From the complaint:
“Since 2000, Plaintiff has been engaged in the commercial entertainment distribution industry. Plaintiff formerly sold and rented edited movies. Plaintiff currently rents unedited movies via an online business. Until recently, Defendant sold and rented edited movies. This case is about Defendant falsely representing himself to be a founder, owner, franchisee, or dealer of Clean Flicks or otherwise affiliated with Clean Flicks.
. . .
Since on or about 4 December 2007, numerous news stories have appeared identifying Defendant as “CleanFlicks Founder”, “co-founder of CleanFlicks”, “Former ‘Clean Flix’ owner”, “the owner of ‘Clean Flix’, the company that edited R-rated movies and was recently closed down by Hollywood lawyers”, “a former Clean Flicks franchisee”, “a franchise operator for Clean Flicks”, a man who “used to own four Clean Flicks franchises”, a man who “at one time ran a successful Clean Flicks store”, a man who “formerly operated Clean Flix – a business in Orem that edited feature films to remove or alter conduct deemed inappropriate for children”, and “a former dealer of edited movies with CleanFlicks”. Each of these statements is false.”
Clean Flicks Media, Inc. v. Daniel Dean Thompson, 2:08-cv-00086-PMW (D Utah (Central) Feb 1 2008).