ANS15PR0068

BEFORE THE HEARING BOARD
OF THE
ILLINOIS ATTORNEY REGISTRATION
i l
OCT 3 0 2015
AND
DISCIPLINARY COMMISSION
ATTY REG &DISC COMM

CHICAGO
In the Matter of:
JOHN LAWRENCE STEELE,

Comm. No. 2015PR00068
Attorney-Respondent,
No. 6292158.
ANSWER
Respondent, John Lawrence Steele, by and through his attorneys, Mary Robinson
and James A. Doppke, Jr., Robinson Law Group, LLC, hereby answers the Administrator's
Complaint, as follows:
ALLEGATIONS COMMON TO ALL COUNTS
The Formation of Steele Hansmeier, Alpha Law, Prenda Law, and the
Anti-Piracy Law Group
1.
Between 2008 and 2010, Respondent Steele was a sole practitioner who
maintained an office in Chicago. During that time, he concentrated his practice in the area of
domestic relations matters.
ANSWER:
Respondent admits that he created Steele Law LLC on May 7,2007; that
he was a sole practitioner at that time; that he focused on domestic relations matters during
the operation of Steele Law LLC; and that Steele Law LLC had an office located in Chicago.
Respondent denies any remaining allegations of paragraph 1. Further answering,
Respondent states that Steele Law LLC had other attorneys and employees from 2008-2010.
Further answering, Respondent states that during the latter part of 2010, Steele also handled
cases dealing with intellectual property law through his other law firm, Steele Hansmeier
PLLC.
2.
In or about 2010, Respondent Steele created the law firm known as Steele
Hansmeier, PLLC ("Steele Hansmeier"), with attorney Paul Hansmeier ("Hansmeier"), who
was admitted to practice law in Minnesota in 2007. Between September 2010 and November
2011, Steele Hansmeier maintained an office at 161 N. Clark Street, Suite 3200, in Chicago,
and concentrated its practice in copyright infringement matters filed on behalf of entities
which purported to own exclusive copyrights to pornographic videos. At all times alleged in
this complaint, Steele Hansmeier also maintained a registered business address at the Alpha
Law Firm, 80 S. 8th Street, Suite 900, in Minneapolis.
ANSWER:
Respondent admits the allegations contained in the first sentence of
paragraph 2, and the allegations contained in the second sentence of paragraph 2 up to the
word "Chicago." Respondent denies all other allegations contained in paragraph 2. Further
answering, Respondent states that Steele Hansmeier, PLLC concentrated its practice in
intellectual property matters. Further answering, Respondent states that Alpha Law Firm,
80 S. 8th Street, Suite 900, in Minneapolis was Steele Hansmeier, PLLC's registered agent for
service of process, which was required to be designated under Minnesota law.
3.
In or about 2010, Hansmeier created the law firm known as Alpha Law Firm
("Alpha Law") which maintained an office in Minneapolis. Alpha Law was affiliated with
Steele Hansmeier, and Respondent Steele appeared in certain matters as an attorney of
Alpha Law. In matters which Alpha Law handled for certain pornographers, proceeds were
paid and deposited into a bank account maintained by Prenda Law, an entity further
described in paragraph 4 below.
ANSWER:
Respondent admits the allegations of the first sentence of paragraph 3,
upon information and belief. Respondent denies the allegations of the second sentence of
paragraph 3. Respondent has insufficient information to admit or deny the allegations

contained in the third sentence of paragraph 3.
4.
In or about November 2011, Paul Duffy, an Illinois attorney licensed in 1992
who died on August 10, 2015, and Respondent Steele agreed that they would create a
successor law firm to Steele Hansmeier that would operate under the name Prenda Law, Inc.
("Prenda Law"). Paul Duffyand Respondent Steele agreed that Prenda Law would take over
Steele Hansmeier's copyright infringement practice on behalf of pornographers. Respondent

Steele and Paul Duffy further agreed that Respondent Steele would continue to perform the
same work for Prenda Law that he had performed for Steele Hansmeier, including filing
pleadings and communicating with opposing counsel, handling the financial aspects of the
firm, and managing client relationships. Respondent Steele and Paul Duffy also agreed that
Hansmeier would continue to practice with Prenda Law. At all times alleged in this
complaint, Prenda Law maintained its office at 161 N. Clark Street, Suite 3200, in Chicago,
having assumed the office space of Steele Hansmeier. In 2012 in a Florida litigation matter,
Paul Duffy held himself out to the court as a principal of Prenda Law.
ANSWER:
Respondent denies the allegations contained in the first sentence of
paragraph 4, except that he admits that Duffy was licensed to practice law in Illinois in 1992
and that he died on August 10, 2015. Respondent denies the allegations contained in the
second sentence of paragraph 4 as alleged. Respondent denies the allegations contained in
the third sentence of paragraph 4. Respondent denies the allegations contained in the fourth
sentence of paragraph 4 upon information and belief. Respondent admits the allegations
contained in the fifth and sixth sentences of paragraph 4 upon information and belief.
Further answering, Respondent states that he agreed to sell Duffy his book of business and
various assets, including his lease for office space at 161 N. Clark Street, the web domain for
Steele Hansmeier, and certain equipment Further answering, Respondent states that Duffy
consistently and repeatedly stated, including during sworn testimony given during the
Administrator's investigation of this matter, that he was the owner and only member of
Prenda Law from the time he created his firm in 2011 until the time Duffy dissolved Prenda
in 2013.
5.
In 2013, in California litigation, Respondent Steele was identified by his
client's local counsel as a decision maker of Prenda Law.
ANSWER:
Respondent has insufficient information to admit or deny the
allegations contained in paragraph 5, and those allegations are too vague to allow
Respondent to formulate an answer. The Administrator has chosen not to identify the
litigation at issue, the "client" at issue, the "local counsel" at issue, the circumstances of the
"identification" at issue, or the meaning of the term "decision maker" in the context of any
such alleged "identification."
6.
In or about November 2012, Respondent Steele and Paul Duffy created a law
firm known as The Anti-Piracy Group, LLC ("Anti-Piracy Group"), as a successor law firm to
Prenda Law because Prenda Law's litigation practice was receiving negative publicity. The
Anti-Piracy Group took over the copyright infringement practice of Prenda Law, and
assumed Prenda Law's office suite in Chicago.
ANSWER:
Respondent denies the allegations contained in paragraph 6, and each
of them.
7.
At all times alleged in this complaint, Respondent Steele and Paul Duffy's law
firms maintained a website at wefightpiracy.com.

ANSWER:
Respondent denies the allegations contained in paragraph 7. Further
answering, Steele states that he, through his participation in the operation of Steele
Hansmeier PLLC, participated in controlling the website www.wefightpiracy.com between
2010 until approximately November 2011, when the website and the authorization to
operate it was transferred to Prenda as part of the sale of Respondent's book of business to
Duffy. Further answering, Respondent states, upon information and belief, that shortly after
the sale, Duffy overhauled the website, removing any references to Steele Hansmeier PLLC
or attorney Steele.
Respondent's Copyright Litigation Practice

8.
An Internet Service Provider ("ISP") is a company that provides services for
accessing, using, or participating in the Internet. An ISP assigns an identifying number, called
an Internet Protocol address ("IP address") to each ISP subscriber whose wireless router or
other networking device the ISP connects to the Internet. An IP address reflects the location
at which computer devices may be deployed, serves to route traffic through the network, but
does not identify the computer being used or its user.
ANSWER:
Respondent admits the allegations contained in paragraph 8. Further
answering, Respondent states that the ISP assigns a particular IP address to a particular
subscriber and keeps extremely accurate files of which of the ISP's client had which IP
address at any particular moment in time.
9.
BitTorrent is a protocol for sharing large files over the Internet, in which there
is no centralized server, and each downloading user becomes a source for another user who
wants the same file. BitTorrent breaks large files into smaller ones, and is widely used for
transferring movies and videos.
ANSWER:
answering, Respondent states that upon information and belief, the vast majority of
BitTorrent traffic is used for the illegal transfer of copyrighted works.
10.
Between 2010 and 2012, Respondent Steele and Paul Duffy represented
business entities which produced pornographic movies and videos in copyright
infringement matters. Beginning in or about 2012, Respondents also began representing

limited liability companies organized in the Federation of St. Kitts and Nevis, West Indies.
These companies purported to own the exclusive copyrights to adult entertainment videos
through an assignment of copyright interests. At all times alleged in this complaint, St Kitts
and Nevis had laws preventing the recording or disclosure of corporate ownership
information of any entity organized there. At various times, in litigation filed by Respondent
Steele and Paul Duffy there were attempts to ascertain the ownership of the West Indian
LLCs. Respondent Steele and Paul Duffy always resisted those attempts and to this date, the
ownership of the LLCs is unknown to the courts.
ANSWER:
Respondent admits that from 2010 through November 2011, Steele
Hansmeier represented businesses which produced copyrighted works. Respondent denies
the remaining allegations contained in the first sentence of paragraph 10. Respondent denies
the allegations contained in the second sentence of paragraph 10. Respondent neither admits
nor denies the allegations of the third sentence of paragraph 10, as they state conclusions of
lawwhich require no answer. Respondent has insufficient knowledge to admit or deny the
allegations contained in the fourth sentence of paragraph 10, which are too vague to allow
Respondent to formulate an answer. Respondent denies the allegations contained in the fifth
sentence of paragraph 10.
11.
Between September 2010 and February 2012, Respondent Steele and Paul
Duffyfiled 118 copyright infringement actions in various United States federal district courts
on behalf of pornographers and against 15,878 John Doe defendants. As of February 2012,
Respondent Steele and Paul Duffy had not served any of the John Doe defendants with
service of process. During that time, Respondent Steele and Paul Duffy communicated with
the John Doe defendants by letters and phone calls in which they attempted to exact
monetary settlements related to allegations that the John Doe defendants had illegally
downloaded pornography, and in exchange for the agreement to maintain the confidentiality
of the Does' identity by not naming them in threatened public litigation if settlement funds
were received. Respondent Steele and Paul Duffy sent settlement demand letters that
identified an entity that produced a pornographic work or owned a copyright to that work,
the name of the movie or video, and the date of an alleged illegal download. Respondent's
settlement letters demanded an amount of money ranging from $2,500 to $4,000, and an
example of one of Respondent's settlement demand letters, in pertinent part, follows:
Dear
We have received a subpoena return from your ISP confirming that you are indeed
the person that was associated with the IP address that was performing [an] illegal
downloading of our client's content listed above on the exact date(s) listed above.
On [date] we filed an action against several anonymous digital pirates [gives

examples]. Under the applicable rules of civil procedure, our lawsuit against you personally
will not commence unless we serve you with a Complaint.
While it is too late to undo the illegal file sharing associated with your IP address, we
have prepared an offer to enable our client to recover damages for the harm caused by the
illegal downloading and to allow both parties to avoid the expense of a lawsuit.
Under the Copyright Law of the United States, copyright owners may recover up to
$150,000 in statutory damages (incaseswhere statutory damages are applicable, which may
or may not be the case here) per infringing file plus attorney's fees in cases, whereas here,
infringement was willful. In at least one case where the Copyright Law has been applied to
digital piracy and statutory damages were applicable, juries have awarded over $20,000 per
pirated file. During the RIAA's [Recording Industry Association of America] well-publicized
campaign against digital music piracy, over 30,000 people nationwide settled their cases for
amounts ranging from an average of $3,000 to $12,000. More recently, on December 22,
2010, a case in which a defendant was accused of illegally downloading six works via
BitTorrent, a settlement was reached for $250,000.
In light of these factors, we believe that providing you with an opportunity to avoid
litigation by working out a settlement with us, versus the costs of attorneys' fees and the
uncertainty associated with jury verdicts, is very reasonable and in good faith.
In exchange for a comprehensive release of all legal claims in this matter, which will
enable you to avoid becoming named Defendant in our lawsuit, our firm is authorized to
accept the sum of[example of dollar amount] as full settlement forth claims. This offer will
expire on 05/19/2012 at 4:00 p.m. CST. Ifyou reject our settlement offers, we expect to serve
you with a Complaint and commence litigation.
To reiterate: If you act promptly you will avoid being named as a Defendant in the
lawsuit
(hereinafter referred to as "settlement shakedown" letters).

