"This Case Begins with a Viral Video" (and Goes on to Involve "the Anti-Doxing League")

From today’s decision by Judge Kyle Dudek (M.D. Fla.) in Noshirvan v. Couture (for a 2023 decision stemming from the same incident, see Plaintiff Sues Defendant, Alleging Defendant’s “Niche Is Cancel Culture”):

This case begins with a viral video. Plaintiff Danesh Noshirvan is a citizen journalist who built a social media following by exposing bad behavior in public spaces. In January 2022, he posted a video of Defendant Jennifer Couture confronting a young woman in a Dunkin Donuts parking lot. The video caught fire, resulting in criminal charges for Couture and public backlash. Couture and her now-husband, Defendant Dr. Ralph Garramone, allegedly decided to get even.

According to Noshirvan, Couture and Garramone—acting individually and through Garramone’s various business entities—hired a convicted computer hacker named Joseph Camp to retaliate. Camp, in turn, connected the couple with Defendant Patrick Trainor, a New Jersey lawyer who operates the Anti-Doxing League. What followed, Noshirvan alleges, was a retaliatory conspiracy by these defendants to systematically destroy his life and livelihood.

Trainor responded to Noshirvan’s lawsuit with counterclaims for defamation and civil conspiracy. According to Trainor, Noshirvan used his social media account to falsely brand Trainor as a “Nazi,” a “White supremacist,” and a “pedophile.”

Trainor also alleges that Noshirvan enlisted two non-parties—James McGibney (who runs the account @bullyville) and an anonymous user known as @credibleintel—to amplify the smear campaign and republish the offending statements. Noshirvan then allegedly weaponized these posts to file bogus complaints against Trainor with state and federal law enforcement, as well as the New Jersey Office of Attorney Ethics. …

The conflict with Trainor ignited in January 2024, when McGibney emailed Trainor to accuse him of misrepresenting facts to a court. That private dispute quickly spilled onto the internet. Between February 2024 and 2025, Noshirvan, McGibney, and @credibleintel unleashed a barrage of social media posts targeting Trainor. The publications accused him of harassment, professional misconduct, conspiring with a fugitive, and being a Neo-Nazi and pedophile. According to Trainor, the offending posts remain publicly visible today….

The court threw out Trainor’s claims against Noshirvan, concluding:

Trainor cannot defeat summary judgment with a patchwork of stale claims, non-actionable opinions, and a conspiracy theory lacking an actual agreement. Yet that is all he offers. Trainor has failed to muster the specific facts necessary to show a conspiratorial agreement between Noshirvan and his associates. Strip away the conspiracy framework, and Trainor’s defamation case reduces to statements that are either time-barred or constitutionally protected hyperbole.

The court concluded that defamation claims based on statements from before July 30, 2024 are barred by New Jersey’s one-year defamation statute of limitations. The court also rejected Trainor’s civil conspiracy claims, as well as Trainor’s attempt to hold Noshirvan liable for McGibney’s claims:

Viewing the documents cited by Trainor that he contends evidence a conspiracy between Noshirvan and McGibney, no reasonable jury could find an agreement to defame. Trainor’s first document reflects McGibney offering to post about Noshirvan’s lawsuit on two social media accounts “couture.camp” and “bullyville”—nothing more. Other communications between Noshirvan and McGibney are either too temporally disjunctive from the underlying conspiracy, do not relate to any conspiracy at all, or discuss a motion filed by Trainor or a drafted filing rather than the alleged defamatory posts. Through no stretch of the imagination could a reasonable jury conclude Noshirvan, McGibney, and @credibleintel entered an agreement to defame Trainor based on these documents.

And the court concluded that the post-July 30, 2024 statement by Noshirvan is not actionable:

The post features a screenshot of Senator Dick Durbin questioning [Kash] Patel about his appearances on a podcast whose host “promotes conspiracy theories and worked with a neo-Nazi.” Below the exchange, a caption reads, “Sounds like Patrick Trainor.” Trainor insists this post is actionable because it effectively brands him a neo-Nazi.

But rhetorical hyperbole and name-calling do not amount to defamation. Under New Jersey law, a general statement accusing someone of bias is an opinion. Instead, there must be some other “reasonably specific facts that are capable of objective proof of truth or falsity.” Generalized accusations of bigotry or extreme bias—without a tether to specific, verifiable facts—are protected opinions. Gomez Noriega v. City of Jersey City (D.N.J. 2025) (statement that the plaintiffs “hate Jews” was not actionable as defamation); Jorjani v. New Jersey Inst. of Tech. (D.N.J. 2019) (“[C]alling someone a racist, hater, or bigot—without more—will not result in defamation liability[.]“). Noshirvan’s snarky caption is a textbook example of a non-actionable, rhetorical comparison….

Nicholas A. Chiappetta (Chiappetta Trial Lawyers) represents Noshirvan.

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