User talk:Amortias/Archives/2015/July

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Please comment on Wikipedia talk:WikiProject Pornography

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Change from announced time table for the Arbitration enforcement arbitration case

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Epoch Times

I did include a source in my edits, which is the book Falun Gong and the Future of China by David Ownby, and I even included a page number (238). In fact, the same book was already being used as a source for several other points on the page. You can check it in the history. Snesbogyi (talk) 12:53, 1 July 2015 (UTC)

Please comment on Talk:Derry

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Please comment on Talk:Hillary Clinton

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The Signpost: 01 July 2015

Please comment on Wikipedia talk:Deletion policy

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Please comment on Talk:List of European cities by population

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Motion passed in AE arbitration case granting amnesty and rescinding previous temporary injunction

This message is sent at 12:53, 5 July 2015 (UTC) by Arbitration Clerk User:Penwhale via MassMessage on behalf of the Arbitration Committee. You are receiving this message because your name appears on this list and have not elected to opt-out of being notified of development in the arbitration case.

On 5 July, 2015, the following motion was passed and enacted:

  1. Paragraphs (2) and (3) of the Arbitration Committee's motion of 29 June 2015 about the injunction and reporting breaches of it are hereby rescinded.
  2. The Arbitration Committee hereby declares an amnesty covering:
    1. the original comment made by Eric Corbett on 25 June 2015 and any subsequent related comments made by him up until the enactment of this current motion; and
    2. the subsequent actions related to that comment taken by Black Kite, GorillaWarfare, Reaper Eternal, Kevin Gorman, GregJackP and RGloucester before this case was opened on 29 June 2015.

Please comment on Talk:Israel

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Account Creation Interface application

Hi, Amortias. Are you still interested in joining the Account Creation Team? If so, please complete your application by leaving a signed edit below with your identification diff from the Identification noticeboard and acknowledgement that you have read, understand and will comply with the WMF Privacy Policy and the Request an account/Guide|ACC Guide. Take care, DocTree (ʞlɐʇ·ʇuoɔ) WER 04:02, 6 July 2015 (UTC)

[1]. Acknowledged have read above links. Amortias (T)(C) 11:41, 6 July 2015 (UTC)
Hate to be a stickler but please state that you understand and will comply with policy and guidelines. If you have questions about then, I will try to clarify. Regards, DocTree (ʞlɐʇ·ʇuoɔ) WER 16:59, 6 July 2015 (UTC)
That's fine. Guidelines read and will be abided to.Amortias (T)(C) 17:01, 6 July 2015 (UTC)
Thanks. The huge backlog has now been knocked down. The ACC Team is now getting most account requests handled in minutes or hours rather than days. You may have to hang around IRC and act quickly to reserve new requests for an account. I recommend that you request a wikimedia cloak as described here to use on IRC. The ACC Team's IRC channel is restricted to help preserve privacy of the requesters and security of the system. There's usually a couple of experienced ACC team members on the channel to answer questions and help with borderline or difficult requests. I'm about to approve your request but it may take a day or two before a tool root gets your ID bit set in the tool. They're still busy dealing with recovery from the recent catastrophic crash of the wmflabs database servers. Once that bit is set, you will be able to log into the system. Start out slow and handle each request carefully. Welcome to the team! DocTree (ʞlɐʇ·ʇuoɔ) WER 19:38, 6 July 2015 (UTC)

ACC tool access request approved

Amortias, thank you for your interest in the account creation process. I have verified that you are identified to the Wikimedia Foundation and approved your request.

You may now access the interface here pending a tool root marking your account as identified in the tool database. Before you begin handling requests, please ensure you have read and understood the account creation guide and username policy to familiarise yourself with the process.

Please subscribe yourself to the private ACC mailing list following the instructions on that page. I also advise that you also join us on IRC #wikipedia-en-accounts connect where a bot informs us when new account requests come in and you can get real time advice on how to handle requests.

Please note failure to correctly assess requests will result in suspension of tool access. Account creation is not a race, and each one should be handled diligently and thoroughly. Releasing personally identifying information (such as IP and email addresses), whether intentionally or unintentionally, is treated very seriously and will generally result in immediate suspension.

Currently you are allowed to create up to six accounts per day, and you won't be able to create an account with a similar name to that of another user; these requests are marked as "Flagged user needed" on the interface. However, if you reach the limit frequently, you can request the account creator permission at WP:PERM/ACC.

Please don't hesitate to get in touch with me if you have any questions. Thank you for participating in the account creation process. Again welcome! DocTree (ʞlɐʇ·ʇuoɔ) WER 19:40, 6 July 2015 (UTC)

Please comment on Talk:Soka Gakkai

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Please comment on Talk:Herbert Hope Risley

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Please comment on Wikipedia talk:WikiProject Food and drink

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Please comment on Talk:Poland

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Please comment on Talk:Same-sex marriage in the Pitcairn Islands

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The Signpost: 08 July 2015

Please comment on Talk:Philip Benedict

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Please comment on Talk:On Becoming Baby Wise

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Please comment on Talk:Eliot Higgins

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Please comment on Wikipedia talk:WikiProject Military history

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Please comment on Talk:United States

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Mars Callahan Controversy on Wiki removed

Mars Callahan's involvement with Gawk Corp. has been fully dismissed. Please remove this section.

