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IN THE UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF OKLAHOMA

1. NATIONAL ASSOCIATION OF FORENSIC )
COUNSELORS, INC., a Nevada Non-Profit )
Corporation; et al., )
)
Plaintiffs, )
)
v. ) Case No. 6:14-cv-00187-RAW
)
1. NARCONON INTERNATIONAL, a )
California Non-Profit Corporation; et al., )
)
Defendants. )


REPLY BRIEF IN SUPPORT OF MOTION TO DISMISS OF DEFENDANT
RELIGIOUS TECHNOLOGY CENTER, INC.
FOR LACK OF PERSONAL JURISDICTION OR, ALTERNATIVELY,
FOR FAILURE TO STATE A CLAIM, AND BRIEF IN SUPPORT
Defendant Religious Technology Center (RTC) submits this brief in further support of
its Motion to Dismiss (the Motion, Dkt. No. 247) and in reply to Plaintiffs Response in
opposition to that Motion (the Response, Dkt. No. 261). The Response makes clear that
Plaintiffs attempt to establish jurisdiction over RTC and to state a claim against RTC essentially
boil down to a single faulty premise i.e., that RTC engaged in a conspiracy to misuse Plaintiffs
logos, trademarks, and certifications. Because Plaintiffs have failed to allege any facts
supporting such a claim, the Court should dismiss RTC from this action.
ARGUMENT AND AUTHORITIES
I. THIS COURT LACKS PERSONAL JURISDICTION OVER RTC.
A. Plaintiffs Cannot Establish General Jurisdiction Over RTC.
Without even citing much less discussing the application of the Supreme Courts
recent decision on general jurisdiction decision in Daimler AG v. Bauman, 134 S. Ct. 746 (2014),
Plaintiffs contend that this Court has general jurisdiction over RTC because RTCs chairman
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allegedly micromanages all portions of Scientology programs and Defendant Narconon
Arrowhead is an Oklahoma resident that allegedly utilizes Scientology materials in its work.
(Resp. at 11.) Therefore, Plaintiffs assert, RTC must micromanage Narconon Arrowhead,
creating systematic and continuous contacts with this forum that are sufficient to create general
jurisdiction.
1
(Id.)
Plaintiffs factual allegations are unsupported and untrue,
2
but more importantly also
irrelevant, because they could not support general jurisdiction over RTC even if they were true.
The Supreme Court, in Daimler, soundly rejected the notion that an organization is subject to
personal jurisdiction in any forum where it may be shown to routinely conduct business. The
question is not whether a foreign corporations in-forum contacts can be said to be in some
sense continuous and systematic, it is whether the corporations affiliations with the State are
so continuous and systematic as to render it essentially at home in the forum State. 134 S. Ct.
at 762 (emphasis added). In Daimler, the Supreme Court concluded that a German corporation
was not subject to general jurisdiction in California even if the contacts of its American
subsidiary, Mercedes-Benz USA, LLC (MBUSA), could be imputed to it. MBUSA has
multiple facilities in California, including a regional office, and reigns as the largest supplier of
luxury vehicles to the California market sales that comprised 2.4 percent of Daimlers
worldwide sales. Id. at 752. Yet the Court deemed these extensive contacts insufficient to create

