in the united states district court for the district of ... · hartman & winnicki, p.c. richard l....

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA

EAST COAST TEST PREP LLC d/b/a Achieve Test Prep, and MARK OLYNYK Plaintiffs,

v. ALLNURSES.COM, INC., BRIAN SHORT, R.N., ABC COMPANIES 1-10 and JOHN DOES 1-10, Defendants.

) ) ) ) ) ) ) ) ) ) ) )

Case No. 15-cv-03705 JRT-JSM

DECLARATION OF MARK OLYNYK RIEZMAN BERGER, P.C. Charles S. Kramer, Esq. Admitted Pro Hac Vice Paul A. Grote, Esq., Admitted Pro Hac Vice 7700 Bonhomme Ave. 7th Floor St. Louis, MO 63105 Phone: (314) 727-0101 Fax (314) 727-6458 Email: [email protected] Email: [email protected] Attorneys For Plaintiffs East Coast Test Prep LLC, and Mark Olynyk

HARTMAN & WINNICKI, P.C. Richard L. Ravin, Esq. Admitted Pro Hac Vice, 74 Passaic Street Ridgewood, NJ 07450 Phone: (201) 967-8040 Fax: (201) 857-4076 Email: [email protected] BEITO & LENGELING, PA Robert A. Lengeling, Esq. Thomas M. Beito, Esq. 310 Fourth Avenue South, Suite 1050 Mpls, MN 55415 Phone: (612) 767-1618 F: (612) 333-8003 [email protected] [email protected]

CASE 0:15-cv-03705-JRT-JSM Document 159 Filed 09/02/16 Page 1 of 24

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I, Mark Olynyk, being of full age, do hereby declare as follows:

1. I am President of Plaintiff East Coast Test Prep LLC d/b/a Achieve

Test Prep (“ATP”), and am also an individual Plaintiff in the above-captioned

matter (collectively, “Plaintiffs”). I am fully familiar with the facts set forth

herein.

2. I submit this Declaration in support of Plaintiff’s Motion to Compel

Discovery of Defendants Allnurses.com, Inc., and the Estate of Brian Short, R.N.,

(collectively “Defendants”).

3. ATP commenced operation in 2009. I have been its President since

its inception.

4. As President of ATP, I am responsible for all aspects of its

operations, including without limitation, sales, marketing, advertising, Website,

leasing, instruction, purchasing, and accounting and personnel.

Achieve Test Prep

5. ATP is in the business of providing test preparation services for

individuals seeking various degrees, including without limitation, nursing.

6. ATP is well publicized on the Internet, including without limitation,

via its Websites, and appearing on Google as part of its first organic search result

for the search “achieve test prep” (See Second Amended Complaint (“SAC”)

Exhibit “A”, at 14-15, Screen Shot Set 6, ECF 97-1.)

7. ATP has used “Achieve Test Prep” as its service mark at least as

early as 2009, and used the mark in interstate commerce at least as early as 2009.


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8. ATP is not a college and does not issue degrees or give college

credit. Instead, ATP's services are designed to prepare nursing students for

standardized exams which enable the students to get full credit for college courses

without taking the courses, a process known as credit-by-examination.

9. The standardized exams are given by an independent college, or an

independent testing center, which enable the student to earn credit towards their

degree such as a Bachelor of Science in Nursing (“BSN”) or Associates of Science

in Nursing (“ASN”) from such college.

Allnurses.com

10. The Allnurses.com Website is self-described as "the collective voice

of the nursing community, supporting the profession by providing a place where

nurses can network, share and learn from their peers."

(http://allnurses.com/aboutus-info.html accessed on March 2, 2015.

11. Allnurses Website states that it is the “largest peer to peer nursing

site in the world. We are a global site reaching nurses and nursing students around

the world.” (http://allnurses.com/aboutus-info.html) accessed on June 29, 2016.)

(See Exhibit “B” attached hereto, Screen Shot Set 1, at 1.)

12. On March 13, 2015, Allnurses published that there were 10,172

readers online (at time of access) and had 891,799 members. (See SAC, Exhibit

“A” at 4 and 5, Screen Shot Set 1, ECF 97-1.)

