(a) are warmongerers;
(b) are complicit in the deaths of innocent people; and
(c) make things that kill children.
Since their business is the manufacture of weapons (see http://www.indymedia.org.uk/en/2005/02/304814.html), these would all seem to be at the very least fair comment, and arguably simple fact.
(Text below, original M$ Word file attached.)
The subject of the complaint would appear to be the following pages:
and posibly others, which report on the ongoing campaign against this company.
Definite shadows of McLibel and GANDALF here...
| | |
| email@example.com |Email firstname.lastname@example.org |
| | |
|Fax No |
|Our Ref: SDM/MBM2.3 |3rd February 2005 |
| | |
|Dear Sirs, |
|EDO MBM TECHNOLOGY LIMITED |
We act for EDO MBM Technology Limited.
Our client has become aware of false and defamatory information about our client that has been posted on your website at www.indymedia.org.uk.
We refer in particular to the statements that our client "war-mongers", is "complicit in the deaths of innocent people" and makes "things to kill children" and to the comments posted on your website which are falsely ascribed to Paul Hills and David Jones of EDO MBM Technology Limited.
Furthermore, you publish the names and private addresses of MBM EDO Technology Limited employees and comments which actively encourage readers to target these individuals, who are described as a "Mass Murderer at large" and "Masochistic".
These statements are false and highly damaging to our client's reputation and the reputation of it's employees. Our client manufactures weapons interfacing systems and deals only with reputable customers. Our client takes this matter very seriously and is minded to commence proceedings
against you for libel, seeking an injunction, damages and costs.
Our client is, however, prepared to try and settle this matter without recourse to the courts on the condition that on or before Monday 7th February 2005 you remove all material from your website which is defamatory of our client and that, within 14 days of the date of this letter, (by 18th February 2005), you return to us the enclosed draft Undertaking, typed on your letterhead. If you do not comply with this request within the time specified our client reserves its right to commence court proceedings against you without further notice, claiming an injunction and damages and all other reliefs to which it is entitled.
Provided that you comply with our client's requirements, our client will refrain from commencing proceedings against you for libel in respect of your unlawful activities to date, although, of course, our client reserves all its rights in the event of any breach by you of the undertaking.
We look forward to hearing from you as a matter of urgency.
REYNOLDS PORTER CHAMBERLAIN
DRAFT UNDERTAKING TO BE TYPED
ON THE LETTERHEAD OF INDYMEDIA UK
EDO MBM Technology Limited
C/o Reynolds Porter Chamberlain
278-282 High Holborn
In consideration of you not commencing proceedings against us for libel for defaming EDO MBM Technology Limited in the manner set out in the letter from Reynolds Porter Chamberlain dated 3rd February 2005 we, Indymedia UK,
hereby undertake that we will not in the future (whether acting by ourselves, our employees or agents or otherwise howsoever) publish defamatory statements relating to the activities of EDO MBM Technology Limited, including, without limitation, those statements complained of in Reynolds Porter Chamberlain's letter of 3rd February 2005 or words to a similar effect.