1
Notably, Plaintiffs do not refute the declaration testimony of RTC President Warren McShane
including RTCs lack of contacts with Oklahoma that was submitted as Exhibit 1 to RTCs
Motion.
2
The documents submitted by Plaintiffs are not only unauthenticated, but they also include
hearsay (sometimes multiple layers of hearsay) and otherwise inadmissible materials. RTC
reserves its rights to object to the documents admissibility in the future, if necessary. But, even
assuming their validity for purposes of this Motion only, they are irrelevant to the issue before
the Court.
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general jurisdiction, noting that [a] corporation that operates in many places can scarcely be
deemed at home in all of them. Id. at 762 n.20.
Thus, applying Daimler, one appellate court has recognized that general jurisdiction now
extends beyond an entitys state of incorporation and principal place of business only in the
exceptional cases where its contacts with another forum are so substantial as to render it at
home in that state. Sonera Holding B.V. v. Cukurova Holding A., 750 F.3d 221, 223 (2d Cir.
2014). Here, even if Plaintiffs allegations were correct regarding the degree of oversight
exercised by RTC regarding Narconon Arrowhead, which they are not, these allegations simply
do not render RTC sufficiently at home in Oklahoma to establish general jurisdiction. Indeed,
Plaintiffs basic premise is that RTC micromanages all Scientology programs, and their
Complaint demonstrates the worldwide reach of those programs. (See Compl. 3-84 (alleging
that Defendants reside in at least 14 states, Canada, and the United Kingdom).) Thus, Plaintiffs
fall far short of establishing the type of exceptional circumstances necessary under Daimler to
find general jurisdiction over a defendant outside of the forum in which it resides.
B. No Specific Jurisdiction Exists Because Plaintiffs Fail To Establish A Nexus
Between RTCs Alleged Contacts With Oklahoma And Their Claims In This
Case.
In support of their claim that this Court has specific jurisdiction over RTC, Plaintiffs cite
the following three factual allegations:
3


3
In their Complaint, Plaintiffs claimed personal jurisdiction over all Defendants based on their
operation of active websites. (Compl 86.) In the Motion, RTC demonstrated that RTCs
website could not provide the basis for personal jurisdiction over RTC in Oklahoma. (Resp. at 7-
8.) Failing even to address this issue in their Response, Plaintiffs apparently have abandoned
this theory of jurisdiction as to RTC.
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1. [RTC Chairman David] Miscavige personally oversaw the establishment
of Narconon Arrowhead [in Oklahoma] in conjunction with Defendant
Gary Smith.
2. Mr. Miscaviges approval was necessary for the move to Arrowhead and
he maintained particular interest in the weekly reports concerning the
flagship location.
3. Mr. Miscavige spoke in detail about NBAE certifications and the
purported approval of Narconons programs by Plaintiffs in his 2002
speech.
(Resp. at 12.) None of these allegations, even if true, supports the exercise of jurisdiction here.
Although the first two allegations purport to show RTCs interest in and oversight of
activities within Oklahoma, they allegedly occurred in 2001, do not relate to Plaintiffs, and are
not tied in any way to the purported conduct at issue in this case, i.e., the alleged misuse of
Plaintiffs marks. Thus, they cannot constitute a basis for specific jurisdiction over RTC in
Oklahoma.
4
See Dudnikov v. Chalk & Vermillion Fine Arts, Inc., 514 F.3d 1063, 1071 (10th Cir.
2008) (noting that a court may exercise specific personal jurisdiction over a defendant only if the
defendant has purposefully directed its activities at residents of the forum state and the
plaintiffs injuries arise out of defendants forum-related activities.) (citation omitted).
5

Further, in the Motion (at 16), RTC noted Plaintiffs failure to tie their control allegations
to a legally cognizable theory of vicarious liability or jurisdiction (e.g., alter ego or agency). The
Response similarly makes no mention of alter ego or agency undoubtedly because even

4
Plaintiffs similarly fail to establish any connection between the alleged conduct at issue in this
case and other factual allegations cited elsewhere in the Response concerning RTCs purported
support and oversight of Narconon. These include the unsubstantiated claim (see Rinder Aff.,
7, Pls. Ex. 2) that RTC must authorize and approve all materials and promotional items used
by the Narconon Network (Resp. at 8), and Plaintiffs contentions that Chairman Miscavige
visited the Oklahoma facility on one occasion (Id.). None of these claims, even if true, would
establish personal jurisdiction.
5
Plaintiffs reside in Indiana and have sued 82 defendants of which only 13 are located in
Oklahoma.
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Plaintiffs recognize such theories would be doomed to failure here.
6
Rather, Plaintiffs seek to
create a new hybrid jurisdictional doctrine, attempting to force their control allegations into their
conspiracy theory of jurisdiction. They suggest that any entity that exercises control over a party
engaged in a conspiracy is presumptively also a party to that conspiracy even if there is no
allegation that the out-of-state defendant either engaged in or exercised control over the specific
conduct at issue. Plaintiffs cite no authority for this implicit proposition, which is contrary to
principles of fairness and common sense and, if adopted by the Court, would permit an end-run
around the well-established agency and alter ego jurisdictional doctrines.
Plaintiffs appear to concede that the third allegation concerning a 2002 speech by
Chairman Miscavige in Florida has no direct connection to Oklahoma, yet they assert that it
constitutes evidence of RTCs participation in a conspiracy that includes actions purportedly
taken in Oklahoma by RTCs alleged co-conspirators. (Id.) Invoking a conspiracy theory of
jurisdiction, they contend that specific jurisdiction lies here because RTC allegedly participated
in the same conspiracy as Defendant Kent McGregor, an Oklahoma citizen, whom Plaintiffs
label [o]ne of the main players in the civil conspiracy. (Resp. at 12.) The problem with this
theory is that the allegations concerning the 2002 speech, even if true, simply do not establish
RTCs participation in that purported conspiracy.
Although the Complaint summarily claims that the speech contained false statements
(Compl. 248), Plaintiffs do not attempt to state a claim against RTC for any allegedly false