ANSWER:
Respondent admits that while participating in the operation of Steele
Hansmeier PLLC, he caused to be filed certain copyright infringement actions in various

United States federal district courts; that the clients he represented as part of the operation
of Steele Hansmeier PLLC directed him to issue settlement demand letters on various
occasions between 2010 and November 2011; and that he did issue those letters.
Respondent denies all remaining allegations contained in paragraph 11. Further answering,
Respondent states that Steele Hansmeier PLLC caused defendants in civil actions to be
served with process. Further answering, Respondent asserts an objection to the use in this
8
Complaint of argumentative language such as the term "'settlement shakedown' letters."
Respondent requests that that language be stricken and replaced, if need be, with a more
neutral and therefore fair term.
12.
At the time Respondent Steele and Paul Duffy sent the settlement shakedown
letters described in paragraph 10 [sic],above, while Respondent Steele had an IP address, he
did not know the identity of the individual who had actually downloaded the pornographic
work at issue, had not taken steps to determine who had "illegally" downloaded the
copyrighted content, and did not have a reasonable basis to believe that the recipient of the
letter was an actual "infringer."
ANSWER:
answering, Respondent reasserts his objection to the argumentative term "'settlement

shakedown' letters."
13.
As of October 2012, Respondent Steele and Paul Duffy had settled
approximately 5,000 copyright infringement matters, and recovered millions of dollars in

settlement funds.
ANSWER:
answering, Respondent reasserts his objection to the argumentative term "'settlement

shakedown' letters."
COUNT I
[Alleged dishonest conduct and allegedfraud on the court in Ingenuity 13 LLC v. John Doe)
14.
On September 27, 2012, Respondent Steele and Paul Duffy, then operating
under the firm name Prenda Law, and through California local counsel Brent Gibbs ("Gibbs"),
filed a complaint in the United States District Court for the Central District of California on
behalf of Ingenuity 13, LLC, alleging that John Doe illegally downloaded "A Peek Behind the
Scenes at the Show," an adult entertainment video to which Ingenuity 13 claimed it had an
exclusive copyright. The Clerk of the Court received the matter and docketed it as Ingenuity
13, LLC v.John Doe, case number 12-CV-8333.
ANSWER:
Respondent denies the allegations contained in paragraph 14, except
that he admits that public records would disclose the filing and subject matter of case
number 12-CV-8333. Respondent specifically denies having had any involvement in,
participation in, or knowledge of case number 12-CV-8333 until he was required to
participate in sanctions proceedings later brought in the case.
15.
In the complaint Respondent Steele and Paul Duffy filed in case number 12-
CV-8333, Respondent only identified the IP address of John Doe. The IP address identified in
the complaint did not identify the computer being used to allegedly download the
pornographic video, or who was allegedly downloading the pornography. Shortly after filing
suit, Respondent Steele sought leave of court to engage in pre-service discovery in order to
issue subpoenas to ISPs to determine the identity of John Doe.
ANSWER:
Respondent denies that he caused the complaint in case number 12-
CV-8333 to be filed, or that he had any involvement in, participation in, or knowledge of case
number 12-CV-8333 until he was required to participate in sanctions proceedings later
brought in the case. Respondent denies any remaining allegations contained in paragraph
15.
16.
At the time Respondent Steele caused case number 12-CV-8333 to be filed, he
had 49 cases pending in the Central District of California which Respondent and Paul Duffy
had filed on behalf of Ingenuity 13 and AF Holdings, LLC, another entity which purported to
10
hold exclusive copyrights to pornographic videos. Ingenuity 13 and AF Holdings were both
limited liability companies organized under the laws of the Federation of Saint Kitts and
Nevis, West Indies, and Respondent identified "AlanCooper" as the principal of Ingenuity 13
and AF Holdings in documents filed in their pending cases, including copyright assignment
forms and verifications that used an electronic signature for "Alan Cooper."
ANSWER:
Respondent denies the allegations contained in paragraph 15.
Respondent specifically denies having had any involvement in, participation in, or
knowledge of case number 12-CV-8333, or any of the other cases referred to in paragraph
15, until he was required to participate in sanctions proceedings later brought in case
number 12-CV-8333.
17.
At the time Respondent filed the cases described in paragraphs 13 through 15,
above, Respondent Steele employed Alan Cooper ("Cooper") as a caretaker of his vacation
home and property in McGrath, Minnesota. During visits to his Minnesota property,
Respondent Steele told Cooper that he had a plan involving copyright lawsuits, and that if
anyone asked Cooper about companies, Cooper should call Respondent Steele.
ANSWER:
answering, Respondent states that Cooper was a friend of Respondent's whom Respondent
allowed to live on property owned by Respondent in Minnesota. Upon information and
belief, Respondent states that Cooper worked as a construction worker. Further answering,
Respondent states that after he received harassing and threatening phone calls and emails
from persons who took issue with the work he did during the operation of Steele Hansmeier
PLLC, he told Cooper (as well as many other friends and family members) that if he was
contacted by any such persons, he should contact Respondent.
11
18.
Atno time was Cooper an owner or officer ofany West Indian entity, including
AF Holdings or Ingenuity 13, and at no time did Coopergive Respondent Steele permission
to use his name or sign documents.
ANSWER:
Respondent admits, upon information and belief, that Cooper was
never an officer or owner of AF Holdings or Ingenuity 13. Further answering, Respondent
states that Alan Cooperasked Steele to introduce him to MarkLutz, the owner ofAF Holdings
and Ingenuity 13. Respondent admits that Cooper did not give him permission to use his
name or sign documents, and further answering he states that he did not ask Cooper for
permission to do any such thing. Respondent denies any remaining allegations contained in
paragraph 18.
19.
At the time Respondent and Paul Duffy asserted that Cooper was a principal of
AF Holdings and Ingenuity 13 as described in paragraph 15 [sic] above, those statements

were false because Cooper was not a principal of AF Holdings or Ingenuity 13 and held no
position with either West Indian entity. Respondent Steele knew Cooper was in no way
connected with AF Holdings and Ingenuity 13 at the time those statements were made.
ANSWER:
Respondent specifically denies having made any assertions concerning Cooper's

participation in any manner in the ownership or operation of AF Holdings or Ingenuity 13,
or making any false statements in relation thereto, at any time referred to in Count I of this
Complaint.
20.
At all times alleged in this complaint, Local Rule 83-13 for the United States
District Court of the Central District of California, titled "Notice of Related Cases," provided
12
impertinent part as follows: It shall be the responsibility of the parties to promptly file a
Notice of Related Cases whenever two or more civil cases filed in this District:
(a) Arise from the same or a closely related transaction,

happening, or event;
(b) Callfor determination of the same or substantially related or

similar questions of law and fact; or
(c) For other reasons would entail substantial duplication of

labor if heard by different judges.
Local Rule 83-13 further required that the Notice of Related Cases be filed at the time
any case appearing to relate to another is filed, or as soon thereafter as it reasonably should
appear that the case relates to another.
ANSWER:
The allegations contained in paragraph 20 contain legal conclusions, to
which no answer is required. To the extent an answer is deemed required, Respondent

denies the allegations of paragraph 20. Further answering, Respondent states that he has
never been licensed to practice in any state or federal court in California. Further answering,
Respondent states that he has never filed a pro hac vice application to appear in any state or
federal case in California.
21.
The cases Respondent Steele and Paul Duffy filed in the Central District of
California described in paragraphs 13 through 15, above, were identical except for the
particular pornographic work at issue and the varying IP addresses identified in the
complaints.
ANSWER:
Respondent denies that he filed any cases in California at any relevant
time. Respondent denies any remaining allegations contained in paragraph 21.
13
22.
At no time did Respondent or Paul Duffy file a Notice of Related Cases in the
Central District ofCalifornia notifying the court that the caseswhichthey had filed on behalf
ofIngenuity 13 andAF Holdings were related, as required byLocal Rule 83-1.3.

ANSWER:
Respondent admits that he did not file any notices pursuant to Local
Rule 83-1.3. Respondent denies that he filed or was involved in any litigation in California
that would have required him to file any such notices. Respondent denies any remaining
allegations contained in paragraph 22.
23.
On December 3, 2012, John Doe's attorney, Morgan E. Pietz ("Pietz"), filed a
"Notice of Related Cases" in case number 12-CV-8333 on behalf of John Doe in which Pietz
identified multiple Ingenuity 13 cases filed by Prenda Law in the Central District of
California. In the Notice of Related Cases, Pietz informed the court that Prenda Law had filed
multiple "John Doe pornographic copyright infringement actions" in United States District
Courts, including 49 cases then pending in the Central District of California on behalf of
Ingenuity 13and AF Holdings, LLC; that the complaints filed by Prenda Law were identical
except for the particular pornographic work at issue and the varying IP addresses identified
in the complaints; and that common issues oflaw and fact relating to the propriety ofpreservice discovery could best be addressed in a unified proceeding before a single judicial
officer.
ANSWER:
The allegations contained in paragraph 23 purport to summarize
public documents whose contents speak for themselves, and of which Respondent had no
knowledge atthe time they were filed. Therefore, Respondent neither admits nor denies the
allegations contained in paragraph 23, and leaves the Administrator to his proof regarding
them. Further answering, Respondent states, upon information and belief, thatPeitz directed
14
his communications and pleadings toward Brett Gibbs, the California lawyer who filed the
cases referred to in paragraph 23.
24.
On December 18,2012, Pietz filed "Putative John Doe's ex parte Application for
Leave to Take Early Discovery and For a Further Stay of the Subpoena Return Date" in case
number 12-CV-8333. In the application, Pietz requested leave to take limited discovery
because of concerns that Prenda Law misused Alan Cooper's identity. Pietz raised concerns
that Prenda Law had held Cooper out to be the principal of Ingenuity 13 without Cooper's
knowledge or consent. In support of his application, Pietz attached an affidavit of Alan
Cooperin which Cooper averred that he was not the owner or CEO of AF Holdings, and was
not the owner or manager of Ingenuity 13, and that he never gave Respondent Steele
permission to use his name or sign documents on his behalf.
ANSWER:
knowledge at the time they were filed. Therefore, Respondentneither admits nor denies the
allegations contained in paragraph 24, and leaves the Administrator to his proofregarding
them. Further answering, Respondent states, uponinformation and belief, that Peitzdirected
his communications and pleadings toward Brett Gibbs, the California lawyer who filed the
cases referred to in paragraph 24. To the extent the allegations contained in paragraph 24
are meant to assert that Peitz' or Cooper's allegations as set forth therein are or were
truthful, Respondent lacks sufficient information to admit or denyany suchassertion.

25.
On December 19, 2012, the court issued a General Order by which all of the
Ingenuity 13 cases pending in the Central District of California were transferred to the
15
Honorable Otis D. Wright, who was already assigned to the copyright infringement actions
Respondents had filed on behalf of AF Holdings.
ANSWER:
Respondent denies that he filed copyright infringement actions on
behalf of AF Holdings in California, or that he filed any cases in California at any relevant
time. The remaining allegations contained in paragraph 25 purport to summarize public
documents whose contents speak for themselves, and of which Respondent had no
knowledge at the time they were filed. Therefore, Respondent neither admits nor denies the
remaining allegations contained in paragraph 25, and leaves the Administrator to his proof
regarding them.
26.
On December 20,2012, Judge Wright entered an order in case number 12-CV-
8333. In his order, Judge Wrightvacated all earlier orders permitting Respondent Steeleand
Paul Duffy to issue subpoenas, ordered all discovery efforts to cease, and quashed all
previously issued subpoenas.
ANSWER:
Respondent denies that any order entered by Judge Wright on
December 20, 2012 applied to or pertained to him. The remaining allegations contained in
paragraph 26 purport to summarize public documents whose contents speak for themselves,
and of which Respondent had no knowledge at the time they were filed. Therefore,
Respondent neither admits nordenies the remaining allegations contained in paragraph 26,
and leaves the Administrator to his proof regarding them.
27.
In his December 20, 2012 order, Judge Wright also ordered Ingenuity 13 to
show cause, in writing, by December 31, 2012, why early discovery was warranted. In his
order, Judge Wright stated:
The Court is concerned with the potential for discovery abuse in
cases like this. Ingenuity 13 accuses the Doe Defendant of

16
illegally copying a pornographic video. But the only information

Ingenuity 13 has is the IP address of the Doe Defendant. An IP
address alone may yield subscriber information. But that will
only lead to the person paying for the internet service and not
necessarily the actual infringer, who may be a family member,
roommate, employee, customer, guest, or even a complete
stranger, (citation omitted] And given the subject matter of
Ingenuity 13's accusations and the economics of defending such
a lawsuit, it is highly likely that the subscriber would
immediately pay a settlement demand regardless whether the
subscriber is the actual infringer. This Court has a duty to
protect the innocent citizens of this district from this sort of

legal shakedown, even though a copyright holder's rights may
be infringed by a few deviants. And unlike law enforcement in
child pornography or other internet crime cases, the Court has
no guarantee from a private party that subscriber information
will not be abused or that it would be used for the benefit of the
public. Thus, when viewed with the public interest in mind, the
Court is reluctant to allow any fishing-expedition discovery
when all a plaintiff has is an IP address-the burden is on the

plaintiff to find other ways to more precisely identify the
accused infringer without causing collateral damage.
Thus, the Court hereby ORDERS Ingenuity 13 TO SHOW CAUSE
in writing by December 31, 2012, why early discovery is
warranted in this situation. Ingenuity 13 must demonstrate to
the Court, in light of the Court's above discussion, how it would

proceed to uncover the identity of the actual infringer once it
has obtained subscriber informationgiven that the actual
infringer maybe a person entirelyunrelatedto the subscriber

while also considering how to minimize harassment and
embarrassment of innocent citizens. Ingenuity 13 must also
explain how it can guarantee to the Court that any such

subscriber information would not be used to simply coerce a
settlement from the subscriber (the easy route], as opposed to
finding out whothe true infringer is (the hard route].

