MATTHEW INMAN OF "THE OATMEAL" SUCKS!

[Tara Carreon]

The Devil Quotes Scripture: "Blessed are the Pterodactyls for they shall tear the humans new assholes!"

[Tara Carreon]

[Tara Carreon]

And I'm getting hate emails as well. So they've targeted our whole family. These are not good people.

[Tara Carreon]

The Matt Inman Mafia got our local paper, The Tucson Weekly, to repeat the same old lies about our client Funnyjunk removing Inman's attribution from his pictures -- Funnyjunk NEVER did that -- and that we're suing The American Cancer Society for a bad purpose, instead of a good purpose, which is to make sure they get the money, and not Matt Inman. The Tucson Weekly author, Dan Gibson, didn't even read the complaint we sent him. He later said, "I'm not a lawyer!" Therefore, he wrote the piece -- which I've never seen anything like it before in the Weekly, a whole special thing just for Charles -- from pure prejudice and stupidity.

Matt Inman's like, "All the money's going to charity." But he has REFUSED several times to relinquish control of the fund either to the Court or to Indigogo, after Charles made requests for him to do so. He's a game-player, this little Matt Inman. He thinks he's going to get his hands on a big pot of money.

This idea that Funnyjunk did the thing that his users are alleged to have done, is the same stupid reasoning that got us into the war in Afghanistan and Iraq: the idea that every person in those countries was guilty because of what some people allegedly did. What happened to individual responsibility? I know, I know, everything's Communist now -- we have GROUP responsibility now. Human rights are out the window -- everything's State's rights now. The Leviathan won against Democracy. The Bill of Rights is in the trash can.

This is a nazi-communist-fascist-right-wing argument.

[Tara Carreon]

Matt Inman word balloon: Oh, yeah, it's all about Bears & Cancer
Matt Inman thought balloon: AS IF !

[Tara Carreon]

It appears that Charles and I have gone to hell, and we're playing with the little hell children. I think it's damn nice of us, as grown-ups, to play with the evil little kids. Not that we had a choice in the matter.

I just realized I live in a different dimension than the one I grew up in. Things have gotten a lot worse, not any better. Anyone noticed the proliferation of "Devil-Death" titles on the video store shelf? I bet the young kids don't even notice it. It's disturbed me for years and years. It portends something very UGLY emerging into our culture ... through our children. It's like one of those movies. What's that one where the children are zombies and they run the town? Very, very creepy. It's like the worst aspects of mind being passed down from father to son and daughter. So we have the experience of an increase in evil.

I spend a lot of time looking at Matt Inman's face in my photoshop projects. I'm looking at it now. It's disturbed. I feel for him. He has a hate angst he doesn't know what to do with. He's tormented, really. He looks like a child who grew up on the streets. He doesn't trust anyone. Everyone's going to fuck him. Extremely paranoid. Actually, sick. There's a pallor to his face. I bet he has a hard time breathing. And there are deep lines in his forehead, another sign of stress and unhappiness. I've never seen him smile. Due to his paranoia, he strikes first, like Henry Kissinger.

For a second, I wondered whether I should blame his parents. But that wouldn't be fair. There's just too many influences out there that parents can't control. But I could help him if he wanted. The answer is in Identity Philosophy, which it appears that I created, although it's hard for me to believe that nobody thought of it before me. It's about Being -- You can't deny it! And with Being comes stability and fearlessness. As opposed to all this fascist tabula rasa-nihilist philosophy pushed on us from every conceivable quarter and angle in this world.

In Tibetan Buddhism, there's this cool idea of the wisdom hag that every man needs in order to get enlightened --- but, that's actually a subject of great secrecy.

Anyway, it's not a surprise we finally got to this hellish place as a culture. Tautological nature of the mind says that when we travel down a road, we experience the experiences we experience along the way, experiences that are peculiar to that road.

I am going to be glad to finally leave this realm. Although, like my guru once said, "plenty of time for death later." Maybe next lifetime, I'll do better, if there is a next lifetime. This is a sad realm we live in. And it's morphing into ever worse places. Though I don't see how much worse it can get. Though the Tibetans say that it will get so bad, that people will live their entire lives in ten years, at which point Maitreya Buddha will come and teach only one teaching: DO NOT KILL. Then things will turn around. I say, why wait until then? Let's do it now.

