 But what's wrong, Paul? You didn't make enough money selling snake oil on the Joe Rogan podcast? Over two million views and nothing to show, huh? Maybe if you were half as handsome and charismatic as me, you might have a dime in your pocket. Oh, and stealing every single thing you've said probably had something to do with your lack of success. It's kind of hard to sell something when you don't understand it. This absolute scumbag has plagiarized me word for word over 100 times, has copied every single business idea I've had from my natural cosmetic products to my meat company, my book cover, podcast name, even selling the same supplements. And here he is, suing me again, this time for $500,000. The first case resulted in dismissal based on jurisdiction and I was out over $13,000 in lawyer fees, which was actually supposed to be my new car fund. Now I guess Paul is going to attempt to seize my 2001 Ford Taurus, too bad his lawsuit is complete dog shit. And Paul, if you do get my Ford Taurus, it'll probably cost you more to take the dense out than the car is worth. So, you know, you might want to put your eggs in a better basket. Is this guy just trying to dig his grave deeper and deeper? I'm sitting here living with my parents. I'm almost 30 years old trying to scrape together every dime I've saved my entire life just so I can provide quality foods to other people from bartending, working with mentally disabled kids, and my YouTube revenue over the past few years. And I'm broke from that one BS lawsuit. This guy is sitting on who knows how much money from selling you pus filled testicles, eggshell supplements, while suing the guy he wishes he was. I don't need to explain all of this again. My friend has the website paulsaladino.com, which highlights all of the videos. The main concern I have with this is all the lawyers, judges, these people against me are in secret societies, so I'm basically screwed from both ends. You know, at least if I defend myself, I don't have to waste any more money and get jerked around by the club. So let's go through this lawsuit, which has many similar points to the last one. United States District Court for the Southern District of New York, Paul Saladino MD versus Frank Tafano, summons in a civil action, David D. Lin, Lewis N. Lin, LLC. And you know, I thought Paul was pretty ugly on the outside and inside, but if you look at the lawyers from this firm, they look like some sort of ghouls that climbed out of a cave. Jerry Trial demanded, plaintiff Paul Saladino, MD, Dr. Saladino, what a jerk off, man. No one cares, buddy. What you shove psychiatry medications down people's throats and you mislead people to keep racking up that sweet insurance money. What are you bragging about? Through his undersigned attorneys, as and for his complaint against defendant Frank Tafano, alleges as follows, statement of case one, this is an action for money damages and corrective and injunctive relief due to defendant Tafano's wrongful and malicious campaign over the last year to attack Dr. Saladino and Dr. Saladino's business and services as a licensed physician and a certified functional medicine practitioner. In order to promote his own competing health consultancy, Paul, you think you're competing with me? We might as well be on two different planets, buddy. Two, defendant Tafano has created and published over half a dozen defamatory videos that contain numerous false statements of fact, as well as misrepresentations about Dr. Saladino and his services. Furthermore, upon information and belief, defendant Tafano created and registered the domain name PaulSaladino.com on October 23, 2020 and immediately began posting it to a defamatory website containing inter-Elia, sexually graphic and homophobic images of Dr. Saladino, as well as links to the defamatory videos created and published by defendant Tafano on his YouTube channel, which defendant Tafano uses to promote his competing business interests. Paul, that's an interesting way to word free speech on YouTube, as well as a website that who knows if I made it, who knows if my buddy made it. I guess that's what lawsuits are about, pretending you know what the other person is doing. Three, Dr. Saladino is thus forced to bring this action to recover damages and for injunctive relief to seek redress for and stop the blatant harassment and defamation by defendant Tafano and to order the removal and destruction of the defamatory videos, website and domain name that encompasses Dr. Saladino's distinctive PaulSaladino mark in its entirety. Well Paul, if someone registers the domain name PaulSaladino.com and decides to post videos of your plagiarism on it, I'm not so sure how that works. Parties. Four, Dr. Saladino is an individual residing in San Diego, California. I thought the guy moved to Texas a couple months ago. I don't know what's going on. Five, defendant Tafano is an individual residing in New York. Jurisdiction and venue. This court has personal jurisdiction over defendant Tafano since defendant Tafano resides and transacts business in New York. Well, I guess you're going to have to prove that one too. Nine, venue is proper in this judicial district under 28 USC 1391. Okay, so you're claiming you know I resided in New York now, but I wonder what the judge is going to think of your previous case that was simply intended to waste my money because you knew I didn't reside in San Diego and that's where you sued me and the case was dismissed based on lack of jurisdiction. So now you're coming to New York to try to waste my money again. I wonder what the judge is going to think about that. Facts relevant to all claims. 10, Dr. Saladino is a licensed physician and certified functional medicine practitioner through the Institute for Functional Medicine. 