Category Archives: Texas (TX)

Siemens Product Lifecycle Management Software Lawsuits.

SIEMENS PLM SOFTWARE LAWSUITS — “THEY’RE BACK!”

I didn’t want to let this one slide. Remember the Siemens Product Lifecycle Management (Siemens PLM) lawsuits (where Siemens sued a number of engineers who used their NX software without a license)? Well, in July, 2018, they have filed their newest copyright Infringement lawsuit (this is the FIFTH TIME they are suing), this time against 107 John Doe Defendants (here in our own Texas Southern District Court, no less).

Siemens Product Lifecycle Management Software Inc. v. Does 1-107 (4:18-cv-02344), filed July, 2018

I’ve already written all that needs to be known about the Siemens Product Lifecycle Management Software Inc. lawsuits

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Siemens Product Lifecycle Management Software Piracy Lawsuit
Screenshot from Siemens PLM Software’s website on the NX Mach 3 software.

What happened to the Siemens Product Lifecycle Management’s older lawsuits?

WAVE 1

In Wave 1, Siemens solicited licenses for their NX software. At first, we thought that these were bittorrent-based lawsuits like the others we have been dealing with, but then we learned that Siemens was actually tracking the unlicensed USE of the software (e.g., think “software phone home”).

This complicated the lawsuits because they were dealing with actual evidence (rather than the “snapshot bittorrent-based evidence” we have seen in the movie lawsuits). As a result, we put together a list of steps an attorney should take in defending a Siemens PLM lawsuit, and this has proven to be an effective strategy.

Over time, the lawsuit progressed, and eventually Siemens dismissed the lawsuit once they realized who they wanted to name and serve in their own lawsuits, and they filed individual copyright infringement lawsuits against companies they discovered were using their software without a license.

WAVE 2

In Wave 2, Siemens filed a similar lawsuit, this time against 100 new defendants. They surprised a number of defendants with settlement numbers of $50,000+ (eventually, we learned that they were settling licenses to their software, and they actually cost that much). This second wave lawsuit “on the books” looked to be a failure because they missed a FRCP Rule 4(m) deadline to name and serve defendants. As a result, they dismissed the entire lawsuit, however, I know that they continued after the dismissal to contact accused defendants (or their attorneys) with the intention of having those accused defendants [now dismissed] purchase a license to cover their use of the Siemens PLM NX software.

WAVES 3-4 (2017 – mid-2018)

In Waves 3-4, Siemens continued to target engineers in their lawsuits.  The purpose of these lawsuits was to “legitimize” those who were using their NX software “for profit.”  They were more reasonable this time on the settlement amounts (no settlements, just purchase of software licenses), but they allowed the defendant some leeway in determining what software title would best benefit the user, and whether Mach 3 was needed, or whether a lower-cost alternative was an option.  Siemens PLM also started to discuss settlement negotiations themselves (e.g., offering money to settle the claims), however, this never materialized.

WAVE 5 (late 2018)

Now in Wave 5, I do not yet know whether these 107 John Doe Defendants are from the same pool as the earlier lawsuits were filed, or whether these are from an entirely new pool of accused infringers. However, at least the lawsuit itself (its intentions, and what to expect) are less of a mystery, as we were able to settle a number of claims in their previous lawsuits through the purchase of a software license.

As always, here is how an attorney should be handling a Siemens PLM software lawsuit, and how we at the Cashman Law Firm, PLLC would handle your Siemens PLM case. This has been an effective strategy in each of the various Siemens PLM lawsuits, and thus I am suggesting it again with this newest wave of lawsuits.


[CONTACT AN ATTORNEY: If you have a question for an attorney about the Siemens PLM software copyright case and options on how to proceed (even specifically for your circumstances), you can e-mail us at info[at]cashmanlawfirm.com, you can set up a free and confidential phone consultation to speak to us about your Siemens PLM case, or you can call us at 713-364-3476 (this is our Cashman Law Firm, PLLC’s number].

CONTACT FORM: If you have a question or comment about what I have written, and you want to keep it *for my eyes only*, please feel free to use the form below. The information you post will be e-mailed to me, and I will be happy to respond.

NOTE: No attorney client relationship is established by sending this form, and while the attorney-client privilege (which keeps everything that you share confidential and private) attaches immediately when you contact me, I do not become your attorney until we sign a contract together. That being said, please do not state anything “incriminating” about your case when using this form, or more practically, in any e-mail.