It's not the fault of the universe, as much as it is the fault of man. Our fathers have betrayed us.

And so have our mothers!

They were unable to conceive of a better way, and then act on it. People are by and large ignorant cowards. No wonder the fascist right-wingers feel superior. At least, they are men and women of action!

And I admire that. I could only hope that they similarly will admire my superior state of mind. Let's get together and think superiorly, and then act a whole bunch. Can you imagine what we could do?

[Tara Carreon]

FIRST AMENDED COMPLAINT, CARREON VS. INMAN:

CALIFORNIA LAW GOVERNING CHARITABLE CONTRIBUTIONS

18. In 1959, California enacted the “Supervision of Trustees and Fundraisers for Charitable Purposes Act.” Calif. Government Code Sections 12580 et seq., (the “Act”), modified by the Nonprofit Integrity Act of 2004 (the “NIA”). In 1972, the California legislature decided the best protection against solicitation fraud was to require substantial, comprehensive registration and disclosure procedures. To promote public education about charitable solicitation costs through disclosure to the donor, California passed the “Charitable Solicitation Disclosure Law.” Calif. Business & Professions Code Sections 17510 et seq. (the “CSDL”).

19. The Act requires all charitable organizations to “establish and exercise control” over their own fundraising activities, and over all fundraising activities conducted by others for their benefit. Charitable organizations operating in California must approve all written contracts for fundraising on their behalf. Cal. Govt. Code § 12599.6(b).

20. Cal. Govt. Code § 12599(a) defines commercial fundraisers:
"Commercial fundraiser for charitable purposes" means any individual, corporation, unincorporated association, or other legal entity who for compensation does any of the following:

(1) Solicits funds, assets, or property in this state for charitable purposes.

(2) As a result of a solicitation of funds, assets, or property in this state for charitable purposes, receives or controls the funds, assets, or property solicited for charitable purposes.

(3) Employs, procures, or engages any compensated person to solicit, receive, or control funds, assets, or property for charitable purposes.”

21. Subsection (b) of Section 12599 provides in relevant part: “A commercial fundraiser for charitable purposes shall, prior to soliciting any funds, assets, or property … in California for charitable purposes, or prior to receiving and controlling any funds, assets, or property, including salvageable personal property, as a result of a solicitation in this state for charitable purposes, register with the Attorney General's Registry of Charitable Trusts on a registration form provided by the Attorney General.” Subsection (c) requires commercial fundraisers to file yearly accountings pursuant to subsection (d) that disclose (1) total yearly revenue, (2) the fee or commissions charged, (3) salaries paid to their officers and employees, (4) fundraising expenses, (5) distributions to the identified charitable organization or purpose, and (6) the names and addresses of any director, officer, or employee who are of charitable fundraisers that also serve as directors, officers or employees of charitable organizations.

22. Section 12599(f) provides in relevant part:

“Failure to comply with these registration or annual renewal and financial reporting requirements shall be grounds for injunction against solicitation in this state for charitable purposes and other civil remedies provided by law.” (Emphasis added.)

23. Section 12599(m) provides:

“A commercial fundraiser for charitable purposes shall not solicit in the state on behalf of a charitable organization unless that charitable organization is registered or is exempt from registration with the Attorney General's Registry of Charitable Trusts.”

24. Section 12599(f) specifically prohibits charitable fundraisers from conducting solicitation campaigns in violation of the Act, committing unfair and deceptive acts, engaging in fraudulent conduct, using any name that implies a contribution is for a particular charitable organization, falsely telling donors that a contribution is for a charitable organization, or will be used for a charitable purpose, or misrepresenting a person as having endorsements that they do not have.

25. Pursuant to Section 12599(h), “[n]ot less than ten (10) days prior to the initiation of a solicitation campaign … a commercial fundraiser for charitable purposes shall file with the Attorney General’s Registry of Charitable Trusts a notice” on a prescribed form, setting forth the following:

“(1) The name, address, and telephone number of the commercial fundraiser for charitable purposes.

(2) The name, address, and telephone number of the charitable organization with whom the commercial fundraiser has contracted.

(3) The fundraising methods to be used.

(4) The projected dates when performance under the contract will commence and terminate.

(5) The name, address, and telephone number of the person responsible for directing and supervising the work of the commercial fundraiser under the contract.”