13. On June 29, 2016, I visited the about page

(http://allnurses.com/aboutus-info.html), which stated that there were at that time:


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12,786 Readers Online, 969,557 Members. (See Exhibit “B” attached hereto,

Screen Shot Set 1, at 1-2).

14. Allnurses provides a platform for its members to post comments

and/or questions and receive feedback and responses from members on a range of

topics in the field of nursing, including but not limited to education and required

coursework/exams for licensure.

15. To post a comment or participate in the online discussion, a user

must register with Allnurses.

16. Members of Allnurses are permitted to create new discussion threads

on the Website discussion boards or publish comments on existing threads.

17. Discussion threads are initiated in forums on Allnurses.com.

18. The Allnurses.com Website hosts a discussion thread titled:

“Achieve Test Prep….anyone?” located at URL: http://allnurses.com/excelsior-

college-online/achieve-test-prep-815067.html (accessed on March 13, 2015). (See,

e.g., Exhibit “A”, at 58-82, Screen Shot Set 14.)

19. The “Achieve Test Prep….anyone?” thread appears in the “Excelsior

College Online Nursing” forum.

20. To date, the “Achieve Test Prep. . . .anyone?” thread remains

viewable by the public on the Allnurses Website.

21. The thread contains false and defamatory statement about ATP

posted by John Doe Defendants JustBeachyNurse, monkeyhq, LadyFree28,

duskyjewel, and Pixie.RN.


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22. Attached hereto as Exhibit “B”, Screen Shot Set 2, at 3, is a copy of

the top portion of the first page of the “Achieve Test Prep….anyone?” thread

accessed on September 1, 2016, showing the number of views for thread is

70,278. Notwithstanding that the thread remains closed, but visible to the public,

the present number of views reported on the thread is more than the double the

views reported by Allnurses on March 15, 2015 of 34,016 views (see e.g. SAC,

Exhibit “A” at 58 (ECF 97-3)).

Specific Actionable Statements

23. Attached hereto as Exhibit “A”, and included in Plaintiffs’

Memorandum in Point I.B.3, are excerpts from the Second Amended Complaint

(“SAC”) (ECF 97), which set forth the specific false and defamatory statements at

issue, posted by JustBeachyNurse, monkeyhq, LadyFree28, duskyjewel, and

Pixie.RN, namely, ¶¶ 117-123, 163-172, 175-180, of the SAC. I hereby verify

that the allegations contained in these paragraphs of the SAC are true and correct,

including without limitation as to the falsity of the defamatory statements posted

by the John Doe Defendants on the Allnurses Website.

ATP Does Not Have Contact Information For The John Doe Defendants

24. Because Plaintiffs do not know the identities of any of the John Doe

Defendants, Plaintiffs had no ability to independently or directly notify the John

Doe Defendants as to the instant Motion To Compel Discovery. Moreover,

Allnurses’ closed the thread to new postings from subscribers, and, in any event,


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disabled Plaintiffs’ subscriber accounts, preventing, Plaintiffs from posting on the

subject thread.

25. Plaintiffs do not have any contact information for any of the John

Doe Defendants.

26. Without obtaining the requested discovery information, Plaintiffs

will not be able to identify the John Doe Defendants who use the screen names:

JustBeachyNurse, monkeyhq, LadyFree28, duskyjewel, and Pixie.RN.

LPN’s are ATP’s Prime Market

27. ATP’s target market is, overwhelmingly, individuals who are

currently Licensed Practical Nurses (“LPN’s”), Paramedics, Respiratory

Therapists, and Doctors with a foreign medical license, who desire to become a

Registered Nurse (“RN”). Of the LPNs, Paramedics, Respiratory Therapists, and

Doctors with a foreign medical license, LPNs make up the vast majority of this

market. We refer to this market as the “RN Bridge” market.

28. We do target individuals outside of the RN Bridge market, but the

number of sales outside of this market only accounts for a small fraction of our

sales (approximately less than 2 percent of our sales for the period of 2014

through August, 2016).

29. Overwhelmingly, ATP’s customer base is LPN’s seeking to become

RN’s.

30. Because the Allnurses thread is specifically about our RN Bridge

program, and because the RN Bridge market makes up virtually all of our sales,


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any calculations regarding damages have been based on our historical data relating

to our RN Bridge program and all numbers referenced herein are referencing the

same market.