ANSWER:
knowledge atthe time they were filed. Therefore, Respondent neither admits nor denies the
them.
17
28.
On December 26, 2012, Judge Wright granted Pietz's ex parte application
seeking leave to propound limited written discovery. On January 4,2013, Pietz propounded
special interrogatories and a request to produce documents to Respondent Steele and Paul
Duffy, seeking answers about the identity of Alan Cooper.
ANSWER:
Respondent denies that Pietz ever served any interrogatories on him.
The remaining allegations contained in paragraph 28 purport to summarize public

documents whose contents speak for themselves, and of which Respondent had no
remaining allegations contained in paragraph 28, and leaves the Administrator to his proof
regarding them.
29.
On December 31,2012, Respondent Steele did not show cause, in writing, why
early discoverywas warranted in case number 12-CV-8333, as required by Judge Wright in

the order set forth in paragraph 26, above. On that date, Respondent Steele and Paul Duffy
caused to be filed a motion to disqualify Judge Wright for cause.
ANSWER:
Respondent denies that he was ordered or required to show cause, on
December 31, 2012, for any reason or in any manner. Respondent denies any remaining
allegations contained in the first sentence of paragraph 29. Respondent denies the
allegations containedin the second sentence of paragraph 29.
30.
On January 15, 2013, the Honorable Michael W. Fitzgerald entered an order
denying Respondent's motion to disqualify Judge Wright. In the order, Judge Fitzgerald
stated "[plaintiff]'s argument boils down to its disagreement with the merits of Judge
Wright's discovery orders. This is nota cognizable basis for disqualification."
18
ANSWER:
Respondent denies that he filed, at any relevant time, any motion to
disqualify Judge Wright. The remaining allegations contained in paragraph 30 purport to

summarize public documents whose contents speak for themselves, and of which
Respondent had no knowledge at the time they were filed. Therefore, Respondent neither
admits nor denies the remaining allegations contained in paragraph 30, and leaves the
Administrator to his proof regarding them.
31.
On January 28, 2013, Prenda Law filed a "notice of voluntary dismissal of
action without prejudice" in case number 12-CV-8333 and the matter was dismissed on that
date.
ANSWER:
them.
32.
On February 7,2013, Judge Wright issued an Order to Show Cause re Sanctions
("OSC"] in case number 12-CV-8333 stating that "the court has a duty to supervise the
conduct of attorneys appearing before it." The OSC required Respondent Steele and Paul
Duffy, through local counsel Gibbs, to address Respondent Steele and Paul Duffy's lack of
reasonable investigation of copyright infringement activity and lack of reasonable
investigation of the actual infringer's identity. The OSC further required an explanation of
why Respondent Steele and Paul Duffy ignored the Court's discovery-stay Order, filed
complaints without reasonable investigation, and defrauded the Court by asserting a
copyright assignmentsecured with a stolen identity. Judge Wrightstated:

19
Upon review of papers filed by attorney Morgan E. Pietz, the

Court perceives that Plaintiff may have defrauded the Court. At
the center of this issue is the identity of a person named Alan
Cooper and the validity of the underlying copyright
assignments. If it is true that Alan Cooper's identity was
misappropriated and the underlying copyright assignments
were improperly executed using his identity, then Plaintiff faces
a few problems.
First, with an invalid assignment, Plaintiff has no standing in

these cases. Second, by bringing these cases, Plaintiffs conduct
can be considered vexatious, as these cases were filed for a
facially improper purpose. And third, the Court will not idle
while Plaintiff defrauds this institution.
Judge Wright scheduled a hearing for the OSC on March 11,2013.
ANSWER:
Respondent denies any allegation contained in paragraph 32 to the
effect that any order entered by Judge Wright on February 7, 2013 was directed at him or
otherwise pertained to him in any way. The remaining allegations contained in paragraph
32 purport to summarize public documents whose contents speak for themselves, and of
which Respondent had no knowledge at the time they were filed. Therefore, Respondent
neither admits nor denies the allegations contained in paragraph 32, and leaves the
33.
On March 5,2013, Judge Wright entered an order in case number 12-CV-8333
requiringRespondent Steele and Duffy to attend the March 11, 2013 hearing on the OSC. On
Friday, March 8, 2015, Respondent Steele and Paul Duffy caused to be filed an ex parte
application requesting that Judge Wright withdraw his March 5, 2013 order requiring their
attendance on Monday, March 11,2013. On March 11, 2013,Judge Wrightheld a hearing on
the OSC, at which neither Respondent Steele or Paul Duffy appeared.
ANSWER:
The allegations containedin the first sentence of paragraph 33 purport
to summarize public documents whose contents speak for themselves, and of which
20
Respondent had no knowledge at the time they were filed. Therefore, Respondent neither
admits nor denies the allegations contained in the first sentence of paragraph 33, and leaves
the Administrator to his proof regarding them. Respondent admits the allegations contained
in the second sentence of paragraph 33. Respondent denies the allegations contained in the
third sentence of paragraph 33. Further answering, Respondent states that as public records
reflect, he appeared at the March 11, 2013 hearing through counsel and made himself
available to address the Court via telephone, which the Court was made aware of at the
hearing. Further answering, Respondent states that he received 2 business days' notice of
the court's requirement that he appear at the hearing.
35.
On March 11,2013, at the OSC hearing, Alan Cooper testified. Cooper testified
in court that the signature of his name on a copyright assignment agreement allegedly
related to the Ingenuity litigation, was not his signature and he had never signed it or seen
the copyright assignment. He testified that several other copyright assignments, corporate
documents and pleadings in related federal litigation matters appeared to contain his
signature but in fact, it was not his signature. In addition, he testified that he had never given
anyone permission to sign his name on any of the documents. Further, although he was listed
as a manager of Ingenuity 13 LLC, the president of VPR, Inc. and the registrar of an internet
domain name called notissues.com, he had nothing to do with any of those entities, had never
signed any of the documents, given permission for his name to be signed, was never the
manager or president of either corporation and never lived in Phoenix, Arizona, the address
of record for those entities. In addition, one of the documents contained an e-mail contact
address of johnsteele(5).gmail.com which Mr. Cooper testified was never his email address.
21
ANSWER:
Cooper's March 11, 2013 testimony, the contents of which speak for themselves, and of
which Respondent had no knowledge at the time the testimony was given. Therefore,
Respondent neither admits nor deniesthe allegations contained in paragraph 35,and leaves
the Administrator to his proof regarding them. To the extent that the allegations contained
in paragraph 35 are meant to assert that Cooper's testimony was accurate or true,
Respondent denies any such assertion. Further answering, Respondent states that prior to
2013, Cooper asked him how to get involved in the adult entertainment industry. Further
answering, Respondent states that prior to 2013, he assisted Cooper, at Cooper's request, in
forming a Nevada corporation called VPR, Inc. Further answering, Respondent states that
upon information and belief, Cooper did not take any actions necessary to operate VPR, Inc.
at a profit or inany othermanner, and that upon information andbelief, VPN, Inc. never had
any operations, assets or obligations. Further answering, Respondent states that
johnsteele(5)gmail.com has never been his email address.
36.
At the March 11,2013 OSC hearing Brett Gibbs testified about his relationship
with Prenda Law. Gibbs was supervised at all times by Respondent Steele and Paul
Hansmeier and Gibbs stated that they were the decision makers at that firm. Gibbs was told
by Respondent Steele and Paul Hansmeier that Prenda Law was taking over the business of
Steele Hansmeier. Gibbs testified that at all times, he was given authority to do what he was
doing by Respondent Steele and Hansmeier, including they would instruct him on what cases
to file and give himthe guidelines on what to do with the case.
ANSWER:
Gibbs' March 11, 2013 testimony, the contents ofwhich speak for themselves, and ofwhich
22
Respondent had no knowledge at the time the testimony was given. Therefore, Respondent
Administrator to his proof regarding them. To the extent that the allegations contained in
paragraph 36 are meant to assert that Gibbs' testimony was accurate or true, Respondent
denies any such assertion.
37.
On March 14, 2013, Judge Wright entered orders denying Respondent's ex
parte application and requiring Respondent and Paul Duffy to appear on April 2, 2013, to
show cause why they should not be sanctioned for their participation, direction and
execution of the acts described in the February 7,2013 OSC set forth in paragraph 31, above;
why they should not be sanctioned for failing to notify the court of all parties that have a
financial interest in the outcome of the litigation; why they should not be sanctioned for
defrauding the court by misrepresenting the nature and relationship of the individuals and
entities involved in the litigation; why Respondent Steele and Hansmeier should not be
sanctioned for failing to make a pro hac vice appearance before the court, given their
involvement as "senior attorneys" in the cases; and why Respondent Steele and Paul Duffy
should not be sanctioned for contravening the court's March 5, 2013 order and failing to
appear on March 11, 2013.
ANSWER:
public documents whose contents speak for themselves. Therefore, Respondent neither
admits nor denies the allegations contained in the first sentence of paragraph 37, and leaves
in paragraph 37 are meant to assert that Respondent defrauded any court, made any
misrepresentation with respect to any litigation, was a "senior attorney" in connection with
23
any California case, contravened any court order, or failed to appear for the March 11, 2013
hearing, Respondent denies any such assertion.
38.
On April 2, 2013, Judge Wright held a hearing in case number 12-CV-8333 on
the OSC. At that time, Respondent Steele and Paul Duffy appeared, invoked their right to
remain silent under the 5th Amendment to the United States Constitution, and refused to
answer any questions concerning case number 12-CV-8333, or address the questions raised
by Judge Wright in his February 7 and March 14 orders described in paragraphs 31 and 36,
above.
ANSWER:
answering, Respondent states that he invoked his 5th Amendment rights in order to avoid
any possibility of violating the attorney-client privilege, and upon advice of counsel.
39.
On May 6, 2013, Judge Wright entered an order issuing sanctions against
Respondent Steele in case number 12-CV-8333, and ordered Respondent to pay John Doe's
attorneys, within 14 days of the order, attorney's fees and costs totaling $81,319.72, which
included a punitive multiplier justified by Respondent's "brazen misconduct and relentless
fraud." In his sanction order, Judge Wright found that Respondent Steele and Duffy formed
AF Holdings and Ingenuity 13 for the sole purpose of litigating copyright-infringement

lawsuits, to shield themselves from potential liability, and to give an appearance of
legitimacy; that AF Holdings and Ingenuity 13 have no assets other than several copyrights
to pornographic movies and the Respondent Steele and Duffy are the defacto owners and
officers; that Respondent engaged in vexatious litigation designed to coerce settlement; that
Respondent Steele stole the identity of Alan Cooper and fraudulently signed his name to a
copyright assignmentand held him out to be an officer ofAF Holdings; that Respondent has
24
demonstrated their [sic] willingness to deceive the court; that Respondent's representations
about their [sic] operations, relationships, and financial interests have varied from feigned
ignorance to misstatements to outright lies; and that the deception was calculated so that
the Court would grantRespondent's early-discovery requests, thereby allowing Respondent
Steele toidentify defendants andexact settlement proceeds from them. The Court also stated
that Respondent:
Demonstrated [a] willingness to deceive not just [that] Court,

but other courts where they have
appeared.
[Their]
representations about their operations, relationships and

financial interests have varied from feigned ignorance to
misstatements to outright lies. Butthis deception was calculated

so that the Court would grant [their] early discovery requests,
thereby allowing [them] to identify defendants and exact

settlement proceeds from them.
ANSWER:
The allegations contained in paragraph 39purportto summarize Judge
Wright's May 6, 2013 order, the contents of which speak for themselves. Therefore,
Respondent neither admits nor denies the allegations contained in paragraph 39, and leaves
in paragraph 39 are meant to assert that Judge Wright's findings and conclusions as
expressed in the order were accurate, or that they stand as proof of any other matter
asserted in the Administrator's Complaint, Respondent denies any such assertion. Further
answering, Respondent states that an appeal of Judge Wright's order is currently pending
before the U.S. Court of Appeals for the Ninth Circuit.
40.
On May 17, 2013, Respondent Steele caused to be filed notices ofappeal of
Judge Wright's May 6, 2013 order to the United States Court of Appeal for the Ninth Circuit
on behalf of themselves [sic] individually, as well as Prenda Law, Ingenuity 13, and AF
Holdings.
25
ANSWER:
Respondent admits the allegations contained in paragraph 40 through
and including the word "Circuit." Respondent denies any remaining allegations contained in
paragraph 40.
41.
In orders dated May 21 and June 6, 2013, Judge Wright required Respondent
Steele and Paul Duffy to post bond totaling $237,583.66, as security for the May 6, 2013
sanction order, and to cover costs and attorneys' fees on appeal. On May 23, and July 18,
2013, Respondent caused the required bond to be posted. On May 4, 2015, a three-judge
panel heard oral arguments in the appeal, and the matter is under advisement.
ANSWER:
paragraph 41. Respondent denies the allegations contained in the second sentence of
paragraph 41. Respondent admits the allegations contained in the third sentence of
paragraph 41.
42. By reason of the conduct described above, Respondent has engaged in the
following misconduct:
a.
bringing a proceeding without a basis in law and fact for

doing so that is not frivolous, by conduct including filing
lawsuits without supporting facts, under the names of
fictional entities, and misusing the identity of Alan
Cooper, for purposes of exacting settlements, in violation
of Rule 3.1 of the Illinois Rules of Professional Conduct;
b.
knowingly disobeying an obligation under the rules of a

tribunal by conduct including failing to abide by Judge
Wright's order quashing discovery, and failing to appear
as ordered at the OSC hearing, in violation of Rule 3.4(c]
of the Illinois Rules of Professional Conduct;
c.
in a pretrial procedure making a frivolous discovery

request(s], by conduct including filing the motions for
early discovery on behalf of shell corporations in
violation of Rule 3.4(d) of the Illinois Rules of
Professional Conduct;
26
d.
in representing a client, using means that have no

substantial purpose other than to embarrass or burden a
third person, or using methods of obtaining evidence
that violate the legal rights of such a person, by conduct
including sending the settlement shakedown letters in
violation of Rule 4.4 of the Illinois Rules of Professional
Conduct;
e.
conduct involving dishonesty, fraud, deceit, or

misrepresentation, by conduct including filing lawsuits
without supporting facts, under the names of fictional
entities, misusing the identity of Alan Cooper as a
principal of Ingenuity 13 and AF holdings, for purposes
of exacting settlements, in violation of Rule 8.4(c]; and
f.
conduct that is prejudicial to the administration of

justice, by conduct including failing to respond to
reasonable inquiries posed by the tribunal regarding
lawsuits Respondents initiated, in violation of Rule
8.4(d) of the Illinois Rules of Professional Conduct.
ANSWER:
The allegations contained in paragraph 42 are not factual, but rather
state legal conclusions. Therefore, no answer is required. To the extent an answer is deemed
to be required, Respondent denies the allegations contained in paragraph 42.
COUNT II
[Alleged entryofdefaultjudgmentinAlan Cooper v. John Lawrence Steele and Prenda Law)