11, Dr. Saladino is passionate about understanding and correcting the roots of chronic disease and using this information to help patients enjoy better lives. To that end, he is one of the leading authorities on the science and application of the carnivore diet to human well-being. I think we went over this in the last one because some of these statements are the same. Paul, if you learned everything from my YouTube channel, I guess that puts me above the leading authority. Also, I thought you weren't carnivore anymore, aren't you eating rice and honey and fruit now? Following in someone's footsteps perhaps? Dr. Saladino offers fee-based private consultation services to consumers regarding use of a carnivore diet to treat medical conditions. He has used this diet to reverse autoimmunity, chronic inflammation, and mental health issues in hundreds of patients. Hmm, hundreds of patients. Yeah, yeah. Be a real shame if someone asks for an order of discovery and said, hey, you're plagiarizing me on fair business practice. I think I should be the one getting the 500 grand, Paul. We'll see what the judge thinks. Dr. Saladino is the best-selling author of the carnivore code, unlocking the secrets to optimal health by returning to our ancestral diet, published by Euthan Nifflin Handcourt. The book is currently a top 10 bestseller on Amazon in the category of men's health books. Paul, I wonder what the judge is going to think when half of the information in your book was copied from my book, which was published six months prior. I also wonder what the judge is going to think when you actually redid your book to change the cover as well as content to reflect my personal views more. Not too bright, Paul. Dr. Saladino maintains a social media presence on the internet, including on YouTube, Twitter, and through numerous collaborative podcasts, including the Minimalist, Bulletproof Radio, the Dr. Gundry podcast, the Ben Greenfield podcast, Dr. Mercola, Health Theory, Mark Bell's Power Project, the Joe Rogan experience, and many others. Paul, why didn't you put in here that you colluded with the Minimalist against me in the prior lawsuit? I mean, I guess I wouldn't want the judge to know that either, that you're willing to lie and cheat in a lawsuit through collusion. Dr. Saladino is the owner of all common law rights to the Paul Saladino trademark, the Paul Saladino mark, and has used his first and last name in commerce and on the internet and social media since as early as June 2017. Dr. Saladino created and registered PaulSaladinoMD.com in October 2017, and shortly thereafter pointed the domain to a website that promotes his business and services. Dr. Saladino operates a San Diego-based business under the Paul Saladino mark, which involves his specialty and promotes the use of a carnivore diet to treat health issues and lead better lives. The business caters to four varieties of customers. One, YouTube viewers, which generate advertising revenue through the YouTube platform. Two, third-party social media podcasters who desire Dr. Saladino's audio, video, and real-time interactive content. Three, purchasers of Dr. Saladino's merchandise, including a line of nutritional supplements. And four, patients who desire private consultations for the treatment of health issues. Is this guy lying about being in San Diego? Isn't he in Texas now? Dr. Saladino has used the Paul Saladino mark continuously and extensively in connection with the marketing of the business. As a result, Dr. Saladino has established a reputation and goodwill in his personal name separately as a trademark. The Paul Saladino mark is unique, distinctive, and has acquired distinctiveness through its association with Dr. Saladino's business as advertised and sold throughout the United States. Well, Paul, maybe you should have gone through the US Patent and Trademark Administration to register your trademark. Perhaps you should have actually bought the website paulsaladino.com. How about that one? For example, as a result of Dr. Saladino's efforts and his association with the Paul Saladino mark, his YouTube channel has over 67,000 subscribers, his Twitter account has over 40,000 followers, and his book, The Carnivore Code, has recently released a second edition. Oh, did you mention the reason you needed to do a second edition was to change your stance on plant foods to reflect Frank Tafano's stance on plant foods? You should really mention your plagiarism. Defendant Tafano also maintains a presence on social media and publishes videos and written statements, including on YouTube and Twitter, to promote his own fee-based medical nutritional therapy services regarding use of a carnivore diet to treat medical conditions. Upon information and belief, Defendant Tafano is not licensed to provide medical nutritional therapy. Paul, did you receive education on a carnivore diet in medical school? Aren't you a psychiatrist? Not licensed to provide medical nutritional therapy? You aren't either, buddy. Dr. Saladino and Defendant Tafano are competitors. They compete for consumers and viewers in the same industry. You know, Paul, I wouldn't put it that way. I would say you came in after I've been doing this for four years, and you're basically vying for stealing my customers. I don't think we're competitors. I think you're just a parasite that's attempting to leech off of me, and I think anyone would blatantly see that. Saying we're competitors is incredibly misleading. When you've copied every single business idea I've had, when every single word that comes out of your mouth that's remotely intelligent, pertaining nutrition came out of my mouth three months prior, not too bright, buddy. Welcome to New York. Upon information of belief, Defendant Tafano saw the growth of Dr. Saladino's presence on social media and the spread of Dr. Saladino's good reputation as a threat to his own enterprise, which is similar in vision to that of Dr. Saladino's. No, what I actually saw was your DM to me on Twitter that you wanted to debate me to attempt to promote yourself more