Venice PI LLC (not so “new” copyright troll) filing in select Carl Crowell local counsel courts.

There is a “new” copyright troll filing lawsuits with a fervor across the US named “Venice PI, LLC” (more on the word “new”; more on “across the US”).  The Venice PI lawsuits all claim $150,000 copyright infringement damages for the illegal download of the “Once Upon a Time in Venice” movie starring Bruce Willis.  ISPs are sending notices to their subscribers informing them that a Venice PI subpoena requesting their identity has been provided to them, and that they are under an order signed by a federal judge to comply, unless the subscriber files a “motion to quash” the subpoena.

ISPs sending the subpoena notices to its subscribers informing them about the Once Upon a Time in Venice movie lawsuit include CenturyLink, Comcast Xfinity, Hawaii Telecom, Optimum Online, Verizon Fios, and Time Warner Cable, depending on where you live.

As of this evening, I see lawsuits filed as early as 6/28/2017 and as recent as 7/18/2017. Once Upon a Time in Venice movie lawsuits are being filed in Texas, Indiana, New York, North Carolina, Oregon, and Washington.

…Where have we seen those list of states before?!?

Already, without even looking, I can already see based on where the lawsuits are filed that this is yet one more “common troll” set of lawsuits masterminded by Carl Crowell and his RIGHTS ENFORCEMENT entity. I bet you if I looked up the RIGHTSENFORCEMENT.com website, I’d see the “Once Upon a Time in Venice” movie listed there. Let’s look. …Yup. Bottom right, LSD style.

venice-pi-subpoena-once-upon-a-time-in-venice-movie-lawsuit Venice PI

Personally, for a Once Upon a Time in Venice movie lawsuit, I would prefer something less noisy, but you’re not reading this for my aesthetic preferences.

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Point being, we are dealing with Carl Crowell and his local counsel in the various states.  This means that we know not only what the lawsuits will look like (as far as which judge will allow what), but we know the plaintiff attorney who has sent the subpoenas, and their proclivities.  This means that we know which attorneys are squeamish in naming and serving defendants, which are comfortable taking the lawsuit straight into discovery, and which are “quick on the trigger,” (think, the train whistle blows before the train has left the station) meaning, which attorneys will get him or herself into trouble with a judge by not following the rules, and as a result, names and serves every John Doe Defendant.

This historical knowledge of who has done what is one reason to hire an attorney, but knowing which way to approach the lawsuit based on the proclivities of the attorney filing the lawsuit is another reason you hire an attorney.  In short, we all know that the options are FIGHT, NO-SETTLE REPRESENTATION, SETTLE (without describing each option, as I’ve done this before), and we all know that for a defendant who did not do the download, I recommend one set of options, and for someone who did do the download, I recommend another set of options.  Don’t be fooled — it’s not black and white. [SPEAK TO ME if you want my opinion on your particular case.]

Now for those who want to settle, we already have an idea of what Venice PI settlement amounts each attorney will likely ask for (their asking prices), and based on the other lawsuits filed by these attorney, we have a good idea of what settlement amounts Venice PI, LLC will accept, if you decided to settle in the first place.  Again, there is the no settlement representation, where you have me keep an open line of communication with the plaintiff attorney to demonstrate to him/her why you did not do the download, and there is also a “no settlement letter” which I write for innocent clients to stop the troll scheme cold.

In short, there is a lot of repeat here because this lawsuit contains a lot of repeat from what we’ve seen in the past with the ME2 Productions (Mechanic:Resurrection) movie lawsuits, the UN4 Productions (Undisputed 4) movie lawsuits, the Headhunter LLC (A Family Man) movie lawsuits, the WWE Studios (Eliminator) movie lawsuits, the Cook Productions (Mr. Church) movie lawsuits, etc.  Rinse, repeat, rinse repeat.

For those interested in learning more about the Venice PI LLC lawsuits, see the two links below:

Venice Pi (‘Once Upon a Time in Venice’) Movie Lawsuit Page,” written on 7/19/2017, and
All I know about the Venice Pi, LLC (‘Once Upon a Time in Venice’) Movie Lawsuits (FAQ),” written on 7/18/2017.

