Areas of Concentration: Partner, Hartman & Winnicki, P.C., Head of Internet, Technology and Intellectual Property Law Practice, as well as concentrating in online anonymous speech litigation involving defamation, reputation, the First Amendment, commercial litigation, trusts and estates litigation, debtor-creditor rights and bankruptcy, and Business Law; trial and appellate practice.
Appointments and Offices: Chair (founding Co-Chair) of the Internet and Technology Law Committee of the New York State Bar Association’s Intellectual Property Law Section (1998-2002 and 2008 to present); Past Chair, Intellectual Property Law Section of the New York State Bar Association (2004-2006); New York State Bar Association House of Delegates Member; Master, John C. Lifland Intellectual Property Law Chapter, American Inns of Court; Former Arbitrator, National Arbitration Forum.
Education: Syracuse University (B.S. 1978); Newhouse School of Public Communications (Television and Radio Advertising); Nova Southeastern University Shepard Broad Law Center (J.D., 1986); Winner, 1985 Association of Trial Lawyers of America Mock Trial Competition School Chapter; Internship, State of Florida, Office of the State Attorney, Palm Beach County, Office of the Prosecutor.
Recognizied for inclusion in 2010-2019 editions of The Best Lawyers in America® in the practice area of Intellectual Property Law. No aspect of this advertisement has been approved by the Supreme Court of New Jersey. See www.bestlawyers.com for details on selection methodology.
Recognized as a “New Jersey Super Lawyer” (2006-2008, 2018-2019), in the practice area of Intellectual Property Law. No aspect of this advertisement has been approved by the Supreme Court of New Jersey. See www.superlawyers.com for details on selection methodology.
Recognized as one of “Bergen’s Top Lawyers” in (201) Magazine (June 2011-2017)in the area of Intellectual Property and Bankruptcy & Creditor/Debtor Rights. No aspect of this advertisement has been approved by the Supreme Court of New Jersey. For selection methodology, click here.
Past Employment: Law Clerk to The Honorable Herman D. Michels, Presiding Judge for Administration, Appellate Division, Superior Court of New Jersey.
Author/Co-Author: (Expected April 2019): “What Happens to My Emails, Social Media Content, Cloud Storage and Online Accounts When I Die? Look to UFADAA and Federal Law”, New Jersey Lawyer Magazine (Internet/Social Media Issue, April 2019);“What’s the Big Idea? The N.J. Trade Secret Act”, lead article in the Intellectual Property & Life Sciences, supplemental issue of the New Jersey Law Journal (April 9, 2012) “The High Court’s Contradiction”, The Record newspaper, Page 1, Opinion section, July 3, 2011 (Brown v. Entertainment Merchants Association, ___U.S. ___ (2011) holding California law banning violent video games to minors violates First Amendment) Avoiding Online Identity Theft and Representing Its Victims”, New Jersey Lawyer magazine (Internet Law Issue, December 2008); “Using Public Wi-Fi Hotspots Can Land You in Hot Water by Risking Disclosure of Confidential Information”, New Jersey Lawyer magazine (Privacy Issue, April 2008); Online “Phishing” Scams and Identity Theft by: Richard L. Ravin, Esq. (version appearing in Bright Ideas, Spring, 2005, a publication of the Intellectual Property Law Section of the New York State Bar Association, as the “Message From The Chair”);”Piracy of Satellite and Cable TV Signals: Liability Under The Digital Millennium Copyright Act and The Federal Communications Act”, State Bar News, Technology Issue (November 2002, New York State Bar Association); “Anonymous Online Speech: New Jersey’s First Amendment Privacy Interest”,New Jersey Lawyer Magazine (Privacy Issue, February 2002); “Lanham Act For Lenders: Increasing Collateral Value By Obtaining Related Intellectual Property Rights”; Is My Domain Name Property And Can I Own It?“, State Bar News, Technology Issue, (New York Bar Association, December 2000); “Employee and Student Privacy Interests in the Computer Age“, New Jersey Lawyer Magazine (Law and the Internet Issue); “Who Really Owns Your Web Site? Look to Copyright Law” and “Keeping Trade Secrets On Computer: Protecting Your Secret Formulas, Customer Lists And Designs”, Intellectual Property Counselor; “The Year 2000 Computer problem A Concern For Your Clients” and “Make Sure Your Own Computer Is Y2K Compliant As Well”, State Bar News, Technology Issue (New York State Bar Association); “The Digital Millennium Copyright Act: Protection for ISP’s And Copyright Owners”, “On-Line Music And Videos Protected by Digital Watermarking”, “Protecting the Loss of Your Domain Name Through Trademark Registration,” Internet Business Law Alert Newsletter; “The Legalities of Workplace E-Mail Systems,” New Jersey Lawyer; “Digital Watermarking: Copyrights Receive New Protection On-Line,” Bright Ideas; “Trade Secrets and Digital Signatures”, Seton Hall Constitutional Law Journal; “Losing Your Company Name And Trademarks To The Internet”, “Can You Be Sued Wherever Your Web Site Is Viewed?”, “What You Should Know About Company E-Mail Systems”, “The Right Of Privacy In Cyberspace”, “Three Impediments To Commerce On The Internet”, Internet Business Law Alert.
