking system (App. No. 63/840,157).
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`Both filings were made prior to the observed intrusion attempts, strengthening the claim
`of knowing misappropriation.
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`Case 1:25-cv-01258-PTG-IDD Document 68 Filed 09/12/25 Page 3 of 4 PagelD# 346
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`V. Procedural Copying & Legal Misplacement
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`Defendants have copied arguments intended for commercial tech companies. Their
`motion includes:
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`e Jurisdictional defenses (12(b)(2)) inappropriate for nonprofit research institutions;
`e Copyright-based 12(b)(6) defenses that are irrelevant here;
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`e Ageneralized dismissal of Traplog evidence without addressing its structure,
`cryptographic integrity, or academic access context.
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`These arguments fail to address the actual conduct alleged: unauthorized reverse-
`engineering of a sealed technical system.
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`VI. Legal Relief Requested
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`Plaintiff respectfully requests that this Court:
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`1. Deny MIT and Stanford’s Motion to Dismiss;
`2. Acknowledge the legal admissibility of Traplog evidence under FRE 1006;
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`3. Permit the claims against both institutions to proceed to discovery and injunctive
`relief.
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`VII. Consistency with Verified Complaint
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`This rebuttal is fully consistent with the Verified Complaint submitted on July 30, 2025. The
`Complaint alleged unauthorized structural access and reverse-engineering attempts from
`institutional IP blocks. This filing does not expand the claims but rather clarifies their
`institution-specific application.
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`Commercial Defendants are named for platform-based infringement. MIT and Stanford are
`named solely for reverse-engineering, which they conducted without license or
`correspondence, and in violation of NDA-bound terms.
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`Plaintiff notes that while research institutions are alleged only for direct structural analysis
`without platform integration, commercial defendants are implicated in both system-level
`resonance and unauthorized structural reconstruction. These claims are presented
`separately to assist the Court in evaluating the distinct factual and legal grounds.
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`Case 1:25-cv-01258-PTG-IDD Document 68
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`3
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`Respectfully submitted,
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`/s/ Su-Mi Kim (a.k.a. A
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`Pro Se Plaintiff
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`7360 McWhorter PL1#201
`Annandale, VA 22003
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`Email: healingwaveva@gmail.com
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`Filed 09/12/25
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`Page 4 of 4 PagelD# 347
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