TLDR

Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Gawk Incorporated, No. CV-14-02416-PHX-DLR Plaintiff, ORDER v. Gregory Mars Martin, et al., Defendants. Before the Court are Defendants Gregory Mars Martin, aka Mars Callahan, Paul Mayersohn, and Surpin & Mayersohn, LLP’s (collectively, the “Moving Defendants”) Motion to Dismiss for Lack of Personal Jurisdiction, (Doc. 13), and Plaintiff’s Motion to Strike, (Doc. 32). The Court has considered the motion to dismiss, Plaintiff’s Response, (Doc. 23), Plaintiff’s Notice of Filing the Affidavit of Ryan Wyler, (Doc. 24), the Moving Defendants’ Reply, (Doc. 25), and Plaintiff’s Complaint, (Doc. 1). The Court has also considered the parties’ statements at oral argument, (Doc. 26), and their supplemental briefs, (Docs. 30, 31). For the following reasons, the motion to dismiss is granted and the motion to strike is denied. BACKGROUND Plaintiff Gawk, Inc. (“Gawk”), a Nevada corporation, is an online distributor of digital programming, including feature films, television series, and sporting events. (Doc. 1 at ¶ 12.) Defendant Gregory Mars Martin was the CEO and a director of Gawk 

Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 2 of 11 until he was fired for “misuse, conversion, and looting of corporate funds” and for failing to disclose a cease-and-desist order issued by the State of California. (Doc. 1 at ¶ 11.) Before his termination, Martin—along with his partner John Hermansen (who is a defendant in this case but not a party to this motion)—paid entertainment attorney Paul Mayersohn $80,000 in Gawk funds, which Mayersohn used for work he did for Martin and Hermansen personally. (Id. at ¶ 13(f).) Additionally, Martin and Hermansen paid themselves exorbitant salaries; used corporate funds for personal obligations, including payments to the accounting firm EllisPenn & O’Connor, Inc.; raised over $3 million from an investor for two “nonexistent movie or television projects,” which “forced [Gawk] to settle with that investor at a substantial cost”; and sold to Gawk the assets of LLCs in which they had interests, but never delivered any assets. (Id. at ¶ 13.) Gawk filed this lawsuit on October 30, 2014, naming Martin and his spouse, Hermansen and his spouse, Mayersohn and his spouse, Surpin & Mayersohn LLP (the “Firm”), Michael O’Connor and his spouse, and EllisPenn & O’Connor, Inc. as defendants.1 Martin, Mayersohn, and the Firm have filed a motion to dismiss, arguing that the Court does not have personal jurisdiction over them. MOTION TO DISMISS I. Legal Standard The Moving Defendants have moved to dismiss the claims against them under Fed. R. Civ. P. 12(b)(2). They argue that the Court has neither general nor specific personal jurisdiction over them. The plaintiff bears the burden to show that personal jurisdiction is appropriate. Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797, 800 (9th Cir. 2004). Because the Court is considering only the parties’ pleadings and their submitted written materials, Gawk need only make a prima facie showing of jurisdictional facts to defeat the motion to dismiss, Martinez v. Aero Caribbean, 764 F.3d 1062, 1066 (9th Cir. 2014), i.e., it need only “demonstrate facts that if true would support jurisdiction over the defendants,” Ballard v. Savage, 65 F.3d 1495, 1498 (9th Cir. 1995). 1 All of the spouses were named as Jane Does. - 2-  Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 3 of 11 “The plaintiff cannot simply rest on the bare allegations of its complaint, but uncontroverted allegations in the complaint must be taken as true.” Mavrix Photo, Inc. v. Brand Techs., Inc., 647 F.3d 1218, 1223 (9th Cir. 2011) (internal quotation marks and citation omitted). The court may not assume the truth of such allegations if they are contradicted by affidavit. Id. (citing Data Disc, Inc. v. Sys. Tech. Assocs., Inc., 557 F.2d 1280, 1284 (9th Cir. 1977)). However, factual disputes are resolved in the plaintiff's favor. Id. (citing Pebble Beach Co. v. Caddy, 453 F.3d 1151, 1154 (9th Cir. 2006)). “Federal courts ordinarily follow state law in determining the bounds of their jurisdiction over persons.” Daimler AG v. Bauman, --- U.S. ---, ---, 134 S. Ct. 746, 753 (2014). Arizona has authorized its courts to exercise jurisdiction over persons to the maximum extent permitted by the Due Process Clause of the Constitution. See Ariz. R. Civ. P. 4.2(a); A. Uberti and C. v. Leonardo, 181 Ariz. 565, 569, 892 P.2d 1354, 1358 (1995) (“Arizona will exert personal jurisdiction over a nonresident litigant to the maximum extent allowed by the federal constitution.”). The Constitution permits courts to exercise personal jurisdiction over nonresident defendants if there are at least “minimum contacts” with the forum such that the exercise of jurisdiction “does not offend traditional notions of fair play and substantial justice.” Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945) (internal quotation marks and citations omitted). II. General Jurisdiction Gawk states that this Court “may have” general jurisdiction over Martin “because of the sheer number of contacts” he had with Arizona. (Doc. 23 at 8.) General jurisdiction exists over a non-resident defendant when the defendant “engage[s] in continuous and systematic general business contacts that approximate physical presence in the forum state.” Schwarzenegger, 374 F.3d at 801 (internal quotation marks and citations omitted). “For an individual, the paradigm forum for the exercise of general jurisdiction is the individual’s domicile . . . .” Goodyear Dunlop Tires Operations, S.A. v. Brown, --- U.S. ---, ---, 131 S. Ct. 2846, 2853 (2011). The standard for general jurisdiction is “exacting” because “a finding of general jurisdiction permits a defendant to - 3-  Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 4 of 11 be haled into court in the forum state to answer for any of its activities anywhere in the world.” Schwarzenegger, 374 F.3d at 801 (citations and internal quotation marks omitted). Martin is a resident of California, (Doc. 1 at ¶ 2), and Gawk has not shown that he has contacts approximating domicile in Arizona. Gawk claims that Martin attended multiple meetings in Arizona, but provides only one specific occasion—a meeting on April 9, 2014, in Scottsdale. (Doc. 23 at 9–10.) Gawk also alleges that Martin regularly communicated with individuals in Arizona by telephone and email. However, “[m]aking telephone calls and sending telexes and letters . . . are not activities which support a finding of general jurisdiction.” Gates Learjet Corp. v. Jensen, 743 F.2d 1325, 1331 (9th Cir. 1984). Additionally, on the record before it, the Court cannot conclude that Martin’s meetings in Arizona—even if they were frequent—approximated his being domiciled here. Gawk has not shown that this Court has general jurisdiction over Martin. III. Specific Jurisdiction Gawk contends this Court has specific jurisdiction over Martin, Mayersohn, and the Firm. “When a plaintiff relies on specific jurisdiction, he must establish that jurisdiction is proper for ‘each claim asserted against a defendant.’” Picot v. Weston, 780 F.3d 1206, 1211 (9th Cir. 2015) (quoting Action Embroidery Corp. v. Atl. Embroidery, Inc., 368 F.3d 1174, 1180 (9th Cir. 2004)). “If personal jurisdiction exists over one claim, but not others, the district court may exercise pendent personal jurisdiction over any remaining claims that arise out of the same common nucleus of operative facts as the claim for which jurisdiction exists.” Id. (internal quotation marks and citations omitted). The Ninth Circuit employs a three-part test to assess whether a defendant has sufficient contacts with the forum state to be subject to specific personal jurisdiction: (1) The non-resident defendant must purposefully direct his activities or consummate some transaction with the forum or resident thereof; or perform some act by which he purposefully avails himself of the privilege of conducting activities in the forum, thereby invoking the benefits and protections of its laws; (2) the claim must be one which arises out of or relates to the - 4-  Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 5 of 11 defendant’s forum-related activities; and (3) the exercise of jurisdiction must comport with fair play and substantial justice, i.e. it must be reasonable. Id. (citing Schwarzenegger, 374 F.3d at 802). The plaintiff has the burden of proving the first two prongs. CollegeSource, Inc. v. AcademyOne, Inc., 653 F.3d 1066, 1076 (9th Cir. 2011). If he does, the burden shifts to the defendant to set forth a “compelling case” that the exercise of jurisdiction would not be reasonable. Id. The exact form of the Court’s jurisdictional inquiry depends on the nature of the claims at issue. When a claim sounds in contract, the Court applies a “purposeful availment” analysis and asks “whether a defendant has purposefully availed himself of the privilege of conducting activities in the forum State, thus invoking the benefits and protections of its laws.” Picot, 780 F.3d at 1212 (quoting Schwarzenegger, 374 F.3d at 802). For claims sounding in tort, the Court applies a “purposeful direction” test and finds that a defendant purposefully directed his activities at the forum state if he: “(1) committed an intentional act, (2) expressly aimed at the forum state, (3) causing harm that the defendant knows is likely to be suffered in the forum state.” Id. at 1214 (citing Calder v. Jones, 465 U.S. 783 (1984)). a. Mayersohn and the Firm Mayersohn is a resident of California, (Doc. 1 at ¶ 4), and the Firm is a California limited liability partnership, (id. at ¶ 5). Gawk has brought claims against them for conversion, civil conspiracy to defraud plaintiff, and civil conspiracy to covert plaintiff’s property. The essence of Gawk’s claims is that Mayersohn received $80,000 of Gawk’s funds from Martin and used those funds to satisfy Martin’s personal obligations, not to perform work for Gawk. It is undisputed