using my own platform, and after reviewing your information, your videos, they sounded awfully familiar, and then I discovered your plagiarism. You're gonna try to blatantly lie in a court case like this, man, maybe I'll get a fat check and buy my Mercedes. Defendant Tafano has undertaken a malicious campaign to spread false information and attack Dr. Saladino's good character and reputation for the purpose of hurting Dr. Saladino's business and to benefit his own competing business. You know, Paul, if someone tells the truth about something, it's free speech, and if telling the truth hurts your business, hey, tough luck. The coordinated and persistent advertising campaign includes half a dozen videos directly attacking Dr. Saladino and making numerous false representations of a fact. More recently, on October 23rd, 2020, Defendant Tafano, upon information and belief, registered and created the domain name, paulsaladino.com, and immediately began pointing it to a defamatory website containing inter alia, sexually graphic and homophobic images of Dr. Saladino, as well as links to the defamatory videos created and published by Defendant Tafano on his YouTube channel, which he uses to promote his own competing business and arrest. Hey Paul, I'll give it to you for your creativity. Implying I own the website, implying as a 43 year old single man that takes shirtless pictures with dudes in gyms, that you're not home, I don't know what to tell you buddy. I mean, it's not too far out of the realm of possibility, and if it's the truth, it's not defamatory, but I do appreciate your attempt at misinterpreting reality. So the next few talking points on this lawsuit are identical to the last lawsuit. He brings up the copy pasta salad video, November 7th, 2019, where I stated things like, Dr. Saladino has to copy me word for word, Dr. Saladino is willing to blatantly lie, all he cares about is making money and promoting himself, which he's claiming to be our false statements. In reality, we can prove them all pretty easily. So if you guys do wanna go back and watch the first lawsuit video, you can hear these talking points again, I'd rather not repeat them. On February 5th, 2020, Defendant Tafano published a video on his YouTube channel entitled, Carnivore MD, Paul Saladino's plagiarism, which has over 14,000 views, and which contains many of the same defamatory statements and false misrepresentations as the above videos. I mean, Paul, I don't think posting a clip of you saying something, and then me saying the same thing three months prior is a defamatory statement. On October 16th, 2020, Defendant Tafano published a video on his YouTube channel entitled, Carnivore MD, Paul Saladino, copied his way to the Joe Rogan experience, which features Defendant Tafano again, peeking directly into the camera and includes numerous statements about Saladino. The video has over 15,000 views. The October 16th video contains multiple general and specific misrepresentations of fact about Dr. Saladino and his services, including that Dr. Saladino plagiarized Defendant Tafano, that Dr. Saladino plagiarized throughout medical school, that Dr. Saladino used Defendant Tafano's information on the Ben Greenfield podcast, and that Dr. Saladino has hundreds of social media workers monitoring comments. Defendant Tafano's campaign attacking Dr. Saladino has included at least three more such defamatory videos. I mean, basically he's claiming that there's misrepresentations of facts, false defamatory statements, but he's not listing any statements here. He's just saying it. He doesn't have proof, because everything I said was likely true. It was likely pointing out plagiarism. I mean, the main focus here, and the reason he's doing me is probably because of the paulsaladino.com website. He's repeating some of those points again, saying I've taken my malicious campaign against Dr. Saladino to a whole new level. Repeating some stuff again. So his first claim for relief is basically that all of my statements are false and unlawful and that he's being damaged. Second claim for relief has to do with him owning the paulsaladino trademark and me having no rights to the website if I own it. And his third claim for relief is that I'm profiting off of Dr. Saladino's name. This guy's a fucking comedian. As a direct and proximate result of Defendant Tafano's unlawful, deliberate, and malicious conduct as set forth above, Dr. Saladino has been and will continue to be damaged both irreparably and monetarily. More claims for defamation. An award of compensatory damages according to proof and trial, but in an amount no less than $500,000, as well as punitive and exemplary damages, were authorized, including from the Lanham Act and Common Law due to defendants willful and wanton behavior. You guys should call these clowns up. Louis N. Lin, LLC. David D. Lin. 718-243-9323. Attorneys for plaintiff, Dr. Saladino. Yeah, let him know what you think of them having Dr. Saladino as their client and representing him. There's a lot that could be said about this absolute degenerate, but one thing's for certain is that he has dollar signs in his eyes. His intentions are in the wrong places. Does he want a $14 million mansion like Joe Rogan? Does he want to have a bunch of free time so he can play with his Masonic buddies in the sauna? I don't know. Whatever it is, it's very clear. What he's doing isn't working, so he's gotta sue me. Hey, you guys can go over to Paul Saladino's channel. Thank him for delaying you obtaining high-quality animal foods from Frank Tifano. The fresh beef slaughtered every week, the local raw dairy, corn and soy-free eggs, high-quality nutritious animal and plant foods. Call up those lawyers, tell them the same thing. But hey, once the Masonic degenerates push Frank Tifano out of business, you can go buy their shitty oxidized meat from ButcherBox and make sure to sprinkle some eggshell powder on it.