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RECENT CASE HISTORY OF THE VENICE PI SUBPOENA CASES:

VENICE PI ISP subpoenas ordered in the Texas Southern District Court
Venice PI, LLC v. Does 1-16 (Case No. 4:17-cv-02203)

VENICE PI ISP subpoenas ordered in the various North Carolina District Courts

Venice PI subpoena cases in the North Carolina Eastern District Court:
Venice PI, LLC v. Does 1-12 (Case No. 5:17-cv-00337, Case No.5:17-cv-00333)
… v. Does 1-11 (Case No. 5:17-cv-00334)
… v. Doe 1 et al (Case No. 5:17-cv-00340, Case No. 5:17-cv-00339, Case No. 4:17-cv-00089)

Venice PI subpoena cases in the North Carolina Middle District Court:
… v. DOES 1-11 (Case No. 1:17-cv-00611)
… v. DOES 1-18 (Case No. 1:17-cv-00610)

Venice PI subpoena cases in the North Carolina Western District Court:
… v. Does 1-10 (Case No. 3:17-cv-00409, Case No. 1:17-cv-00170)

VENICE PI ISP subpoena ordered in the New York District Courts
Venice PI, LLC v. Doe et al (Case No. 1:17-cv-04076, 1:17-cv-04249, 1:17-cv-04904)

VENICE PI ISP subpoenas ordered in the Oregon District Court
… v. Doe-73.96.114.240 (Case No. 3:17-cv-01002)
… v. Doe-71.59.242.118 (Case No. 3:17-cv-01001)

VENICE PI ISP subpoenas ordered in the Indiana Northern & Southern District Courts
… v. Doe 1 et al (Case No. 2:17-cv-00284, Case No. 2:17-cv-00285, Case No. 1:17-cv-02274, Case No. 1:17-cv-02328)

VENICE PI ISP subpoenas ordered in the Colorado District Court
… v. Doe 1 et al (Case No. 1:17-cv-01664)

VENICE PI ISP subpoenas ordered in the Hawaii District Court
… v. Doe 1; et al. (Case No. 1:17-cv-00335)

VENICE PI ISP subpoenas ordered in the Washington Western District Court
Venice PI LLC v. Doe 1 et al (Case No. 2:17-cv-01076, Case No. 2:17-cv-01075, Case No. 2:17-cv-01074, Case No. 2:17-cv-00988, Case No. 2:17-cv-00990, Case No. 2:17-cv-00991)


FOR IMMEDIATE CONTACT WITH AN ATTORNEY: To set up a free consultation to speak to an attorney about your matter, click here.  Lastly, please feel free to e-mail me at [email protected], or call 713-364-3476 to speak to me now about your case (I do prefer you read the articles first), or to get your questions answered.

CONTACT FORM: Alternatively, sometimes people just like to contact me using one of these forms.  If you have a question or comment about what I have written, and you want to keep it *for my eyes only*, please feel free to use the form below. The information you post will be e-mailed to me, and I will be happy to respond.

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NOTE: No attorney client relationship is established by sending this form, and while the attorney-client privilege (which keeps everything that you share confidential and private) attaches immediately when you contact me, I do not become your attorney until we sign a contract together.  That being said, please do not state anything “incriminating” about your case when using this form, or more practically, in any e-mail.

UN4 Productions movie lawsuits spread with Boyka: Undisputed 4

UN4 Productions ISP Subpoenas sent

I don’t take pleasure in writing this, but there is a new copyright troll on the block named UN4 Productions, Inc. (a Millennium Films company). For the past two weeks, UN4 Productions ISP subpoenas have been going out to internet users informing them that they have been implicated as being a John Doe defendant in the UN4 Productions lawsuit (a.k.a. the Boyka: Undisputed 4 lawsuit). Each lawsuit claims copyright infringement damages of $150,000 for the illegal download or streaming of the Boyka: Undisputed 4 movie using bittorrent, or some other streaming device.

The name Boyka generally means “One Who Terrifies in Battle,” fitting for a gory fighting movie. Boyka: Undisputed 4 focuses on the story of Yuri Boyka, a mixed martial arts fighter.

