LEWITT, HACKMAN, SHAPIRO,

MARSHALL & HARLAN

David Gurnick, Esq.

DGURNICK@LEWITTHACKMAN.COM
(818) 9 0 7 - 3 2 8 5

LAW CORPORATION

(818) 990-2120
TELECOPIER (818) 981-4764

16633 VENTURA BOULEVARD

WWW. LEWITTHACKMAN. COM

ELEVENTH FLOOR

ENCINO. CALIFORNIA

91436-1865

REFER TO FILE NUMBER

16735-1

January 26,2015

Vijaya Gadde, Esq.

Twitter, Inc.

vijaya@twitter.com
1355 Market St Ste 900

San Francisco, CA 94103

Re: Brian Glicklich

Dear Vijaya:
1.

Introduction.

As you know from prior communications, this law firm represents Brian Glicklich. Mr.
Glicklich serves as spokesperson for broadcaster Rush Limbaugh. Mr. Limbaugh is America's
most listened-to radio broadcaster, with an audience of 20 million people weekly over
approximately 600 radio stations nationwide. Mr. Glicklich is a private individual.

We are concerned that Mr. Glicklich has become the target of improper harassment by a
group ofTwitter users whose actions are violating Twitter Rules. The misconduct includes
perpetrators using Twitter to harass Mr. Glicklich and also advertisers. These actions include
threats, stalking, intimidation, misleading Twitter to improperly suspend Mr. Glicklich's
account, and use of Twitter's platform in other ways that violate Twitter's rules.

This letter asks Twitter to investigate the misconduct, enforce Twitter's rules with regard
to any accounts and perpetrators who are misusing Twitter, and protect Mr. Glicklich's account
from being improperly suspended.
2.

Background.

A group opposed to Rush Limbaugh has conducted a campaign in which they (1) tweet
outrageous false claims about Mr. Limbaugh, (2) tweet photos of CEOs and claim the CEOs
support the false claims, based solely on their companies sponsorship of Mr. Limbaugh's show,
and (3) send large volumes ofrude, unwanted spam tweets that disparage the reputation and

interfere with operations ofthe advertisers. This campaign involves harassment, disparagement
and intimidation.

The perpetrators recently expanded the campaign, to attack Mr. Glicklich, and escalated

with tactics that violateTwitter Rules, disparage Mr. Glicklich and indicatehe is in physical

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LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A

LAW CORPORATION

Vijaya Gadde, Esq.

January 26,2015
Page 2

danger. Mr. Glicklich has been targeted due to his defense against the attacks on Mr. Limbaugh
and advertisers. However, Mr. Glicklich is a private individual who is not in a position to
respond via radio broadcast and paid counter-advertising.
Mr. Glicklich's own use of Twitter has been attempts to expose the true size ofthe
#stoprush activism, identify the group's key members, expose the falsity of their claim to be
customers of sponsors, expose the falsity and unfairness of their actions, and respond with
corrections to their improper tweets. But the perpetrators responded to Mr. Glicklich's
participation on Twitter by using tactics that violate Twitter Rules, including organized, targeted
harassment and threats of physical harm directed against Mr. Glicklich. They are using Twitter to
disseminate photography that includes Mr. Glicklich's wife. They have brought Mr. Glicklich
and his family into their anti-Rush Limbaugh campaign.
The perpetrators are making the following specific false claims using Twitter, as elements of
an overall false narrative that Mr. Glicklich is a bad person, a criminal, a drug addict, a harasser,
a bully, and other pejorative characteristics:
a. They claim Mr. Glicklich committed a "federal crime;"

b. They claim he harasses women;

c. They claim he put a woman into the hospital;

d. They claim his wife performed a sex act on a participant in the activist group;
e. They claim he is addicted to methamphetamines;
f. They claim he is the "filth of Limbaugh's sewer;"
g. They claim he performs sex acts on Rush Limbaugh;
h. They claim he hacked a bank account and caused the account to be overdrafted;

i.

They claim he is a cyberstalker and extortionist.

Each of these claims is false. Each violates Twitter's rule against abuse, targeted abuse and
spam.