43.
The Administrator realleges paragraphs 13 through 40 of Count I, above.
ANSWER:
Respondent reincorporates his answers to paragraphs 13 through 40
as set forth above.
44.
OnJanuary 23,2013, Cooper filed suit against Respondent Steele, Prenda Law,
AF Holdings, and Ingenuity 13 in the Fourth Judicial District Court, Hennepin County,
Minnesota. The Clerk of the Court received the matter and docketed it as Alan Cooper v.John
Lawrence Steele, Prenda Law, LLC, AF Holdings and Ingenuity 13, case number 27-CV-13-
3463. In the complaint, Cooper alleged that Respondent engaged in identity theft, by using
27
his name in connection with AF Holdings and Ingenuity 13's purported purchase of
copyrights to pornographic movies, and then bringinglawsuits usinghis identitywithout his

permission.
ANSWER:
Respondent admits the allegations contained in the first two sentences
of paragraph 44.The allegations containedin the third sentence of paragraph 43 purport to
summarize Judge Wright's Gibbs' May 6, 2013 order, the contents of which speak for
themselves. Therefore, Respondent neither admits nor denies the allegations contained in
paragraph 44, and leaves the Administrator to his proofregarding them. To the extent that
the allegations contained in paragraph 44 are meant to assert that Cooper's allegations are
accurate or true, Respondent denies any such assertion. Further answering, Respondent
states that Cooper requested reliefin the total amount of $4.6 million.
45.
On or about April 21,2015, RespondentSteele agreedto settle Cooper's claims
against him in theamount of$35,000. On thatdate, thecourt also dismissed AF Holdings and
Ingenuity 13 from case number 27-CV-13-3463 because the entities had never been served.
ANSWER:
answering, Respondent states that as part ofsettling the matter for a small fraction of the
relief sought, Respondent made no admissions offact and agreed to no conclusions oflaw
concerning Cooper's allegations and claims. Further answering, Cooper admitted, during the
pendency of his case, that he had no personal knowledge of the allegations made in the
complaint.
46.
As ofApril 27, 2015, Respondent had not filed an answer on behalf ofPrenda
Law in casenumber 27-CV-13-3463. On that date,the court entered an order finding Prenda
28
Law in default, and scheduled a hearing for June 10, 2015, to determine the appropriate
damages to be awarded Cooper.
ANSWER:
Respondent admits the allegations contained in paragraph 46, except
to the extent that those allegations tend to assert or imply that Respondent had any
obligation of any kind to file an answer, or take any other action, on behalf of Prenda.
Respondent denies any such assertion or implication.
47.
On June 10, 2015, the court held a hearing in case number 27-CV-13-3463 to
determine Cooper's damages at which Paul Duffy appeared "in his personal capacity as a
former principle [sic] of Prenda Law." At the hearing, Paul Duffy stated that Prenda Law is no
longer in business. The court allowed Paul Duffy until July 10, 2015, to respond to Cooper's
affidavits regarding his damage claim. Paul Duffy then requested additional time to respond
to Cooper's affidavits, and the court extended the time to July 13, 2015, for Paul Duffy and
Respondent Steele to submit the response.
ANSWER:
proceedings in case number 27-CV-13-3463 as reflected in public records, the contents of

which speak for themselves, and in which Respondent had no involvement. Therefore,
in paragraph 47 are meant to assert that Respondent had any involvement in case number
27-CV-13-3463 as of the dates referred to in paragraph 47, Respondent denies any such
assertion.
48.
At no time did Respondent Steele or Paul Duffy file any response to Cooper's
affidavits in case number 27-CV-13-3463.
29
ANSWER:
obligation of any kind to file responses to Cooper's affidavits, or take any other action, on
behalf of Prenda, or on behalf of himself following his settlement of Cooper's claims.
49.
On July 15, 2015, the court entered an order for judgment in case number27-
CV-13-3463. The court found that Cooper was entitled to a judgment against Prenda Law in
the amount of $5,000 as damages for humiliation. The court also found that Cooper was
entitled to judgment against Prenda Law in the amount of$250,000 as punitive damages,
stating
Attorneys have a special obligation not to use another person's

name without their explicit permission. If such permission had
been given, Prenda as a law office could have and should have
gotten that permission in writing. It is also obvious that Prenda
undertook this deception to avoid namingits principles [sic] as

the drivingforce ofthis scheme. Cooper was straw man [sic] put
up to protect them from obvious ethical violations of creating
litigation. Although the court is uncertain about the exact gains
that Prenda reaped from this enterprise, it has no doubt that
substantial gains were made. The gains were sufficiently

tempting that Prenda was willing to overlook what it considered
minimal risk. Punitive damages are critical in situations like this
where money damages does not adequately encompass the

wrong done in stealing a person's name for one's own benefit.
Punitive damages must be sufficient to deter similar abuses of
professional integrity. The court finds that $250,000 in punitive

misappropriate and necessary to act as stern warning not to
engage in this type of conduct.
ANSWER:
proceedings in case number 27-CV-13-3463 as reflected in public records, the contents of

which speak for themselves, and in which Respondent had no involvement. Therefore,
30
in paragraph 49 are meant to assert that the quote from the order referred to in paragraph
49 is the full text of the order, Respondent denies any such assertion. To the extent that the
allegations contained in paragraph 49 are meant to assert that Respondent had any
involvement in case number 27-CV-13-3463 as of the dates referred to in paragraph 49,
Respondent denies any such assertion. To the extent that the allegations contained in
paragraph 49 are meant to assert that Respondent stole the identity of Cooper or anyone
else, Respondent denies any such assertion. Further answering, Respondent states that the
order referred to in paragraph 49 also stated:

Despite litigating this case for over two years... and even though
Mr. Godfread has admittedly been chasing Mr. Steele and Prenda
around the country, Plaintiff did not produce one affidavit or
deposition substantiating profits that Prenda made from this
copyright scheme, or more specifically from the use of Mr.
Cooper's name. The claim is notable for what is lacking.
50.
At the time this complaint was filed with the Hearing Board of the Commission,
Respondent Steele had not paid the judgments entered against Prenda Law in case number
27-CV-13-3463.
ANSWER:
obligation of any kind to pay any judgment, or take any other action, on behalf of Prenda, or
on behalf of himself following his settlement of Cooper's claims. Respondent denies any such
assertion or implication.
51.
By reason of the conduct described above. Respondent has engaged in the
31
a.
bringing proceedings without a basis in law and fact for

lawsuits under the names of fictional entities and
misusing the identity of Alan Cooper, for purposes of

exacting settlements, in violation of Rule 3.1 of the
Illinois Rules of Professional Conduct;
b.

entities, misusing the identity of Alan Cooper as a
principal of AF Holdings and Ingenuity 13, for purposes

of exacting settlements, in violation of Rule 8.4(c); and
c.
justice, by conduct including filing lawsuits without

supporting facts, under the names of fictional entities,
misusing the identity of Alan Cooper as a principal of AF

Holdings and Ingenuity 13, for purposes of exacting
settlements, in violation of Rule 8.4(d) of the Illinois
Rules of Professional Conduct.
ANSWER:
state legal conclusions. Therefore, no answer is required. To the extent an answer is deemed
to be required, Respondent denies the allegations contained in paragraph 51. Further

answering, Respondent states that the allegations contained in paragraphs 43 through 51 do
not state a cause of action against him, and should be dismissed.
COUNT III
{Alleged badfaith litigation and alleged improper use ofthejudicialsystem

in Guava v. Spencer Merkel)
52.
On or about September 28, 2012, Spencer Merkel ("Merkel"), a resident of
Beaverton, Oregon, received a September 26, 2012 settlement shakedown letter caused to
be sent by Respondent Steele on Prenda Law letterhead, signed by Paul Duffy. The letter
stated that the firm had been retained by Hard Drive Productions, Inc. "to file lawsuits
against people caught stealing its movies." The letter stated that Merkel's IP address was
32
identified by Respondent's client's forensic experts as illegally downloading Hard Drive's

movie titled Amateur Allure - Maelynn. The letter further stated that Prenda was authorized
to accept the sum of$3,400as full settlement of Hard Drive's claims against Merkel, and that
the offer would expire on October 11, 2012. The letter gave the address of Prenda Law in
Chicago for mailing in the settlement payment.
ANSWER:
53.
The September 26 letter stated that copyright owners like Hard Drive may
recover up to $150,000 in damages per infringing file; that others whohad engaged in similar
conductand contested the allegations ended up subjectto damage awards of $222,000; that
if Merkel wished to avoid the stress of litigation he could settle now for $3,400 and avoid
being subject to a public lawsuit where hewould be named as a defendant. The letter stated
that their client had weighed aspects ofthe case including "likelihood ofsuccess, recovery of
damages and the burden of federal litigation on all parties" and was willing to accept a
settlement offer in exchange for not filing a lawsuit. The letter contained litigation hold
language and threatened damages for spoliation ofevidence ifMerkel deleted any files on
his computer.
ANSWER:
The allegations contained in paragraph 53 purport to summarize a
letter, the contents ofwhich speak for themselves, andin relation to which Respondent had
noinvolvement. Therefore, Respondent neitheradmits nor denies the allegations contained
in paragraph 53, and leaves the Administrator tohis proofregarding them. To the extent that
the allegations contained in paragraph 53 are meant to assert orimply that Respondent had
any involvement in creating orsending the letter, orthat he had knowledge of its contents at
any relevant time, Respondent denies any such assertion or implication.
33
54.
Shortly after Merkel, who lived below the poverty level in Oregon,received the
letter from Prenda Law, he phoned the Prenda Law offices and spoke with a Prenda
employee who identified himself as "Mike or Michael." Merkel informed "Michael" that he
could not afford the $3,400 settlement payment. At that time, and at Respondents' direction,
"Michael" told Merkel that Prenda Law would settle Hard Drive's claims against Merkel
under the following terms: Merkel would agree to be sued; in the lawsuit filed against Merkel,
Prenda Law would request a copy of the BitTorrent log from Merkel's computer under the
pretext of corroborating Prenda's evidence of Merkel's IP address; upon receipt of Merkel's
BitTorrent log, Prenda would then dismiss the lawsuit against Merkel. "Michael" informed
Merkel that he did not know of any pro bono attorneys in Oregon, but that he could provide
the name of a Minnesota attorney who would represent Merkel pro bono in the lawsuit
Prenda would file against Merkel. Merkel agreed to be represented pro bono by a Minnesota
attorney, Trina Morrison ["Morrison"), and further agreed to be sued by Hard Drive and
Prenda Law in the State of Minnesota.
ANSWER:
allegations contained in paragraph 54. Further answering, Respondent states that his name
is not, and has never been, "Mike" or "Michael," and that he has never held himself out as
having either of those names or referred to himself as having either of those names.
55.
On or about October 15,2012, Respondent Steele and Paul Duffy, operating as
Alpha Law, not Prenda Law, served Merkel with a complaint, purportedly on behalf of Guava
LLC, not Hard Drive, which was titled Guava LLC v. Spencer Merkel. On October 17, 2012,
Respondent Steele caused the complaint to be filed in the Fourth Judicial District Court,
Hennepin County, Minnesota. Michael Dugas ("Dugas"), a Minnesota attorney who went to
34
law school with Morrison, had been an associate for Prenda Law, and handled cases with
Respondent, signed the complaint on behalf of Alpha Law. The Clerk of the Court received
the matter and docketed it as Guava LLC, v. Spencer Merkel, case number 27-CV-12-20976. In
the complaint, Guava LLC was described as "a limited liability company that owns and
operates protected computer systems accessible throughout Minnesota," and alleged Merkel
engaged in the interception of electronic communications in violation of a Minnesota statute,
and also engaged in civil conspiracy to violate the same statute.

ANSWER:
Respondent denies any allegations contained in paragraph 55 to the
effect that he took any action with respect to, or had anything whatsoever to do with, the
matters referred to in paragraph 55. Respondent has insufficient information to admit or
deny any remaining allegations contained in paragraph 55.
56.
On October 25, 2012, Guava filed an "unopposed discovery motion for
authorizing order," in which it sought the court's approval of subpoenas directed to more
than 300 Internet Service Providers, purportedly to discover Merkel's alleged co
conspirators' names, addresses, telephone numbers, e-mail addresses, and media access
control addresses.
ANSWER:

57.
On October 31,2012, the court held a hearing on Guava's discovery motion, at
which neither Morrison nor Merkel appeared. At that time, the court denied the motion,
finding that Guava had "not demonstrated that the personally identifying information
possessed by over 300 Internet Service Providers is relevant and material to this matter."
35
ANSWER:
58.
On November 6, 2012, Guava filed an "emergency renewed unopposed
discovery motion for authorizing order" in case number 27-CV-12-20976. In the motion,
Guava sought the approval for subpoenas directed to 17 ISPs, and asserted that "these
specific ISPs unquestionably possess information connected to the issues in this litigation."
ANSWER:
59.
On November 7, 2012, the court held a hearing in case number 27-CV-12-
20976 on Guava's emergency motion. At that time, the court issued an order granting
Guava's motion but allowing the targeted ISPs a period of 30 days to file motions to quash
the subpoenas.
ANSWER:

60.
In or about November 2012, Guava issued subpoenas to the 17 ISPs outlined
in its emergency motion. After service of the subpoenas from Guava, certain ISPs and
individual Internet subscribers, referenced as "John Does," moved to quash the subpoenas.
ANSWER:

61.
On November 27, 2012 and January 12, 2013, Respondent Steele, through
Anti-Piracy Law Group, not Prenda Law or Alpha Law, caused a letter to be sent to James
Jungers Hungers"), a resident of Nebraska, settlement shakedown letters signed by Paul
Duffy, advisingJungers of case number 27-CV-12-20976. In the letters, Jungers was informed
36
that Respondent's client's "engineers" had observed Jungers' IP address as associated with
an IP address engaged in activities violating "computer access statutes" attempting to
circumvent their client Guava's computer security measures. The January 12, 2013 letter
offered to settle Guava's claims for the sum of $4,000, or else Jungers' identity would be
disclosed in a public lawsuit. The letters contained language similar to the language in the
settlement shakedown letter described in paragraph 10, above, and Merkel's letter described
in paragraphs 51 and 52, above.
ANSWER:
effect that he took any action with respect to, or had anything whatsoever to do with, the
matters referred to in paragraph 61. Respondent has insufficient information to admit or
deny any remaining allegations contained in paragraph 61. Further answering, Respondent
reasserts his objection to the use throughout the Administrator's Complaint of the
argumentative term "'settlement shakedown' letter."
62.
On January 15, 2013, Merkel received a voice mail message from a phone call
on behalf of Prenda Law stating that he needed to make payment arrangements or he would
be sued.
ANSWER:
63.
On January 25, 2013, the court held a hearing on the motions to quash the
Guava subpoenas in case number 27-CV-12-20976. Respondent Steele and Hansmeier
represented Guava at the hearing. Respondent Steele asserted that Guava was not required
to file a certificate of authority, which was a statutory prerequisite for foreign entities doing
business in Minnesota before bringing suit, because Guava was not doing business in
37
Minnesota, and despite Guava's and Merkel's lack of connections to Minnesota, personal
jurisdiction was proper because the parties consented to it Counsel for the ISPs and John
Does asserted at the hearing that the litigation was being pursued for the improper purpose
of using third-party discovery to obtain names of Internet subscribers from whom
settlements could be extorted. In support of their position, counsel for the ISPs submitted an
affidavit from Merkel describing his interactions with Prenda Law prior to the initiation of
the lawsuit, as described in paragraphs 51 through 53, above.