Search Terms and Search Results

31. I am charge of sales, marketing and advertising, including without

limitation, Internet sales, marketing and advertising. I have been responsible for

these areas since the founding of ATP.

32. Based on my knowledge and experience as President of ATP,

responsible for sales, marketing and advertising, I chose 10 highly relevant

descriptive search terms that would typically be used to search on the Internet for

the services provided by ATP, and conducted searches on Google.

33. The 10 highly relevant search terms that I chose are: “lpn to rn”,

“lpn to rn online”, “lpn to bsn”, “lpn to rn programs”, “lpn to rn bridge programs”,

“lpn to bsn bridge programs”, “lpn to rn online programs”, “online lpn to rn”, “lpn

to bsn programs”, and “lpn to rn bridge program”.

34. I searched on Google using these 10 descriptive search terms. None

of the searches resulted in “Achieve Test Prep…. anyone?” thread appearing on

the first page of search result.

35. As far as I am aware, the only two search terms that result in the

“Achieve Test Prep…. anyone?” thread appearing on the first page of the Google

search results are: “achieve test prep” and “achieve test prep review”, both of


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which contain the ATP trademarks. These results appeared as numbers two and

five, respectively, on the first page of search results.

36. Additionally, I searched for the above ten descriptive search terms

on the Allnurses search bar on the allnurses.com Website (not Google). None of

the searches produced the “Achieve Test Prep…. anyone?” thread. As far as I am

aware, the only two search terms that resulted in the “Achieve Test Prep….

anyone?” thread appearing on the first page of the search results using the

Allnurses search bar on the Allnurses.com Website are: “achieve test prep” and

“achieve test prep review” (ATP trademarks). Both of these results appear as the

number one organic search result on the first page.

37. I provided Plaintiffs’ expert witness, Dr. James Roberts, with the 10

highly relevant search terms. According to his Expert Report, he conducted the

same searches on Google and on the Allnurses Website, and experienced the same

results.

38. I also provided Dr. Roberts with certain information regarding the

behavior of ATP’s leads and customers, which Dr. Roberts used in his report to

draw certain conclusions as to the behavior of ATP’s prospective customers

visiting the allnures.com. Specifically, I provided Dr. Roberts with the following

information:

a. Based on a survey of recent ATP leads, approximately 10% (of new leads) had conducted research on ATP on websites other than ATP (“Third Party Websites”) prior to filling out a lead form online. Conversely, 90% of ATP persons who completed lead forms


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had not conducted research on Third Party Websites prior to becoming a lead.

b. Based on a survey of recent ATP customers, 74% of ATP’s customers conducted research on ATP on Third Party Websites prior to becoming customers.

c. All or substantially all of ATP’s customers were leads, prior to becoming customers.

39. I also informed Dr. Roberts that the percentage of leads that are

converted to paying ATP customers is approximately 11% (for the period 2014-

2015) (“Conversion Rate”).

Lost ATP Customers And Damages

40. According to the Expert Report of Dr. Roberts, based on his research

and surveys he conducted involving the “Achieve Test Prep….anyone?” thread, he

concluded that:

1. The percentage of potential ATP customers lost as a result of reading the negative comments on the “Achieve Test Prep….anyone?” thread referenced above ranges from 40 percent who would not consider searching for more information to 67 percent who would not use ATP services after reading the entire comment thread.

2. The loss of potential customers for ATP services ranges from 40 percent to approximately 95 percent after they have been exposed to either individual negative comments or the entire thread of comments found under the thread, “Achieve Test Prep ….anyone?”

3. Readers of the “Achieve Test Prep ….anyone?” thread on

www.allnurses.com would have formed negative attitudes toward ATP and have been less likely to use its services, causing a significant loss of goodwill and injury to the reputation of ATP.

(Expert Report at 23; emphasis in original).


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41. Dr. Roberts quantified the loss of ATP customers as a result of

viewing the negative comments of the John Doe Defendants which are the subject

of this lawsuit as ranging from 629 to 905 lost customers. (Dr. Robert’s Expert

Report at 33, ¶¶ N and P.)

42. ATP’s average sale is approximately $8,000 (for the period 2014-

2015, based on sales to RN Bridge customers, which comprise almost all of ATP’s

sales).