The harassing, bullying and stalking postings targeting Mr. Glicklich, include the
following:

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LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A

LAW CORPORATION

Vijaya Gadde, Esq.

January 26,2015
Page 3

j. Stating that the person tweeting the message will make sure Mr. Glicklich will
regret ever posting using the #stoprushhash. This violates Twitter's rule against
violence and threats.

k. Stating it would be "nice if someone hacked [Mr. Glicklich's] emails." This

violates Twitter's rule against abuse and Spam.
1.

Stating Mr. Glicklich should "come after me, bitch... and you'll never forget it,
ever." This violates Twitter's rule against violence and threats.

m. Repetitively distributing, via Twitter, photos of Mr. Glicklich's wedding and

vacation. This violates Twitter's rule against invasion of privacy and abuse, and is
a pattern of organized and individual harassment.
n. Calling for Mr. Glicklich's home phone number to be posted on Twitter so they
can "call him at 2 A.M." This violates Twitter's rule against targeted abuse.

o. Phoning Mr. Glicklich at home. This violates Twittier's rule against targeted
abuse and invasion of privacy.
p. Posting false claims about Mr. Glicklich repetitively, and referencing the
@Anonyops account controlled by individuals aligned with the group known as
Anonymous. This violates Twitter's spam policy, and organized harassment
policy.
q. The perpetrators induced @Anonyops to repeat a false claim to an estimated
320,000 or more accounts, which generated an outpouring of hateful and
threatening Tweets and emails against Mr. Glicklich. This violates the spam
policy and organized harassment policy.
The perpetrators took actions to mislead Twitter to believe incorrectly that Mr. Glicklich
violated Twitter's rules. The perpetrators' actions included:
r. Generating large numbers of false claims that Mr. Glicklich violated Twitter
Rules. The perpetrators claimed falsely that Mr. Glicklich harassed #stoprush
activists. This violates the spam policy and organized harassment policy.
s. Obtaining thousands of false followers ("Spam accounts") to follow Mr.
Glicklich's account, making it appear he violated Twitter's rule against
-3-

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LEWITT, HACKMAN, SHAPIRO,

MARSHALL & HARLAN
A

LAW CORPORATION

Vijaya Gadde, Esq.

January 26,2015
Page 4

buying/inducing followers in the form of Spam Accounts. This violates Twitter's

rule against impersonating others. The perpetrators then reported falsely that Mr.
Glicklich violated Twitter's rule based on the false accounts thev had attached to

his account. This violates the serial accounts and spam policy, and the organized
harassment policy.

t.

Registering numerous Twitter accounts for their own use, and then using these
Spam accounts to tweet and retweet false information; they do this to falsely
make the small group conducting the campaign appear larger. This violates
Twitter's rule against creating multiple accounts for disruptive or abusive
purposes.

u. Using software that calls the Twitter API to let participants easily send large
volumes oftweets. The software itself tells users to monitor the rate of sending
tweets to avoid being noticed by Twitter. This violates the spam policy, and
organized harassment policy, and the API terms.
These actions were taken partly to induce Twitter to suspend Mr. Glicklich's Twitter
account. The improper efforts succeeded in that at least 3 times in the past 2 weeks Twitter
suspended Mr. Glicklich's account. This preventing his efforts to respond to the perpetrators'
false allegations.

The perpetrators have attacked advertisers by:

v. Posting photos of Rush Limbaugh sponsor CEOs alongside outrageous and false
claims about Mr. Limbaugh and charging that the CEO and their business
supports the false claims;
w. Threatening to continue or extend harassment of sponsors unless they stop
advertising on Mr. Limbaugh's show;
x. Using Twitter to encourage followers to harass advertisers, such as by buying and
returning products, to intimidate retailers to stop advertising on Mr. Limbaugh's
show;

y. Suggesting that followers compile and distribute directories of staffmembers of

these companies to facilitate harassment;

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LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A

LAW CORPORATION

Vijaya Gadde, Esq.

January 26, 2015
Page 5

z. When sponsors block tweets from these perpetrators, they alert others in their
group to punish the business by harassing them more, using other Twitter
accounts.