26. Section 12599(i) requires “a commercial fundraiser for charitable purposes and a charitable organization” to enter into a written contract that shall be available for inspection by the Attorney General “for each solicitation campaign, event, or service, that shall be signed by the authorized contracting officer for the commercial fundraiser, and by an official of the charitable organization who is authorized to sign by the organization's governing body.” The requirements of such a written contract include provisions that give the charitable organization important rights of control over any campaign, including, in subsection (i)(12)(c), the right to cancel campaigns that “conduct fundraising activities in a manner that causes or could cause public disparagement of the charitable organization’s good name or good will.” (Emphasis added.)

INMAN AND INDIEGOGO ARE NOT REGISTERED WITH THE AG TO SOLICIT
ON BEHALF OF THE NATIONAL WILFLIFE FEDERATION, THE AMERICAN CANCER SOCIETY, OR ANY CHARITABLE ORGANIZATION, IN CALIFORNIA

27. Inman and Indiegogo are commercial fundraisers for charitable purposes within the meaning of Cal. Govt. Code § 12599(a).

28. Inman and Indiegogo are not registered with the Attorney General’s Registry of Charitable Trusts pursuant to § 12599(b).

29. Inman and Indiegogo have not filed the disclosures required by § 12599(c).

30. Inman and Indiegogo have not filed the annual reports required by § 12599(d).

31. Inman and Indiegogo are not exempt from registration, and therefore pursuant to subsection § 12599(m), they are prohibited from soliciting “in the state on behalf of a charitable organization.”

32. Inman and Indiegogo did not enter into the written contract with the NWF and/or the ACS, required by § 12599(i).

33. Inman and Indiegogo did not provide the ten-day notice to the Attorney General required by § 12599(h).

INMAN’S CONDUCT DISPARAGES THE IMAGE OF THE CHARITABLE DEFENDANTS AND DAMAGES CHARITABLE FUNDRAISING

34. Inman is not a fit person to design and administer charity fundraising, and Indiegogo acted unlawfully in making him its agent for the promotion of the Bear Love campaign. Inman described how he provokes his fans into sending him “massive traffic” in an online interview published January 6, 2011:

Inman: I work for myself and really no one can control what I say. So usually I tell them that I slept with their mom or I say the most vile, awful thing I can think of. If you read my Twitter account, it is like Hitler’s port-a-potty. It’s the worst thing that you’ve ever seen, just this awful stuff that I say to my critics on there. Just to troll them, mostly. So that’s usually how I respond to it. Like a drunk 15 year old, I think, is the best way to put it....

Interviewer: What about in the beginning when you were going into Digg and you knew that if you won this group of people over, they’d send you massive traffic and if you turned them into haters, they’d bury you and you wouldn’t get anything from them. At that point, weren’t you nervous?

Inman: Yeah. At that point, I wouldn’t have gotten on Digg and been like, “Hey, your mom and I made love under the stars. Ha ha ha. I liked it.” That probably wouldn’t go over so well. But now I’m kind of at this comfortable level. And part of my writing style and the persona that I have online is sort of this crass, bloated, obese, drunk monster. (Emphasis added.) http://mixergy.com/matthew-inman-oatmeal-interview/

35. Inman has announced his vindictive response to his real and imagined enemies by posting, within the source code of all of the webpages on his main website, www.theoatmeal.com, the following image and text, depicting himself as a pterodactyl that will “ptero-you a new asshole.”



36. Following the link to http://pterodactyl.me leads the Internet user to a page on TheOatmeal.com where a video created by Inman and Sarah Donner depicts Inman, in his character as a carnivorous, prehistoric flying reptile that first rips the intestines out of a man’s anus, then flogs him with his entrails, then steals a pineapple from a boy, tears his head off, flings it at a girl and knocks her head off, then grinds the girl’s head up in a wood-chipper, blends it with the pineapple, and drinks the grisly cocktail:


Inman’s followers are by and large technologically savvy young people eager to follow the latest trend, who embrace Inman’s brutal ideology of “tearing you a new asshole,” and believe that people who “don’t get the Internet” are properly fair game for the acts of cybervandalism alleged in the Second and Third Claims for Relief alleged hereinbelow. In addition to being an unsuitable person to run a charitable fundraising campaign, Inman is not an IRS-approved 501(c)(3) charitable organization, and thus could not issue tax-deductible donation receipts to donors. Thus, when Indiegogo and Inman launched the Bear Love campaign, naming the NWF and ACS as beneficiaries, they knew or should have known that reasonable consumers/donors would be mislead into thinking that their donations would be tax-deductible, when in fact, they both knew that donations to the Bear Love campaign would not be tax-deductible.