6
Plaintiffs cannot establish the lack of separateness or absence of corporate formalities that are
essential to an alter ego claim. Moreover, a federal court in Georgia recently held, after
analyzing many of the same factual assertions and some of the exact same exhibits offered by
Plaintiffs here that Narconon is not an agent of RTC for purposes of the Georgia long-arm
jurisdictional statute. See Burgess v. Religious Tech. Ctr., Inc., Case No. 1:13-cv-02217-SCJ
(N.D. Ga. Feb. 19, 2014) (attached as Exhibit 1). The Georgia court thus granted RTCs Rule
12(b)(2) motion.
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assertions contained in the 2002 speech. Rather, they contend that Chairman Miscaviges
statements in the 2002 speech furthered the alleged conspiracy at issue here merely because he
discuss[ed] the precise certifications at issue in this lawsuit. (Resp. at 17.) But the fact that he
generally discussed those certifications in 2002 in no way indicates that RTC conspired to
wrongly claim that certain Defendants held certifications roughly a decade later.
There is simply no allegation that Mr. Miscavige made the type of allegedly false
statements in the 2002 speech that are at issue here, i.e., that Narconon personnel possessed
certifications when, in fact, they did not. Indeed, the Complaint affirmatively alleges that almost
80 percent of the individual Defendants (34 of 43) actually were certified by Plaintiffs at some
time in the past. Although Plaintiffs do not specify when those certifications were first issued,
they contend that all of the certifications either expired or were revoked between February 2009
and August 2013. Thus, at the earliest, the misconduct asserted by Plaintiffs here began in 2009.
Indeed, Plaintiffs concede that the Oklahoma Defendants alleged misuse of Plaintiffs marks
and certifications did not begin until 2013 (Resp. at 17) eleven years after Chairman
Miscaviges Florida speech, thus undercutting any claim that a conspiracy directed at Oklahoma
existed in 2002. If Plaintiffs had evidence that the purported conduct at issue in this case began
closer in time to Chairman Miscaviges speech, they could and should have provided that
evidence in response to RTCs Rule 12(b)(2) motion. They did not. Accordingly, based on the
temporal and substantive differences between the speech and the purported conduct undertaken
by the alleged conspiracy, Plaintiffs have failed to make a prima facie showing that RTC has
participated in that conspiracy and have failed to refute RTCs Presidents declaration testimony
that RTC never communicated, let alone conspired, with any other defendant with respect to any
use of any NAFC logo, mark or certification in this action. (McShane Decl. 16.) See Shrader
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v. Biddinger, 633 F.3d 1235, 1242 (10th Cir. 2011) (noting that to establish personal jurisdiction
based on a conspiracy theory, a plaintiff must offer more than bare allegations that a
conspiracy existed, and must allege facts that would support a prima facie showing of a
conspiracy). Accordingly, Plaintiffs have not established specific jurisdiction over RTC in this
forum.
II. ALTERNATIVELY, PLAINTIFFS CLAIMS AGAINST RTC SHOULD BE
DISMISSED FOR FAILURE TO STATE A CLAIM.
The Response confirms that Plaintiffs claim against RTC is based solely on their
contention that RTC participated in a conspiracy with Defendants who allegedly misappropriated
Plaintiffs trademarks, logos, and certifications. (See Resp. at 5 (This case is about Defendant
[RTC] spearheading the theft of Plaintiffs goodwill in order to bait vulnerable victims into the
Scientology religion.); Id. at 6 (RTC operates a common scheme with the other Defendants to
promote the Narconon Network through the misuse of Plaintiffs logos, trademarks, and
certifications.).) Plaintiffs attempt to tie RTC to the alleged conspiracy on two equally
meritless bases.
First, Plaintiffs contend that [i]n order to expand and promote Scientology, RTC and
ABLE strictly control Narconon. (Resp. at 17; see also id. at 7-8 (reciting facts allegedly
showing RTCs control).) RTC disputes many of Plaintiffs factual contentions, which are
unsupported by Plaintiffs exhibits
7
and notes that several exhibits even predate the 1996
formation of NBAE (sub-board of NAFC) (Compl. 240), and registration of NAFCs mark in