Accompanying this letter are samples of tweets, evidencing each of the above forms of
misconduct, and a spreadsheet of key twitter accounts involved in these campaigns. Mr.
Glicklich advises that these tweets are representative only, and that he has collected and can
provide hundreds of additional tweets with similar characteristics.
3. Requests.

On behalf of Mr. Glicklich, we request that Twitter investigate these matters and on
confirming what is described, enforce Twitter's Rules by taking at least the following actions:

1. Protect Mr. Glicklich's account, @brianglicklich so that the activists are not able to have
it suspended by making false or organized complaints.
2. Delete the estimated 19,000+ Spam accounts that are following Mr. Glicklich.

3. Investigate and confirm the organized harassment and stalking, creation of Spam
accounts and use of the Twitter API to send spam tweets, using metadata available to
Twitter to identify and source these accounts.
4. Cancel accounts that are violating Twitter's rules.

5. Identify and cancel other falsified Twitter accounts that these groups have established,
including those "lying in wait" in the event their current accounts are suspended or
cancelled.

We urge Twitter to make a public statement of the actions taken, to discourage this
misconduct and misuse ofTwitter by users.
Mr. Glicklich and I are available to speak with you by phone to discuss these matters in more
detail.
4.

Conclusion.

Mr. Glicklich is being victimized by an organized group of perpetrators acting in

violation ofTwitter's rules. On behalf of Mr. Glicklich we request that Twitter take the above
steps to investigate, and to end this organized abuse, harassment, threatening behavior, and
-5-

ram Cj
LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A LAW CORPORATION

Vijaya Gadde, Esq.

January 26, 2015
Page 6

intimidation. We request that Twitter enforce its rules against the organized violators who are
misusing Twitter. Please let me know the means by which you are doing so.

Very truly yours,

LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLA]

By:

-6-

David Gurnick

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LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A

LAW CORPORATION

Vijaya Gadde, Esq.

January 26, 2015
Page 7
EXHIBITS/SAMPLE TWEETS
la.

E) CMMorgan retweeted some Tweets you were mentioned in

54m: a_standal Yes, cyber bullying and threats are a federal crime.
Can't wait til police knock on brianglicklich's door socallks
GeeGeeAkili
1 other retweet

lb.

$P julie sigwart

* Follow

jsigwart

socallks AnonyOps Yeah he's been

harassing women so badly he put one in the
hospital, brianglicklich is an uncivil
monster. #stoprush
RETWEETS

FAVORITES

_ ..

fi-= -,

arm

v_

Hilt. BLDBS'^a

lc.

D The Adversary D AdversAerialOne 56s

brianglicklich Your .stoprush-stalking tweets are pathetic, your follower count

is pathetic, and your wife blew me.
7:41 PM - 28 Nov 2014 Details
Hide conversation

-7-

LEWITT, HACKMAN, SHAPIRO,

MARSHALL & HARLAN
A

LAW CORPORATION

Vijaya Gadde, Esq.

January 26,2015
Page 8
The Adversary

<e AdversAerialOne 5m

brianglickiich She's done it like six times now, by the way. I'm losing count.
1:53 PM -13 Jan 2015- Details
Hide conversation

Id.
4 Zaffod Beeblebrox

ZaffodB 15s

brianglickiich < still on the meth I see

kommonKat
View conversation

le.

Shawtwo

Shawtwo 1 h

: brianglickiich BTW the businesses can see my tweets, filth of Limbaugh's

Ji\S? sewer, Brian StopRush Just you can't LOLOL

View conversation

If.
Mari

narisoLbeck Dec 13

Is Glicklich on his knees yet for Rush?

r stoprush

lg.

LEWITT, HACKMAN, SHAPIRO,

MARSHALL & HARLAN
A

LAW CORPORATION

Vijaya Gadde, Esq.

January 26, 2015
Page 9

f*% cydniey buffers cydniey Jan 22

StopRush Does anyone have screen caps

of the whole dOxing and calling on the phone
thing with BG? I need them for the feds.
f"^ cydniey buffers cydniey Jan 22

Is viciously hacking someone who is

-V mentallyill considered a hate crime if the
person doing the malicious knows? Need to
know, stoprush
tr*

lh.