43. The approximate lost revenue represented by the lost customers

ranges from $5,032,000 (629 x $8,000) to $7,240,000 (905 x $8,000).

44. The loss of those customers represent lost profits ranging in excess

of $1,900,000 ($8,000 x 629 customers) to $2,700,000 ($8,000 x 905 customers).

45. While the foregoing numbers represents lost revenue and profits to

date, the “Achieve Test Prep….anyone?” remains accessible and searchable to the

public, and continues to generate views.

46. As of the date of this Declaration, the Allnurses reports that the

thread has generated approximately 70,000 Views (http://allnurses.com/excelsior-

college-online/achieve-test-prep-815067.html).

47. On March 13, 2015, Allnurses reported the Views on the thread were

approximately 34,000 (see SAC, Exhibit “A”, Screen Shot Set 2, at 6 (ECF 97-1).

Nearly 18 months later, the Views have more than doubled, increasing by 36,000

Views.


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48. The thread continues to generate about 2,000 views per month, or

about 24,000 views per year

49. The thread was created on February 12, 2013 (see SAC, Exhibit

“A”, Screen Shot Set 2, at 6 (ECF 97-1). During the first 25 months of the thread,

the average number of monthly views was 1,360. Thus, the average monthly

views have increased.

50. The average views per month over the life of the thread is 1,750

(70,000 / 40 months).

51. Thus, the amount of monthly views has increased in the past 1.5

years as compared to the first 2 years of the thread.

52. Notwithstanding the apparent upward trend of monthly views of the

thread, over the life of the thread, the monthly average of lost customers is

15.725 (629 / 40 months) ranging to 22.625 (905 / 40 months); the monthly

average of lost revenue is $125,800 (15.725 x $8,000) ranging to $181,000

(22.625 x $8,000); and the monthly average of lost profits is $47,500 ($1,900,000 /

40) ranging to $67,500 ($2,700,00 / 40).

53. Put another way, as a result of false and defamatory comments on

the thread, ATP is losing

a. customers at the yearly rate of 188.7 (15.725 x 12) to 271.5 (22.625

x 12),

b. revenue at the yearly rate of approximately $1,504,000 (188 x

$8,000) to $2,168,000 (271 x $8,000), and


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c. profits at the yearly rate of approximately $570,000 ($47,500 x 12)

to $810,000 ($67,500 x 12).

54. This case has been pending in the federal courts for nearly 1-1/2

years (almost two years since it was filed in state court), but Plaintiffs’ diligent

efforts to obtain the most basic of discovery from Defendants have been thwarted

every step of the way by Defendants and their counsel. One can only assume that

this case will not be concluded at the trial level for at least another two years.

55. Based on the Expert Report of Dr. Roberts, over the next two years,

ATP projects that it will lose customers, revenues and profits as a result of the

false and defamatory comments posted on the thread as follows:

a. lost customers ranging from 376 (188 x 2 years) to 542 (271 x 2

years),

b. lost revenue ranging from approximately $3,008,000 (376 x $8,000)

to $4,336,000 (542 x $8,000), and

c. lost profits ranging from approximately to $1,140,000 ($570,000 x

2) to $1,620,000 ($810,000 x 2 years).

56. When the lost customers, revenue and profits to date are added to the

projected lost customers, revenue and profits, respectively, projected for the

coming two years, the total for the 5-1/2 year period (through August 2018) is as

follows:

a. lost customers ranging from 1,005 to (629 + 376) to 1,447 (905 +

542),


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b. lost revenue ranging from approximately $8,040,000 (1,005 x

$8,000) to $11,576,000 (1,447 x $8,000), and

c. lost profits ranging from approximately $3,040,000 ($1,900,000 +

$1,140,000) to $4,320,000 ($2,700,000 + $1,620,000).

57. However, the total losses to ATP will continue into the future, even

beyond the September 2018, as long as the false and defamatory statements

remain accessible by the public and the subscribers of Allnurses. The injuries to

ATP will be far in excess of the lost customers, revenues and profits cited in the

foregoing paragraph.


I hereby and declare under penalty ofperjury that the foregoing is true and

conect. This Declaration has been executed in the United States.