7
For example, contrary to Plaintiffs allegation that RTC holds the ultimate authority regarding
the standard and pure application of Hubbards technologies (Resp. at 9), the cited exhibits (Ex.
1 3; Ex. 6) merely confirm what RTC acknowledges in its Motion that RTC owns and
licenses the intellectual property rights used by churches of Scientology, whereas ABLE owns
and licenses the intellectual property rights associated with the secular technologies used by
Narconon and other social betterment programs the Church supports.
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2008 (id. 109).
8
However, RTC is not marshaling the facts necessary to refute all the
inaccurate factual allegations because it will not be baited into factual disputes that do not matter
here, nor should the Court.
The fundamental flaw in Plaintiffs attempt to plead a civil conspiracy claim against RTC
is that even if all their facts were assumed to be true, they cannot establish RTCs participation
in any common scheme to have other defendants misuse or misappropriate any of the claimed
intellectual property rights. What they could show, and RTC does not dispute, is that RTC, its
Chairman of the Board, the Churches of Scientology and Scientology parishioners all over the
world fully support Narconons social betterment programs and humanitarian efforts to get
people off drugs. None of that, however, is the stuff of a civil conspiracy claim, because, as
Plaintiffs concede, [t]o maintain a cause of action for civil conspiracy, the plaintiff must allege
a combination of two or more persons acting in concert for an unlawful purpose. (Resp. at 16
(emphasis added).) The promotion of Narconons programs does not constitute an unlawful
purpose.
In addition to their irrelevant control allegations, Plaintiffs also contend that they have
stated a claim for conspiracy based on a 2002 speech by RTCs Chairman. (Resp. at 17.) As
shown above, the speech referring to Plaintiffs certifications provides no plausible basis for
concluding that RTC participated in a conspiracy to misuse those certification many years later.
Therefore, Plaintiffs have failed to state a claim upon which relief may be granted.

