TAODB

Complaint for Injunctive Relief and Damages, Jury Demand

Original filing by Rosenfeld, Peter Todd’s attorney over statements by Reichwein that characterize and explicitly claim that Peter Todd is a rapist: https://storage.courtlistener.com/recap/gov.uscourts.cand.340308/gov.uscourts.cand.340308.1.0.pdf

Introduction

Plaintiff Peter Todd (“Plaintiff” or “Todd”) is a former Bitcoin Core developer and an applied cryptography consultant. Todd regularly speaks at conferences throughout the world regarding his work in cryptography.
Defendant Sarah Michelle Reichwein (“Defendant”), who goes by the fictitious name Isis Agora Lovecruft, is a self-described “anarchist; hacker; once-upon-atime theoretical physicist.” Like Todd, Defendant regularly attends cryptography conferences.
Todd and Defendant are acquaintances, having interacted on multiple occasions at cryptography conferences and social events.
In or around June 2016, Defendant publicly accused third party Jacob Appelbaum of sexually assaulting her.
When Todd did not publicly condemn Appelbaum, Defendant published false statements about Todd on her Twitter profile accusing Todd of rape and sexual assault.
Defendant’s statements are false as Todd has never raped or sexually assaulted anyone.
Defendant’s statements accusing Todd of rape and sexual assault remain publicly viewable on Defendant’s Twitter profile.
Todd has been harmed and continues to be harmed by Defendant’s defamatory statements.

some legal content omitted for brevity and relevance - see original for expansion

Parties

Plaintiff Peter Todd is an individual and a citizen of Canada, residing in Ontario, Canada
On information and belief, Defendant Sarah Michelle Reichwein, who goes by the fictitious name Isis Agora Lovecruft, is an individual, a U.S. citizen, and a domiciliary of California.

Factual Allegations

Todd is a Bitcoin enthusiast and expert, consultant, and a leading developer of cryptocurrency and blockchain software.
Todd is highly-regarded in the cryptography and cryptocurrency sectors for his expertise in the security properties of the Bitcoin network and other decentralized technologies.
Given his standing in the cryptography and cryptocurrency sectors, Todd is regularly invited to speak at cryptography conferences throughout the world.
Additionally, Todd provides professional consulting services in cryptography and cryptocurrency, for which he receives a premium in compensation based on his knowledge and experience.
Todd has developed a large online following, and he regularly posts to his Twitter profile under the handle @peterktodd, where he has numerous followers in the cryptography and cryptocurrency sectors.
Todd’s reputation, including his online reputation, are important aspects of his standing in the cryptography community and his ability to maintain his consulting profession.
Defendant is a self-described “anarchist; hacker; once-upon-a-time theoretical physicist.”
Defendant previously worked for The Tor Project, Inc., the goal of which is to provide a way of using the Internet with as much privacy as possible, including by routing Internet traffic through multiple servers and encrypting it each step of the way.
Like Todd, Defendant regularly attends cryptography conferences.
Todd initially met Defendant at the Summer 2014 Tor Dev Meeting, a conference regarding the anonymizing software Tor.
Defendant disclosed her name to Todd as “Isis Agora Lovecruft.” Todd recognized the name as a pseudonym, as the use of pseudonyms is a common practice in the cryptography community. Todd only discovered Defendant’s actual name right before filing this Complaint, after he engaged a private investigator to find that information for purposes of bringing this lawsuit.
Between 2014 and 2016, Todd and Defendant had intermittent in-person contact when they attended cryptography conferences.
Additionally, between 2014 and 2016, Todd and Defendant spent time together socially on a few occasions
Todd and Defendant also engaged in semi-regular online communications, including via Twitter and Pond, an encrypted messaging application.
On or around June 15, 2016, Defendant publicly published on her Twitter profile that third party Jacob Appelbaum had sexually assaulted her. Appelbaum is a cryptography expert and was a core member of the Tor Project.
Initially, Todd published statements to Defendant commending her on her bravery and denouncing sexual violence. Defendant reflected her approval of Todd’s statements, liking one of Todd’s Twitter comments.
In August 2016, Todd publicly stated that he did not know what was true regarding Defendant’s and others’ allegations against Appelbaum.
Around that same time, Defendant blocked Todd from viewing her Twitter profile.
In May 2017, Todd communicated with Defendant through Github, a professional platform designed for public software development. More specifically, Todd requested more information from Defendant regarding a software programming issue, namely, “how the callee is supposed to ensure that the bytes represent a valid CompressedEdwardsY.”
In response to Todd’s request, Defendant published the following statement:

“First things first: @petertodd, you’ve publicly, repetitively defended a man who raped me and several other people, and disparaged the victims who were brave enough to come forward with their stories. Do not speak to me. Do not use work as an excuse to speak to me. Do not use cryptography as an excuse to speak to me.”
Thereafter, Todd did not initiate any contact with Defendant, either in person or electronically.
On February 5, 2019, Defendant published the following statement on her Twitter profile at https://twitter.com/isislovecruft/status/1093033203219148800:

“This is not even touching upon the stories of the rape and assault survivors of you and @petertodd and @ioerror and you all have been seen to behave conveniently alike and seen to dutifully protect one another .”
On February 8, 2019, Defendant published the following statement on her Twitter profile at https://twitter.com/isislovecruft/status/1094091846047985666 as a follow up to her February 5, 2019 statement:

“i love watching the men in my industry who’ve sexually abused me and many others squirm as I take them out one by one while they nervously await their turn [¶] hahahahahahahaha eat goat dung you epoxy brained cowards.”
On February 20, 2019, Defendant published the following statement on her Twitter profile at https://twitter.com/isislovecruft/status/1098270385148022784:

“Nadim Kobeissi is a serial rapist and abuser who defends other rapists including Jacob Appelbaum and Peter Todd and in 2012 he grabbed my face and force kissed me at a conference and i absolutely believe the multiple survivors i’ve personally spoken with since then.”
On February 20, 2019, Defendant published the following statement on her Twitter profile at https://twitter.com/isislovecruft/status/1098280935353606144:

“yes, similar to Nadim, i personally have a story about Peter Todd and i’ve personally spoken with survivors with absolutely awful and horrifying reports who are terrified of him and of coming forward (rightly so) [¶] i however am not afraid and shitty dudes are going down”
The Statements contain and comprise false assertions of fact.
Contrary to the Statements, Todd has not raped Defendant or anybody else.
Contrary to the Statements, Todd has not sexually assaulted or otherwise assaulted Defendant or anybody else.
Defendant’s Twitter profile has over 20,000 followers.
Numerous people have viewed Defendant’s Statements, and numerous people have publicly commented on Defendant’s Statements.
Defendant knew that her Statements were false when she made them because Defendant knew that Todd had never raped her or sexually abused her. Alternatively or additionally, Defendant acted in reckless disregard of the falsity of her Statements when she published them because the Statements falsely represent that Todd engaged in the most serious of misconduct, because Defendant had no credible evidence supporting her Statements when she published them, and because Defendant’s social history with Todd contradicted the Statements.
As of the filing of this Complaint, the Statements remain publicly viewable on Defendant’s Twitter profile.
Todd has been harmed by Defendant’s Statements, including shame, embarrassment, hurt feelings, anxiety, mortification, embarrassment, and loss or reputation among his friends, peers, and professional community.
Additionally, and on information and belief, Todd has lost business and professional opportunities, including conference speakerships, because of Defendant’s Statements.

some legal content omitted for brevity and relevance - see original for expansion