B Sarah Fournier, ReResist and CMMorgan retweeted a Tweet you were

mentioned in

3h: Pis help report this cyber stalker. brianglickiich trying to

intimidate volunteers of stoprush flushrush. Thanks UniteBlue
justsaying

Matt Osborne

Twitter Suspends Rush Limbaugh's $900/Hour Fixer For Extortion,

Harassment ift.tt/1 FM9feG

2a.
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LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A

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Vijaya Gadde, Esq.

January 26, 2015
Page 10

| Matt Osborne

+ Follow

Osbornelnk

Is brianglickiich going to regret ever

mentioning #stoprush in a tweet? Oh my yes.
I will make that happen.
-

5:14 PM-14 Dec 2014

2b.
Alexis

AlexisDeWinter Dec 13

Gee I hope no one ever hacks Glicklich's emails. Can u imagine?? stoprush

2c.

|^

ConchUSMCGunny-thug

ConchGunny 12h

5 brianglickiich come after me bitch., and youll never forget it., ever.
*** Expand
2d.

Kui^ Shawtwo Shawtwo 32m

Is anyone missing

brianglickiich ? We still have his wedding picture framed by

tfv^B right wing wackos. stoprush.info/bgp.html StopRush

2e.

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LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A

LAW CORPORATION

Vijaya Gadde, Esq.

January 26,2015
Page 11
CMMorgan

socallks 4m

brianglickiich Should you receive emails, I did NOT request anyone to write
you. I only posted FACTS on my FB wall. :) stoprush
4:04 PM - 14 Dec 2014 Details

2f.
BardOfEarth

BardOfEarth 6m

SERIOUSLY #limbaugh PUBLICIST #glicklich declares "open 4 business @

2A.M. Please #StopRush ACTIVISTS POST HIS NUMBER! UnitePink
Details

BardOfEarth "BardOfEarth 2h

.UnitePink Please post Glicklick # I'm a night owl HAPPY 2 call him back 2
A.M. #StopRush
Details

2g.
Anonymous

Reports: ! brianglickiich is being paid to

harass women online who tweet "StopRush.
He's doxing and making calls at 2am,
apparently.
29

I^Di1^l4,.ll

3a.

CMMorgan socallks 19h

RT grimcity

Props to the StopRush crew,

brianglickiich seems to have been spirited away

from Twitterville.

4%

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LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A

LAW CORPORATION

Vijaya Gadde, Esq.

January 26, 2015
Page 12
The Adversary

AdversAerialOne

6h

I submitted multiple reports on brianglickiich for harassment of

#stoprush, so if anyone has any problem with his suspension... y #p2
1

3b.
KAT " kommonKat 39m

sk45202 AnonyOps brianglickiich >said he didn't know anything about the

fakes lol you have to give ur Twitter password to get them > LIAR
View conversation

3c.

KittyLovesObama
@kittyFitz50

12

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LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A

LAW CORPORATION

Vijaya Gadde, Esq.

January 26, 2015
Page 13

Sam's opinion
SamanthaGoIded

Watson
@KKatarinaa_a

3d.

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LEWITT, HACKMAN, SHAPIRO,

MARSHALL & HARLAN
A LAW CORPORATION

Vijaya Gadde, Esq.

January 26, 2015
Page 14
6/26/14. 1:54 PM

swch

Ange'cCaiusone AngeJo Carusone

Logn

Lckkjoo into trie Twiller blast ;:sNoF)jke

Happy Birthday ((StopRush. We are now 2 years old, help us celebrate by tweeting to sponsors
When you click a Ink. rl wis auto Iwm! without asking are you sure . !!l DO NOT TWEET TOO FAST !!!
Sporjoi
i

. .

Remember this? -

http://wwv.cbsnews.com'2100-201 1G2-:So132.|.html. . Rush Limbajgh wrested on drug cha-gei. StopRush

ItsNoFluke
.

..

limbaugh Says Pom KimStaivmg Good Way to Lose Weight hllp^/youtu.bo.'GeWIBOJIL1 ultsNcFluke

. - ; .1

.-,:.