8
Ex 10 (1992); Ex 14 (1989); Ex 18 (1991); Ex 20 (1987); Ex 22 (1998); Ex 23 (1996).
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III. THE COURT SHOULD DENY PLAINTIFFS REQUEST FOR LEAVE TO
AMEND THEIR COMPLAINT.
Plaintiffs ask the Court to grant them leave to amend their Complaint if the Court finds
that they have failed to state a plausible claim for civil conspiracy. (Resp. at 17.) Such an
amendment, however, should not be allowed.
Although Rule 15(a) gives the Court discretion to grant leave to amend when justice
requires it, [t]he district court is not required to grant leave to amend [] if amendment would be
futile. Murchison v. Progressive N. Ins. Co., 572 F. Supp. 2d 1281, 1283 (E.D. Okla. 2008).
A proposed amendment is futile if the complaint, as amended, would be subject to dismissal.
Peterson v. Grisham, No. CIV-07-371-RAW, 2008 WL 4363653, at *9 (E.D. Okla. Sept. 17,
2008). Here, Plaintiffs have offered nothing to suggest that, given the opportunity to amend,
they could allege facts sufficient to state a plausible claim for conspiracy. Indeed, Plaintiffs
attached 26 exhibits to their Response but have still not set forth enough facts to make their
theory plausible. This failure to identify how they would fix their Complaint if they could is fatal
to Plaintiffs request to amend. See Toone v. Wells Fargo Bank, N.A., 716 F.3d 516, 524 (10th
Cir. 2013) (The district court is not required to imagine all possible amendments and determine
whether any would state a claim . . . . Rather, the plaintiff must submit a proposed amendment
for the courts consideration, or at least specify how an amendment would cure the deficiency.)
Lundahl v. Pa. Mfg. Assn Ins. Co., 440 Fed. Appx. 629, 633 (10th Cir. 2011) (district court did
not abuse its discretion by not allowing plaintiff to amend her complaint because plaintiff never
explained how a proposed amendment would cure the deficiencies identified by the district
court). The Court should deny Plaintiffs request to amend their Complaint.
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CONCLUSION
Plaintiffs seek to substitute conspiracy theories in lieu of plausible allegations of
conspiracy to commit a specific wrong. Although the Complaint, Response, and exhibits thereto
contain copious amounts of the former, they offer none of the latter. Accordingly, Defendant
RTC should be dismissed from this action for lack of personal jurisdiction. Alternatively, the
Court should dismiss Plaintiffs claims against RTC for failure to state a claim upon which relief
can be granted.
Dated: August 4, 2014
Respectfully submitted,

/s/ David L. Bryant
David L. Bryant, OBA No. 1262
David E. Keglovits, OBA No. 14259
Amelia A. Fogleman, OBA No. 16221
GABLEGOTWALS
1100 ONEOK Plaza
100 West Fifth Street
Tulsa, Oklahoma 74103-4217
(918) 595-4800
ATTORNEYS FOR DEFENDANT
RELIGIOUS TECHNOLOGY CENTER

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CERTIFICATE OF SERVICE
I hereby certify that on the 4th day of August, 2014, I electronically transmitted the
attached document to the Clerk of Court using the ECF system for filing. Based on the records
currently on file, the Clerk of Court will transmit a Notice of Electronic Filing to the following
ECF registrants:
David R. Keesling
david@KLGattorneys.com
Heidi L. Shadid
heidi@KLGattorneys.com
Sloane Ryan Lile
sloane@KLGattorneys.com
Keesling Law Group, PLLC
401 South Boston Avenue
Mid-Continent Building, 4th Floor
Tulsa, OK 74103
Attorneys for Plaintiffs National Association
of Forensic Counselors, Inc.;
American Academy of Certified Forensic
Counselors, Inc.
Donald M. Bingham
don_bingham@riggsabney.com
M. David Riggs
driggs@riggsabney.com
Wm. Gregory James
gjames@riggsabney.com
Riggs Abney Neal Turpen Orbison & Lewis
502 West Sixth Street
Tulsa, OK 74119
Attorneys for Defendant Narconon of
Oklahoma, Inc.;
Derry Hallmark; Janet Watkins;
Tom Widman; Vicki Smith;
Michael Otto; Michael J. Gosselin;
Kathy Gosselin; Michael George;
Kent McGregor; Dena G. Goad;
Michael St. Amand; Gary W. Smith;
Pita Group, Inc.

John H. Tucker
jtuckercourts@rhodesokla.com
Colin H. Tucker
chtucker@rhodesokla.com
Denelda L. Richardson
drichardoncourts@rhodesokla.com
Kerry R. Lewis
klewis@rhodesokla.com
Rhodes Hieronymus Jones Tucker & Gable
P.O. Box 21100
Tulsa, OK 74121
Attorneys for Association for Better Living
and Education International;
Narconon International; Clark Carr; Robert
Wiggins; Jason Burdge; Steven K. Bruno


