1.The
Plaintiff is a small Canadian publisher with editorial offices in Toronto, Ontario, and
administrative and distribution offices in Brantford, Ontario.The Plaintiff specializes in books on Judaica
by Canadian authors.The book, The Second Catastrophe, (hereinafter
called the “book”) by Howard Rotberg (hereinafter called the “author”) was the
first volume of three projected titles in a series called “New Judaica”.The other two volumes have been in the
pre-publication stage, and as a result of the following acts of the Defendants,
have not been able to be published.
2.The
Defendant Indigo Books & Music Inc. (hereinafter called “Indigo”) is
the largest chain of bookstores in Canada and operates under the trade
names, Chapters, Indigo, Coles, SmithBooks, World’s Biggest Bookstore and other
names.The Defendant Indigo is the dominant retailer for
books in Canada.
3.The
Defendant Alan Roper (hereinafter called “Roper”) was at all material times the
Manager of Indigo’s store in Waterloo,
Ontario.
4.The
Defendant Matthew Zarnke (hereinafter called “Zarnke”) was at all material
times the Assistant Manager of Indigo’s store in Waterloo, Ontario.
5.The
Defendant Raneem Al-Halimi (hereinafter called “Al-Halimi” was at all material
times an employee of the Indigo store in WaterlooOntario.
6.The
Defendant Ali Khedr (hereinafter called “Khedr”) is a friend of Al-Halimi and
resides in WaterlooOntario, with her parents, Elsayed Khedr and
Howaida Wahdan.
7.The
Defendant Howaida Wahdan (hereinafter called “Wahdan”) is the mother of the
Defendant Khedr, and at all material times was the owner/licensee of the IP
address for the internet connection and service provided to her residence by
Rogers Telecom.
8.In
March, 2004, the Defendant Indigo ordered 300 copies of the book by the
author.The Plaintiff gave the Defendant
Indigo the option of delivering various copies of the book to individual
stores, or the option of delivering all 300 copies to the Indigo’s
central warehouse in Brampton,
Ontario, with Indigo
delivering copies to various stores.Indigo
selected the latter option, and the Plaintiff gave the Defendant Indigo a
larger retailer’s discount in consideration for Indigo distributing the
books to its individual stores.
9.On
March 29th, the Plaintiff delivered the 300 copies of the book to Indigo’s
warehouse pursuant to invoice and purchase order, attached hereto.
10.The
Plaintiff made arrangements with Indigo for the author to do lectures
and signings at three of Indigo’s stores, starting with its Waterloo
Chapters store on May 17, 2004, and generally commenced its publicity campaign
for the book.Indigo represented
that the books would be delivered to its stores within a reasonable time
frame.In fact, Indigo failed to
have the books distributed to its stores for a period of over 2 months, thus
frustrating the Plaintiff’s publicity campaign for the book.Various of Indigo’s stores started
sending purchase orders to the Plaintiff, who contacted Cheryl Watson, of Indigo,
who advised that she would make sure that the orders were fulfilled from the
warehouse, but she did not do so, within a reasonable time.Some three weeks after the delivery of the
books to the warehouse, prospective purchasers were reporting to the Plaintiff
that not only was the book unavailable at any store, but store employees were
unable to state when the book would be available.Indigo blamed the delay on a new
computer system, but in fact had adequate time before implementing the new
system to have the books distributed.
11.Pursuant to Indigo’s invitation to
speak at its Waterloo
store, the author appeared there on May 17, 2004.The Defendant Roper introduced the
author and then left the area where the author was to speak, and no store
employee was left in charge of monitoring the event.The author’s book is a novel about a Canadian
professor who writes a pro-Israel book, and finds that he creates a lot of
opposition on the campus where he teaches.As such, the author’s book is somewhat controversial, but is in no way
hostile to the rights of any people and is in no way racist.It supports a two-state solution for peace
between Israel
and the Palestinians.
12.The format
of the author’s event at the Waterloo Chapters’ store was a lecture, not a
debate.Notwithstanding this, two hecklers
took over the lecture, and would not stop their criticisms of the author, and
would not let him continue speaking.The
author was talking generally about terrorism, and one minority group of Muslims
called “Islamists” who are radical and violent fundamentalists who have been
behind much of the terrorism.The author
criticized terrorists and Islamists but did not criticize Muslims in
general.One heckler identified himself
as Palestinian, and another as an Iraqi Kurd.The self-described Palestinian interrupted the author to allege that the
author thinks that all Muslims are terrorists, and the author clearly denied
having such an opinion.Some audience
members asked the self-described Palestinian to let the author continue his
lecture, and he replied that the author had “no right” to speak if he was
pro-Israel.Then the self-described
Iraqi was told to be quiet and he replied that the author was a “fucking Jew”.
