{"id":366,"date":"2014-09-25T16:10:40","date_gmt":"2014-09-25T20:10:40","guid":{"rendered":"https:\/\/defiantly.net\/?p=366"},"modified":"2023-03-22T13:20:36","modified_gmt":"2023-03-22T17:20:36","slug":"chan-v-ellis-text-of-appellant-supplemental-brief-in-response-to-2nd-amicus-brief-of-timothy-b-mccormack","status":"publish","type":"post","link":"https:\/\/defiantly.net\/?p=366","title":{"rendered":"Chan v. Ellis: Text of Appellant Supplemental Brief in Response to 2nd Amicus Brief of Timothy B. McCormack"},"content":{"rendered":"

IN THE SUPREME COURT OF THE STATE OF GEORGIA<\/strong><\/p>\n

Case No.: S14A1652<\/a>
\n<\/span>Lower Court No.: SU13DM409<\/p>\n

MATTHEW CHAN, Appellant<\/p>\n

-against-<\/p>\n

LINDA ELLIS, Appellee<\/p>\n

.<\/p>\n

SUPPLEMENTAL BRIEF OF APPELLANT IN RESPONSE TO SECOND AMICUS CURIAE BRIEF OF TIMOTHY B. MCCORMACK<\/strong><\/p>\n

.<\/p>\n

Respectfully Submitted,<\/p>\n

Oscar Michelen (Courtesy Admission)
\nNY State Bar No.: 2058477
\nCUOMO LLC
\n9 East 38th Street
\nNew York, NY 10016<\/p>\n

William J. McKenney
\nGA State Bar No.: 494725
\nMCKENNEY & FROEHLICH
\n50 Polk Street NW
\nMarietta, GA 30064<\/p>\n

.<\/p>\n

.<\/p>\n

TABLE OF CONTENTS<\/strong><\/p>\n

Table of Citations \u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026 ii<\/p>\n

I. Preliminary Statement \u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026.. 1<\/p>\n

II. Discussion of Facts \u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026. 1<\/p>\n

II. Argument and Citation of Authorities \u2026\u2026\u2026\u2026\u2026\u2026\u2026.\u2026\u2026\u2026\u2026… 2<\/p>\n

A. THE US SUPREME COURT HAS ANALYZED CIVIL INJUNCTIONS BETWEEN PRIVATE LITIGANTS AS PRIOR RESTRAINTS ON SPEECH \u2026\u2026\u2026….. 2<\/p>\n

B.\u00a0 BECAUSE APPELLANT\u2019S POSTS ARE NOT \u201cTRUE THREATS\u201d THEY ARE PROTECTED BY FEDERAL LAW AND WERE THE SUBJECT OF AN OVERLY BROAD RESTRICTIVE ORDER \u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026 4<\/p>\n

C.\u00a0 APPELLANT HAS NOT WAIVED HIS RIGHTS \u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026 7<\/p>\n

D.\u00a0 THE COMMUNICATIONS DECENCY ACT MAKES APPELLANT IMMUNE FROM LIABILITY FOR POSTS MADE BY OTHERS \u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026 8<\/p>\n

E.\u00a0 THAT APPELLANT CAN POSSIBLY SPEAK ABOUT APPELLEE ON OTHER OUTLETS HAS NO BEARING ON WHETHER THIS ORDER IS CONSTITUTIONAL . . . 9<\/p>\n

IV. Conclusion \u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026 10<\/p>\n

.<\/p>\n

.<\/p>\n

TABLE OF AUTHORITIES<\/strong><\/p>\n

Cases<\/strong><\/p>\n

Austin v. Keefe 402 U.S. 415 (1971) \u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026\u2026.. 2<\/p>\n

Fair Housing Council of San Fernando Valley v. Roomates.com, 521 F.3d 1157 (9th Cir. 2008) …………………………………………………………………………………………. 9<\/p>\n

Jones v. Dirty World Entertainment Recordings, LLC. 840 F. Supp 2d 1008 (ED Ky. 2012) ………………………………………………………………………………………………..10<\/p>\n

Madsen v. Women\u2019s Health Center, Inc., 512 U.S. 753 (1994) …………………………. 4<\/p>\n