Boyka: Undisputed 4 Video Trailer (click here)

Why the Boyka: Undisputed 4 ISP subpoenas mirror what we have seen

As soon as I looked into this new copyright troll, I realized that this is a “wolf in sheep’s clothing” copyright troll. The UN4 Productions ISP subpoena that you just received in the mail is coming from the same copyright enforcement entity (think Carl Crowell, or rightsenforcement.com) who just finished sending you bittorrent lawsuits for the ME2 Productions movie lawsuits, the Cook Productionsmovie lawsuits, the I.T. Productions movie lawsuits, LHF Productions movie lawsuits (think, London Has Fallen), and so many others.

Are the Boyka: Undisputed 4 movie lawsuits targeting a particular ethnic group??

The difference here with the Boyka: Undisputed 4 lawsuit is that this pirated movie has been dressed up as an ethnic movie (the previews I saw had arabic subtitles). Think, ME2 Productions, Inc. with no shirt, ripped bloody muscles, adrenaline-pumping punches all in line with the three previous Undisputed 4 movies [Undisputed (2002), Undisputed II: Last Man Standing (2006), and Undisputed III: Redemption (2010]).

UN4 Productions ISP subpoenas sent for the Boyka: Undisputed movie lawsuit
antfrank / Pixabay

“tracking an ethnic-based movie based on a specific nationality”

Again, just in case you did not get my innuendo. The twisted offense here with the Boyka: Undisputed 4 lawsuit is that the  UN4 Productions copyright trolls have developed a new way of catching people — by tracking an ethnic-based pirated movie based on a specific nationality.  They spread a fishnet, monitor the downloads, and vwallah!  They catch bittorrent downloaders with ethnic names. When that defendant claims “it isn’t me who did the download!” the plaintiff attorney just chuckles at Youssef, Oleksiy, Omar, or whichever ethnic name just happened to be the same ethnic group or nationality for whom the movie was made.

UN4 Productions ISP subpoenas sent for the Boyka: Undisputed movie lawsuit

How you can understand the Boyka: Undisputed 4 cases

First of all, at some point this evening, I will be writing a FAQ page so that you can understand what is going on with your Boyka: Undisputed 4 lawsuit.  I will be posting that link here.

To keep things simple, when you think of the UN4 Productions ISP subpoena you just received, or when you think about the Boyka: Undisputed 4 movie lawsuit, just think to yourself, “this is ME2 Productions in disguise. Same rules apply.” With the UN4 Productions lawsuit, the plaintiff attorney lawyers are exactly the same lawyers as with the ME2 Productions, Cook Productions, LHF Productions lawsuits we’ve been seeing for months now.

Thus, you must come to the logical conclusion that the Boyka: Undisputed 4 movie lawsuit is simply another Carl Crowell (RightsEnforcement.com) common troll lawsuit with the same attorney characters we have seen before. We can infer that behind the scenes, the common troll entity (with MPAA’s blessing) approached the real production company of the Boyka: Undisputed 4 movie, and offered to license the rights to monetize the copyright rights on behalf of the Boyka: Undisputed 4 copyright holder (this means, sue defendants, extort multi-thousand dollar settlements from each John Doe Defendant, name some, dismiss some).

How we at the Cashman Law Firm, PLLC understand the Boyka: Undisputed 4 cases.

In sum, because we know the copyright enforcement entity behind the scenes of this lawsuit (think, APMC, or Anti-Piracy Management Company), and because we know the proclivities of the plaintiff attorneys (who names and serves, who settles, etc.) coupled with the federal judges who are assigned the various cases in each federal district court, we can predict with some relative certainty what will happen in each case.

Whether that means filing a motion to quash an ISP subpoena, whether that means we will recommend that we defend your case, or whether we settle the claims against you or simply convince the plaintiff attorneys that it was not you who did the download (no settlement representation), there are a number of options we could take to represent our clients in these cases.

Here are the cases:

UN4 Productions ISP subpoenas ordered in the Colorado District Court
[Most cases assigned to Judge Wiley Y. Daniel]
UN4 Productions, Inc. v. Doe 1 et al (Case No. 1:17-cv-01419, Case No. 1:17-cv-01477, Case No. 1:17-cv-01577, Case No. 1:17-cv-01253, Case No. 1:17-cv-01299)

UN4 Productions ISP subpoena ordered in the Hawaii District Court
… v. Doe 1 (Case No. 1:17-cv-00282)