13.When the
author was unable to get any words out, in the face of constant talking and
shouting by the hecklers, in the presence of one or two Chapters’ employees
who made no attempt to intervene to restore order, he stood up and collected his notes, as if to
leave.One Chapters’ employee had
dropped by the periphery of the seating area for a few minutes, but had left,
and at the time of the final disruption of the lecture, the only Chapters’
employee within view was the Defendant Al-Halimi, a young woman wearing
a Muslim head-covering, who later identified herself as a Palestinian, and
who knew both of the hecklers, and knew, or ought to have known, that the
self-described Iraqi had recently been ejected from the same store after trying
to disrupt a publisher’s presentation by Random House Canada concerning the
book by Irshad Manji called The Trouble
with Islam.The Defendant Al-Halimi
made no efforts to protect the guest author from the aggressive behaviour by
the hecklers and in fact she stood by, smirking, as the hecklers disrupted the
lecture.It was the Defendant Al-Halimi
who, having thus participated in the abuse of the guest author by hecklers who
she knew, then misrepresented to Indigo and to her fellow employees what
transpired at the lecture.
14.After the
self-described Iraqi yelled that the author was a ‘fucking Jew”, the author
replied that he would not be called a “fucking Jew” at his lecture.By that time, two store managers, the
Defendants Roper and Zarnke appeared, and instead of confronting the
hecklers, told the author that he was not allowed to continue the lecture and
they gathered up the books for sale, and escorted the author to a rear
office.The author asked the Defendants
Roper and Zarnke to call the Police, because he feared for his safety.The Defendants Roper and Zarnke said
they did not see any reason to call the Police, and that they didn’t have the
number.The author insisted that the
store call “911”.The Defendants
Roper and Zarnke detained the author in the rear office, thus placing him under
false arrest, and when the police did come, the police interviewed and
released the hecklers before talking to the author, who was being detained by
the store officials and was not able to talk to the police before they
apparently completed their investigation, based on talking to the hecklers and
the Defendants Al-Halimi, Roper and Zarnke, and not to the author or two
professors who were sitting in the front row throughout the lecture.
15.Later that
evening the Plaintiff publisher went out a press release advising that future
appearances by the author at Chapters’ stores, including scheduled appearances
at stores in Ancaster and Ottawa,
were being cancelled.The Plaintiff did
not criticize Chapters in the press release, but simply said the events were
being cancelled due to security concerns in protecting the author, and the concern
that Chapters’ customers should not have to hear the shouting and racial
epithets of protestors and hecklers.
16.The next
day, the Public Relations Director of Indigo called the author directly
and complained that the Plaintiff had issued a press release before giving her
the opportunity to review it and approve it.She stated that the publisher should have had her review and approve any
press release that mentioned Chapters’ name in any way.She was very upset.Then, she told the author that as a result
the Defendant Indigo would issue its own press release and that the
author would not be very happy with it.She told the author that she had heard that the author said things “just
as objectionable” as what the hecklers said.When the author asked what that was, she stated that she had heard that
he had said that “all Muslims are terrorists”.The author told her that that was ridiculous and she had better think
twice about putting such an untruth out in a press release.The author told her that if she wanted to
know the true story of what was said he could give her the name and telephone
number of two professors who were in the front row throughout the whole
lecture.
17.In fact the
Defendant Indigo did put out its own press release, and did not talk to
independent witnesses, thus allowing its employee, the Defendant Al-Halimi
to fabricate what happened, and then acting on that fabrication, Indigo
stated in said press release, “We are saddened that our customers witnessed
inappropriate behaviour and heard racist comments both from the guest author
and some of the attendees at this particular event.”