[Tara Carreon]

$220,024 Tax Writeoff
Matt Inman Christ: "I fuckin' earned it!"

[Tara Carreon]

FIRST AMENDED COMPLAINT, CARREON VS. INMAN

THE “BEAR LOVE” CAMPAIGN

37. On June 11, 2012, Defendants published the webpage now appearing at http://www.indiegogo.com/bearlovegood, as shown in Exhibit B attached hereto (the “Bear Love campaign webpage”).

38. The Bear Love campaign webpage states as follows:
“I run a comedy website called The Oatmeal.

Last year I wrote a blog post about another website called FunnyJunk which stole a bunch of my comics and hosted them on their website without giving me credit. They apparently didn’t like my blog post and recently FunnyJunk sent me a letter stating that unless I pay them $20,000 in damages they’re going to file a federal lawsuit against me. You can view the letter along with my response here.
Instead of mailing the owner of FunnyJunk the money, I'm going to send the above drawing of his mother. I'm going to try and raise $20,000 and instead send it to the National Wildlife Federation and the American Cancer Society.
I’m hoping that philanthropy trumps douchebaggery and greed.More information here.” (Emphasis added.)

39. By making the foregoing bolded statement, Inman and Indiegogo jointly misappropriated the popularity of the NWF and ACS as reputable charitable organizations, lead donors to believe that donations to the Bear Love campaign would go exclusively to the NWF and ACS, and lead donors to believe that donations to the Bear Love campaign would be tax-deductible.

40. In order to accomplish the true purpose of the campaign, which was to initiate a hate campaign against Plaintiff, and induce donors to make donations to the NWF and ACS to express approval of Inman’s hate campaign against Plaintiff, Inman drew and Indiegogo published a misogynistic cartoon depicting an obese female dressed in her underwear, with pendulous breasts popping out of her brassiere, an enormous posterior distended by an overstretched thong, rouged cheeks, and a crudely-lipsticked mouth, calling out to an apparently disinterested brown bear half her size, “COME HURR AND LOVE MEEEE!” He described it as a “drawing of your mom seducing a Kodiak bear.” A true copy of the webpage is attached as Exhibit B.

41. Collecting funds to donate to the National Wildlife Foundation and the American Cancer Society was not Inman’s true purpose in launching the Bear Love campaign. Rather, the Bear Love campaign was launched to utilize Indiegogo’s Internet mass-communication tools to revile Inman’s legal adversaries, Plaintiff and his client, and initiate a campaign of “trolling” and cybervandalism against them which has borne abundant toxic results, including criminal misconduct by Inman’s Internet followers against Plaintiff in the form of repeated events of computer hacking and false personation in violation of Cal. Penal Code § 529, all while pulling in lots and lots of “donations.”

42. Inman made clear his intention to utilize the Charitable Organization defendants as a “human shield” for his assault on Plaintiff and his client when he summed up his attack with the following unequivocal statement:



43. Inman’s insult is much more than a profane witticism. It is a frank declaration of his wrongful, uncharitable motive. It is a non-sequitur that underscores his intent to create a toxic hybrid of malicious intent and “philanthropy.” There is no such thing as a “philanthropic, kind-spirited way” to say “F*ck off.” There is only one way to say it, and one purpose for saying it, and that purpose cannot be lawfully associated with tax-exempt charitable solicitation in the State of California.

44. A day after Inman and Indiegogo launched the Bear Love campaign, on June 12, 2012, at around 7:38 a.m., the campaign had already far exceeded its funding goal of $20,000, raising $104,029, and Plaintiff requested that Indiegogo suspend the campaign on the grounds that it violated its terms of service, sending an email through the Indiegogo website, citing the fact that Inman was violating the provisions of the Indiegogo contract quoted at paragraph 10 above. Venality triumphed over discretion and decency, however, and Indiegogo did nothing to alter the tone or manner of the campaign. Indeed, as news of Plaintiff’s efforts to “block charity” hit the Internet, the negative spin went wild, and Plaintiff was excoriated as the latest Internet victim to self-immolate due to his lack of understanding of “the ways of the Internet.”