UN4 Productions ISP subpoenas ordered in the Illinois Northern District Court
UN4 PRODUCTIONS, INC. v. DOES 1-22 (Case No. 1:17-cv-04865)
… v. DOES 1-25 (Case No. 1:17-cv-04868)
… v. DOES 1-21 (Case No. 1:17-cv-04866)
… v. DOES 1-18 (Case No. 1:17-cv-04863)
… v. DOES 1-23 (Case No. 1:17-cv-04861)

UN4 Productions ISP subpoenas ordered in the Indiana Northern & Southern District Courts
UN4 Productions, Inc. v. Doe 1 et al (Case No. 3:17-cv-00473, Case No. 1:17-cv-00257, Case No. 1:17-cv-00228, Case No. 1:17-cv-02037, Case No. 1:17-cv-02070, Case No. 1:17-cv-01710)

UN4 Productions ISP subpoenas ordered in the New York Eastern & Southern District Courts
UN4 Productions, Inc. v. Doe-67.243.172.121 et al (Case No. 1:17-cv-03621)
… v. Doe-173.68.177.95 et al (Case No. 1:17-cv-03278)
… v. Doe-184.152.88.112 et al (Case No. 1:17-cv-04817)

UN4 Productions ISP subpoenas ordered in the North Carolina Eastern District Court
UN4 Productions, Inc v. Doe 1 et al (Case No. 5:17-cv-00278, Case No. 5:17-cv-00286, Case No. 5:17-cv-00317, Case No. 5:17-cv-00232, Case No. 7:17-cv-00109)
UN4 Productions, Inc v. John Doe 1-12 (Case No. 5:17-cv-00238)

UN4 Productions ISP subpoenas ordered in the North Carolina Middle District Court
… v. DOES 1-10 (Case No. 1:17-cv-00502)
… v. DOES 1-10 (Case No. 1:17-cv-00528)
… v. DOES 1-12 (Case No. 1:17-cv-00444)
… v. DOE 1, et al. (Case No. 1:17-cv-00453)

UN4 Productions ISP subpoenas ordered in the North Carolina Western District Court
… v. Does (Case No. 3:17-cv-00295, Case No. 3:17-cv-00297, Case No. 3:17-cv-00315, Case No. 3:17-cv-00329, Case No. 3:17-cv-00282, Case No. 3:17-cv-00284)

UN4 Productions ISP subpoenas ordered in the Ohio Northern & Southern District Courts
… v. Does (Case No. 3:17-cv-01190)
… v. Does 1-11 (Case No. 5:17-cv-01185)
… v. Does 1-12 (Case No. 1:17-cv-00388)
… v. Does 1-11 (Case No. 2:17-cv-00492)

UN4 Productions ISP subpoenas ordered in the Oregon District Court
… v. Doe-76.27.210.76 (Case No. 3:17-cv-00721)
… v. Doe-71.238.54.166 (Case No. 3:17-cv-00722)

UN4 Productions ISP subpoenas ordered in the Pennsylvania Eastern District Court
… v. JOHN DOES 1-9 (Case No. 2:17-cv-02481)
… v. JOHN DOES 1-15 (Case No. 2:17-cv-02768)

UN4 Productions ISP subpoenas ordered in the Texas Southern District Court
… v. Doe 1 et al (Case No. 4:17-cv-01685)
… v. Does 1-13 (Case No. 4:17-cv-01788)
… v. Does 1-13 (Case No. 4:17-cv-01834)

UN4 Productions ISP subpoenas ordered in the Washington Western District Court
[Most cases assigned to Judge Robert S. Lasnik]
… v. Doe 1 et al (Case No. 2:17-cv-00892, Case No. 2:17-cv-00786, Case No. 2:17-cv-00785)

Siemens NX Lawsuit | Expecting FRCP Rule 4(m) Dismissal Due To a Missed Deadline

Siemens PLM v. Does 1-100 (TX) and missed deadlines.

As many of you know, our Cashman Law Firm, PLLC is representing a number of engineer clients who are accused in a Siemens NX lawsuit of using their Siemens NX Mach 3 software without a valid license.

Siemens as we know is using the lawsuit as a pretext to convert accused infringers into valid license holders.  The name of their lawsuit is the Siemens Product Lifecycle Management Software, Inc. v. Does 1-100 (Case No. 4:16-cv-03552) case filed in the Texas Southern District Court.

The Siemens NX lawsuit attorneys just missed a deadline to name and serve defendants.