Speaking Engagements: Speaker: Recent Developments and Important Topics in Internet Law (including: Manipulation/Synthesis of Audio and Visual Images of People), Annual Meeting, Intellectual Property Law Section of the New York State Bar Association, The New York Hilton Midtown (January 23, 2018); Moderator: What IP Practitioners Should Know about Estate Planning and Administration of Intellectual Property and Keeping Competent Under the RPC by Understanding the New Digital Assets Laws, Fall Meeting, Intellectual Property Law Section, NYSBA, New York City (November 9, 2017); Advising Clients and Spotting the Issues; Speaker: Fiduciary Access to Digital Assets, Hackensack New Jersey, Other Big 8 (September 13, 2016); Panel Chair: “Recent Developments in European Union Data Privacy and Security”, Annual Meeting, Intellectual Property Law Section of the New York State Bar Association, The New York Hilton Midtown (January 26, 2016); Speaker: “Legal Ethics Concerning Cloud Computing; Ethical Use of Social Media; Fiduciary Access to Digital Assets; Illegal Phishing Scams Targeting Lawyers” presented on behalf of Nation Business Institute, Newark New Jersey (December 14, 2015); Panel Chair: “Understanding How To Acquire And Use Social Media Evidence And Recent Legal Developments In The Cloud, Internet And Mobile Computing”, presented by the Internet & Technology Committee of the Intellectual Property Law Section of the NYSBA, Sagamore Resort, Lake George, NY, Fall Meeting of the IP Law Section (October 25, 2014); Speaker, “Illegal Seafood: Shark Phishing; Deconstructing Attempted Shark Attack” Micro Strategies Technology Roundtable, Four Seasons Hotel, New York City, November 16, 2011; Speaker, “Technology Forecast: Ethical Storm Brewing Over Attorneys Computing in the Cloud and on the Ground”, 2011 Annual Meeting, Intellectual Property Law Section of the New York State Bar Association (January 25, 2011); Speaker, “Caveat Transmitor – Wi-Fi Hotspots Can Land You In Ethical Hot Water by Risking Disclosure of Confidential Information”, Fall Meeting (2008) of the Intellectual Property Law Section, New York State Bar Association; and presented to the Section’s Internet and Technology Law Committee (Spring 2008); Program Co-Chair: “U.S. Copyright Office Comes To New York”, (Spring 2006, 2007, 2008, 2009 & 2010); Moderator: “Phishing, Spyware, Identity Theft, Database Protection and Cyber-Piracy”, Fall Meeting (2005), Intellectual Property Law Section, New York State Bar Association; Program Co-Chair: “U.S. Copyright Office Comes To New York”, Cardozo School of Law (April 2005); Panelist, “Everything You Wanted To Know About Intellectual Property Law But Were Afraid To Ask”, New Jersey Business Law Symposium (October 2004); Program Co-Chair, “IP Law: The Next Generation” Fall Meeting, Intellectual Property Law Section, New York State Bar Association (October 2004); “CAN-SPAM Act”, Internet and Computer Law Committee Meeting, New Jersey State Bar Association (June 2004); Panel Chair, Privacy Panel, “Piracy and Discovery: Litigating in the Electronic Age”, Spring Meeting, Commercial & Federal Litigation Section, New York State Bar Association (May 2004); Speaker: “The Digital Millennium Copyright Act After 5 Years”, U.S. Copyright Office Comes To New York (April 2004) and Co-Chair of the Program; Speaker: “Piracy Under the Digital Millennium Copyright Act”, New York State Bar Association Bridging The Gap Continuing Legal Education Seminar (Spring 2003); Panelist: “Bankruptcy and Intellectual