that these actions occurred in California. As clarified at oral argument, Gawk’s position seems to be that Arizona courts have personal jurisdiction over Mayersohn and the Firm because Mayersohn was Gawk’s attorney and Gawk’s principal place of business is Arizona. The Moving Defendants dispute that Arizona was Gawk’s principal place of business and claim that, even if it was, - 5-  Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 6 of 11 Mayersohn and the Firm did not have sufficient Arizona contacts to warrant personal jurisdiction over the claims. The parties agree that a corporation’s principal place of business is the place where it “maintains its headquarters—provided that the headquarters is the actual center of direction, control, or coordination.” (Doc. 31 at 2; see Doc. 30 at 3.) In its Complaint, Gawk states that it is a corporation “doing business in the State of Arizona.” (Doc. 1 at ¶ 1.) Similarly, Gawk’s current CEO stated in an affidavit that Gawk is “a Nevada Corporation doing a significant amount of business in the State of Arizona.” (Doc. 23-1 at ¶ 2.) Neither Gawk’s Complaint nor its affidavits state that Gawk’s headquarters are located in Arizona. Citing a Securities and Exchange Commission filing stating that Gawk’s “principal executive offices” are located in Los Angeles, the Moving Defendants assert that Gawk’s principal place of business is in California. (See Doc. 13-1.) Gawk claims that the office listed on the form “is a virtual office or simply a mail drop,” (Doc. 30 at 4), but does not provide any evidence supporting this allegation. Gawk asserts that its principal place of business is in Arizona because its IT department, its Chief Technology Officer, its accountant, a consultant, and its largest investor are located in Phoenix. (Id. at 3.) Notably, however, Gawk admits that Scott Kettle, its current Chief Executive Officer and Chairman, does not live in Arizona. Rather, he visits Arizona “on a weekly basis” to meet with Gawk’s IT department and accountant. (Id. at 3.) Likewise, the record reveals that Martin, Gawk’s former CEO, did not live in Arizona. Gawk has not disclosed whether it has corporate officers beside a CEO and CTO, and, if so, where those officers live and work. Gawk also has not alleged that Arizona is the center of direction and control of Gawk activities, other than its IT operations. Therefore, even taking as true Gawk’s allegation that the address in Los Angeles is simply a place where mail is received, Gawk has not shown that it is directed and controlled from Arizona. Additionally, Gawk’s emphasis on its own Arizona connections runs afoul of the Supreme Court’s instruction that the Court’s “‘minimum contacts’ analysis” must “loo[k] to the defendant’s contacts with the forum State itself, not the defendant’s contacts with - 6-  Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 7 of 11 persons who reside there.” Walden v. Fiore, --- U.S. ---, ---, 134 S. Ct. 1115, 1122 (2014) (citing Int’l Shoe, 326 U.S. at 319). The plaintiff “cannot be the only link between the defendant and the forum,” and, although “a defendant’s contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties, . . . a defendant’s relationship with a plaintiff or third party, standing alone, is an insufficient basis for jurisdiction.” Id. at 1122–23. Gawk insists that Mayersohn knew that Gawk did business in Arizona and would be harmed in Arizona. But the Supreme Court has cautioned against looking to a defendant’s knowledge of a plaintiff’s “strong forum connections.” Id. at 1124. Examining Mayersohn and the Firm’s own contacts with the state of Arizona, the Court concludes those connections do not warrant the exercise of personal jurisdiction in this case. In its Response, Gawk focuses on communications between Mayersohn and Gawk’s counsel in Arizona. In June of 2014, Gawk’s counsel sent a letter to Mayersohn inquiring about the legal services Mayersohn performed with the $80,000 he received from Gawk. (Doc. 23 at 11.) Mayersohn replied to Gawk’s counsel in a letter and refused to provide information about the funds received or the services performed for Gawk. (Id. at 11.) In early July of 2014, Mayersohn sent another letter to Gawk’s counsel, stating that his office did not receive $80,000 from Gawk and that he had “rendered significant services for Gawk for which [he had] not been fully paid.” (Doc. 23-1 at 11.) Mayersohn explained that he had not been paid for, among other services, preparing “an exclusive negotiating agreement with Doyle Knudson.” (Doc. 32-1 at 11.) In November of 2014, Gawk’s counsel sent a letter to Mayersohn, to which Mayersohn replied, admitting that he received $80,000 from Gawk and distributed $55,000 of those funds to third parties. (Docs. 23-5, 23-6.) All of these communications took place after the alleged torts occurred, and, therefore, Gawk’s claims against Mayersohn and the Firm do not arise out of these contacts. Gawk contends, however, that the July 3, 2014 letter, (Doc. 23-1), “establishes without a doubt that [Mayersohn] specifically aimed and targeted an Arizona resident” - 7-  Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 8 of 11 because “Mr. Mayersohn’s description of the work he did for Gawk summarizes what Defendant Martin did during his four and one-half (4 1⁄2) month tenure as Chief Executive Officer of Gawk, much of which was done in the state of Arizona.” (Doc. 23 at 13.) Even if Gawk is correct that Martin did much of his work for Gawk in the state of Arizona, Gawk has not explained why Martin’s contacts should be imputed to Mayersohn or the Firm. Gawk does not allege that Mayersohn dealt directly with Doyle Knudson, the Arizona investor and, even if Mayersohn did, Gawk has not explained how its claims against Mayersohn and the Firm arise out of any contacts relating to Knudson. Gawk also points to communications between Mayersohn and the Firm and Gawk employee Scott Kettle and consultant William Lane. (Id. at 14.) Kettle stated, “I received a series of E-mails from Paul Mayersohn and members of his law firm, some when I was in Los Angeles and some when I was working in Phoenix, Arizona, concerning the acquisition by Gawk of Poker Junkies and various licensing and trademark issues, among other issues.” (Doc. 23-1 at 6.) Similarly, Lane stated he “spoke with Paul Mayersohn by telephone while I was in Phoenix several times on Gawk business.” (Doc. 23-2 at 2.) However, Gawk does not explain how Mayersohn’s conduct was purposefully directed toward or Arizona, particularly when both Kettle and Lane worked in places other than Arizona, or how its claims arise out of these contacts. Personal jurisdiction does not exist “solely as a result of ‘random,’ ‘fortuitous,’ or ‘attenuated’ contacts, or of the ‘unilateral activity of another party or third person.’” Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475 (1985). The Court cannot find personal jurisdiction over Mayersohn and the Firm based on Gawk’s contacts with Arizona, and Gawk has not shown that Mayersohn and the Firm purposefully directed their allegedly tortious conduct toward Arizona. Accordingly, because Gawk has failed to make a prima facie showing that the Court has personal jurisdiction, the Court grants the motion to dismiss Mayersohn and the Firm. b. Martin Gawk has brought claims against Martin sounding in both tort (violations of - 8-  Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 9 of 11 Section 10(b) of the Securities and Exchange Act of 1934, Rule 10b-5, RICO, and the Arizona Rackeetering statute; common law fraud; breach of fiduciary duty; conversion; and civil conspiracy to defraud Plaintiff and to convert Plaintiff’s property) and in contract (breach of contract and of the covenant of good faith and fair dealing). Gawk, however, does not argue that Martin purposefully availed himself of the privilege of conducting activities in Arizona and only contends that Martin’s contacts were purposefully directed at Arizona. (Doc. 23 at 10.) Gawk focuses on Martin’s contacts with Arizona relating to Doyle Knudson’s investment.2 After he became Gawk’s CEO, Martin “represented to Doyle on multiple occasions” that Gawk would use any funds Doyle invested with Gawk to produce a television series about poker players called “Suited Connectors” and exercise and yoga television projects. (Doc. 23-4 at ¶ 4.) In April 2014, Martin traveled to Arizona for the “primary purpose” of securing an investment from Doyle. (Id. at ¶ 6.) He stayed overnight at the Talking Stick Resort in Scottsdale and met with Doyle there on April 9th. (Id. at ¶¶ 10–11.) At the meeting, Martin represented to Doyle that Gawk would use his investment only to produce Suited Connectors and exercise and yoga television projects. (Id. at ¶ 13.) Doyle invested $3.3 million in Gawk and later sued Gawk “because of the representations made by Defendant[] Martin.” (Doc. 1 at ¶ 27.) Martin does not dispute that, with regard to his interactions with Knudson, he committed an intentional act that was expressly aimed at Arizona. He argues, however, that Gawk has not met the third prong of the Calder effects test—“causing harm that the defendant knows is likely to be suffered in the forum state.” Martin contends that it had to be foreseeable that he would harm Gawk in Arizona and that it is not sufficient that he could foresee harm to Doyle there. Gawk claims that harm was foreseeable in Arizona. 2 Gawk fleetingly mentions that Martin’s contacts with Knudson were “only a fraction of [his] contacts with this state.” (Doc. 23 at 10.) As discussed above, Gawk claims that Martin attended multiple meetings in Arizona and communicated regularly with individuals in Arizona by telephone and email. Gawk provides no information about when these contacts occurred or the purpose or subject of these contacts. On this limited record, the Court cannot conclude that Gawk’s claims against Martin arise out of or are related to these contacts. - 9- 

Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 10 of 11 The parties seem to agree that the Ninth Circuit “has relied on a corporation’s principal place of business in determining the location of its economic injury.”3 (Doc. 25 at 9; see Doc. 30 at 6.) For the reasons discussed above, Gawk has not shown that its principal place of business in Arizona. Accordingly, Gawk has not satisfied the Calder test to establish that, through his interactions with Doyle, Martin caused harm to Gawk that he knew was likely to be suffered in Arizona. The Court grants Martin’s motion to dismiss because Gawk has failed to make a prima facie showing that the Court has personal jurisdiction. MOTION TO STRIKE Gawk has moved to strike the Declaration of Paul Mayersohn from the Moving Defendant’s supplemental briefing or, alternatively, for supplemental discovery. Gawk provides no legal basis or authority for striking the declaration. For this reason, the motion to strike will be denied. Alternatively, Gawk requests “limited discovery,” which the Court understands would serve to gather evidence that would controvert Mayersohn’s declaration. The declaration makes three main points—that Mayersohn did not believe that Gawk’s principal place of business was in Arizona, did not know that Knudson resided in Arizona, and did not communicate with Knudson. Mayersohn’s belief about Gawk’s principal place of business is not relevant to the Court’s analysis and, as explained above, even if Mayersohn had meaningful Arizona contacts through his work regarding Knudson, Gawk has not explained how its claims against Mayersohn and the Firm relate to those contacts. Gawk’s request for discovery is denied because discovery would not serve to controvert any material facts before the Court. CONCLUSION Gawk has not made a prima facie showing that this Court has personal jurisdiction over any of the Moving Defendants. Accordingly, 3 The Court notes that “in appropriate circumstances a corporation can suffer economic harm both where the bad acts occurred and where the corporation has its principal place of business,” Dole Food Co. v. Watts, 303 F.3d 1104, 1113 (9th Cir. 2002), but neither party argues that this case presents such a circumstance. - 10 -  Case 2:14-cv-02416-DLR Document 33 Filed 06/19/15 Page 11 of 11 IT IS ORDERED that Defendants Gregory Mars Martin, aka Mars Callahan, Paul Mayersohn, and Surpin & Mayersohn, LLP’s Motion to Dismiss for Lack of Personal Jurisdiction, (Doc. 13), is GRANTED. IT IS FURTHER ORDERED that Plaintiff Gawk, Inc.’s Motion to Strike the Declaration of Paul Mayersohn or, in the Alternative, Motion for Limited Discovery, (Doc. 32), is DENIED. Dated this 19th day of June, 2015. Douglas L. Rayes United States District Judge - 11 -  

