Date: Tue, 10 Jun 2003 18:19:55 -0400 (EDT)
From: Dean Anderson <dean@av8.com>
To: abuse@xo.com
Subject: Complaint regarding www.sorbs.net (209.220.100.158)

It is come to my attention that Matthew Sullivan, operator of SORBS.NET
is willfully, and maliciously making false statements through his
SORBS.NET site:

http://www.dnsbl.sorbs.net/cgi-bin/lookup?IP=130.105.0.0

> The full listing is:
>
> Netblock 130.105.0.0 / 16
> Summary The OSF doesn't exist anymore, making this hijacked.
> Announced By [1784] Global NAPs Networks
> Entry Created Wed May 21 11:51:29 2003 AEST
> Record Updated Wed May 21 11:52:38 2003 AEST
> Currently active and flagged to be published in DNS
> Spam has not been received from this netblock.

        That The OSF no longer exists
        That the 130.105/16 is hijacked

Neither of these claims are true and are provably false.

Dean Anderson, his companies Av8 Internet and Plain Aviation, 130.105/16,
and the OSF, are well known and easilly found. There is no possibility
that Mr. Sullivan could reasaonably have believed these statements true.
Therefore, the false statements are made with malice.

These statements are made with the intent to cause economic harm to Dean
Anderson and his companies, and to interfere with contracts between his
companies and the OSF as well as contracts with current and future
customers.

Wrongly calling an ASN or IP space hijacked may subject that person to a
lawsuit for tortious interference with a contract, defamation, commercial
disparagement, intentional and negligent misrepresentation, unfair
business practices, and false advertising in violation of the Lanham Act.

We believe that this activity is in violation of your AUP, which prohibits
unlawful activity, and which is (from http://www.xo.com/legal)

*      Is unlawful, threatening, abusive, harassing, libelous,
       defamatory, obscene, deceptive, fraudulent, invasive of another's
       privacy, tortious, indecent, pornographic or inaccurate

*      Victimizes, harasses, degrades, or intimidates an individual or
       group of individuals on the basis of religion, gender, sexual
       orientation, race, ethnicity, age, disability or any other reason

We ask that you take the appropriate action to halt this activity.

We also note that 209.220.100.157 (www.isux.com) is operated by the same
person, and threatens mailbombing, which is also in violation of your AUP.

Thanks,


Dean Anderson
President, Av8 Internet, Inc