Deirdre Saoirse Moen

Sounds Like Weird

Ellora's Cave: Reply on Opposition to Remand

02 November 2014

elloras-cave-blog-header
I had some expectations about what the reply would consist of.
tl;dr version: I’m disappointed.

My Take on It

  1. 10/24 (Friday) EC’s lawyer files a motion to punt (remand) the case back to state court relying on Rose v. Giamatti.
  2. The same day, DA’s lawyer shoots an email to EC’s saying, “I’m unsure if you’ve reviewed the case you primarily rely upon, but I believe that Rose v. Giamatti says the exact opposite of what you’ve raised it for.” In other words, Randazza said, basically: “Heads up: brain fart?” Which offered the opportunity for Mastrantonio to fix it.
  3. Not hearing anything back, DA’s lawyer files an opposition on Sunday the 26th, including the email from #2. Which was included to demonstrate several points made, not just that one.
  4. On Monday, 10/27, the judge gave EC/JJ a week to file a response. No evidence the judge had read the underlying paperwork, but it decreases his odds of getting it punted to a higher court if he allows time for Plaintiff to clarify.
  5. EC/JJ filed their response on the 31st. Halloween. Trick or treat. It used the same single case citation.

It’s unusual for a motion to rely on a single case cite, and unusual for both sides to rely on the same single cite.
What I expected EC’s lawyer to do: find some other case cites that also cited Rose v. Giamatti and use some more of his skills to strengthen his narrative. ::cough::
Courtney’s analyzed the underlying issues, and I agree. Especially this part:

I lay this all out because EC’s reply confuses the merits of the controversy with the merits of a temporary restraining order. In order to evaluate the reply, you need to understand that first, these are two separate things, and second, that no lawyer–indeed, no halfway decent law student–should confuse the two.

Another Issue Here

In the footnote:

Plaintiffs indicated that because the facts on the ground had changed, the urgency associated with a temporary restraining order had become attenuated and that a consolidation of the hearing with the final hearing on the merits under Rule 65(a)(2) would avoid 2 hearings, 2 trips for defense counsel and his client, 2 briefings, and twice the use of the Court’s time and resources.

I just mention the following and allow you to draw your own conclusions….

  1. Randazza is a noted first amendment attorney.
  2. EC files for a TRO/Preliminary injunction against Dear Author to prevent further postings about EC from DA.
  3. Case law about prior restraint is heavy first amendment case law.
  4. First amendment cases are best heard in federal court (though I’m not sure they’re necessarily federal questions).
  5. EC/JJ wants a remand to state court.
  6. Suddenly the TRO’s urgency has “become attenuated.”

::cough::
Note that the case wasn’t removed because of federal questions, though. It was removed for diversity. Here’s a bit from the UScourts.gov site that explains that (emphasis mine):

A case also may be filed in federal court based on the “diversity of citizenship” of the litigants, such as between citizens of different states, or between United States citizens and those of another country. To ensure fairness to the out-of-state litigant, the Constitution provides that such cases may be heard in a federal court. An important limit to diversity jurisdiction is that only cases involving more than $75,000 in potential damages may be filed in a federal court. Claims below that amount may only be pursued in state court. Moreover, any diversity jurisdiction case, regardless of the amount of money involved, may be brought in a state court rather than a federal court.

This is one case where the defense gets to pick the court, though, because it’s about fairness to them.

Let’s Dig Into Some Older Cases

I wanted to look and see if there were other similar remand cases the federal judge had decided on. “Remand” is a hard word to search on because most federal judges of any tenure have had cases go up on appeal, then be remanded back to their original (federal) court to resume the remainder of the case.
This, however, was a different kind of remand: a case originally filed in state court being removed to federal, then an opposition filed.

22 Exchange LLC v. Exchange Street Associates LLC

Ruling here. Remand was allowed. (Remand ruling took 7 days; attorney’s fees were allowed.)
This situation does not apply in the EC/DA case.
In the case ruled on, a Delaware Plaintiff sued an Ohio Defendant, and the Defendant removed to federal. However, one of the situations where you can’t remove to federal for diversity jurisdiction is if you’re sued in your home state. It’s called the forum defendant rule.
In other words, if Dear Author/Jane Litte had been sued in Iowa where they are based, they wouldn’t have been able to remove to federal. However, that didn’t happen, and thus the underlying reason Exchange was remanded isn’t applicable here.
Similarly, IndyMac Bank, F.S.B. v. Harrison, Rivard, Zimmerman & Bennett, Chartered et al is inapplicable.