McGuire v. Reilly, 386 F.3d 45 (1st Cir. 2004) ………………………………………………… 4<\/p>\n

Near v. Minnesota ex rel. Olson, 283 U.S. 697 (1931) ……………………………………… 2<\/p>\n

Schenck v. Pro-Choice Network of Western New York. 519 U.S. 357 (1997) ……… 4<\/p>\n

Southeastern Promotions Ltd. v. Conrad, 420 U.S. 546 (1979) ………………………… 10<\/p>\n

Tory v. Cochran, 544 U.S. 734 (2005) ……………………………………………………………. 5<\/p>\n

U.S. v. Alaboud, 347 F.3d 1293 (11th Cir. 2003) ………………………………………………. 8<\/p>\n

.<\/p>\n

Statutes<\/strong><\/p>\n

Communications Decency Act of 1996 (CDA) …………………………………………………. 9<\/p>\n

.<\/p>\n

Other Authorities<\/strong><\/p>\n

“Doxing”<\/em> https:\/\/en.wikipedia.org\/wiki\/Doxing ……………………………………………. 6<\/p>\n

\u201cSocial Shaming Works Faster Than Legal Recourse\u201d<\/em>
\nhttps:\/\/www.techdirt.com\/articles\/20120730\/07105419881\/social-shaming\u00ad-works-faster-than-legal-recourse.shtml ………………………………………………………… 7<\/p>\n

\u201cWhy Social-Media Shaming is Okay\u201d<\/em>
\nhttp:\/\/www.buzzfeed.com\/mattbuchanan\/why-social-media-shaming-is-okay ….. 7<\/p>\n

.<\/p>\n

.<\/p>\n

PRELIMINARY STATEMENT<\/strong><\/p>\n

This supplemental brief is submitted by Appellant in response to the Supplemental Amicus Curiae Brief of Timothy B. McCormack, filed in support of Appellee.<\/p>\n

.<\/p>\n

DISCUSSION OF FACTS<\/strong><\/p>\n

The Supplemental Amicus Curiae Brief (referred to hereafter as \u201cSACB\u201d) attempts to paint the few Internet posts involved in this case as \u201ctrue threats\u201d in order to have the Lifetime Protective Order survive the strict scrutiny analysis required of content-based restrictions on speech. The only way the SACB can do that is by mischaracterization of the facts in the record and mischaracterization of Appellant\u2019s argument. Appellant will highlight some of those factual mischaracterizations in this section.<\/p>\n

(A) On page 8 of the SACB, the Appellant is accused of cyber-bullying\u00a0 Appellee\u2019s daughter when the only post about Appellee\u2019s daughter was \u201cMEE, museum\u201d -her initials and her workplace. T. at pages 53 and 66;<\/p>\n

(B) On page 10 of the SACB, one of the purported threats was characterized as a \u201cransom note\u201d when the only evidence of the purported note was Appellee\u2019s uncorroborated testimony that she \u201creceived a letter from [ELI], which I am currently trying to locate so I can honestly say yes, I have been notified with a ransom note type letter.\u201d (T. at page 62). No such note is in the record.<\/p>\n

(C)\u00a0 The SACB, on pages 10-11, then lists other purported threats contained on ELI but not the context in which they were made or that, as Appellant testified, they were just \u201cfigurative\u201d speech (T. at pages 21-24).\u00a0 Appellant\u2019s Brief and Supplemental Brief in Response to the Amicus Brief analyze and discuss these posts in detail.<\/p>\n

.<\/p>\n

ARGUMENT AND CITATION OF AUTHORITIES<\/strong><\/p>\n

.<\/p>\n

A.\u00a0 THE US SUPREME COURT HAS ANALYZED CIVIL INJUNCTIONS BETWEEN PRIVATE LITIGANTS AS PRIOR RESTRAINTS ON SPEECH<\/strong><\/p>\n

The SACB argues that the First Amendment is not implicated in this case as the order does not qualify as \u201cState action\u201d because it only deals with the rights of private parties.<\/p>\n