— Preceding unsigned comment added by 76.91.4.111 (talk) 20:31, 16 July 2015 (UTC)
And if you would be willing to provide a link to that document on an official court website or other reliable source when removing the information from the page then theres a better chance of it being removed, there is no proof that the information you have posted above is anything official or even in existance. Amortias (T)(C) 20:35, 16 July 2015 (UTC)

The Signpost: 15 July 2015

Please comment on Talk:Supply-side economics

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Changes to bishop and knight checkmate page, 8 Jun 2015

According to the history of the above page you made a series of twelve changes on 8 Jun 2015, the last ten of which resulted in the following text in the lead section:

With the stronger side to move and with perfect play, checkmate can be forced in at most thirty-three moves from any starting position where the defender cannot quickly win one of the pieces,[1] [2], (1) The defending king may be forking the bishop and knight so that one of them is lost on the next move, or (2) the knight may be trapped in a corner by the defending king and the knight is lost in one or two moves. and the position is not in the "stalemate trap" (see below).

changed from:

With the stronger side to move and with perfect play, checkmate can be forced in at most thirty-three moves from any starting position where the defender cannot quickly win one of the pieces (Müller & Lamprecht 2001:19), (Speelman, Tisdall & Wade 1993:7),[3] and the position is not in the "stalemate trap" (see below).

Could I ask what prompted the change please? There was apparently no "copy edit" request on the page, and you don't appear to have edited any chess related material before.

Did you in fact make the change? The punctuation appears a little strange for a member of the Guild of Copy Editors.