Electrical Enlightenment, Inc. v. Lallemand et al

Electrical Enlightenment, Inc. v. Lallemand et al remanded for lack of subject matter jurisdiction. Judge says it best:

Although Defendants attempt to couch the terminology used in the Complaint to assert a federal cause of action under copyright law in paragraphs 13-15, the mere use of the terms “copying Plaintiff’s commercial speech” does not make a copyright claim out of a breach of contract action.

(Remand ruling took over 2 months; attorney’s fees were allowed.)

Lasher v. Bank of America

Ruling here. (Remand ruling took just over a month, but denied attorney’s fees.)
Essentially: lack of a federal question, so lack of subject matter jurisdiction.

In addition, the resolution of the federal question will not be dispositive of the case. First, numerous pure state law claims have been plead by Plaintiffs. Furthermore, even the third cause of action will not be resolved by resolution of the federal law.

Two Others

This case there was a remand mentioned, but I don’t see a response to it on the docket.
Last but not least, this docket has a boatload of people and I don’t want to have to sort it out.
So the prior history I could find doesn’t really shed any light, unfortunately.

So When?

I’m unclear if a remand is considered a dispository motion—or not. Dispository (or dispositive) motions are ones that dispose of some aspect of a case: a motion for summary judgment, for example.
Since a remand ends the case with respect to that court, I’m not sure if it’s considered dispositive. It’s simply a civil procedure point I don’t know.
Anyhow, local rules say dispository motions need rulings within 30 days and other motions within 60. So it could be a while.
Or not.

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My New Greeting Card Line

31 October 2014

Unique, distinctive, and humorous greeting cards sure to please. Now available from my Redbubble store. I’ve had greeting card products available for a while, but now I’ve got some items that are only available in greeting cards, including a few holiday cards.

I Am Not a Turkey

i-am-not-a-turkey-preview
Whimsical fall holiday card. (link)

Tree? What Tree?

what-tree-preview
Whimsical Christmas or Yule card. Even alien cats get into trouble with trees. (link)

May Your New Year Be Cage Free

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Happy New Year! May it be a good one. (link)
Honestly? I think that one’s my favorite.

Missed a Present? I’ve Got You Covered

This one’s in both a Christmas-y variant and a more generic variant.
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Link for the Christmas-y card.
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Link for the generic card.

Congratulations on the New Addition

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Great card for a family with a new baby. Works for a boy or a girl, and the birds aren’t gender specific. (link)
Designed for my favorite actor and his wife and their new baby.

More Cards

I have some great back catalog too! Click images to view the card. Most of these also have other products if you’re interested.
plan-a-25-letters-preview
all-the-important-stuff-preview
Sum-Total-450
doing-the-right-thing-preview

Free Speech Is Best Served #notchilled

This is of limited interest, and the poster’s not actually this big, but the mockup looks awesome so grant me some artistic license here.
notchilled-mockup
not-chilled-preview

Credits

Believe it or not, the new card graphic elements are (except for the tree bits) all fonts.

  1. York Handwriting by Thinkdust.
  2. Monstrinhos by Pinstassilgo Prints.
  3. Card-o-Mat Buddy Birds, also by Pintassilgo Prints.

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Happy Halloween! With Treats!

31 October 2014

happy-halloween
Happy Halloween!
As a kid, my favorite holiday. Still my favorite.

Last Day on Cat Grant’s GoFundMe to Get Her Ellora’s Cave Rights Back

I had the awesome privilege of meeting Cat Grant in person last weekend when I was in her area. We talked for several hours! She’s trying to buy the rights back to her three books still with EC. GoFundMe link.

All Treats for Design Cuts’ Birthday

I’ve spoken about my great love of Design Cuts ever since I discovered them earlier this year. They are re-running twenty-two of their prior deals.
The font used in the image above is Brush Up from Pintassilgo Prints, and is from the Monster Creative Font Bundle.
If I had to pick three of the above….

