PRELIMINARY STATEMENT
Gaia files this Motion to Dismiss to resolve, at the outset of this action,
claims by Plaintiffs that have no basis in the law and are entirely inadequately pleaded.
Plaintiffs, whose activity in the “Conscious Community” focuses on Goode’s experiences in a secret space program and with alien beings, bring this action purportedly to protect themselves from a suspected conspiracy to misappropriate their intellectual property and defame Goode.
But Plaintiffs’
purported claims are simply not supported by the wild, disjointed, and vague allegations against various, apparently unconnected Defendants.
Indeed, each of Plaintiffs’ claims fails to state a cause of action as a matter of law and must be dismissed, certainly as to Gaia, if not against all Defendants.
Plaintiffs’ inability to plead legitimate, valid claims is indicative of Plaintiffs’ true intent in filing—which is evident upon even a cursory review of the Complaint—
to attempt to garner attention and stir controversy.
Such a conclusion is confirmed by Plaintiffs’ actions both prior to and since filing, as Plaintiffs have made hundreds of internet and social media posts about their supposed crusade against Gaia and the other Defendants.
However, as this Memorandum explains,
Plaintiffs’ claims are merely conclusory pronouncements that do not constitute plausible legal causes of action and are nothing more than baseless conspiracy theories and persecution fantasies.
The Complaint includes sixteen separate numbered claims, all of which are brought against all Defendants—some of whom Gaia has never had any contact with—in an undifferentiated fashion, and incorporate by reference all allegations of the Complaint.
This approach furthers the impression that Plaintiffs are not seeking redress for valid claims, but are merely trying to collectively smear the Defendants and gain publicity.
Likewise, the Complaint is rife with allegations that in no way relate to any asserted claim;
Plaintiffs apparently believe that every perceived slight is evidence of a grand and far-reaching conspiracy, and have included reference to such slights in the Complaint, regardless of whether any such actions could plausibly constitute a legal claim.
Plaintiffs’ scattershot approach is not consistent with the pleading requirements of the Federal Rules of Civil Procedure, and unfairly burdens both Defendants and the Court.
To the extent that anything can be gleaned from the Complaint, it is clear that Plaintiffs’ purported claims are deficient as a matter of law.
For example,
Plaintiffs assert a RICO conspiracy against the Defendants, but fail to plausibly plead any necessary predicate offenses.
Likewise, Plaintiffs bring a claim for breach of oral contract against Gaia, but then admit that the parties subsequently entered into a written contract on the same subject—which contains a merger clause of all prior representations—that did not include the purported oral promises Plaintiffs now seek to enforce.
Plaintiffs also attempt to assert certain trademark claims, but fail to allege how and when the purported trademarks were violated by Gaia.
Beyond just failing to state cognizable claims, the Complaint violates procedural and ethical obligations.
Plaintiffs have brought claims where there can be no good faith basis for doing so, including claims barred by the applicable statute of limitations, a claim that completely ignores statutory prerequisites to filing, and claims that are not recognized as valid causes of action at all.
Plaintiffs have even alleged that the Court has diversity jurisdiction where it plainly does not, as both Plaintiffs and multiple Defendants are alleged to be citizens of Colorado.
The Complaint is an apparent attempt not to use the Court for the administration of justice but to provide fodder for Goode’s online community, a community apparently hungry for content and conflict.
What began as a carefully orchestrated attempt to elicit clicks must end with a complete dismissal of all purported claims, and an imposition of sanctions on Plaintiffs and their counsel.
For all of the foregoing reasons, Plaintiffs’ claims and the Complaint should be dismissed in their entirety with prejudice as to Gaia.
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