Dated: September 2, 2016Mark Olyny

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EXHIBIT “A”

EXHIBIT “A”


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SPECIFIC ACTIONABLE STATEMENTS

ALLEGED IN SECOND AMENDED COMPLAINT (ECF 97)

Below are the specific actionable statement alleged by Plaintiffs in the Second

Amended Complaint (ECF 97) which are the subject of Plaintiffs’ Motion To Compel

Discovery:

117. On or about August 22, 2014, Poster monkeyhq published a comment on the thread "Achieve Test Prep….anyone?”. (See Exhibit “A” at 62) (ECF 97 at 14, ¶ 117).

118. This comment falsely states that "Test Prep companies for Excelsior Exams will be obsolete by July 1, 2015… it is a total waste of your investment."

(http://allnurses.com/excelsior-college-online/achieve-test-prep-815067-page3.html, accessed March 10, 2015.) (See Id.) (ECF 97 at 14, ¶ 118).

119. Poster monkeyhq's August 22, 2014 comment is a false representation because ATP's test preparation services will not be obsolete by July 1, 2015. (ECF 97 at 14, ¶ 119).

120. monkeyhq’s post expressly refers to facts misstated by JustBeachyNurse in the prior post (“As Beachy said….”). (ECF 97 at 14, ¶ 120).

121. JustBeachyNurse stated in his or her post:

ATP and similar services will be redundant as of July 1, 2014 when all challenge exam candidates will be mandated to take the

Excelsior online exam prep classes prior to becoming eligible to sit the challenge

exams. The prep classes are not free (though prep class plus challenge exam should cost

less than the online courses)[.] (Emphasis added.) (See FAC Exhibit “A” at 61) (ECF

97 at 14, ¶ 121).


http://allnurses.com/excelsior-college-online/achieve-test-prep-815067-page3.htmlhttp://allnurses.com/excelsior-college-online/achieve-test-prep-815067-page3.html

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122. The statement that all Excelsior College challenge exam candidates would be required to take

Excelsior College’s own online exam prep class prior to becoming eligible is false. (ECF 97 at 14, ¶ 122).

123. The statement made by JustBeachyNurse that ATP’s test prep for Excelsior College would be redundant is false. (ECF 97 at 14, ¶ 123).

163. On February 12, 2013, Pixie.RN misrepresents that

Excelsior College warns about using third-party test prep companies, and promotes Excelsior College, including providing a

link to its Website. (ECF 97 at 14, ¶ 163).

164. Since the focus of the “Achieve Test Prep….anyone?” thread is about ATP, the statement posted by Pixie.RN is of and

concerning ATP. (ECF 97 at 14, ¶ 164).

165. Pixie.RN posted the following:

Feb 12, '13 by Pixie.RN, BSN, RN, EMT-P Senior Moderator

EC warns students about third-party

publishers and test prep companies -- they are not affiliated with EC, nor does EC

endorse their use (http://www.excelsior.edu/about-test-

...ation-services). EC's program is set up to provide an outline/syllabus for each class in

the form of a free exam content guide that you can download. * * * I'd advise you to think twice before you add a lot of money to

the bottom line of your education bill! Good luck, whatever you decide. (Emphasis

added.)

(See Exhibit “A”, at 60, Screen Shot Set 14.) (ECF 97 at 14, ¶ 165).

166. This statement is false because Excelsior College did

not "warn" students about third-party publisher test preparation companies. (ECF 97 at 14, ¶ 166).


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167. On September 12, 2014, member LadyFree28 posted to the “Achieve Test Prep….?” thread stating that ATP was under federal

investigation. (ECF 97 at 14, ¶ 167).

168. The September 12, 2014 post by LadyFree28 was responding to posts made earlier on in the thread about another test preparation

company, “TCN”, being under federal investigation. (ECF 97 at 14, ¶ 168).

169. LadyFree28’s post stated:

But the discussion is about THIS particular test-prep program that IS being investigated

by the federal government and is under a current lawsuit; there are too many forums

that have stated the Achieve "deceived" them with their practices; that is the MAIN

focus of this discussion, NOT "other test prep companies." (Capitalized emphasis in

original; underlined emphasis added.) (ECF 97 at 14, ¶ 169).