  1. The All Inclusive Design Bundle.
  2. Monster Creative Font Bundle. or any font bundle.
  3. Any 2 Lil Owls bundle.

This will be running for another week and a half in case you are just overwhelmed with choice. Hell, I was, and I already had 14 of the bundles being re-run. I now, uh, have 17 of them.

A Plug for DealJumbo

Peter of Cruzine Design also runs DealJumbo.com, where he pulls together a lot of great deals, often from Creative Market shops.
Cruzine has some really complicated vintage-style logos and frames that I can’t ever see myself using but want to hoarde all the same. Here’s one of the freebies where you can see what I mean.
The deals DealJumbo runs, though, are far broader in appeal. The “5in1” deals are from five different designers, which is a great concept.
Here are a few active deals I’ve bought:

The monster in the box up top came from one of DealJumbo’s freebies, but it appears to be one only available to mailing list subscribers.

But, But, I Don’t Know How to Do Design Stuff

Another treat!
Look, I get it. I was a Photoshop idiot for years even after taking a couple of classes. These days, I consider myself intermediate in Photoshop skill.
Dustin Lee at Retro Supply started making amazing videos to show off how to use his products. Then he started adding extra videos when you bought his stuff, and they were useful enough that, well, hell with whether or not I need/want the product, I wanna see the videos!
He’s just opened Retro Academy which will feature tutorial videos.

And Now for Something Really Scary: Scientology

Last year, the EEOC sued Dynamic Medical Services for Religious Discrimination.

According to the EEOC’s suit, the company required Norma Rodriguez, Maykel Ruz, Rommy Sanchez, Yanileydis Capote and other employees to spend at least half their work days in courses that involved Scientology religious practices, such as screaming at ashtrays or staring at someone for eight hours without moving. The company also instructed employees to attend courses at the Church of Scientology. Additionally, the company required Sanchez to undergo an “audit” by connecting herself to an “E-meter,” which Scientologists believe is a religious artifact, and required her to undergo “purification” treatment at the Church of Scientology. According to the EEOC’s suit, employees repeatedly asked not to attend the courses but were told it was a requirement of the job. In the cases of Rodriguez and Sanchez, when they refused to participate in Scientology religious practices and/or did not conform to Scientology religious beliefs, they were terminated.

It was later settled for $170,000.
I saw this a lot from the Scientology side of the fence when I was on staff (except for the terminations).
For many years, Scientology’s big clients have been chiropractors, dentists, and related non-mainstream medical practices. There are Scientology-based consulting practices, such as Sterling Management Systems, whose entire goal it is to get everyone in an office “trained” in “Scientology tech.” And audited. And Clear.
Whether they want to be or not.
Most weeks, it was more than half the income of the local Scientology church I worked at.
At the time, I thought it was great. Now, of course, I want to wash all the ick off my psyche.

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Guinness World Record, and I Helped

30 October 2014

great-namaste
Remember in June when I participated in The Great Namaste? An attempt to break the Guinness World Record for the number of people simultaneously doing yoga.

We Did It!

I got this funny email from organizer Tyler Tervooren:

Well, for those last four months, the record was only technically broken. We’ve been waiting… and waiting… and waiting for them to give us the official nod. Kind of like when you’re really excited to get someone’s phone number, but you can’t get a hold of them so you leave a message saying, “Uh, it was really nice to meet you and I think you’re super cool so, um… call me back?” And then you sit and wonder if you had bad breath or crazy eyes or something as each week passes and they don’t call.
And that’s how it felt with Guinness. UNTIL TODAY!

official-certificate

The only thing that’s missing at this point is they haven’t updated the listing on the website yet, which is kind of like when you start dating someone new and realize they still talk to their ex on Facebook. We’re trying not to be jealous, though. We’re certain it will be updated soon.

And Here I Am

In the detail of the above photo….
namaste-detail

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Upcoming Travel, Hotel Envy Edition

29 October 2014

Ladera Resort
So, remember last month when I said I was at 97 countries after an ill-advised tromping through the Vatican museums?
We’re heading to the Caribbean on Friday, and I’ll cross the 100-country mark.
A few years ago, I listed nine hotels from my “hotel envy” list. I used to work in the luxury hotel industry, so I’ve seen and heard about a ton of beautiful hotels, but these were particular standouts for me.
This will be my third visit from that list of nine. (One, Kona Village, has since closed for good. Palazzo Sasso is now called Palazzo Avino.)