Richard P. Hix
Richard.hix@mcafeetaft.com
Alison A. Verret
Alison.verret@mcafeetaft.com
McAfee & Taft, P.C.
1717 South Boulder Avenue, Suite 900
Tulsa, OK 74119
Attorneys for David S. Lee; Philip R. Kelly, II
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Charles D. Neal, Jr.
cdn@steidley-neal.com
Steidley & Neal
P.O. Box 1165
McAlester, OK 74502
Attorney for Defendants Friends of Narconon
International;
Best Drug Rehabilitation, Inc.;
A Life Worth Living, Inc.;
Golden Millennium Productions, Inc.;
Joseph Guernaccini; Thomas Garcia;
David S. Lee, III; Richard Hawk;
Anthony Bylsma; Glen Petcavage;
Narconon Freedom Center, Inc.;
Jonathan Beazley;
Narconon Spring Hill, Inc.;
Royalmark Management, Inc.;
International Academy of Detoxification
Specialists; Premazon, Inc.;
Jonathan Moretti
Charles D. Neal, Jr.
cdn@steidley-neal.com
Rachel D. Parrilli
rdp@steidley-neal.com
Stacie L. Hixon
slh@steidley-neal.com
Steidley & Neal
2448 East 81st Street, Suite 5300
Tulsa, OK 74137
Attorneys for Defendant Friends of Narconon
International;
Best Drug Rehabilitation, Inc.;
A Life Worth Living, Inc.;
Golden Millennium Productions, Inc.;
Joseph Guernaccini; Thomas Garcia;
David S. Lee, III; Richard Hawk;
Anthony Bylsma; Glen Petcavage;
Narconon Freedom Center, Inc.;
Jonathan Beazley;
Narconon Spring Hill, Inc.;
Royalmark Management, Inc.;
International Academy of Detoxification
Specialists; Premazon, Inc.;
Jonathan Moretti; Luria K. Dion;
Michael DiPalma; Mary Rieser; Carl Smith;
Nicholas Thiel; Robert Hernandez;
Daphna Hernandez;
Narconon of Georgia, Inc.; Rebecca Pool;
Narconon - Hawaii; Narconon of Northern
California; Intervention Services and
Technologies, Inc.; Narconon Fresh Start,
Inc.; Narconon South Texas, Inc.; Narconon
Eastern United States, Inc.; Narconon Trois-
Rivieres. Narconon London; Narconan, Inc.;
The Virtual Workforce Co., Ltd.;
Encognitive.com; GreatCircle Studios, LLC;
James McLaughlin; Robert Newman; Joseph
Sauceda; Nicholas Bailey; D. Eric Michell;
Shana Austin; Nick Hayes; Scott Burgess;
David Miscavige; Tibor Platinus; Sylvain
Fournier; Marcel Gemme; Kenneth H.
Pomerance; Richer Dumais; James
Woodworth; Desiree Cardoso; Cheryl
Williams; Marc Bernard; Martin Gamsby;
Luria K. Dion


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Robert D. Nelon
Nathaniel T. Haskins
Hall, Estill, Hardwick, Gable, Golden &
Nelson, P.C.
Chase Tower
100 North Broadway, Suite 2900
Oklahoma City, OK 73102-8865
Attorneys for Defendants Narconon Freedom
Center, Inc.; Nicholas Thiel; Narconon
Trois-Rivieres

Todd A. Nelson
Fellers Snider Blankenship Bailey & Tippens,
P.C.
The Kennedy Building
321 South Boston Avenue, Suite 800
Tulsa, OK 74103-3318
Attorney for Defendants Michael DiPalma,
Joseph Guernaccini and Jonathan Beazley

John J. Carwile
McDonald McCann & Metcalf & Carwile,
LLP
15 E Fifth St, Ste 1400
Tulsa, OK 74103
918-430-3700
Email: jcarwile@mmmsk.com

Attorneys for Church of Scientology
International
Alison A. Verret
McAfee & Taft (Tulsa)
1717 S Boulder Ave, Ste 900
Tulsa, OK 74119
918-574-3065
Email: alison.verret@mcafeetaft.com

Richard P. Hix
McAfee & Taft (Tulsa)
1717 S Boulder Ave, Ste 900
Tulsa, OK 74119
918-587-0000
Fax: 918-599-9317
Email: richard.hix@mcafeetaft.com

Attorneys for Defendant Kevin Lee; Sharon
Kubacki; Philip R. Kelly, II


/s/David L. Bryant
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