Martin Rattigan (talk) 21:41, 17 July 2015 (UTC)

Hi Martin,
The only changes I'm aware I made were to tidy up some references to reduce the overall page size while maintaining the page information. As far as im aware I didnt make any changes to the body of the article (and if they were it was not intentional). Amortias (T)(C) 22:07, 17 July 2015 (UTC)
There wasn't any change to the meaning - the contents of the footnote were moved into the sentence. The question was what prompted you to make the change in the first place? Can you remember?
I cant off the top of my head, I have been known to hit Random article to see if theres anything I can do when vandalism is on a go slow. Amortias (T)(C) 22:19, 17 July 2015 (UTC)
Ok Thanks. — Preceding unsigned comment added by Martin Rattigan (talk • contribs) 22:21, 17 July 2015 (UTC)
  1. ^ Müller, Karsten (2001). Fundamental Chess Endings. Gambit Publications. p. 19. ISBN 1-901983-53-6.
  2. ^ Speelman, Jon; Tisdall, Jon; Wade, Bob (1993). Batsford Chess Endings. London England: B.T. Batsford. p. 7. ISBN 978-0-7134-4420-9.
  3. ^ (1) The defending king may be forking the bishop and knight so that one of them is lost on the next move, or (2) the knight may be trapped in a corner by the defending king and the knight is lost in one or two moves.

Please comment on Wikipedia talk:Manual of Style/Icons

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Proposed Deletion of J. L. Verma

You proposed a deletion of the page J. L. Verma but only put a box on the top of the page. You didn't put it in AfD so there is currently no discussion. Snood1205 (talk) 17:25, 20 July 2015 (UTC)

Have prodded it not sent it to AFD so wouldnt expect there to be a discussion there. Amortias (T)(C) 17:27, 20 July 2015 (UTC)

I have removed the {{prod}} tag from J. L. Verma, which you proposed for deletion. I'm leaving this message here to notify you about it. If you still think the article should be deleted, please don't add the {{prod}} template back to the article. Instead, feel free to list it at Wikipedia:Articles for deletion. Thanks! Snood1205 (talk) 17:30, 20 July 2015 (UTC)

AN/I

Thanks for your remark. To be honest I am not in denial of what OppositeGradient is saying and yes I did edit-war on Kosovo Verification Mission. So perhaps I am in line for some form of sanctioning. That is why I felt no reason to provide links. I also feel that to have shortened my reply it would have 1) looked abrupt and defiant, and 2) not said everything I felt needed mentioning. At the moment I am concerned as to why I have recieved a warning from one admin before I replied, and yet the person who began the thread, the other party in the debate, has not been spoken to. I find that upsetting especially as I believe I have worked hard to improve and balance Balkans articles. --Oranges Juicy (talk) 19:02, 20 July 2015 (UTC)

Hi, the warnings (posted to both yours and the other involved users pages) are Discretionary sanctions alerts. They are used to advise that articles you are involved in are subject to strict editing limits on what can and can not be done with regards to them. They are not used to imply any blame lies with either party but are used to advise editors they need to be extra careful when working on these topics. The best thing you can do would be to go ack to ANI explain that you are aware where you went wrong (as youve stated above) and expani what you are going to do in future to prevent it from reoccuring. An appology and a promise to prevent the issue from reoccuring can only assist with the issue at present.

It may be a good idea to hat the section above your appology by using the appropriate coding.

{{ctop|Response from Oranges Juicy}} - above the response section
{{cbot}} - below the response section but before the apology.

This will keep the information on the page but present it in a format more easily accessed by readers without taking up large amounts of text on the page. Amortias (T)(C) 19:20, 20 July 2015 (UTC)

Thanks a lot Amortias. My closing paragraph did that but as you rightly say, it lies at the bottom of a TLDR essay! :) --Oranges Juicy (talk) 19:24, 20 July 2015 (UTC)

your message

hello Amortias, thank you for your message. I edited what the Dutch law says, but the reference to it is in Dutch however (http://maxius.nl/burgerlijk-wetboek-boek-1/artikel41). I will see If I can find an English language reference. I was a bit annoyed by how it looked on the page because it was not really correct. Cheers! — Preceding unsigned comment added by 2001:1C00:2432:3B00:295C:7951:B9A6:3D1D (talk) 20:48, 20 July 2015 (UTC)

Refereces in Dutch are just as valid as those in English. Feel free to include them. Amortias (T)(C) 20:55, 20 July 2015 (UTC)

Rex is a bad person

Hi Amortias,

My friend and I think that Rex is a terrible person and think that he will be responsible for the Co2 Armageddon, so please let us have some fun before that event.

Sincerely,

Friends of Earth — Preceding unsigned comment added by 95.157.27.6 (talk) 21:29, 20 July 2015 (UTC)

Hi unfortunatley Wikipedia does not count opinion as a reliable source and as such cant be included in articles. Amortias (T)(C) 21:32, 20 July 2015 (UTC)

bouquet of barbed wire

i noticed while looking at the bouquet of barbed wire page that the executive producer for the 1976 adaptation was ROY Firkin, however i am trying to change it to the correct exec producer of REX Firkin. I haven't put in a reference/citation, because he is my grandfather, so don't know what to put the citation as. however it is listed on his IMDB page. 109.147.244.37 (talk) 21:46, 20 July 2015 (UTC)

You would need to find a reliable source that backs this up, something like a listing on a music website or similar would be sufficient. Wikipedia relies on what we can verify for inclusion on the site. IF you are able to find a suitable reference feel free to make the change but it would be advisable not to make the change again util you can find one. Amortias (T)(C) 21:49, 20 July 2015 (UTC)

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Funk This

Hey Amortias,

I am trying to add the following to reflect the success of the Funk This album track 'Disrespectful' in the UK, which was licensed to Megafan Records in June 2008. I could clearly do with your help!