45. The Charitable Organization defendants are both registered charitable organizations with the Office of the Attorney General who appear in the Charitable Registry. Neither NWF nor ACS have entered in the written contracts statutorily mandated by Section 12599(i) with Inman or Indiegogo, that would secure their rights to: exercise control over the Bear Love campaign; receive a pre-agreed amount of revenue from the campaign; and assure that the campaign is not conducted in a manner that could cause public disparagement of the Charitable Organization defendants’s good name and good will.

46. Although the Charitable Organization defendants were notified by Plaintiff in writing about the fact that the “Bear Love” campaign alleged infra is being conducted by Inman and Indiegogo in violation of the Act, and that the campaign is being conducted in a manner that could cause public disparagement of the Charitable Organization defendants’s good name and good will, neither the ACS or the NWF have acted to disavow their association with the Bear Love campaign, thus lending their tacit approval to the use of their names to the Bear Love campaign.

47. As of the date of this filing, neither the ACS nor the NWF have communicated with Plaintiff. Nor have either of the Charitable Organization defendants made any public statement; wherefore, the defendants, the general public, and the media have accepted the silence of the Charitable Organization defendants as tacit approval of the Bear Love campaign. On information and belief, Inman has stated that the Charitable Organization defendants approve of the Bear Love campaign, which further brings the ACS and the NWF into disrepute in the minds of right-thinking prospective donors.

48. As of June 24, 2012, Indiegogo, that receives contributions using credit card payments or PayPal, was reporting the full amount of the funds collected by the Bear Love campaign as $213,308, from over 14,136 donors, as recorded in Exhibit B. The Bear Love campaign is scheduled to continue until 11:59 p.m. on Monday, June 25, 2012, so the full amount of the funds that will be raised by the Bear Love campaign is an unascertained number well in excess of this Court’s jurisdictional requirement, hereinafter referred to as the “Charitable Fund.”

49. The purpose and effect of the actions initiated by Inman and published by Indiegogo as above-alleged has been to cloak a hate campaign in charitable appearance for purposes inimical to and inconsistent with charitable purposes by:

a. Falsely representing to donors that they had the endorsement of the Charitable Organization defendants for the Bear Love campaign;

b. Inducing the Charitable Organization defendants to grant post-hoc approval of the Bear Love campaign tacitly by public silence and privately by express encouragement of the Fundraising Defendants; and thereby

c. Bribing the Charitable Organization defendants to endorse a fundraising campaign to which neither would have lent its name if given prior notice of the purpose and manner of the campaign, and that both would have cancelled pursuant to Cal. Gov. Code § 12599(i) for operating “in a manner that causes or could cause public disparagement of the charitable organization’s good name or good will,” but for the inducement of receiving tainted money from the Charitable Fund.

50. The particular danger of Inman’s tactics is that they are wildly successful. The Bear Love campaign is on track to exceed Inman’s $20,000 goals by more than a factor of ten. Fueled with irrational hatred, it pushed into six figures in the first 48 hours, while many legitimate campaigns on Indiegogo, such as those to meet private health care needs -- raise modest four-figure sums over a much longer time period. See Exhibit D, a campaign for “My Kidney Transplant Fund” that has raised $3,570 in three weeks. If Inman’s deceptive methods, sanctioned by Indiegogo and tolerated by the Charitable Organization defendants, are given the green light simply because they get the fundraising job done, they will corrupt an already vulnerable industry. All manner of unregistered fundraisers will adopt Inman’s tactics. Needy charitable organizations will first be backed into fundraising campaigns without their knowledge, then bribed into winking at whatever bizarre, malevolent campaign will fill their treasury with spite donations. In place of legitimate charitable fundraising, unscrupulous, unregistered fundraisers like Inman will prosper as kingmakers who call the tune, inducing charitable organizations to dance to whatever grotesque melody they choose to play. Inman’s methods of fundraising will make true generosity an antiquated, outmoded reason for giving, and donating to satisfy spiteful motives, fueled by venomous Internet postings, will supplant the wholesome impulse to benefit others.

[Tara Carreon]