Property Law”, IP Law Symposium, New Jersey Institute For Continuing Legal Education (Spring 2003); Speaker: “Contractual Relations Online”, Fourth Annual Internet Law Symposium, sponsored by New Jersey Institute For Continuing Legal Education (Spring 2003); Panelist: “The Digital Millennium Copyright Act Subpoena and the Verizon v. Recording Industry Association of America Case, sponsored by the Intellectual Property Law Society of Quinnipiac Law School (Spring 2003); “Signal And Copyright Piracy Under The Digital Millennium Copyright Act and Federal Communications Act,” Fall (2002) Meeting, Intellectual Property Law Section, New York State Bar Association; Program Chair and Moderator: “When Intellectual Property Meets Bankruptcy and U.C.C. Article 9: Navigating Your IP Clients Through Rough Waters,” Cardozo School of Law co-sponsored by the Intellectual Property Law Section of the New York State Bar Association (Fall 2002); Moderator: “Internet Privacy”, Princeton University, Woodrow Wilson School of Public and International Affairs; Speaker, “First Amendment Online Anonymous Speech and Immunity Under the Communications Decency Act For Online Re-Publishers and Editors”, Third Annual E-Commerce and Internet Symposium, sponsored by New Jersey Institute for Continuing Legal Education; Moderator: “What Intellectual Property Lawyers Need To Know About Bankruptcy and Perfecting Security Interests in IP”, Intellectual Property Law Section, New York State Bar Association, Annual Meeting 2002; Panelist, “Recent Developments In Internet Privacy Law”, Internet Law 2001, sponsored by the National Practice Institute and New Jersey Institute for Continuing Legal Education; Speaker, “Domain Name Ownership And Web Site/Portal Development Agreements”, Second Annual E-Commerce and Internet Law Symposium, New Jersey Institute For Continuing Legal Education; Panelist, “Recent Developments In Intellectual Property Law Affecting Web-Based Transactions”, presented by the New York County Lawyers’ Association and National Practice Institute; Program Co-Chair and Speaker, Fall Meeting, Intellectual Property Law Section, New York State Bar Association, “Intellectual Property Law Issues in Cyberspace” (October 2000); Speaker, “Web/Portal Law”, New Jersey Bar Foundation; Speaker, “Web Site Legal Issues”, Venture Association of New Jersey; Speaker, “Analysis of the Anticybersquatting Consumer Protection Act, and ICANN’s Uniform Dispute Resolution Policy”, Annual Meeting Intellectual Property Law Section, New York State Bar Association, and First E-Commerce Symposium, New Jersey Institute of Continuing Legal Education; Speaker, “Employee Privacy Interests in Age of Computer and Internet”, Computer-Related Law Committee, New Jersey State Bar Association; Moderator, “Internet Liability In The Workplace”, Benjamin N. Cardozo School of Law/Yeshiva University; Panelist, Internet Insurance Issues, Zurich Reinsurance; “What Every Lawyer Should Know: How to Prevent and Litigate Year 2000 Problem Claims”, Mississippi State Bar Annual Meeting and Summer School for Lawyers; Program Chair, New Jersey Institute of Continuing Legal Education: “How to Prevent & Litigate Year 2000 Problem Claims”; Speaker, Brooklyn Law School Intellectual Property Law Association, “Current Issues in CyberLaw”; Speaker, Seton Hall Law School Symposium on Constitutional Issues Involving Use Of The Internet; Speaker, “Cyberlaw for the Business Community”, Business News New Jersey; Speaker, Brooklyn Law School, Current Issues in CyberLaw.