ANSWER:
paragraph 63. Further answering, Respondent states that he was appearing only as a
courtesy and an accommodation to Paul Duffy, who was unable to attend. Respondent admits
the remaining allegations contained in paragraph 63, except any allegation to the effect that
it was necessary to have filed a certificate of authority in the Guava case, which allegation is
not factual but a conclusion of law, and therefore no answer is required.
64.
At the January 25,2013 hearing in case number 27-CV-12-20976, the court also
heard testimony from Morrison. In her testimony, Morrison stated that she graduated from
law school with Michael Dugas. She stated that Hansmeier and Dugas told her they had some
pro se defendants who they would refer to her so she could get experience and because it
was easier to deal with lawyers than pro se litigants. Subsequent to her conversation, Merkel
contacted Morrison and she agreed to represent him. Morrison testified that based on what
she had been told, she expected a lawsuit against Merkel filed by Hard Drive and Prenda Law,
and that "[t]here's been some bait and switch you might call it in this case." At the January
38
25,2013 hearing,counselforthe ISPs and JohnDoes also asserted that the improper purpose
of the litigation was evidenced by Guava's failure to seek any discovery from Merkel himself.
ANSWER:
The allegations contained in paragraph 64 purport to summarize the
testimony of Trina Morrison, the contents of which speak for themselves, and of which
Respondent had no knowledge prior to the time at which it was given. Therefore,
in paragraph 64 are meant to assert or imply that Respondent had any relationship or
contact with Morrison, or that he had knowledge of her conduct at any relevant time,
65.
An affidavit from Merkel was presented to the court at the January 25 hearing.
Merkel stated under oath in the affidavit that the Hard Drive Productions, Inc. movie that he
admitted to downloading was downloaded from a now-defunct website www.cheggit.com.
The website operated on a membership-basis that was, when Merkel joined, free and open
to anyone who was interested in joining, and Merkel did not illegally download Hard Drive
Productions' copyrighted material.

ANSWER:
The allegations contained in paragraph 65 purport to summarize the
affidavit of Spencer Merkel, the contents of which speak for themselves, and of which
Respondent had no knowledge prior to the time at which the affidavit was provided to the
court. Therefore, Respondent neither admits nor denies the allegations contained in
paragraph 65, and leaves the Administrator to his proof regarding them. To the extent that
the allegations contained in paragraph 65 are meant to assert or imply that Respondent had
39
any relationship or contact with Merkel, or that he had knowledge of his actions or conduct
at any relevant time, Respondent denies any such assertion or implication.
66.
At the conclusion of the January 25 hearing, the court indicated that it would
take the matter under advisement, but was inclined to dismiss the entire action based on
Guava's failure to file a certificate of authority as required by Minnesota statute.

ANSWER:
67.
Respondent admits the allegations contained in paragraph 66.
On February 26, 2013, Respondent Steele, through Anti-Piracy Law Group in
Chicago, caused another settlement shakedown letter to be sent to Jungers, signed by Paul
Duffy advising him of case number 27-CV-12-20976 and offering to settle Guava's claims
against Jungers for the sum of $4,000. The letter also advised Jungers that he would be named
in a public lawsuit if he did not pay them the demanded $4,000 and settle with them.
ANSWER:
paragraph 67. The remaining allegations of paragraph 67 purport to summarize a letter, the
contents of which speak for themselves, and of which Respondent had no knowledge at any
relevant time. Therefore, Respondent neither admits nor denies the allegations contained in
any relationship or contact with Merkel, or that he had knowledge of his actions or conduct
at any relevant time, Respondent denies any such assertion or implication. Respondent
admits the allegations contained in the third sentence of paragraph 67. Further answering,
Respondent reasserts his objection to the use throughout the Administrator's Complaint of
the argumentative term "'settlement shakedown' letter."
40
68.
On March 1, 2013, before the court issued a ruling on the motions to quash,
Guava and Merkel filed a stipulation for dismissal with prejudice in case number 27-CV-1220976.
ANSWER:
The allegations of paragraph 68 purport to summarize a stipulation, the
any involvement in creating or filing the stipulation at any relevant time, Respondent denies
any such assertion or implication.
69.
On March 1, 2013, counsel for one group of the John Does filed a motion to
recover attorneys' fees, and requested that the court issue an order to show cause ("OSC")
why Guava and its counsel should not be required to pay the attorneys' fees incurred by all
of the ISPs and John Does in defending against the subpoenas in case number 27-CV-1220976.
ANSWER:
The allegations of paragraph 69 purport to summarize a motion, the
paragraph 69, and leaves the Administrator to his proof regarding them.
70.
On March 6, 2013, the court issued an OSC in case number 27-CV-12-20976
requiring Guava, Dugas, and Alpha Law to personally appear and show cause at a hearing on
April 23, 2013, "why the court should not order them to pay the reasonable attorneys' fees
and costs incurred by the non-parties to this action."
41
ANSWER:
The allegations of paragraph 70 purport to summarize an order, the
the allegations contained in paragraph 70 are meant to assert or imply that Respondent was
required to do anything, or to refrain from doing anything, by the order referred to in
paragraph 70, Respondent denies any such assertion or implication.
71.
On April 23, 2013, the court held a hearing on the OSC in case number 27-CV-
12-20976. No corporate representative from Guava appeared at the hearing as required by
the OSC and neither Respondent [sic] appeared. The only attorney to appear was Dugas. The
court inquired why there was no evidence presented regarding Guava's structure or its
business, and statedThe allegations of paragraph 70 purport to summarize an order, the

So if you want to show me that you're not doing a fraud on the
Court, then why wouldn't you say Your Honor, this is wholly
unjust, how dare they say these things? Look here's my affidavit
from the President and CEO of Guava LLC. This is the nature of
the business that we do. This is how we found out about what
Mr. Merkel was doing. Why don't I have anything like that?
ANSWER:
Respondent has insufficient knowledge to admit or deny the allegations
contained in paragraph 71.

42
72.
On August 7, 2013, the court issued an order granting in part the nonparties'
motions for attorneys' fees and costs in case number 27-CV-12-20976. The court ordered
Guava, Dugas, and Alpha Law jointly and severally liable to pay within 30 days a total of
$63,367.52 in attorneys' fees and costs to one attorney and four law firms representingthe
ISPs and John Does.
ANSWER:
73.
On August 30, 2013, the court issued a memorandum in support of its August
7 order in case number 27-CV-12-20976. In that memorandum, the court concluded that
With no good faith pursuit against Merkel in this case, the Court
is left only with Guava's attempts to harass and burden NonParties through obtaining IP addresses to pursue possible
settlement rather than proceed with potentially embarrassing
litigation regarding downloading pornographic movies.
ANSWER:
43

74.
On September 20,2013, the court entered a judgment with findings of fact and
conclusions of law and held that the plaintiff, Guava LLC and Respondent Steele and Paul
Duffy (through Alpha Law firm) acted in bad faith to the Non-Party John Does, Non-Party
ISPs and their counsel, and found them jointly and severally liable in the total amount of
$63,367.
ANSWER:
75.
On October 30, 2013, Guava filed a notice of appeal of the court's sanction
order in case number 27-CV-12-20976. In an August 4, 2014 opinion, the State of Minnesota
Court of Appeals upheld the court's order of attorneys' fees and sanctions against Guava,
finding that Guava pursued the litigation in bad faith and engaged in an improper use of the
judicial system.
ANSWER:
The allegations of paragraph 75 purport to summarize a pleading and
an appellate opinion, the contents of which speak for themselves, and of which Respondent
had no knowledge at any relevant time. Therefore, Respondent neither admits nor denies
the allegations contained in paragraph 75, and leaves the Administrator to his proof
regarding them. To the extent that the allegations contained in paragraph 75 are meant to
assert or imply that Respondent had any involvement in the pleading or the appellate
opinion referred to in paragraph 75, Respondent denies any such assertion or implication.
76.
As of July 14, 2015, the date the Inquiry Panel voted to file this complaint
against Respondent Steele, the attorneys' fees and costs totaling $63,367.52 had not been
paid.
44
ANSWER:
Respondent has insufficient knowledge to admit or deny the allegations
77.
By reason of the conduct described above, Respondent has engaged in the
a.

lawsuits without supporting facts, under the names of
fictional entities, for purposes of exacting settlements,
for the improper purpose of using third-party discovery
to obtain names of Internet subscribers from whom
settlements could be exacted, in violation of Rule 3.1 of

the Illinois Rules of Professional Conduct;
b.

tribunal by conduct including failing to appear as
ordered at the OSC hearing, in violation of Rule 3.4(c) of
c.

request by conduct including filing the motions for early
discovery on behalf of a shell corporation, in violation of
Rule 3.4(d) of the Illinois Rules of Professional Conduct;
d.

including sending the settlement shakedown letters, in
Conduct;
e.

entities, for purposes of exacting settlements, and for the
improper purpose of using third-party discovery to
obtain names of Internet subscribers from whom
settlements could be exacted, in violation of Rule 8.4(c);

and
f.

justice, by conduct including filing lawsuits without
45
supporting facts, under the names of fictional entities, for

purposes of exacting settlements, and for the improper
purpose of using third-party discovery to obtain names
of Internet subscribers from whom settlements could be
exacted, in violation of Rule 8.4(d) of the Illinois Rules of

Professional Conduct.
ANSWER:
state legal conclusions. As such, no answer is required. To the extent an answer is deemed
required, Respondent denies the allegations contained in paragraph 77.

COUNT IV
{Alleged badfaith litigation and alleged dishonest conduct in

Lightspeed Media Corp. v. Anthony Smith)
78.
On December 14, 2011, Respondent Steele caused to be filed suit on behalf of
an online pornography site called Lightspeed Media against one John Doe defendant, who
was identified only through his IP address, in the circuit court of St. Clair County, Illinois. The
Clerk of the Court received the matter and docketed it as Lightspeed Media v.John Doe, case
number ll-L-683. In the complaint, Respondent Steele and Paul Duffy alleged that Doe's IP
address was associated with the unlawful viewing of Lightspeed's pornographic movies,
which was made possible by the use of a widely shared, "hacked" password. The complaint
identified approximately 6,600 other IP addresses as alleged "co-conspirators" in an alleged

scheme to steal passwords and content.
ANSWER:
79.
On December 16, 2011, the court in case number ll-L-683 granted the ex
parte motion for leave to obtain discovery by subpoena from ISPs who were not parties to
the lawsuit which Respondent caused to be filed. In the subpoenas, Respondent Steele and
Paul Duffy requested the personally identifiable information of each of the 6,600 alleged co
conspirators, none of whom had been joined as parties.
46
ANSWER:
Theallegations ofthe firstsentenceofparagraph79 up to and including
the word "lawsuit" purport to summarize an order, the contents of which speak for
themselves, and of which Respondent had no knowledge at any relevant time. Therefore,
Respondent neither admits nor denies the allegations contained in the first sentence of
paragraph 75 up to and including the word "lawsuit", and leaves the Administrator to his
proof regarding them. Respondent denies all remaining allegations contained in paragraph
75.
80.
In or about January 2012, two of the ISPs which had been served with
subpoenas through Respondent, SBC Internet Services, LLC, d/b/a AT&T ("AT&T") and
Comcast Cable Communication ("Comcast"), filed motions to quash the subpoenas that
issued to them in case number ll-L-683. In or about February 2012, the court denied the
ISPs' motion to quash. At that time, Paul Duffy called an attorney representing the ISPs and
requested the name and title of each employee who decided that an ISP would not comply
with the subpoenas. On April 26, 2012, Respondent Steele submitted an affidavit in case
number ll-L-683 stating that an ISP attorney refused to provide the requested information.
ANSWER:
Respondent lacks sufficient information to admit or deny the

81.
Beginning in or about May 2012, Anthony Smith ("Smith"), a 27-year-old
nursing student living in Collinsville, Illinois, began receiving settlement shakedown letters
from Prenda Law stating that if Smith paid Prenda Law $4,000, Lightspeed Media Corp.
would drop its allegations that Smith had illegally downloaded pornographic videos from
the internet. Smith did not respond to the letters he received from Prenda Law.
47
ANSWER:
Respondent lacks sufficient information to admit or deny the
82.
On June 27, 2012, the Illinois Supreme Court issued a Supervisory Order,
requiring the trial court to quash the subpoenas in ll-L-683.
ANSWER:
The allegations contained in paragraph 82 purport to summarize an
order, the contents of which speak for themselves, and of which Respondent had no
knowledge at the time it was entered. Therefore, Respondent neither admits nor denies the
them.
83.
On August 3, 2012, Respondent Steele and Paul Duffy filed an amended
complaint in case number ll-L-683. In the amended complaint, Smith was substituted for
defendant John Doe. The amended complaint also named as defendants and co-conspirators
AT&T, Comcast, and unidentified "corporate representatives" of AT&T and Comcast. The
complaint alleged violations of the Computer Fraud and Abuse Act, deceptive practices, and
aiding and abetting. After filing the amended complaint, Respondent caused new subpoenas
to be issued seeking the personally identifiable information of Smith's purported 6,600 co
conspirators.
ANSWER:
84.
On August 9, 2012, AT&T removed case number ll-L-683 to the federal
district court for the Southern District of Illinois. The Clerk of the Court received the matter
and docketed it as Lightspeed Media Corporation v.Anthony Smith, et al., case number 12-CV00889.
48
ANSWER:
proceedings or pleadings, the contents of which speak for themselves, and of which
Respondent had no knowledge at the time they occurred. Therefore, Respondent neither
admits nor denies the allegations contained in paragraph 84, and leaves the Administrator
to his proof regarding them.
85.
On August 16, 2012, Respondent Steele and Paul Duffy filed an emergency
motion in case number 12-CV-00889 requesting that the court order the ISPs to produce the
same "co-conspirators" personally identifiable information that Respondent Steele and Paul
Duffy had previously sought in the subpoenas in case number ll-L-683.
ANSWER:
86.
On August 20, 2012, the Honorable G. Patrick Murphy held a hearing on
Respondent's emergency motion in case number 12-CV-00889. At the hearing, Respondent
Steele, Paul Duffy and Hansmeier appeared on behalf of Lightspeed. Respondent Steele
identified himself as being with the firm of Steele Hansmeier PLLC; Paul Duffy stated he was
with Prenda Law; and Hansmeier, who had moved for pro hac vice admission, stated that he
was with Alpha Law. During the hearing, Respondent Steele presented arguments to the
court as to Respondent's need for the requested information. At the conclusion of the
hearing, Judge Murphy denied Respondent's emergency motion.