Conrad Maldives

I was extremely lucky to be able to book a three-night stay on Hilton points before the devaluation. There’s no question that this is the nicest place I’ve ever stayed.
The Maldives consist of many thousands of coral atolls in the Indian Ocean. Because of that, and the fragility of the atoll reefs, much of the inter-country travel is via seaplane.
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Maldivian Air Taxi Air Safety Card:
Maldivian Air Taxi Safety Card
Ithaa Restaurant. You can dine underwater! Yeah, I took food photos too (and dinner was fabulous), but that’s not why you go.
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Some other photos:
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Hilton Bora Bora

Bora Bora is far more mountainous, a large atoll surrounding an island with a central volcanic plug.
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Within the atoll, quite a few resorts have overwater bungalows, including the Hilton. Here’s a view from ours:
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And one of my favorite pictures I’ve taken of all time. It’s also available as a print and on other products like t-shirts, coffee mugs, shower curtains and stuff.
Bora Bora 1200

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My Twitter Halloween Outfit

28 October 2014

Seasonal and timely. As usual, my holiday profile name is Dire Red Omen.
Update: I calmed this down because it was driving me crazy.
halloween-avatar-ankh-4
And the older versions….

v 1.0

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v 2.0

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v 3.0

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How to Unpublish a Book from iBooks

28 October 2014

So you’d figured out how to sell your book on iBooks. Now you’ve got a different problem: what if you need to remove your book from sale?
There’s been an assertion that this is a difficult thing to do.
Not so much.

With iBooks, You Publish Via an App

I use iTunesProducer to package and upload my book and make it available for sale. It makes a manifest file around the EPUB that includes product and sales information, then saves it in your iTunes Playlists. (Yet another WTF? from Apple, albeit a minor one.)
However, so far as I can tell, you can’t remove it from sale that way.
There’s a reason for this, I suspect. Since someone who’s purchased the book has the right to redownload their purchases, that means that Apple’s system still need to keep that record of you having published it even if you are no longer the publisher of record for new sales.

Use iTunesConnect to Stop Selling

Here’s the https link.
Log in, and you’ll see this home screen. If you haven’t logged in in a while, it has changed.
iBooks - iTunes Connect Home
Click on My Books. A publisher with a lot of books will need to use the search page. I, uh, don’t.
iBooks - iTunes Book List
Click on the relevant book and you’ll get the book page.
iBooks - Book Page
Click on the Rights and Pricing and you’ll get the sales territory management page.
Click the Select All button above the pricing matrix.
Select No next to Cleared for Sale on the top form.
iBooks - Select No under Cleared
Scroll to the bottom of the page and click Continue.
iBooks - Continue after changing sales info
There’s probably another step or two, but I don’t happen to want to take my own iBooks items off sale for this experiment.
Still, it’s just not that difficult.

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Proving Substantial Truth

27 October 2014

elloras-cave-blog-header
Substantial truth can be tricksy. Here’s a DMLP post with a few examples.
Two of those examples where the statements were ruled substantially true:

A statement that a boxer tested positive for cocaine, when actually he had tested positive for marijuana. See Cobb v. Time Inc. 24 Media L. Rep. 585 (M.D. Tenn 1995).
A statement that a man was charged with sexual assault, when actually he had only been arrested but not arraigned. See Rouch v. Enquirer & News of Battle Creek, 440 Mich. 238 (1992).

Look, I haven’t read up on the case law, but the above two examples should demonstrate that “substantial truth” isn’t cut and dried.

Hypothetically Speaking

Let’s say the claim in question is about “a set of authors” and whether or not they’ve been paid in a timely manner. Let’s say there are more than 500 authors, each of which has one or more books.
Now, the person believing they’ve all been paid may in fact only have been double-checking the highest earners.
However, let’s say the claims are true for three authors:
a = {Fred, George, Mark}
That still means one needs to sift through an unknown large portion of the data set before one determines that it’s true for “a set” of them.

And Now an Intermission

I’m done with the above hypothetical.
I have no personal information about the actual facts of the Ellora’s Cave case. However, I’d like to look at some back-of-the-envelope calculations.