Interviews: My 9 News, WWOR TV, October 2010, interviewed about privacy rights and potentially liable parties arising out of a secret video recording of gay Rutgers University student, Tyler Clementi, who then tragically took his own life; My 9 News, WWOR TV, May 2010, interviewed for Take It On show about blogger Emily Gould, Facebook, privacy and online defamation; WB Channel 11 News, WPIX TV, New York City, Anonymous Online Speech Posted on www.DontDateHimGirl.com, October 6, 2005; WNYE TV Channel 25, The Digital Age: “Can We Stop Spam and/or Telemarketing Calls?” (October 2003) (watch interview: http://www.youtube.com/watch?v=hWxJ9o5eKF0); CBS Market Watch TV: “What can businesses and individuals do about Spam — Unsolicited Commercial E-Mail?” (February 2003); Lawcast: Tip of the Week: “Drafting Web Site Development Agreements”; Lawcast: Top Story: “Experts Share Differing Views On Domain Name Ownership And The Implications For Dot Com Businesses”; Lawcast: Employee Privacy Interests; Lawcast: Fourth Amendment Searches by Employers Rights; Assumption and Assignment of Technology Licenses in Bankruptcy; Lawcast: Year 2000 Problem.
Member: Intellectual Property Law Sections, New York State Bar Association, New Jersey State Bar Association, and the American Bar Association; Internet and Computer Law Committee, New Jersey State Bar Association; Former Pupil, American Inns of Court, Arthur T. Vanderbilt Chapter.
Patents: Inventor, United States Patent No. 5,832,874, Issued November 10, 1998.
Internet, Intellectual Property, and Technology Law: Litigation and transactional representation of clients regarding trademark applications and disputes, copyright infringement and U.S. Copyright claim registration, trade secrets counseling and disputes, patent infringement disputes, domain name and cybersquatting disputes, technology transfers and licensing, electronic discovery disputes, First Amendment anonymous online speech, reputation law, online defamation and immunity under the Communications Decency Act (CDA), Web publishing, Web development agreements, privacy policies, click-wrap and click-through agreements, piracy and anticircumvention under the Digital Millennium Copyright Act (DMCA), data privacy and security, Fiduciary Access to Digital Assets laws, Children’s Online Privacy Protection Act (COPPA), unauthorized interception and access of under the Federal Communications Act (FCA) and the Federal Wiretap Act (FWA) (including, Electronic Communications Privacy Act (ECPA)), privacy and security issues pursuant to the Health Insurance Portability and Accountability Act (HIPAA) and Gram Leach Bliley Act (GLBA), unsolicited email and CAN-SPAM ACT, Fair Credit Reporting Act (FCRA), and N.J. Identity Theft Prevention Act.
Client representation has included Web site developers, software developers, on-line financial service providers, test prep company, content distributors, international financial accounting software publisher, business analysis research firm, neutraceutical developers and manufactures, scientists, national satellite TV system, international limousine service, manufacturer and distributor of energy and conservation products, payroll processing
company, business training consultants, authors, artists, photographers, advertisers, and advertising agencies.
Trust & Estate Litigation: Mr. Ravin’s representations have included, personal represenatives (executors/administrators) of decedents’ estates and trustees of testamentary and inter vivos trusts in will and trust contests in probate actions, and beneficiaries in probate actions, including actions for removal of fiduciaries, undue influence of fiduciaries, beneficiry claims, disputes over wills, litigation involving property and business interests owned by estates and trusts in multiple jurisdictions in court, arbitration and mediation. In addition, Mr. Ravin counsels on Fiduciary Access to Digital Access.
Bankruptcy, Debtor-Creditor Rights and Commercial Litigation: Representation of secured and unsecured creditors (including, banks, other lenders, and landlords) and debtors, in work-outs and in state and federal courts, including bankruptcy courts. Bankruptcy experience in Chapters 11, 13 and 7, includes issues involving stay relief, cash-collateral disputes, financing orders and contests, lien contests, § 341 hearings, § 363 asset sales, assume (and assign) or rejection of executory contracts and unexpired leases pursuant to § 365, and issues involving plan confirmation. Adversary proceeding experience includes prosecution and defense of preference and avoidance actions, and exceptions/objections to discharge.
Mr. Ravin is an aggressive litigator with experience in all phases of litigation in state and federal courts, trial and appeals, including applications for injunctions (temporary restraining orders (TRO’s), preliminary injunctions, and permanent injunctions), depositions and other discovery (including electronically stored information), motion practice, trials, appeals, post judgment enforcement proceedings, and settlements, of various commercial disputes, such as, disputes over agreements, (including cases involving forged instruments, fraud, and fraudulent transfers), mortgages and other liens, shareholder and partnership disputes, employment disputes, insurance coverage disputes, Truth In Lending Act, Consumer Fraud Act, Real Estate Settlement Procedures Act (RESPA), disputes over collateralized mortgage obligations and structured financing (securitizations), securities fraud, RICO, Conscientious Employee Protection Act (CEPA), residential construction disputes, home warranty claims, and “foreclosure rescue” schemes.
