NATS Class action suit

[Lord Aga]

A class action suit has been filed against Too Much Media and its owners.

NATURE OF THE ACTION
This is a proposed “hybrid” action to brought pursuant to F.R.C.P. 23(c)(4).
Specifically, NR Media, Inc. (“NRM”) seeks damages and equitable relief on behalf of itself
and on behalf all persons and entities that operate Affiliate Programs, and that suffered harm
as a result purchasing information processing services from Too Much Media, LLC
(“TMM”) based on NATS, a software program designed for, by and owned by TMM, and/or
John Albright and/or Charles Berrebbi (collectively, the “TMM Defendants”). In addition,
Plaintiffs seek relief based on the tortious conduct that the TMM Defendants specifically
directed at Plaintiffs and which resulted in the destruction of NRM’s profitable and popular
on-line Internet business and sabotaged NR LCC from its inception.

[GTP Dave]

wow, adult industry shocker....

[Lord Aga]

15. Pursuant to Federal Rules of Civil Procedure 23 (a) and 23(b)(2) and/or (3),
NRM brings this action and seeks certification on behalf of a class (the “Class”), consisting
of:
All persons and entities who operate Affiliate Programs and who
purchased information processing services for such purpose from
TMM based on NATS, a software program owned, designed and sold
by TMM and/or Albright and/or Berrebbi in interstate commerce from
2004 to date. Excluded from this Class are the TMM Defendants,

TMM’s officers, directors, and employees, Doe Defendants 1 through
30, and any judicial official to whom this matter is assigned.
16. The Class is so numerous that joinder of all members is impracticable. While
the exact number of Class members is unknown to NRM at this time and may only be
ascertained through discovery, NRM believes there are several hundreds of members in the
proposed class.
17. The claims of NRM are typical of the claims of the members of the Class,
because NRM and all Class members sustained damages out of defendants’ wrongful
conduct complained of herein.
18. NRM will fairly and adequately protect the interests of the Class. NRM has
no interests antagonistic to those of the Class, and has retained counsel and consultants
experienced in consumer class action litigation and who are further familiar with the
technical aspects of the Affiliate Program business model.
19. A class action is superior to other available methods for the fair and efficient
adjudication of the claims asserted herein, because the expense and burden of litigation, and
the power to deny members of the Class vital information-processing services that would
lead to the collapse of their business, make it virtually impossible for the Class members to
pursue individual redress for the wrongs they have suffered and continue to suffer. The
likelihood of individual members of the Class prosecuting individual, separate claims is
remote.
20. In addition, members of the Class reside in many states throughout the United
States and in foreign countries and are so numerous that it will be impracticable to join them
each individually. However, it will be highly practicable to ascertain their identities and to
communicate with them because TMM has a list of all members of the Class.

[AmeliaG]

Which program is NR Media, Inc.?

[GTP Dave]

Originally Posted by AmeliaG

Which program is NR Media, Inc.?

Press Release:I think was wrong site?... Welcome to the Home Page for NR Media Holdings, LLC - The Next Generation in Adult Entertainment.

[Lord Aga]

TMM’S SECURITY IS “BREACHED”
52. As alleged hereinabove, NRM and all members of the Class relied on TMM
to act as their agent and through NATS, administer and coordinate the Personal information
provided by Class Plaintiff’s Processors, Affiliates, and Members.
53. In the performance of TMM’s contractual services for NRM and all members
of the Class, the TMM Defendants had access to the Personal Information of Class Plaintiffs
and/or their Affiliates and/or their Members, as well as other confidential information that is
proprietary to Class Plaintiffs, and the power to direct it to various digital storage locations.
54. Upon information and belief, the TMM Defendants directed and/or were
aware and/or should have been aware that certain design features (hereafter, “Security
Vulnerabilities”) had intentionally been incorporated in the NATS program that would
render the information transmitted by or through NATS accessible to anyone with knowledge
of their existence of such Security Vulnerabilities.
55. Upon information and belief, the Security Vulnerabilities enabled the TMM
Defendants to access, copy and distribute the Personal Information of NRM and all members
Upon information and belief, “Milan” and “Dale,” acting 2 as agents for OC3, alerted TMM to security
breaches NATS-users were suffering, and thereafter waited until late December before disclosing the
problem publicly.

of the Class and/or their Affiliates and/or Members, as well as other proprietary and
confidential information of NRM and members of the Class.
56. At all relevant times prior to December 2007 the TMM Defendants, upon
information and belief, concealed the existence of the above alleged Security Vulnerabilities.

[Lord Aga]

More info when I come back from Dinner.

[pam]

Naked Rhino ... this has been on another board for a long, long time ... affiliates not paid, sponsor accused of shaving, etc