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| 8. | As a direct and proximate result of defendant WF's conduct, the reputation of BBLA has been damaged and it has sustained and will continue to sustain loss of income in amounts that will be established at trial. |
| 9. | Plaintiff has informed WF that the statements about her are false and defamatory but WF has refused to remove the statements from Wikipedia, despite the fact that Brian Lamb the founder of WF has stated publicly that his website is accountable and that mistakes are removed in minutes. |
WHEREFORE, plaintiffs request judgment against defendant Wikimedia Foundation for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
THIRTY SECOND COUNT (TORTIOUS INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE)
| 1. | Plaintiff's repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | The publication by defendant WF of the false and malicious statements about plaintiffs set forth in the previous COUNT, as well as other actions and statements by defendant WF, interfered with the prospective economic advantage of plaintiffs by inducing prospective clients not to engage plaintiff as their literary agent. |
| 3. | As a direct and proximate result of defendant WF's malicious inducement to potential clients of plaintiffs not to engage plaintiff as their literary agent, plaintiffs suffered damages in amounts that will be established at trial. |
WHEREFORE, plaintiffs request judgment against defendant Wikimedia Foundation for compensatory and punitive damages, together with counsel fees, costs of suit, and other relief as the court may deem proper.
THIRTY THIRD COUNT (DEFAMATION)
| 1. | Plaintiffs repeat and reallege the allegations of the previous COUNTS as if same were set forth at length herein. |
| 2. | Defendant Shweta Narayan ("Narayan") is employed at International Computer Science Institute, 1947 Center St., Suite 600, Berkeley, CA 94704.. |
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