170. A reasonable person would understand

LadyFree28’s post would mean that ATP was the subject of a federal investigation, for several reasons:

a. “But the discussion is about THIS particular test-prep program” and the “MAIN focus of this discussion” refers

to ATP, as the thread is predominantly about ATP, as the title of the thread expressly announces: (“Achieve Test

Prep….anyone?”). (Emphasis in original.)

b. This statement is followed by: “there are too many forums that have stated the Achieve ‘deceived’ them with their practices” (emphasis added), implying that

Achieve was under investigation because it deceived people with its practices. No other test prep company is

referred to in the post.

c. The post goes on to exclude other test prep companies: “NOT ‘other test-prep programs’”, again, implying that only ATP is the test prep company under investigation.

(ECF 97 at 14, ¶ 170).


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171. Because LadyFree28's post makes reference to “Achieve ‘deceived’” by its “practices”, a reasonable person of

ordinary intelligence would understand that to mean that ATP is under investigation by the Federal Trade Commission. (ECF 97 at

14, ¶ 171).

172. The statement posted by LadyFree28 on September 12, 2014 that ATP "is being investigated by the federal

government" is false and defamatory. (ECF 97 at 14, ¶ 172, emphasis added).

175. On September 12, 2014, member duskyjewel also posted to the “Achieve Test Prep….anyone?” thread stating that ATP was under federal investigation. (ECF 97 at 14, ¶ 175).

176. duskyjewel’s post was in direct response to a post from learning-is-good:

"Quote from Learning-is-good 'Duskyjewel, You are going to scare

people by saying some test prep centers are under federal

investigation, but my guess is it’s just one.” (ECF 97 at 14, ¶ 176, emphasis added).

177. In response, duskyjewel posted:

"Sounds like you should be scared. TCN + Achieve equals more than

one." (ECF 97 at 14, ¶ 177).

178. By commenting that “TCN + Achieve equals more than one” test preparation company under

investigation, duskyjewel was stating that both TCN (The College Network, another test preparation company) and ATP are both under federal investigation. (ECF 97 at 14,

¶ 178).

179. The post by duskyjewel is false and defamatory. (ECF 97 at 14, ¶ 179).


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180. ATP has not been investigated by the FTC. (ECF 97 at 14, ¶ 180).


EXHIBIT “B”

EXHIBIT “B”


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SCREEN SHOT SETS

SCREEN SHOT SET 1

Allnurses About page stating that, at the time

“12,786 Readers Online, 969,557 Members”

“largest peer to peer nursing site in the world.”

“There are more than 4 million unique visitors each month with 13 million page views.”

(http://allnurses.com/aboutus-info.html, accessed on June 29, 2016)


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Same as above, zoomed in

Allnurses About page stating that, at the time

“12,786 Readers Online, 969,557 Members”

“largest peer to peer nursing site in the world.” “There are more than 4 million unique visitors each month with 13 million page views.”

(http://allnurses.com/aboutus-info.html, accessed on June 29, 2016)


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SCREEN SHOT SET 2

“Achieve Test Prep….anyone?” thread “70,278 Views” accessed September 1, 2016.

http://allnurses.com/excelsior-college-online/achieve-test-prep-815067.html

Same as above, but section zoomed in

“Achieve Test Prep….anyone?” thread

“70,278 Views” accessed September 1, 2016.

http://allnurses.com/excelsior-college-online/achieve-test-prep-815067.html


http://allnurses.com/excelsior-college-online/achieve-test-prep-815067.htmlhttp://allnurses.com/excelsior-college-online/achieve-test-prep-815067.htmlRRavinRectangle

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3_Decl of Olynyk Draft v1-8 CLEAN w Olynyk signatureDecl of Olynyk Draft v1-8 CLEAN (PAG 2016-9-2) (00428380-2x9CD8A)signed mark decl

Exhs A-B, Olynk Decl MTC Disc First Amend v1 (RLR 2016-9-1)Exh A, Olynk Decl, Specific Actionable Statements v1 (RLR 2016-9-1)Exh B, ATP Thread Allnurses acc 2016-9-1) and About 2016-6-20, SSS 1 and 2 v3

in the united states district court for the district of ... · hartman & winnicki, p.c. richard l....

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