  • "Disrespectful" (featuring Mary J. Blige) (2009) — #1 U.K. Music Week Commercial Pop

Source:

http://www.soulshakermusic.com/soulshaker/news_files/0931463d4cdc1118cccd385be0d66e7f-15.html

Thank you 78.147.102.157 (talk) 17:59, 22 July 2015 (UTC)

Hi, if you wish to use the link above as a reference to back up the inclusion it will need to be inserted in <ref> </ref> tags rather than them being placed at the start of the section. The inclusion looks good but you might want to look at this page for advice on how to include the link appropriatley. Other than that the edit looked good. Amortias (T)(C) 18:05, 22 July 2015 (UTC)

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The Signpost: 22 July 2015

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Your submission at Articles for creation: Science Cheerleaders (July 24)

Your recent article submission to Articles for Creation has been reviewed! Unfortunately, it has not been accepted at this time. The reason left by Sulfurboy was:
This submission's references do not adequately show the subject's notability—see the guidelines on the notability of organizations and companies and the golden rule. Please improve the submission's referencing, so that the information is verifiable, and there is clear evidence of why the subject is notable and worthy of inclusion in an encyclopedia.
What you can do: Add citations (see Wikipedia:Referencing for beginners) to secondary reliable sources that are entirely independent of the subject.
Please check the submission for any additional comments left by the reviewer. You are encouraged to edit the submission to address the issues raised and resubmit when they have been resolved.
Sulfurboy (talk) 04:59, 24 July 2015 (UTC)


Teahouse logo
Hello! Amortias, I noticed your article was declined at Articles for Creation, and that can be disappointing. If you are wondering or curious about why your article submission was declined please post a question at the Articles for creation help desk. If you have any other questions about your editing experience, we'd love to help you at the Teahouse, a friendly space on Wikipedia where experienced editors lend a hand to help new editors like yourself! See you there! Sulfurboy (talk) 04:59, 24 July 2015 (UTC)

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The Signpost: 29 July 2015

Adminship

Hi. I do a lot of scouting for potential admin candidates. I couldn't help noticing you've got one of thos 'I want to be an admin' userboxes on your user page. You may wish to read WP:RFAADVICE in its entirety including the footnotes. The page has become the main venue for those seeking advice and as I wrote it, if you have any questions you are welcome to contact me. --Kudpung กุดผึ้ง (talk) 12:31, 27 June 2015 (UTC)

I'll give it a good look. Not 4 hours ago I asked WormThatTurned for a review of my contributions with an aim of running (subject to someone nominating me).Amortias (T)(C) 12:34, 27 June 2015 (UTC)
Kudpung Read, I have a feeling I've read this before but i read so much stuff on here memory passes. Amortias (T)(C) 14:37, 27 June 2015 (UTC)
And can I get your opinion on admins who arent content creators. I fit in this category quite heavily apart forma spate of copyediting in my infancy before I moved onto primarily anti-vandalism work. Amortias (T)(C) 14:38, 27 June 2015 (UTC)
After reading WP:RFAADVICE, the next step is to read user:Kudpung/RfA criteria. It will tell you all you need to know about why and how I vote and how my RfA votes can somtimes have an important impact on an RfA. If you can check all the boxes there you would probably have a 99.9% chance of passing, especially if you were nominated by people like Worm. Candidates who are weak on providing content are sometimes given a hard time, but they might pass, particularly if they have been around for a few years. Kudpung กุดผึ้ง (talk) 15:58, 27 June 2015 (UTC)
Collapsed to save page length

The maturity level of a responsible adult (18+) - evaluation of maturity is highly critical, but subjective, and I believe that minors who are admins should demonstrate an exceptional level of maturity that is beyond average for their real age.

I hope so. This is something others will have to judge though.

The ability to communicate in proper standard English, understanding that WP is not built by teenagers for teenagers.

As far as I'm aware.

12 months autoconfirmed user or at least 6,000 edits non automated edits in the preceding 6 months

yes.

>30% edits to Talk and Wikipedia space

last time i checked.

At least 4 created articles of at least 500 words, perfectly sourced and formatted - no outstanding maintenance tags on any creations where the candidate is still the major contributor. FA, GA, or DYK are not prerequisites, but a very minimum of article creation and/or an equivalent amount of new content should demonstrate that we are here first and foremost to build an encyclopedia and not a WP:MMORPG.

No direct content creation but i have added to some articles copyedited others (copyediting is where i started out and was quite keen on it till i realised vandal hnunting was

No mass creation of very short stubs

Nope

>100 New Page Patrols

Probably but unsure without goign and checkign.

No warnings or comment about wrong NPP tagging in the preceding 6 months

Not that I'm aware of. I may have forgotten to mark as patrolled on a couple of occassions though.

<5% declined CSD at New Page Patrolling

Again not sure but think my numbers are good on this, some have been recreated since such as bad userpages so not sure how much this is throwing my counts.

>10 advice edits to a help desk that demonstrate knowledge of the policies/guidelines

Have given quite a lot of advice at ANI, AN, and through OTRS system.

>50 edits to AfD with adequate rationale that demonstrate knowledge of the policies (hit rate over 75% on Scottywong's tool)

cant recall without checking but I've nominated a fair few and commented on others.

>10 edits to RfA with adequate rationale that demonstrate knowledge of the process (hit rate over 75% on Scottywong's tool)

I think this is below that. I have commented at CU and Oversight permission however that im sure of.