18.The
Plaintiff denies that the author said anything at all racist.The Plaintiff denies there was any
equivalency between the conduct of the hecklers and the conduct of the
author.The Plaintiff states that the
Defendant Indigo owed it a duty to do a proper investigation of
independent witnesses, before making such a shocking statement alleging that
the author made “racist comments”.As
a result of a Court Order in this proceeding, the Defendant Indigo has now had
to disclose the written statements of the Defendants, Al-Halimi, Roper, and
Zarnke.In fact, none of these written
statements allege that the author said that “all Muslims are terrorists”.Instead, they allege that the author said
that “all Middle-Easterners are terrorists.”The Plaintiff denies that the author said even this, but had the author
said this, it would not be a racist statement, because “Middle-Easterners
include a wide variety of races, religions, and ethnicities, including, inter
alia, Israeli Jews, Christian Arabs, Druze, Bahais, Egyptian Coptic Christians,
Armenian and Russian Orthodox, and many more.Accordingly, if the written statements of employees, the Defendants,
Al-Halimi, Roper and Zarnke only allege that the author said that all
“Middle-Easterners” are terrorists, then either the Defendant Indigo through
its Public Relations Director made an incorrect assertion of “racist comments”
based on the employees’ information, or alternatively, the Defendants
Al-Halimi, Roper and Zarnke changed their positions between the time of
speaking to their superiors at Indigo, and the time of making their later
written statements.In either event, the
Plaintiff states that the actions of some or all of the Defendants were wrong
and damaged the interests of the Plaintiff.In addition, the written statements of the Defendants Roper and Zarnke
contradict each other on the sequence of the major point in issue.These statements have such major factual
errors in them, and they were taken so long after the event, that they are
clearly indicative of an attempt to save their jobs at the expense of the
Plaintiff and the author.
19.As a result
of the Defendant Indigo’s press release and the quotation of the above
statement in various news stories, and Indigo’s allegation that the
author made racist comments, the author became afraid for the personal safety
of himself and his family, and was too afraid to do any more public lectures on
the book, thus hurting the ability of the Plaintiff to properly promote the
book and gain income from the book.For
example, the author cancelled an appearance at the University of Toronto.
20.Having gotten away with the promulgation of a
lie about the author, the Defendant Al-Halimi was encouraged to take further
steps against the author.The Defendant
Al-Halimi enlisted the help of her friend, and fellow student, the Defendant
Khedr.Using the computer of the
Defendant, Wahdan, Al-Halimi and Khedr decided to spread more lies about the
Plaintiff’s author on the internet.The
Canadian Coalition for Democracies is a pro-democracy interest group, based in
Toronto, that seeks to advance the interest of liberal democracy around the
world and to seek to influence the Canadian government and Canadian public
opinion if favour of liberal democracies and against dictatorships.On its website there is a Public Message
Forum where interested parties are able to make comments on current events of
interest to this cause.Many people wrote
in to this Public Message Forum expressing dismay at the treatment of the
Plaintiff’s author.
21.Then
there appeared a posting on the said Public Message Forum which, unlike all the
others, was adamantly opposed to the author.In fact, it purported to be from person named “Sela Vomberg” who, in
broken English, with many spelling mistakes, stated that (s)he was at the event
(which (s)he mistakenly called a “reading”), that (s)he was Jewish, that the
author made him/her ashamed to be Jewish, that the author is a “hypocritical
evil little bigot”, a “rascist (sic) scum”, and that in response to the author
being sworn at what he had in fact said was “This just proves that all arabs
and muslims deserve to die.”
22.By means
of a Court Order in the Ontario Superior Court by Mr. Justice Day on December
14, 2004, Rogers Communications Inc. was directed to disclose the name and
address of their customer matching the IP address which the Canadian Coalition
for Democracies had shown was the sender of the above-mentioned internet
posting on their Public Message Forum.Rogers disclosed that the name and address was that of the Defendant
Wahdan, the mother of the Defendant Khedr, who is the friend of the Chapters’
employee, the Defendant Al-Halimi.It
was determined by an investigation by the Plaintiff that the name (Sela
Vomberg) used by the Defendants Al-Halimi, Khedr, and Wahdan, as the supposed
author of the posting was the last name of a Jewish family who live a few doors
down from the Defendants Khedr and Wahdan, and whose child on occasion had
played with the younger brother of the Defendant Khedr and the son of the
Defendant Wahdan.
23.Plaintiff
alleges that once the Defendant Indigo claimed that the author is an
(anti-Muslim) racist, and that once the Defendants Al-Halimi, Khedr and
Wahdan posted their claim that the author said that all Muslims and Arabs
deserve to die, such allegations endangered the life of the author,
who was then justifiably reluctant to make appearances, which lessened the
Plaintiff’s potential income from the book.In addition, even though the author was refusing public appearances, he
would have appeared more before Jewish organizations to speak, but the
Plaintiff alleges that the Defendants had “stigmatized” the author as a racist,
causing even Jewish organizations to be reluctant to have him speak.