Procedurally, Siemens was under a FRCP Rule 4(m) deadline to name and serve defendants by 4/3/2017.  This deadline was set by the judge, and the judge is the one with the discretion on whether to extend it once, multiple times, or dismiss the lawsuit after a certain time period has elapsed.

As of writing this article, The Siemens NX lawsuit attorneys did not file anything on 4/3, and their deadline has passed.  Further, it has been two days without any activity on the court docket from Siemens NX.  This is not surprising, as copyright cases often miss a deadline such as this, and then they request an extension and the federal judges readily approve them, sometimes weeks later.

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What a dismissal means to your case, and how you should proceed depending on your circumstances.

A dismissal of the Siemens NX lawsuit means that you are no longer a John Doe in the case.  However, whether this matter is over or not is based on whether you are before or after the ISP handed out your information in compliance with the subpoena.

If the ISP has not yet complied with the subpoena, your contact information is still hidden from the Siemens lawsuit attorney.

If you are before the due date that your ISP gave you before they comply with the subpoena, you are in luck.  At this point, you are still anonymous, and if you hired an attorney, your attorney will likely offer to return the money you paid to him.  It would benefit you to have him contact the ISP to notify them that the Siemens NX lawsuit has been dismissed and that they should not comply with the Siemens subpoena.

By having the ISP agree not to comply with the subpoena sent to them by the Siemens NX lawsuit attorneys (Robert Riddle & Andrew Bluebond), you will remain anonymous, and your Siemens NX lawsuit plaintiff attorneys will never learn who you are.

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If the ISP has already complied with the subpoena, your contact information has been shared with the Siemens NX lawsuit plaintiff attorneys.

If the ISP date has already passed, the assumption is that the ISP already complied with the subpoena, as they told you they would.  Here, you are no longer anonymous, and the plaintiff attorney already knows who you are.

How the 3-Year statute of limitations for copyright infringement cases suddenly becomes relevant.

A dismissal at this point is inconsequential because the plaintiff attorney has already acquired the information he needs to proceed against you out of court.  The statute of limitations to sue someone for copyright infringement is three years from the alleged date of infringement.  That means that they have three years to sue you as a defendant in a copyright infringement case for this same claim*.

*NOTE: There is more on this topic, but it is outside the scope of this article.

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Whether your plaintiff attorney is a ‘copyright troll’ or now also becomes relevant.

Depending on whether your copyright holder is a ‘copyright troll’ (meaning that they will just file another lawsuit against a new set of John Doe Defendants), or whether they will continue to pursue claims against you out of court (using the information they obtained from this lawsuit), you have two options on how to proceed.

If the copyright holder is a copyright troll, a dismissal such as this one should give you reason to celebrate.  However, Siemens PLM is not a typical copyright troll, and that is why I wrote this article.

To a Siemens PLM attorney, you are worth $30K-$60K.

Each settlement in a Siemens case is worth $30K-$60K for Siemens.  The goal of the Siemens attorney is to contact defendants to arrange for a purchase of one or more NX Mach 3 “seats” or “licenses” (at roughly $30K/seat).

An engineer who has been caught using the software without a license, and who faces an ongoing $150,000 lawsuit is an easy candidate for Siemens to convert into a paying customer.  This can be done with or without a lawsuit being in play, at it would apply regardless of whether the judge dismissed the underlying lawsuit for missing the FRCP Rule 4(m) deadline, or whether they tire of being monitored by a judge and they dismiss the lawsuit themselves.

After all, they already have the information they need, and they have three years to continue contacting defendants until such a time when they are no longer able to proceed (or until the Siemens clients stops paying their fees).

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In sum, the case is NOT yet dismissed.

The Siemens PLM v. Does 1-100 Texas case is not yet dismissed, although I wanted to have this information ready for you so that you will be prepared with your options should a dismissal happen.


CONTACT FORM: If you have a question or comment about what I have written, and you want to keep it *for my eyes only*, please feel free to use the form below. The information you post will be e-mailed to me, and I will be happy to respond.

NOTE: No attorney client relationship is established by sending this form, and while the attorney-client privilege (which keeps everything that you share confidential and private) attaches immediately when you contact me, I do not become your attorney until we sign a contract together.  Also, the contents of topics discussed on this site are not meant to be considered legal advice to act upon or not act upon.  Contact your attorney for answers specific to your particular circumstance.