ANSWER:
paragraph 86, except the allegation that the hearing concerned a motion filed or brought by
Respondent, which allegation Respondent denies. Respondent admits the allegation
contained in the second sentence of paragraph 86 to the effect that he appeared at the
hearing, and he denies all remaining allegations contained in the second sentence of
49
paragraph 86. Further answering, Respondent states that he appeared at the hearing in an
effort to assist Duffy, at Duffy's request. Respondent admits the remaining allegations
87.
Between August 29 and September 18, 2012, the defendants' in case number
12-CV-00889 filed motions to dismiss.
ANSWER:
88.
As of March 21, 2013, defendants' motions to dismiss remained pending in
case number 12-CV-00889. On that date, Respondent caused case number 12-CV-00889 to
be voluntarily dismissed.
ANSWER:
paragraph 88.
89.
At the time Respondent Steele and Paul Duffy voluntarily dismissed 12-CV-
00889, they were under an order entered by Judge Wright to explain the questions he posed
in his February 7 and March 14 orders in case number 12-CV-8333, as described in Count I,
paragraphs 31 and 36, above. Respondent Steele voluntarily dismissed 12-CV-00889

because when he filed the case they [sic] did so to obtain the names of individual IP
subscribers to whom he could send settlement shakedown letters, not to determine the
identity of actual infringers, and only sought early discovery to identify individuals from
whom he could exact settlements. Respondent Steele and Paul Duffy dismissed case number
12-CV-00889because he [sic] did not want his [sic] litigation strategy to come under scrutiny
by the federal court in Illinois.
ANSWER:

50
90.
On April 5, 2013, attorneys for Smith filed a motion for attorneys' fees and
sanctions against Respondent Steele and Paul Duffy in case number 12-CV-00889. On
October 30, 2013, Judge Murphy granted the motion. In his order, Judge Murphy found that
Respondent's litigation against Smith "smacked of bullying pretense."
ANSWER:
Respondent admits the allegations contained in the first and second
sentences of paragraph 90. The remaining allegations contained in paragraph 90 purport to

summarize the contents of an order, the contents ofwhich speak for themselves. Respondent
therefore neither admits nor denies the remaining allegations contained in paragraph 90,
and leaves the Administrator to his proof regarding them.
91.
On November 8, 2013, attorneys for the ISPs filed a motion for fees and costs.
On November 13,2013, the court held a hearing on the ISPs' motion for fees. At the hearing,
the court stated that Respondent Steele and Paul Duffy were engaged in:
abusive litigation...simply filing a lawsuit to do discovery to find

out if you can sue somebody. That's just utter nonsense.
On November 27, 2013, Judge Murphy awarded attorneys' fees to the ISPs, and
ordered Respondent Steele and Paul Duffy to pay attorneys' fees totaling $261,052.11 within
14 days.
ANSWER:
transcript, the contents of which speak for themselves. Respondent therefore neither admits
nor denies the allegations contained in paragraph 91, and leaves the Administrator to his
proof regarding them.
92.
On December 12,2013, Respondent caused to be filed a notice of appeal to the
UnitedStates Court of Appeals for the 7th Circuit, appealing the district court's imposition of
attorneys' fees and sanctions against him and Paul Duffy.
51
ANSWER:
93.
As of December 27, 2013, neither Respondent nor Paul Duffy had complied
with the Court's October 30 and November 27, 2013 orders awarding fees and costs in case
number 12-CV-00889, and had not sought a stay of the order. On that date, counsel for Smith
and the ISPs submitted a joint motion for contempt, or in the alternative, for an order to show
cause why Respondent Steele and Paul Duffyshould not be held in contempt.
ANSWER:
94.
On February 13, 2014, the Honorable David R. Herndon held a show-cause
hearing, at which Respondent Steele and Paul Duffy admitted that they had not paid any part
of the sanctions, and claimed an inability to pay. Based on their claim. Judge Herndon ordered
Respondent Steele and Paul Duffy to submit a financial statement from a certified public
accountant that verified Respondent's and Duffy's asserted lack of resources within 10 days.
During the show-cause hearing, and in response to Respondent's claim of an inability to pay,
Bart Huffman, attorney for AT&T ("Huffman"), informed the court that Respondent Steele
had previously stated that they had "made millions of dollars" in this type of litigation.
Respondent Steele objected to this characterization, asked Huffman to indicate where
Respondent Steele would have made such a statement, and Huffman advised the court that
there was an article in Forbes in which Respondent Steele had made such a statement. In
response to Huffman's assertions, Respondent Steele stated:

No, absolutely, I never did, and I resent being told that I've said
something that's not true. If Mr. Huffman would like to present
something that I personally made money of a certain amount,
feel free, but it will never come, Your Honor.
52
ANSWER:
that he denies any allegation tothe effect thathe stated, to Forbes magazine oranyone else,
that he had made "millions ofdollars in this type oflitigation."
95.
Respondent Steele's statement at the show-cause hearing that he had never
stated that he had made millions of dollars was false and Respondent Steele knew it was
false. Respondent Steele was interviewed in October 2012 for a Forbes magazine article
titled How Porn Copyright Lawyer John Steele Has Made A 'Few Million Dollars' Pursuing
(Sometimes Innocent) Porn Pirates. In response to the article's author's suggestion that
Respondent Steele had made $15 million settling copyright suits, Respondent Steele stated
"Maybe a little less. We don't track the amount we've recovered. More than a few million."
ANSWER:
paragraph 95. Respondent admits the allegations contained in the second sentence of
paragraph 95. Respondent admits making the statement referred to in the third sentence of
paragraph 95, but he denies that that statement was intended to refer, or did refer, to
amounts of money that Respondent himself "made" by virtue of any copyright infringement
litigation.
96.
On or about February 23, 2014, Respondent Steele and Paul Duffy submitted
their financial statements in case number 12-CV-00889. Attached to Respondent Steele and
Paul Duffy's statements was a letter from Respondent's certified public accountant stating
that Respondent had "elected to omit substantially all of the disclosures required by
generally accepted accounting principles."
ANSWER:
answering, Respondent states that the financial information he provided was accurate, and
53
that upon information and belief, it is common practice for an accountant to state that
personal financial information is not GAAP-compliant, because GAAP accounting methods

apply to business financial statements rather than personal financial information.
97.
On March 24,2014, Judge Herndon entered an order granting the defendants'
motion for contempt. In his order, Judge Herndon found that Respondent Steele and Paul
Duffy had willfully violated the sanctions order and made no effort to comply. In makinghis
ruling, Judge Herndon noted that the magnitude of harm was significant, particularly as the
underlying case was baseless and a misuse of the courts. Judge Herndon further found that
Respondent Steele and Paul Duffy made misrepresentations and presented "half-truths" at
the show-cause hearing, showing clear disrespect for the court, and cited to Respondent
Steele's statements and the Forbes article described in paragraphs 93 and 94, above. Judge
Herndon sanctioned Respondent Steele and Paul Duffyin the amount of 10% of the original
sanction and ordered the sum to be divided equally among them, and also set up a schedule
of additional fines if Respondent Steele and Paul Duffy did not pay.
ANSWER:
Respondent admits that Judge Herndon made the findings and entered
the relief referred to in the allegations contained in paragraph 97. Respondent denies that
he willfully engaged in conduct violative of any order, that the underlying case was baseless
or a misuse of the courts, that he made misrepresentations or presented "half-truths" to the
court, or that he showed disrespect for the court. Respondent denies any remaining
98.
On March 31, 2014, Respondent Steele and Paul Duffy caused a notice of
appeal to be filed to the United States Court of Appeals for the 7th Circuit, appealing Judge
Herndon's contempt finding, which was consolidated with their earlier appeal.
54
ANSWER:
99.
Respondent admits the allegations contained inparagraph 98.
On April 8,2014, Respondent Steele posted a bond in the amount of$287,300
inconnection with Respondent's notices ofappeal described inparagraphs 91 and97, above.

ANSWER:
100. On July 31, 2014, the United States Court of Appeals for the Seventh Circuit
issued a decision in which it upheld the imposition ofsanctions and attorneys' fees against
Respondent Steele and Paul Duffy, and the contempt finding. In its affirmance, the Seventh
Circuit stated that:
Lightspeed's suit against the ISPs was premised on the notion
that because the ISPs challenged appellants' [Respondent's]

subpoena of the personally identifiable information of Smith's
6,600 "co-conspirators," they somehow became part of a

purported plot to steal Lightspeed's content If there was any
conceivable merit in that theory, then perhaps fees would have
been inappropriate. But there was not
The Seventh Circuit affirmed the sanctions order imposed against Respondent Steele
and PaulDuffy, and also affirmed the order holding Respondent Steeleand Paul Duffy in civil
contempt and imposing fines. The Seventh Circuitfurther held that the costs of appeal were
to be taxed against Respondent Steele and Paul Duffy jointly and severally.
ANSWER:
Respondent admits that the United States Court of Appeals for the
Seventh Circuit issued the decision referred to in paragraph 100. Respondent denies any
remaining allegations contained in paragraph 100.
101.
In its opinion the Seventh Circuit noted thatthe firm affiliations of Respondent
Steele and Duffy were "provisional, to put it kindly." At the emergency motion hearing
Respondent Steele identified his firm as Steele Hansmeier PLLC, Respondent Duffy said he
was "with Prenda Law," and Hansmeier said he was with "something called Alpha Law Firm."
55
The courtnotedthat Steele Hansmeier and Prenda are listed"atthe same street address, 161
North Clark St, Chicago in different suites."
ANSWER:
Respondent admits that the United States Court of Appeals for the
Seventh Circuit issued the decision referred to in paragraph 101. Respondent denies any
remaining allegations contained in paragraph 101.
102. By reason of the conduct described above, Respondent has engaged in the
a.
bringing a proceeding without a basis in law and fact

fording so that is not frivolous, by conduct including
filing a lawsuit for the improper purpose of using
discovery to obtain names of Internet subscribers from
whom settlements could be exacted, in violation of Rule
3.1 of the Illinois Rules of Professional Conduct;
b.

request, by conduct including filing the motions for early
discovery in violation of Rule 3.4(d) of the Illinois Rules
of Professional Conduct;
c.

including sending the settlement shakedown letters, in
Conduct;
d.

misrepresentation, by conduct including filing a lawsuit
solely for the improper purpose of using discovery to
obtain
names
of Internet subscribers
from
whom
settlements
could
be
exacted,
and
making
misrepresentations to Judge Herndon during the
clearinghouse, in violation of Rule 8.4(c); and
e.

justice, by conduct including filing a lawsuit for the
improper purpose of using discovery to obtain names of
Internet subscribers from whom settlements could be
56
exacted, in violation of Rule 8.4(d) of the Illinois Rules of

Professional Conduct
ANSWER:
contain conclusions of law. Therefore, no answer is required. To the extent an answer is

COUNTV
[Alleged obstructing discovery and alleged dishonestconduct in

Lightspeed Media Corp. v. Anthony Smith)
103.
The Administrator realleges paragraphs 77 through 100 of Count IV, above.
ANSWER:
Respondent reincorporates his answers to paragraphs 77 through 100
of Count IV, above, as if more fully set forth herein.
104.
In or about January 2014, in response to Respondent's claims of inability to
pay the sanctions award entered against them in case number 12-CV-00889, Smith issued
subpoenas to JP Morgan Bank ("JP Morgan") and Sabadell United Bank ("Sabadell")
requesting Respondent's financial records.
ANSWER:
105.
On January 29, 2014, Respondent Steele informed officials at JP Morgan that
he intended to file a motion to quash subpoenas issued by Smith requesting Respondent's

financial records.
ANSWER:
Respondent does not have a present recollection of having the
conversation or contact with JP Morgan officials described in paragraph 105. Therefore, he

has insufficient information upon which to admit or deny the allegations contained in
paragraph 105.
106.
On January 30, 2014, Respondent Steele filed a motion to quash subpoenas
issued by Smith. On that date, Steele sent a copy of the motion to quash, without a file stamp,
57
to JP Morgan. Several days after receiving the motion to quash that Respondent Steele had
sent to them, officials at JP Morgan requested that Respondents [sic] provide them with a
file-stamped copy of the motion to quash.
ANSWER:
paragraph 106. Respondent does not have a present recollection ofsending the motion to
quash to JP Morgan orotherwise ofhaving contact with JP Morgan about the motion to quash,
and he therefore has insufficient information to admit or deny the allegations contained in
the second and third sentences of paragraph 106.
107.
On February 19,2014, Judge Herndon entered an order denying Respondent's
motion to quash the subpoenas Smith issued in case number 12-CV-00889. Respondent
learned of the order shortly after it was entered.
ANSWER:
108. On March 3, 2014, two weeks after Judge Herndon had denied Respondent's
motionto quash,at Respondent's direction PaulDuffy sent a file-stamped copyof the motion
to quash to JP Morgan.
ANSWER:
answering, Respondent states that he had no knowledge of any conduct by Duffy as
described in paragraph 108 until he learned of it during the Administrator's investigation

and prosecution of this matter.
109.
Paul Duffy's actions, in sending the file-stamped motion to quash to JP Morgan
after it had already been denied, were intended to mislead JP Morganofficials into believing
that they did not have to respond to Smith's subpoena because it was subject to a motion to
quash.
58
ANSWER:
The allegations contained in paragraph 109 are not directed toward
Respondent, and therefore no answer is required of him. To the extent an answer is deemed

