Well, Raanan Katz and his attorney Todd Levine of Kluger, Kaplan, Katzen, Silverman, Levine argued in his reply in support of Raanan Katz motion for summary judgement in alleged copyright case. Here are some extractions from the "powerful" arguments that Raanan Katz expressed through his attorney Todd Levine to the Federal Court. Well, I simply love this team...
To remind, Raanan Katz filed a lawsuit against Google and Blogger alleging copyright to his own face, which he found "unflatering" and "atrocity".
"Plaintiff, RAANAN KATZ, hereby files his Reply in Support of his Motion for Summary Judgment, and states as follows:...
...Blogger continues to depict Raanan Katz as a litigious billionaire who purportedly considers an unfiattering picture to be an "atrocity,"...Blogger has been infringing upon Katz's copyright as part of her attacks on Katz."
So, what is the real legal matter then? Raanan Katz being a "litigious billionaire", "his unflattering picture to be an "atrocity"", "infringing upon Katz's copyright as part of blogger's attacks on Katz".
Confused? Why Raanan Katz states that his own activities in multiple courts are " attacks against him".
Another Raanan Katz "killer" argument.
Mr. Raanan Katz produced his OWN correspondence with Broward Bulldog ("letter") and this document was used in support of my summary judgement motion. But, look what Raanan Katz says in his pleadings signed by attorney Todd Levine- this letter - "hearsay...not been authenticated" ...
"Furthermore, Bloger's reliance on an unsigned letter from a non-party to the Broward Bulldog is misplaced. The letter is hearsay and has not been authenticated or corroborated through any other testimony, so it cannot be used to create a genuine issue of fact. Vickers v. Fed. Express Corp., 132 F. Supp. 2d 1371, 1381 (S.D. Fla. 2000) (letters that were not authenticated, corroborated by testimony other than the defendant's own, and were hearsay, could be considered in opposition to summary judgment); see also Duplantis v. Shell Offshore, Inc., 948 F.2d 187 (Sth Cir. 1991); Travlandv. Ector County, Texas, 39 F.3d 319 (5th Cir. 1994); Cameron v. Wall, No. 2:09CV234KS-MTP, 2010 WL 4878705, at 4 (S.D. Miss. Nov. 24, 2010). "
Additionally, Raanan Katz through his attorney Todd Levine argues
"Without a proper foundation, the blogger cannot show, for example, who drafted the letter, whether the scrivener is speaking from personal knowledge, whether the letter is in its final form or is meant to be a mere draft, or whether the letter is simply in artfully drafted. It is blogger's obligation to properly authenticate the letter if she seeks to create a genuine issue of fact. See Vickers, 132 F. Supp. 2d at 1381; Duplantis, 948 F.2d 187; Traviand, 39 F.3d 319; Cameron 2010 WL 4878705, at 4 For similar reasons, Alexis.com's web pages are inadmissible for purposes of summary judgment. See VS Technologies, LLC v. Twiiier, Inc., No. 2:11 CV43 e 2011 WL 4744911, at 8.
Another "powerful" point Raanan Katz is making:"There is no evidence that Haaretz.com is merely an "online newspaper." But this will be covered in a separate article.
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To remind, Raanan Katz filed a lawsuit against Google and Blogger alleging copyright to his own face, which he found "unflatering" and "atrocity".
"Plaintiff, RAANAN KATZ, hereby files his Reply in Support of his Motion for Summary Judgment, and states as follows:...
...Blogger continues to depict Raanan Katz as a litigious billionaire who purportedly considers an unfiattering picture to be an "atrocity,"...Blogger has been infringing upon Katz's copyright as part of her attacks on Katz."
So, what is the real legal matter then? Raanan Katz being a "litigious billionaire", "his unflattering picture to be an "atrocity"", "infringing upon Katz's copyright as part of blogger's attacks on Katz".
Confused? Why Raanan Katz states that his own activities in multiple courts are " attacks against him".
Another Raanan Katz "killer" argument.
Mr. Raanan Katz produced his OWN correspondence with Broward Bulldog ("letter") and this document was used in support of my summary judgement motion. But, look what Raanan Katz says in his pleadings signed by attorney Todd Levine- this letter - "hearsay...not been authenticated" ...
"Furthermore, Bloger's reliance on an unsigned letter from a non-party to the Broward Bulldog is misplaced. The letter is hearsay and has not been authenticated or corroborated through any other testimony, so it cannot be used to create a genuine issue of fact. Vickers v. Fed. Express Corp., 132 F. Supp. 2d 1371, 1381 (S.D. Fla. 2000) (letters that were not authenticated, corroborated by testimony other than the defendant's own, and were hearsay, could be considered in opposition to summary judgment); see also Duplantis v. Shell Offshore, Inc., 948 F.2d 187 (Sth Cir. 1991); Travlandv. Ector County, Texas, 39 F.3d 319 (5th Cir. 1994); Cameron v. Wall, No. 2:09CV234KS-MTP, 2010 WL 4878705, at 4 (S.D. Miss. Nov. 24, 2010). "
Additionally, Raanan Katz through his attorney Todd Levine argues
"Without a proper foundation, the blogger cannot show, for example, who drafted the letter, whether the scrivener is speaking from personal knowledge, whether the letter is in its final form or is meant to be a mere draft, or whether the letter is simply in artfully drafted. It is blogger's obligation to properly authenticate the letter if she seeks to create a genuine issue of fact. See Vickers, 132 F. Supp. 2d at 1381; Duplantis, 948 F.2d 187; Traviand, 39 F.3d 319; Cameron 2010 WL 4878705, at 4 For similar reasons, Alexis.com's web pages are inadmissible for purposes of summary judgment. See VS Technologies, LLC v. Twiiier, Inc., No. 2:11 CV43 e 2011 WL 4744911, at 8.
Another "powerful" point Raanan Katz is making:"There is no evidence that Haaretz.com is merely an "online newspaper." But this will be covered in a separate article.