Business Law: Representation of technology and intellectual property clients, as well as other types of businesses in connection with formation of businesses, shareholder and operating agreements, leases (including, master leases and subleases), licensing agreements, employment and independent contractor agreements, employee separation agreements, purchases and sales of asset/business, and other business arrangements.
Selected Cases and Opinions
Grow Company, Inc. v. Dilip Chokshi and Pharmachem Laboratories, Inc., 2012 WL 715978 (N.J. App. Div. 2012) (full opinion, not approved for publication Click Here. See also abbreviated Published Opinion at 424 N.J. Super. 357 (App. Div. 2012) which omits the rationale for Points I and II Click Here
Somerset Development, LLC et al. v. “Cleaner Lakewood” John Doe et al., Docket No. OCN-C-119-10, oral decision October 29, 2010 Quashing Subpoena in favor of Blog and anonymous posters (http://www.ravin.com/articles/Order_Quashing_Subpoena_SDvCL.pdf).
In the Matter of Slava Lerner To Perpetuate The Testimony of Michael R. , N.J. Super. Law March 19, 2010 (NO. HUD-L-672-10), Opinion at: http://www.ravin.com/articles/L-672-10.pdf,
(See digest at: http://www.ravin.com/news.html)
Court vacates discovery order seeking identity of anonymous authors, preserving online speakers’ first amendment rights to anonymity
A.Z. v. Doe (Alexandra Zubowski Versus John Doe),
2010 WL 816647, N.J.Super.A.D., March 08, 2010 (NO. A-5060-08T3),
Opinion at: http://www.ravin.com/articles/a5060-08.pdf,
(See Digest: http://www.ravin.com/articles/AZvDoeOpinion.pdf)
Appellate court affirms trial court granting anonymous e-mailer’s motion to quash subpoena
Grow Company, Inc. v. Chokshi and Pharmachem Laboratories, Inc. N.J. Super. Ch., March 19, 2010 (BER-C-280-05)
(Opinion After Phase 1 of Trial, Finding No Liability for Defendants as to Plaintiff’s Misappropriation of Trade Secrets Case and Declaring Confidentiality Agreement Between Grow Company, Inc. and Former Employee Unenforceable as Overly Broad and Unreasonably Restraining Competition), Opinion at: http://www.ravin.com/articles/GrowTrOp.pdf. Final Judgement Entered on July 19, 2010: http://www.ravin.com/articles/Judgment.pdf
Grow Co., Inc. v. Dilip Chokshi and Pharmachem Laboratories, Inc.
403 N.J. Super. 443 (App. Div 2008), (NO. A-4282-06T2, decided November 12,
2008) (Opinion of Appellate Division Affirming in Part and Reversing in Part
Summary Judgment and Remanding Misappropriation of Trade Secrets Case To
Trial Court) (Opinion at: http://www.ravin.com/articles/AppDiv08.pdf)
Grow Co., Inc. v. Chokshi and Pharmachem Laboratories, Inc.
2006 WL 3783519, N.J.Super.Ch., December 22, 2006 (NO. BER-C-280-05)
(Opinion on Summary Judgment Permitting Defendants To Proceed with
Counterclaim for Attorneys’ Fees) (Opinion at:
Grow Co., Inc. v. Dilip Chokshi and Pharmachem Laboratories, Inc., et al.
2006 WL 3783522, N.J.Super.Ch., December 22, 2006 (NO. BER-C-280-05)
Opinion on Summary Judgment, Dismissing Misappropriation of Trade Secrets
Case (Opinion at: http://www.ravin.com/articles/OpSJ1Rel.pdf)
Grow Co., Inc. v. Chokshi,
2006 WL 551367, N.J.Super.Ch., March 03, 2006 (NO. BER-C-280-05)
(Opinion Denying Motion for Reconsideration of Order Denying Preliminary Injunction in Misappropriation of Trade Secrets Case)
Grow Co., Inc. v. Chokshi,
2005 WL 2483706, N.J.Super.Ch., October 07, 2005 (NO. BER-C-280-05)
(Opinion Denying Preliminary Injunction in Misappropriation of Trade Secrets Case)
Ameripay, LLC v. Paylocity Corporation (formerly Ameripay Payroll, Ltd.)