110.
As of April 16, 2014, there was no stay in place in 12-CV-00889. On that date,
Respondent Steele sent an e-mail to officials at Sabadell informing them that a stay was in
place in case number 12-CV-00889. Respondent Steele's statement was false and
Respondent Steele knew it was false because he knew that a stay was not in place when he
made that statement in his e-mail, and his statement that a stay was in place was intended
to mislead Sabadell officials into thinking that they did not have to comply with the subpoena
Sabadell had received.
ANSWER:
111.
On November 18, 2014, Smith filed a motion for sanctions against
Respondents [sic] for their [sic] actions described in paragraphs 104 through 109, above.
ANSWER:
Respondent admits the allegations contained in paragraph 111 to the
extent that they pertain to him.
112.
On June 5, 2015, Judge Herndon entered an order in case number 12-CV-
00889, in which he found that Respondent Steele and Paul Duffy engaged in unreasonable,
willful obstruction of discovery in bad faith, and awarded sanctions to Smith in the amount
of the additional expenses incurred in conducting third party discovery. Judge Herndon also
found Respondent Steele in contempt, for statements he made regarding his inability to pay
in court at the February 13, 2014 show-cause hearing when financial records showed
otherwise, including Respondent Steele's $300,000 deposit into a new bank account at
Sabadell two months before. Judge Herndon directed Smith to submit his reasonable costs
59
and attorney fees incurred in connection with Respondent Steele's and Paul Duffy's
obstruction of discovery by July 3, 2015.
ANSWER:
Respondent admits that Judge Herndon entered an order in case
number 12-CV-00889 on June 5, 2015. The remaining allegations contained in paragraph

112 purport to summarize public documents whose contents speak for themselves.
Therefore, Respondent neither admits nor denies the remaining allegations contained in
paragraph 112, and leaves the Administrator to his proof regarding them.
113.
On July 23,2015, Judge Herndon awarded sanctions against Respondent in the
amount of $94,343.51, apportioned equally between Respondent Steele and Paul Duffy.
Judge Herndon further ordered that Respondent Steele and Paul Duffy pay the sanction
award on or before August 10,2015. At the time this complaint was filed, the sanction award
had not been paid.
ANSWER:
Respondent admits the allegations contained in the first and second
sentences of paragraph 113. Respondent denies the allegations contained in the third
sentence of paragraph 113. Further answering, Respondent states that he has tendered his
half of the sanction award to the court, and that he has appealed Judge Herndon's June 5,
2015 order.
114.
a.
making a false statement of fact to a tribunal, by conduct

including claiming an inability to pay the sanction
awards imposed against them, in violation of Rule
3.3(aJ(l) of the Illinois Rules of Professional Conduct;
b.

tribunal by conduct including failing to comply with
60
reasonable discovery requests, in violation of Rule 3.4(c)

of the Illinois Rules of Professional Conduct;
c.

misrepresentation, by conduct including obstructing
discovery and misleading the court in an effort to avoid
paying sanction awards imposed against them, in
violation of Rule 8.4(c); and
d.

justice, by conduct including obstructing discovery and
misleading the court in an effort to avoid paying sanction
awards imposed against them, in violation of Rule 8.4(d)
of the Illinois Rules of Professional Conduct.
ANSWER:
The allegations contained in paragraph 114 are not factual, but rather state
legal conclusions. Therefore, no answer is required. To the extent an answer is deemed

COUNT VI
{Alleged badfaith litigation, alleged dishonest conduct, and allegedfraud on the Court in
Guava v. Comcast Cable Communication, LLC)
115.
On November 20, 2012, Respondent Steele and Paul Duffy, purportedly on
behalf of Guava LLC, filed a petition seeking discovery prior to suit in the Circuit Court of St.
Clair County, Illinois, from Comcast Cable Communication, LLC ("Comcast"). The Clerk of the
Court received the matter and docketed it as Guava v. Comcast Cable Communication, LLC,
case number 12-MR-417. Respondent Steele and Paul Duffy brought the petition pursuant to
Illinois Supreme Court Rule 224, and purportedly sought to identify responsible persons and
entities that Paul Duffy alleged had committed computer fraud by hacking Guava's
computers and obtaining their adult videos. Paul Duffy attached to the petition a document
labeled Exhibit A, which listed approximately 300 IP addresses that were purportedly
identified by Guava to be associated with individuals who had used stolen user names and
passwords to gain unauthorized access to Guava's protected computer systems. Respondent
61
Steele and Paul Duffy further asserted in the petition that Guava had determined Comcast
was the ISP that issued those 300 IP addresses. Respondent Steele and Paul Duffy also
attached a verification to the petition which was signed by an "Alan Mony - Declarant." The
verification was notarized on November 20, 2012, by a Minnesota notary public, and the
relationship of "Alan Mony - Declarant" to Guava was not stated in the petition or in the
verification.
ANSWER:
116.
On December 10, 2012, Comcast filed a motion to dismiss Respondent's
petition. In its motion, Comcast stated that Guava sought to discover the identities of persons
who did not reside in St. Clair County. Comcast also noted that Guava did not plead that it
was incorporated in Illinois, did any business in Illinois, or that it was a registered foreign
corporation entitled to bring lawsuits in Illinois courts.
ANSWER:
pleading, the contents of which speak for themselves, and of which Respondent had no
knowledge at any relevant time. Therefore, Respondent neither admits nor denies the
them.
117.
On December 12, 2012, the court entered an order denying Comcast's motion
to dismiss and granting Guava's petition for discovery before suit. The order required
Comcast to provide all of the John Does that were associated with the 300 IP addresses with
copies of the petition and order by December 26,2012, and that any John Doe seeking to file
an objection, or a motion to quash or dismiss the petition, was given until January 25,2013.
62
ANSWER:
order, the contents of which speak for themselves, and of which Respondent had no
them.
118.
Between December 12, 2012 and January 25, 2013, forty-five John Does filed
objections to the circuit court's order that their personal information be disclosed to Guava.
ANSWER:
several pleadings, the contents of which speak for themselves, and of which Respondent had
no knowledge at any relevant time. Therefore, Respondent neither admits nor denies the
them.
119.
On January 14, 2013, one of the John Does filed a "Petition for Rule to Show
Cause Why Petitioner Guava LLC, a/k/a Lightspeed Media, Its Officers and Directors,
Declarant Alan Mony, Steve Jones, Paul A. Duffyand/or Kevin T. Hoerner Should Not Be Held
in Contempt of Court and for other Sanctions" ("petition for rule to show cause"). The
petition for rule to show cause alleged that Paul Duffy filed hundreds of copyright
infringement lawsuits across the country alleging that ISP subscribers illegally downloaded
pornography; the petition for discovery before suit was frivolous because Guava had
admitted in federal court proceedings that identifying a subscriber associated with an IP
address does not necessarily identify an alleged "hacker;" and that Guava used the
information received pursuant to the court's order to send extortionate settlement demand
letters to such subscribers before ascertaining their actual involvement with the alleged
63
hacking activity. The petition for rule to show cause also asserted that the petition was
verified by an individual who may not exist
ANSWER:
pleading, the contents of which speak for themselves, and of which Respondent had no
them.
120.
On or about January 30, 2013, Respondent Steele and Paul Duffy caused a
settlement shakedown letter to be sent to a John Doe whose information was disclosed by
Comcast pursuant to the circuit court's initial order. The letter contained language similar to
the letters described in paragraphs 10, 51,52, and 60, above, and was signed by Brett Gibbs
an attorney acting at Respondent's direction. The letter stated that Guava's computers were
breached and their data was stolen and that Guava's "engineers" discovered John Doe's IP
address accessing files taken from Guava's computers. Further the letter stated that Comcast
had confirmed that John Doe was the account holder of the IP address so Guava was seeking
to hold him liable for the conduct. The letter continued that in order for the John Doe to avoid
being named as a defendant in the public lawsuit, Guava would accept a payment of$4,000.
The letter also detailed the high costs of litigation and stated that the amount it was willing
to accept to resolve the matter would increase over time.
ANSWER:
Respondent denies any allegation contained in paragraph 120 to the
effectthat he had any knowledge of, or involvement in, the creation or sending of the letter
referred to in paragraph 120. Respondent has insufficient information to admit or denyany

remaining allegations contained in paragraph120.Furtheranswering, Respondent reasserts
64
his objection to the use throughout the Administrator's Complaint of the argumentative term
"'settlement shakedown' letter."
121.
On February 11,2013, Respondent and Paul Duffy caused to be filed, on behalf
of Guava, responses to the various objections of the John Does and the petition for rule to
show cause. In response, Respondent and Paul Duffy stated that "[ujnknown individuals
hacked into Petitioner's computer systems and gained unauthorized access to private and
protected information. Petitioner does not know the true identities of these individuals, but
has identified the individuals by the IP addresses." The response further stated "[i]n order to
identify these unknown individuals and bring a lawsuit against them, Petitioner sought to
identify them through a Petition for Discovery before suit."
ANSWER:
122.
On February 12, 2013, Respondent Steele, listing his law firm association as
Prenda Law, filed an entry of appearance on behalf of Guava in case number 12-MR-
41738123. On February 13, 2013, a hearing was held in case number 12-MR-417, at which
Respondent Steele appeared on behalf of Guava. At the hearing, an attorney for one of the
Doe defendants presented a copy of the settlement demand letter described in paragraph
119, above, and the court entered an order continuing all pending matters in case number
12-MR-417 to February 21,2013.
ANSWER:
Respondent admits that he appeared at an oral argument in case
number 12-MR-417 on February 13, 2013, at Duffy's request Further answering, Duffy had
told Steele that he was prevented from traveling to the oral argument, or otherwise being
present for it, for health reasons. Respondent denies all remaining allegations in this
paragraph.
65
124.
On February 21, 2013, the court held a hearing on all pending motions in case
number 12-MR-417. Respondent Steele appeared on behalf of Guava. At that time, the court
entered an order stating "All Doe objections to the disclosure of identifying information are
overruled and denied." The court also allowed Guava's motion to strike Does' petition for
rule to show cause.
ANSWER:
Further answering, Respondent states that he again appeared at the request of Duffy, who,
upon information and belief, had health problems at that time that were continuing to
prevent him from attending to matters in case number 12-MR-417.
125.
On March 1,2013, some of the Does ("Doe appellants") in case number 12-MR-
417 filed a notice of appeal from the court's February 21, 2013 order. The Clerk of the
Appellate Court of Illinois, Fifth District, received the matter and docketed it as Guava LLC v.
Comcast Cable Communications, LLC, Docket No. 5-13-0091. The Doe appellants also filed an
emergency motion to stay the judgment pending appeal, which the appellate court granted.
ANSWER:
126.
On May 20,2014, the Illinois Appellate Court, Fifth District, issued its decision
in case number 5-13-0091. In its decision, the Appellate Court found that the trial court erred
in granting Guava's request for discoverybefore filing suit, since the petition failed to allege
sufficient factsto support a cause ofaction against the persons the petition sought to identify.
TheAppellate Court further heldthat the trial court erred in denyingthe petition ofthe "John
Doe" subscribers, who were identified only by an IP address, which sought a rule to show
cause and sanctions against Guava, especially when the underlying question in the matter
was whether Guava intended to state a cause of action against the subscribers, or was
66
actually seeking to harass or extort the subscribers without forming a reasonable basis for
believing that they were culpable parties. The Appellate Court directed the trial court on
remand to dismiss the petition for discovery before suit and to conduct an evidentiary
hearing on the petition for rule to show cause, and adjudicate the merits of the Doe
appellants' allegations of false and frivolous pleading, harassment, extortion, identity theft,
and forgery.
ANSWER:
Appellate Court opinion, the contents of which speak for themselves. Respondent therefore
127.
On October 29, 2014, the court held a status conference in case number 12-
MR-417. At that time, the court entered a scheduling order which required the parties to
brief the issues which were to be the subject of the evidentiary hearing on the petition for
rule to show cause and motion for sanctions.
ANSWER:
128.
a.

a petition seeking discovery prior to suit, under the
names of fictional entities, for purposes of exacting
settlements, and seeking discovery to obtain names of

exacted, in violation of Rule 3.1 of the Illinois Rules of

b.

request, by conduct including filing a petition seeking
67
discovery prior to suit on behalf of a shell corporation, in

violation of Rule 3.4(d) of the Illinois Rules of
c.

misrepresentation, by conduct including filing a petition
seeking discovery prior to suit solely for the improper
purpose of using that discovery to obtain names of
exacted, in violation of Rule 8.4(c); and
d.