How Big Is the EC Data Set?

Let’s go with the following assumptions:

  1. 934 authors (last I counted). Let’s round down to 900.
  2. Amazon gives me 6,767 items when I search for “Ellora’s Cave.” Let’s assume 4,500. Ergo, an author has an average of 5 titles, including paperback editions.
  3. Each book sells, per month, in an average of 5 stores from: EC’s own site, ARe, Kindle, Nook, Kobo, Google, iBooks, foreign markets for same, and any paperback vendors.
  4. Need to look back to when the accounting system changed last year, so 10 months of data at present.
  5. Each line item has seven pieces of data per month per author (per Cat Grant’s statements). The 7 pieces of data are: ISBN, title, format, store, amount received per unit, qty sold, total received (calculated, so not actually a separate piece of data), royalty %, royalty paid (also calculated).

So for each month:
4500 books x 5 stores books sold in that month x 7 other pieces of data = 157,000 pieces of data (or 174 per author). Per. Month.
Times ten months, so 1.57 million.
Consider the legal and accounting billing that would be involved in re-verifying and distilling 1.57 million pieces of data.

Another Aspect of Substantial Truth

In a case where “a set of authors” may not have received timely payments, royalty payments received by the publisher not corresponding with line items paid to authors could potentially also be a source of substantial truth.
Therefore, one would also need to audit amounts received from, say, Amazon, and amounts paid out in royalty checks that month, and determine that the amounts were equal. (Especially when others have said they’ve seen no Amazon drops during the same period for similar non-EC books.)
There are also around 9,000 checks to sort out.

  • When were they written?
  • When were they mailed?
  • When were they cashed?
  • When did they clear the bank?
  • Are any missing? Either not paid or not cashed?
  • If they’re missing, were they actually cut?

In theory, all that information is already entered and double-checked and could be provided to the defense at a moment’s notice.

The Question that Started This Post

@deirdresm Law Q: Are EC actions only relevant to the case up until the time it was filed? Recent payment timing immaterial? #notchilled

— Susan Garbanzo (@Soenda) October 27, 2014

It’s a good question. It doesn’t change the absolute truth of what was said on the day it was said, no.
But if events post-filing help show substantial truth, then probably they’re relevant.

@Soenda I haven’t read the case law; I can only guess. My guess: similar actions after filing help substantive truth claim. #notchilled

— Deirdre Saoirse Moen (@deirdresm) October 27, 2014

My Intuition

This case, if it gets all the way to a jury trial, will be far, far more expensive to litigate than other people have expected because the potentially triable matters of fact involve large data sets.
It’s my understanding that the burden of proof is on the plaintiff to show substantive falsity. Meaning: Ellora’s Cave and the mysteriously joined Jasmine Jade Enterprises need to demonstrate that.
Can they sample the data?
I don’t see how they can prove that “a set of authors” is defamatory without the full data being examined. “A set of authors” doesn’t need to be a large set.
My intuition, given the lagging of checks mailed weeks after the check date, all the reports of no answer for months when authors asked about royalty checks, is that that aspect of the DA post, at least, was substantively true.
Consider, for example, how small the two examples at the top are in terms of data. A single arrest. A single drug test, and possibly one or more followups. But not 1.57 million of them.
Completely different animal, litigation-wise.

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Ellora's Cave: No COO? Selling Reverted Books? Lawsuit Update

27 October 2014

elloras-cave-blog-header

First: New EC-themed Art!

See above.
I’ve been trying to make a habit of including art with posts so there’s always a featured image. It’s a tough job. Broken ankh render from The Hairy Man.

Ellora’s Cave Lost Its COO?

Behold the current LinkedIn profile of Susan Edwards, who was Ellora’s Cave’s COO.
Note that it lists “Writer and Editor” as a job from “1980 – Present”, but Ellora’s Cave from “January 2005 – October 2014”, meaning she’s no longer there.
se_linkedin
Detail of the Ellora’s Cave entry:
se_ec_detail
Now Dear Author tweeted this last month:

Re Ellora’s Cave: Whitney Mihalik, the managing editor, and Susan Edwards, the chief operating officer, have both resigned.