Case No. D2007-0452, WIPO Arbitration and Mediation Center,
(See Digest: http://www.ravin.com/wipoarbitration.html)
(Opinion Awarding Transfer Of Domain Name)
Ameripay LLC v. Ameripay Payroll, Ltd.,
2005 WL 2293676, N.D.Ill., September 16, 2005 (NO. 04 C 5253 (RAG)
(Opinion Denying Summary Judgment. Case Resulted Entry of Permanent Injunction and Judgment in Trademark Infringement Case
Ameripay, LLC v. Ameripay Payroll, Ltd.,
334 F.Supp.2d 629, D.N.J., July 20, 2004 (NO. 03-CV-3534 (FSH))
(Opinion Transferring Venue in Trademark Infringement Case)
Dipaolo v. Am Conservation Group, Inc.,
179 N.J. 372, 845 A.2d 1254 (Table) N.J. 2004.
March 25, 2004 (Approx. 1 page)
(Petition for Certification to the New Jersey Supreme Court Denied)
Donato v. Moldow, N.J. Super. Law (NO. BER-L-6214-01), Court Granted Anonymous Posters Motion To Quash Subpoena Seeking Identity of Anonymous Online Poster,
See appeal, Donato v. Moldow, 374 N.J.Super. 475 at 481 (App. Div. 2005), as to other parties; Appellate Division Opinion makes reference to trial court granting motion to quash subpoena on behalf of anonymous posters (fictitious parties)
In re Iommazzo,
149 B.R. 767, 23 Bankr.Ct.Dec. 1479, Bankr. L. Rep. P 75,106, Bkrtcy.D.N.J., January 21, 1993 (NO. 91-2525, 91-21251)
(Opinion Denying Motion To Dismiss)
Vasil v. Zullo,
238 N.J. Super. 572, 570 A.2d 464, N.J.Super.A.D., February 16, 1990 (NO. A-2197-88T5)
Richard L. Ravin, Esq. has represented John Doe defendants and/or forum and blog operators in the following New Jersey anonymous online speech cases: (1) Donato et al. v. Moldow et al., Docket No. BER-L-6214-01 (see appeal as to Web site operator, 374 N.J. Super. 475 at 481 (App. Div. 2005), (2) Grant von Reiman et al. v. Jane and John Does (1-1000) et al., Docket No. BUR-L-428-01, (3) Digital Broadband Networks, Inc., et al. v. Dbbdisfunny, et al. Docket No. AM-000537-03T1 (N.J. App. Div), on Motion For Leave To Appeal from Chancery Division, Docket No. HNT-C-14001-04, (4) A.Z. v. Doe (Alexandra Zubowski v. John Doe), 2010 WL 816647, N.J. App. Div., March 08, 2010, (No. A-5060-08T3), (5) In the Matter of the Petition of Slava Lerner to Perpetuate the Testimony of Michael R. DeLuca, Docket No. HUD-L-672-10, (6) Lerner v. John Does, Docket No. HUD-L-1816-10 (opinion not reported, attached hereto as Exhibit “A”), (7) Somerset Development, LLC et al. v. “Cleaner Lakewood” John Doe et al., Docket No. OCN-C-119-10 and A-281-10T3 (App. Div. 2012), 2012 WL 437271; (8) Nicholas Rizzitello v. John Doe, Docket No. ESX-L-348-10, and (9) In re our lady of Magnificat Roman Catholic Church v. John Doe Docket No. MRS-L-2036-10;
Additionally, Mr. Ravin has represented petitioners in, Application of L-1 Identities Solutions, Inc., and Robert V. LaPenta v. Yahoo,New York Supreme Court, Index No. 09113904, and an anonymous John Doe defendant in Najia Alkateeb et al v. Does 1-15, Case No. 05-cv-4683, U.S. District Court for the Southern District of New York, and Plaintiffs company and owner in federal litigation involving anonymous online posters defamation on forum Website hosting false and defamatory posts and reviews concerning Plaintiff company, and discovery of identity of anonymous posters, East Coast Test prep, et al. v. Allnurses.com, Inc., et al.