justice, by conduct including filing a petition seeking
discovery prior to suit for the improper purpose of using
that discovery to obtain names of Internet subscribers
from whom settlements could be exacted, in violation of
Rule 8.4(d) of the Illinois Rules of Professional Conduct.
ANSWER:
state legal conclusions. Therefore, no answer is required. To the extent that an answer is
deemed required, Respondent denies the allegations contained in paragraph 128.
COUNT VII
[Alleged badfaith litigation, alleged dishonest conductand alleged misrepresentations to the

court in Prenda Law, Inc., v. Paul Godfread, Alan Cooper, and John Does 1-10)
129.
On February 12, 2013, Respondent and Paul Duffy caused to be filed a
complaint on behalf of Prenda Law against Paul Godfread and Alan Cooper, who were both
citizens of Minnesota, and John Does 1-10, in the Circuit Court of St Clair County, Illinois. The
Clerk of the Court received the matter and docketed it as Prenda Law, Inc., v. Paul Godfread,
Alan Cooper, andJohn Does1-10,case number 12 L 75. In the complaint, Prenda Law alleged
claims of libel, defamation, and tortious interference with contractual relationships in
connection with the claims Cooper, and Paul Godfread as his lawyer, had made regarding
Prenda Law stealing his identity, as described in Count I, paragraphs 15 through 18, and
Count II, paragraph 43, above.
68
ANSWER:
effectthat he had any knowledge of,or involvement in, the case referred to in paragraph 129
at any relevant time. Respondent lacks sufficient information to admit or deny any remaining
130.
On March 1,2013, the defendants in case number 12 L 75 removed the matter
to federal court for the Southern District of Illinois, asserting there was federal jurisdiction
based on diversity of citizenship, because Prenda Lawwas an Illinois company and Godfread
and Cooper were Minnesota citizens. The Clerk of the Court received the matter and
docketed it as Prenda Law, Inc., v. Paul Godfread, Alan Cooper, and John Does 1-10, case
number 13-CV-207.
ANSWER:
effectthat he had any knowledge of, or involvement in, the case referred to in paragraph 130
at any relevant time. Respondent lacks sufficientinformation to admit or deny any remaining
131. On April 10, 2013, Respondent and Paul Duffy caused to be filed a motion to
remand case number 13-CV-207 to St. Clair County circuit court. The motion asserted that
on February 21, 2013, an amended complaint was filed in case number 12 L 75 in St. Clair
County circuit court, which included Alpha Law, a Minnesota company, as a plaintiff, andthat
there was now a lack of diversity so the matter could not remain in federal court.
ANSWER:
effect that he hadanyknowledge of, or involvement in, the case referredto in paragraph 131
69
132.
On June 6, 2013, the Honorable David R. Herndon, Chief Judge of the federal
district court for the Southern District of Illinois, denied the motion for remand and entered
an order transferring case number 13-CV-207 to federal court in the Northern District of
Illinois, noting that "a virtually identical, first-filed action is currently pending in the
Northern District of Illinois."
ANSWER:
effect that he had any knowledge of, or involvement in, the case referred to in paragraph 132
133.
In his June 6, 2013 opinion denying Prenda's motion for remand, Judge
Herndon, adopting the reasoning contained in the defendants' opposition to the case being
remanded to state court, found that prior to removal, Prenda Law filed an amended
complaint in St Clair County that would allegedly destroy diversity by adding a Minnesota
plaintiff, Alpha Law Firm; that the purported amended complaint was a legal nullity because
Prenda Law never filed the necessary motion for leave to amend the St. Clair County
complaint; and that Prenda Law knew that the defendants had already been served with the
original complaint, but represented to the Clerk of the St. Clair County Court that defendants
had not yet been served in order to file the amended complaint naming Alpha Law as a
plaintiff.
ANSWER:
70
134.
Upon transfer of case number 13-CV-207 to the Northern District of Illinois,
the matter was consolidated with case number 13-CV-4341, which was assigned to the
Honorable John W. Darrah.
ANSWER:
135.
On August 12, 2013, Respondent Steele and Paul Duffy caused to be filed a
motion to remand case number 13-CV-4341 to state court, which was identical to the motion
that had been previously denied by Judge Herndon in case number 13-CV-207.
ANSWER:
136.
On August 14, 2013, a status hearing was held before Judge Darrah in case
number 13-CV-4341, at which time Paul Duffy appeared and presented a renewed motion
for remand. At the hearing, Paul Duffy stated to Judge Darrah that the court in the Southern
District "denied the motion. They indicated - the Court indicated that on the four corners of
the complaint, it stated that it was a Minnesota corporation. However, the complaint also
states that its principal place of business is in Minnesota." At the August 14, 2013 hearing,
counsel for the defendants explained the facts and reasoning adopted by Judge Herndon in
his denial of the motion for remand, which did not include the statements Duffy attributed
to Judge Herndon.
71
ANSWER:
137.
Paul Duffy's statements at the August 14, 2013 status hearing, set forth in
paragraph 135, above, were false, because Judge Herndon did not address whether or not
Alpha Law was a Minnesota corporation.
ANSWER:
The allegations contained in paragraph 137 do not pertain to
Respondent. Therefore, no answer is required. To the extent that an answer is deemed to be

138.
Paul Duffy knew his statements set forth in paragraph 135, above, were false
at the time he made them because he knew that Judge Herndon did not address whether or
not Alpha Law was a Minnesota corporation.
ANSWER:
The allegations contained in paragraph 138 do not pertain to
Respondent Therefore, no answer is required. Tothe extent that an answer is deemed to be

139. On August 14, 2013, Respondent caused to be filed a motion to withdraw his
renewed motion to remand in case number 13-CV-4341, stating "plaintiff vehemently
disagrees with representations made by Defendants [sic] counsel at the August 14, 2013
hearing regarding its Motion, but nevertheless due to the apparent confusion arising from
Plaintiffs Motion, Plaintiff seeks to withdraw it [sic] motion. Rather than renew its motion,
Plaintiff intends to, at the appropriate time if any, amend its complaint to ad [sic] Alpha Law
Group LLC as a Plaintiff."
72
ANSWER:
140.
On September 24, 2013, Defendants filed a motion for sanctions in case
number 13-CV-4341, alleging Prenda's actions with respect to its motion to remand
amounted to frivolous litigation and abusive practice.
ANSWER:

141.
On February 13,2014, Judge Darrah granted Defendants' motion for sanctions
in case number 13-CV-4341, imposing sanctions against Prenda Law and Paul Duffy due to
his unreasonable and vexatious conduct. In his decision, Judge Darrah stated:
After the case was transferred to the Northern District of
Illinois, Prenda again moved to remand, filing essentially the

same motion that the Court of the Southern District of Illinois
has denied. Prenda had no legal basis for "renewing" this

previously rejected motion. When pressed, at the remand
hearing on August 14,2013, Duffy,counsel for Prenda, admitted
he "filed substantially the same motion in the Southern District"
As discussed above, when asked what the Southern District of
Illinois said about the motion, Duffy stated to the Court: "They
denied the motion. They indicated - the Court indicated that on

the four corners of the complaint, it stated that it was a
Minnesota corporation. However, the complaint also states that
its principal place of business is in Minnesota." However, the

record reflects that the Southern District of Illinois Court said
nothing of the sort. Duffy had the opportunity to address this lie
in his response to the Motion for Sanctions and did not To
fabricate what a federal judge said in a ruling before another
73
court falls well outside the bounds of proper advocacy and

demonstrates a serious disregard for the judicial process.
Judge Darrah further instructed the defendants in case number 13-CV-4341 to submit
an itemized statement of attorneys' fees occasioned by the misconduct of Prenda Law and
Paul Duffy.
ANSWER:
142.
On June 12, 2014, Judge Darrah entered an order awarding sanctions against
Prenda Law in the amount of $11,758.20 in case number 13-CV-4341.
ANSWER:
effectthat he had any knowledge of,or involvement in, the case referred to in paragraph 142
143.
OnJanuary 22,2015, Judge Darrah amended his June 12,2014 order, and held
that Prenda Law and Paul Duffy jointly and severally liable for the sanctions awarded to the
defendants in the amount of $11,758.20. Judge Darrah further ordered that, if either Prenda
Law or Paul Duffy assert an inability to pay the ordered amount, Duffy was to submit
financial statements from a certified public accountant verifying his financial status and
stating any and all assets of Prenda Law.
ANSWER:
effect that he had any knowledge of, or involvement in,the case referred to in paragraph 143
74
144.
At no time did Paul Duffy or Prenda Law pay the $11,758.20 sanction award
ordered by Judge Darrah on January 22, 2015. At no time did Paul Duffy or Respondent
provide any financial statements on behalf of Duffy or Prenda Law as a result of an asserted
an inability to pay, as required by the January 22, 2015 order described in paragraph 142,
above.
ANSWER:
145.
On April 9, 2015, Judge Darrah entered an order in case number 13-CV-4341.
In the order, Judge Darrah stated that "Prenda Law and Duffy have been given multiple
opportunities to file the requested information and to establish the inability of either to pay
the levied sanctions." Judge Darrah further noted that Respondent Steele and Paul Duffy have
exhibited a "serious and studied disregard for the orderly process of justice."
ANSWER:
effect that he had any knowledge of,or involvement in, the case referred to in paragraph 145
at any relevant time. Respondent lacks sufficientinformation to admit or deny any remaining
146.
Asof the date the Inquiry Panel voted to filethis complaint against Respondent
Steele, neither Paul Duffy nor Prenda Lawhad paid the $11,758.20 in sanctions awarded in
case number 13-CV-4341.
75
ANSWER:

147.
By reason of the conduct described above. Respondent has engaged in the
a.

a motion that had previously been denied without a legal
basis for renewing that motion, in violation of Rule 3.1 of
b.

tribunal, by conduct including failing to comply with the
sanction orders entered by Judge Darrah, in violation of
Rule 3.4(c) of the Illinois Rules of Professional Conduct;
and
c.
ANSWER:

justice, by conduct including failing to comply with the
orders entered by Judge Darrah, in violation of Rule
8.4(d) of the Illinois Rules of Professional Conduct.
state legal conclusions. Therefore, no answer is required. To the extent that an answer is
deemed to be required, Respondent denies the allegations contained in paragraph 147.
Further answering, Further answering, Respondent states that the allegations contained in
paragraphs 129 through 147 do not state a cause of action against him, and should be
dismissed.
76
RESPONDENT'S DISCLOSURE PURSUANT TO COMMISSION RULE 231
1.
Respondent was licensed to practice law in Illinois on July 9,2007. Respondent
is admitted to practice before the General and Trial Bars of the United States District Court
for the Northern District of Illinois, United States District Court for the Central District of
Illinois, United States District Court for the Southern District of Illinois, and United States
District Court for the District of Colorado. Other than that, he has never been admitted to
practice law before any other state court, federal court, or administrative agency.
2.
Respondent has no other professional licenses other than his license to
practice law.
Respectfully submitted,
John Lawrence Steele, Respondent
BY:
James A. Doppke, Jr.

Robinson Law Group, LLC
333 West Wacker Drive, Suite 450
Chicago, IL 60606
(312) 676-9878
jdoppke(5)robinsonlawillinois.com
77
James A. Doppke, Jr.

One of his attorneys

ANS15PR0068

Încărcat de

Informații document

Drepturi de autor

Formate disponibile

Partajați acest document

Partajați sau inserați document

Opțiuni de partajare

Vi se pare util acest document?

Este necorespunzător acest conținut?

Drepturi de autor:

Formate disponibile

ANS15PR0068

Încărcat de

Drepturi de autor:

Formate disponibile

BEFORE THE HEARING BOARD

ILLINOIS ATTORNEY REGISTRATION

ATTY REG &DISC COMM

In the Matter of:

JOHN LAWRENCE STEELE,

Respondent admits the allegations contained in the first sentence of

Respondent admits the allegations of the first sentence of paragraph 3,

paragraph 3. Respondent has insufficient information to admit or deny the allegations

In or about November 2011, Paul Duffy, an Illinois attorney licensed in 1992

Steele Hansmeier's copyright infringement practice on behalf of pornographers. Respondent

Respondent denies the allegations contained in the first sentence of

In 2013, in California litigation, Respondent Steele was identified by his

client's local counsel as a decision maker of Prenda Law.

Respondent has insufficient information to admit or deny the

Respondent denies the allegations contained in paragraph 6, and each

firms maintained a website at wefightpiracy.com.

Respondent denies the allegations contained in paragraph 7. Further

Respondent's Copyright Litigation Practice

An Internet Service Provider ("ISP") is a company that provides services for

Respondent admits the allegations contained in paragraph 8. Further

Respondent admits the allegations contained in paragraph 9. Further

business entities which produced pornographic movies and videos in copyright

infringement matters. Beginning in or about 2012, Respondents also began representing

Respondent admits that from 2010 through November 2011, Steele

Hansmeier represented businesses which produced copyrighted works. Respondent denies

On [date] we filed an action against several anonymous digital pirates [gives

(hereinafter referred to as "settlement shakedown" letters).

Respondent admits that while participating in the operation of Steele

Hansmeier PLLC, he caused to be filed certain copyright infringement actions in various

Complaint of argumentative language such as the term "'settlement shakedown' letters."

letters described in paragraph 10 [sic],above, while Respondent Steele had an IP address, he

Respondent denies the allegations contained in paragraph 12. Further

answering, Respondent reasserts his objection to the argumentative term "'settlement

As of October 2012, Respondent Steele and Paul Duffy had settled

approximately 5,000 copyright infringement matters, and recovered millions of dollars in

Respondent denies the allegations contained in paragraph 13. Further

answering, Respondent reasserts his objection to the argumentative term "'settlement

Respondent denies the allegations contained in paragraph 14, except

Respondent denies that he caused the complaint in case number 12-

At the time Respondent Steele caused case number 12-CV-8333 to be filed, he

Respondent denies the allegations contained in paragraph 15.

Respondent denies the allegations contained in paragraph 17. Further

Respondent admits, upon information and belief, that Cooper was

never an officer or owner of AF Holdings or Ingenuity 13. Further answering, Respondent

AF Holdings and Ingenuity 13 as described in paragraph 15 [sic] above, those statements

Respondent denies the allegations contained in paragraph 19.

Respondent specifically denies having made any assertions concerning Cooper's

(a) Arise from the same or a closely related transaction,

(b) Callfor determination of the same or substantially related or

(c) For other reasons would entail substantial duplication of

The allegations contained in paragraph 20 contain legal conclusions, to

which no answer is required. To the extent an answer is deemed required, Respondent

Respondent denies that he filed any cases in California at any relevant

time. Respondent denies any remaining allegations contained in paragraph 21.

ofIngenuity 13 andAF Holdings were related, as required byLocal Rule 83-1.3.

On December 3, 2012, John Doe's attorney, Morgan E. Pietz ("Pietz"), filed a

The allegations contained in paragraph 23 purport to summarize

knowledge or consent. In support of his application, Pietz attached an affidavit of Alan

The allegations contained in paragraph 24 purport to summarize

truthful, Respondent lacks sufficient information to admit or denyany suchassertion.

Respondent denies that he filed copyright infringement actions on

On December 20,2012, Judge Wright entered an order in case number 12-CV-

Respondent denies that any order entered by Judge Wright on

The Court is concerned with the potential for discovery abuse in