".-.11

"..,

3,KMit--ln.

/.

,!.

.,

Oil .ill.omloaIA

Rush Lrnbajah ;cked about a woman raped while she was sleeping. Do you th*ik rape is funny? ItsNoFluko
Obamn On Sandra Fluke

l.i (:...!.! r."

Her Parents Stiould Be Proixf OI Htf http^'puserne'iuGKi:-! IHsNoFUia ncongress

,i Li-. . i. n.i.. A [..."!..: Bl.i 0

.:..- s Di '.'.,: Eiecau* They Far, Bl . ! ThMn'Ml.'. FWD

h!1p//mm-la orpWGueSO
2 years ago. he had many paid advertisers. Now. It s PSAs, dead a- and Umbaogh shilmg Ns own companies filsnofuke stoprush

nl_.mba.jgri'i Legacy: How to Say You're Sorry When Youre Not ICpj'As.od'scWI I "StopRush nsNoFluke
RT Gproglegs Happy Birtiday (stoprush1 Thank you lor making the world a more decent place!! rtsNoFluko

/.

..

fltsNefluke that Rush receives ho marching orders hem tie Koch B-cthers >StcpRus*i
How rs advertising with drsoustng sexist Rush Umbaugh gorng wiln your female customers?
RT a tutt.ccr.tenti eitsfvoFluke eRushLimbaugh not orJy plants seeds of hate. He waters and lertitees them da-y.
RT OCoopsterO-t Hale shouldn't be celebrated or prof table. eiaNoRuke eslcoRush

Umtiaugh on Armed Forces Raao contributes to Mritary Rape http://ow.ry/u58aw ellsNoFruke pu sign lo remove hn ntlp7/ow.ryA>68j

4a.
M CMMorgan socallks 6h
RT &'kittyFitz50
Mr. Jason Robbins DraftKings CEO.
You could choose differently.
Why don't you?
#stoprush

View more photos and videos

44

StopRush.net

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LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A LAW CORPORATION

Vijaya Gadde, Esq.

January 26, 2015
Page 15

G3 CMMorgan retweeted

gfe KittyFitzFerguson @kittyFitz50

5h

.IDriveBackUp CEO Ragh u Kulkarni could stand with people

against Limbaugh.

of color

Ask him to man up.

#stoprush

I
4\

11 9

v*

\
L

View more photos and videos

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LEWITT, HACKMAN, SHAPIRO,

MARSHALL & HARLAN
A

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Vijaya Gadde, Esq.

January 26, 2015
Page 16
23 CMMorgan retweeted

itfl^fil KittyFitzFerguson kittyFitz50 58m

;$* Meet SquareTrade CEO Steve Abernethy.
Does he realize his ads are all over Limbaugh?
Yes. We've told him.

stoprush

Expand

4b.
t-1 KittyFitzFerguson retweeted

Boop

^j^ Last chance @GEICO... Drop limbaugh for his Bigotry, Racism and
< demeaning women & children #stoprush pic.twitter.com/pYirjvrtTt

4c.

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LEWITT, HACKMAN, SHAPIRO,

MARSHALL & HARLAN
A

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Vijaya Gadde, Esq.

January 26, 2015
Page 17

Kate AKRNHSNC

26m

SeamusSaysSo @kittyFitz50 Your local

Home Depot will soon catch on with repeated
returns and will complain to their
headquarters :)
1

Kate AKRNHSNC

< 27m

SeamusSaysSo @kittyFitz50 Buy several

things at Home Depot, recruit like-minded
friends & neighbors to do same, return them
& tell them why

4d.

| Elizabeth Figueroa

* Follow

IngenioMediaPR

Local case:published the emails, cell phones

of product managers.pr and mktg managers
and they started pulling out of the show
#stoprush
*

13

4e.

-17

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LEWITT, HACKMAN, SHAPIRO,
MARSHALL & HARLAN
A

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Vijaya Gadde, Esq.

January 26, 2015
Page 18
CMMorgan

socallks 40s

stoprush Pis tweet to brianwcc Wholesale Cap Corp, many ads per day
during Rush on KTIE He blocked me. LOL