— DearAuthor (@dearauthor) September 15, 2014

…and…

EC trying to retain Susan Edwards, COO, who previously indicated she was leaving.

— DearAuthor (@dearauthor) September 23, 2014

But this is the first I’ve heard that it was externally verifiable.

Ellora’s Cave Allegedly Selling Titles It Doesn’t Have the Rights To

Angelia Sparrow posted this morning.

My mail today. Why does a check cut on September 30 have an October 25 postmark?
Why are books that I have had the rights returned still on sale?

“Eight Days Ablaze” was returned in Feb. I am not getting paid for it. Why is it still available at Amazon, iTunes, GooglePlay, and Ellora’s Site itself?

“Eight Days Ablaze” is apparently still theirs. I checked my reversion letters, and it is not mentioned. “For Love of Etarin” and “Raising the Dead” however, HAVE reverted.
“For Love of Etarin” is the same way. And yet, it still available on GooglePlay.
Glad Hands and Privateer’s Treasure are still up on Amazon, And the rights reverted back August 15.

I can verify that it’s still on sale, but obviously I have no personal notice of whether or not the rights are reverted. I’ll just point authors to a resource out there for you. If your rights are reverted, then a DMCA takedown notice to the vendor is an appropriate—and probably the fastest—action.
It doesn’t give you the correct royalties for any amounts that were due you, though. That has to be addressed separately. Unfortunately.
Previous post of interest from Angelia.
I previously talked about Shoshanna Evers’s related story of books being sold after reversion here.
Also, Cat Grant shows her May 2014 royalty statement, received in September, where she states that she was paid for a Nook ebook on a title that, per her, reverted in November 2013.
B&N/Nook pays 60 days after the end of the month. So, if a sale took place in November while EC still had the rights, it should have been in the royalty statement for February or maybe March. May is unreasonable.
Again, I can see what the allegations are, but I don’t have personal knowledge of the reversion, just taking the claims at face value. If three authors are correct, how many other authors has EC been selling the works of without the rights to?

The No-Frills EC v. DA Lawsuit Page

Yesterday, out of frustration at the lawsuit documents and the order mine weren’t in, I created this simple page that emulates the federal court docket.
For some exhibits, there’s a short summary. Each, where applicable, is color-coded based on the lawsuit “thread” as Courtney defined them. And, if there are blog posts relating to them, they’re listed below the docket item.
It’s a very lightweight page: no images, no Javascript, and very very little CSS.

Lawsuit Update

Yesterday, defense filed their opposition to Ellora’s Cave’s Motion to Remand (from federal court to state court). Courtney Milan analyzes.
Particularly interesting footnote:

On 7 October, an email was sent to at least one of Ms. Lampe’s supervisors. On 14 October that same email was forwarded to the entire department within which Ms. Lampe works. This is consistent with prior actions by directors of Ellora’s Cave. Ellora’s Cave has also engaged in acts to try and intimidate witnesses in this case. Therefore, sending this subpoena on short notice was of great importance. Since the Defense addressed this with Plaintiff’s counsel, these actions have waned.

Wow. Just. Wow.
Let me pull this one line out and bold it.

Ellora’s Cave has also engaged in acts to try and intimidate witnesses in this case.

That is not OK.
From the opposition brief itself:

All parties agreed that the matter required needed additional time, and therefore the parties stipulated to a hearing to be held on 27 October. In the intervening period, counsel for the Defense was able to fully evaluate the case, and on 17 October it became 100% clear that removal was appropriate.

I’m just going to put those two together and back away slowly.

What’s Next?

Jane Litte’s answer is expected soon. The court granted the motion to continue on the TRO and gave EC/JJ 7 days to file a response to defense’s objection about the removal. In that way, the removal issue is settled before the TRO hearing, which does make sense.

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Sales Analysis

25 October 2014

PubNumbers.001
I’m a numbers person, and I like charts and graphs and other ways to reassure myself that things are Getting Done.
I check at the beginning of each month to make sure my titles are up where they’re supposed to be and to record the sales.
It would take more time if I had more books. This is the summary over time; one title dates back to 2011 and the other was published this year. I hear a lot of people wanting to sell on Amazon only. In my case, that would mean cutting 2/3 of my revenue.
I also have a spreadsheet that tracks each title month-by-month, with a different tab for each year.

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