99% edit summaries in the main space

Honestly I have no idea.

No warnings for vandalism

Got reported to WP:AIV by obvious sock who was promptley blocked and the report cancelled but thats it.

No warnings for spam

None.

No sockpuppetry (unauthorised use of multiple accounts)

None.

No L3, L4, or single issue warnings

Think I had one by a sockpuppet who was vandalising my page but I dont think this counts.

A clean block log of at least 12 months, but this could be longer depending on the severity of the issue and the length of the block(s)

Clean.

No confirmed personal attacks reported to a notice board.

None I'm aware of

Users have very different opinions as to what constitutes incivility - I judge this for myself and I'm not very tolerant.

Think I'm clear on this one.

Only 1 3rr warning, and older than 6 months

I forget how old this one was but I have one.

No warnings of any kind 3 months preceding RfA

None

No CSD, PROD, or AfD notices for own creations 6 months preceding RfA, .

None

No reverted non-admin closures of any debate types

None that im aware of.

No unnecessary 'clerking' of admin areas.

Some work at AN and ANI where obiously wrong place or the questions have been answered. Dont think this constitutes unnessecary.

2nd or subsequent RfA not sooner than 3 months

N/A

2nd or subsequent RfA not less than 1,500 new manual, major edits.

N/A

No possible signs that the candidate has joined Wikipedia with the express intention of working towards adminship (includes hat-collecting and over-enthusiastic participation on admin boards).

Will have to take my word on this but no it wasn't.

No canvassing on- or off-Wiki (off-Wiki discussion with your nominator is OK).

No
Kudpung Statements above in table. Amortias (T)(C) 18:51, 28 June 2015 (UTC)
I'll be having a look soon Amortias (Some of the tools I use are down, making things difficult). WormTT(talk) 08:41, 29 June 2015 (UTC)
Appreciated. Take your time if the bits something that I should have to use it'll come when its ready not before. Amortias (T)(C) 21:08, 29 June 2015 (UTC)
Hi, Amortias. I dug through your contribs and talk pages for another reason but I'll weigh in here. I often participate in RfA with a different set of criteria. I vet candidates pretty thoroughly before I participate in discussions. For me, biting newcomers with overly strict interpretation of policy and guidelines can lead to an oppose. Extremely quick tagging or assuming malice rather than ignorance may earn the same. I found none of that in a quick review your history. I like to see helpfulness and found some. Work at the help desk, Teahouse and such improves my opinion of candidates for the mop.
Specific observations from my quick review:
  • Some regulars at RfA dislike hat collectors and Kudpung mentions it in his criteria. Why do you have the autopatrolled right if you haven't created an article? The standard for getting that right is creation of 50 or more quality articles. I saw no request at WP:PERM or on Gilliam's or your talk pages so I'm not sure how or why you have that hat. Automatically marking talk pages you create with automated vandal fighting tools as patrolled is not the purpose of the permission. Seeing the autopatrolled permission prominently displayed on a userpage implies that the editor is a prolific article creator. If still there, expect questions in your RfA about the permission and its display. Something that simple can derail the RfA of a pretty good candidate.
  • Many RfA regulars do their own review (and more should) and may grumble and possibly oppose when they find shortcomings like the 'Archives' button in your page headers that only shows 2014. Fix it to show 2015 archives (perhaps even add a blank 2016 to show you plan to stick around). Look around your userpages for other problems and fix 'em before you transclude your RfA because people will look and judge your competence and attention-to-detail and maybe even trustworthyness based on what they find.
  • Lack of content creation is a killer these days. I'm among those who judge that work on articles is essential. I won't oppose unless I see a lack of clue because the candidate doesn't understand what it takes to write and improve articles. But I won't support a candidate with no content creation.
A challenge: Delete the old stuff and move User:Doctree/sandbox/Science_cheerleaders into your sandbox or a subpage. I'm unlikely to ever find time to work on it. Demonstrate clue by not doing a cut-and-paste. Lots of reliable sources are provided in the project's website to establish notability (the coordinator lists media coverage of events and participants). Google it to find the controversy. Many criticize them saying their physical beauty and booty shorts detract from the science goals. Get the balance right, no WP:UNDUE or other problems. Move the article to main_space once it's fleshed out and well sourced. Wait for it to be patrolled and deal with any tags. (You did give up autopatrolled, didn't you?) Many professional cheerleaders have Wikipedia articles; Wikilink back from those also in the Science cheerleader program to get rid of an orphan tag. Upload the logo and write a WP:FAIRUSE rationale (the Wizard helps). List relevant Wikiprojects on your new article's talk page. Wait for an independent editor to rate the quality of your article and give it low importance. Write a hook for DYK and go through that process. Alternatively, choose your own topic(s) and write one or two solid, well referenced articles and get one through DYK. Then you can honestly say in your RfA that you aren't and likely will never be a content creator but you did that/those article(s) specifically to understand the challenges of those who do create content. Your honesty and that work in the area that's not your preferred activity will earn respect and trust and likely my support. I hope you find this helpful, DocTree (ʞlɐʇ·ʇuoɔ) WER 03:54, 6 July 2015 (UTC)
Archives -  Done,
Autopatrolled - requested a while back just due to the sheer number of new pages I was creating with new page patrolling. Request was denied for reasons mentioned above (no article creation and not purely for the new page patrolling stuff), got a notification a while back that I had been granted the right. Assumed was a policy change as such but didn't think about it again just updated my topboxes and carried on as before. Certainly wont cause me any problems if its gone.
Amortias (T)(C) 11:53, 6 July 2015 (UTC)
Challenge  In progress. Amortias (T)(C) 17:58, 10 July 2015 (UTC)
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