24.The author
wrote to various officials of the Defendant Indigo, including its
President, Heather Reisman, asking for an investigation, a retraction and an
apology, but his letters were not responded to.PenCanada, an advocacy group for the free speech rights of authors wrote
a letter to Heather Reisman asking her to reschedule the lecture, but again,
she chose not to respond.Finally, the
author threatened to sue the Defendant Indigo for libel.All this accomplished was to set in motion a
series of events where some few days after a phone call between the author and
Ms. Reisman where he said he had no alternative but to sue to protect his
reputation, Ms. Reisman had her Vice-President of Supply Chain Management write
to the Plaintiff that Indigo was going to remove all copies of
the book from all of its stores, and keep only 20 copies in the warehouse for
on-line orders only.(In fact, Indigo
breached even this promise, and refused to fulfill any on-line orders
and on its website showed simply that the book was “unavailable”.) The official blamed “poor sales” but in fact
the book had sold out at certain locations, and the Defendant Indigo
refused to keep even 1 or 2 copies in stock in stores where the book was
selling well.The Plaintiff claims that
the Defendant Indigo decided to punish the Plaintiff for the author’s
audacity in speaking out against the actions of the Defendants in
calling him a racist.As further
evidence of the Defendant’s course of action against the author, it decided not
to post on its “Reader Reviews” section of its website certain favorable
reviews of the book sent in by readers.Indigo
at first blamed the absence of posting of the favorable reviews on “computer
problems”, but after posting two favorable reviews, it stopped posting further
favorable reviews and only posted unfavorable reviews.
25.The author
repeatedly offered to make available to Indigo, copies of sworn
affidavits from the professors who heard the entire lecture from the first row,
but Indigo did not accept the offer to look at these affidavits, instead
choosing to base its actions on the biased and mendacious actions of the Defendants,
Roper, Zarnke and Al-Halimi, no matter what the effect would be on the
author and the Plaintiff.
26.The
Plaintiff’s terms of sale of the books to Indigo was “Net 90 days”.Nearly one year after delivery of the books,
the Defendant had not made any payments to the Plaintiff for books sold or
unsold.The Plaintiff’s emails to Cheryl
Watson of Indigo were not responded to, and three separate telephone
calls by the Plaintiff’s Receivables Clerk to Bindu Gupta of Indigo late
in February 2005 were not responded to.The
Defendant Indigo only paid for the books in response to being served with the
Claim herein.
27.The
Plaintiff claims that the actions of the Defendants have hurt the ability of
the Plaintiff to market this book and the rest of the books in the series and
the Defendants’ malicious actions have jeopardized the Plaintiff’s business,
and the Plaintiff will most likely be forced out of business.
28.The
Israel-Hezbollah War in the summer of 2006 enlarged the public’s appetite for
the book, and the Plaintiff was surprised, but happy, when Indigo’s flagship
store at Bay and Bloor Streets in Toronto ordered 30 copies of the book.The lawyer for Indigo was informed of this
step, but when some two weeks after the order and the notification of Indigo’s
lawyer of same, no revocation of the order was made, and upon confirming with a
staff member at the Bay Street store that the book was indeed on the shelves, the
Plaintiff decided to support Indigo’s sale of the book with a ¼ page
advertisement in the Globe and Mail’s Saturday Books section, at a cost to the
Plaintiff of $1272.The advertisement
mentioned that the book was available at “IndigoBooksBay and Bloor and other
fine book stores”.
29.Unfortunately,
there had been a communication breakdown between Indigo and its Bay and Bloor
store, and apparently the store did not know that Indigo was “banning” this
book.As soon as the ad ran, Indigo
management got angry with what had happened, and instructed its staff at the
Bay and Bloor store to pull the book off the shelves and not to sell it to
anyone.Accordingly, on the weekend that
the ad ran, numerous purchasers were told that the staff knew nothing about the
book, and some of these prospective purchasers contacted the Plaintiff.The Plaintiff alleges that this is proof
that the Defendant Indigo is so fixated on harming the Plaintiff that it does
so even when that is contrary to its own financial interests.
30.The
Plaintiff therefore claims:
(a)Against
the Defendant Indigo, for books sold (less an allowance for books returned)
the sum of $2795.55. (Paid after service of the claim)
(b)Against
all the Defendants, for damages on account of lost sales and profit to the
Plaintiff as a result of the Defendants’ improper actions against the
author and the Plaintiff, the sum of $5000.
(c)Against
all the Defendants, for damages on account of the Defendants making
it impossible for the Plaintiff to carry forward its business and publish the
two remaining books in the series, and not earn any future profits, the sum of
$5000.
(d)Against
the Defendant Indigo, the sum of $1272. spent on advertising to support the
sale of books ordered by Indigo in August, 2006, but removed from sale as soon
as Indigo’s Head Office saw the advertisement and realized that its flagship
store was selling the Plaintiff’s author’s book.
(e)Legal
costs and interest.
31.The Plaintiff
hereby waives any portion of its claim beyond the monetary jurisdiction of this
Court.
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