Since Near v. Minnesota ex rel. Olson, 283 U.S. 697 (1931), the United States Supreme Court has evaluated injunctions against speech as prior restraints. In Austin v. Keefe, 402 U.S. 415 (1971), the Court struck down a preliminary injunction granted in a civil action between private parties for violating the First Amendment.\u00a0 The order banned a community organization from distributing leaflets in a Chicago suburb which were critical of a real estate agent\u2019s business practices.<\/p>\n

In overturning the order, the Court stated that it was not important that the matter was between two private parties because the order served to stop the dissemination of information to the general public. Id. at 418-419. The Supreme Court stated that it was also irrelevant that the community organization\u2019s primary motive was \u201cnot to inform the public but to force the respondent to sign a no-solicitation agreement.\u201d Id. at 419.\u00a0 Justice Burger, writing for the majority, used language that could not be more applicable to the case at bar had it been written by Appellant instead:<\/p>\n

The claim that the expressions were intended to exercise a coercive impact on respondent does not remove them from the reach of the First Amendment. Petitioners plainly intended to influence respondent’s conduct by their activities; this is not fundamentally different from the function of a newspaper. Petitioners were engaged openly and vigorously in making the public aware of respondent’s real estate practices. Those practices were offensive to them, as the views and practices of petitioners are no doubt offensive to others. But so long as the means are peaceful, the communication need not meet standards of acceptability. <\/em><\/p>\n

Id. (internal citation omitted).<\/em><\/p>\n

Much of the Supreme Court\u2019s First Amendment jurisprudence regarding abortion clinic buffer zones also has been the result of analyzing injunctions sought by and\/or levied against private parties. See, e.g., Schenck v. Pro-Choice Network of Western New York. 519 U.S. 357 (1997); Madsen v. Women\u2019s Health Center, Inc., 512 U.S. 753 (1994).<\/p>\n

The SACB cites only one case for its proposition that an injunction between private parties cannot invoke State action sufficient to warrant First Amendment scrutiny, McGuire v. Reilly, 386 F.3d 45 (1st Cir. 2004)(an abortion clinic buffer case as well).\u00a0 While McGuire did state that every First Amendment claim requires State action, the court also stated that \u201cenforcement [of a content-neutral statute] against a given person in a particular situation could be invalid on an as-applied basis.\u201d Id. at pg. 59. That is what Appellant is arguing here. There is also State action here as the court below required Appellant to remove all posts about Appellee, even though that was not the relief Appellee was seeking before the court (T. at pages 84-86)(Appellee\u2019s counsel stating they do not want entire forum taken down just alleged threats).<\/p>\n

In another case directly on point, the United States Supreme Court held that a civil injunction issued against protests outside a lawyer\u2019s office was an unconstitutional infringement of the protesters\u2019 First Amendment rights. Tory v. Cochran, 544 U.S. 734 (2005).\u00a0 Moreover, the Tory court held that a \u201cperson subject to a court’s injunction may elect whether to challenge the constitutional validity of the injunction when it is issued, or to reserve that claim until a violation of the injunction is charged as a contempt of court.\u201d Id. at 737. Here, Appellant has chosen to challenge the injunction against his speech upon its issuance and not wait to be held in contempt of court.
\nThere is also State action here as the court required Appellant to remove all posts about Appellee, even though that was not the relief Appellee was seeking before the court (T. at pages 84-86)(Appellee\u2019s counsel stating they do not want entire forum taken down just alleged threats).<\/p>\n

.<\/p>\n

B. BECAUSE APPELLANT\u2019S POSTS ARE NOT \u201cTRUE THREATS\u201d THEY ARE PROTECTED BY FEDERAL LAW AND WERE THE SUBJECT OF AN OVERLY BROAD RESTRICTIVE ORDER<\/strong><\/p>\n

The SACB next analyzes Appellant\u2019s posts and the posts of others on ELI as \u201ctrue threats.\u201d Rather than repeat Appellant\u2019s response to the original Amicus Brief filed on behalf of Appellee, Appellant refers the court to the Amicus Brief filed in Support of Appellant and to the Appellant\u2019s Supplemental Brief in Response to the Amicus Brief on behalf of Appellee.<\/p>\n

The SACB relies heavily on Appellee\u2019s subjective statement that she was reasonably placed in fear of her life but recognizes that it is Appellant\u2019s intent to intimidate and create fear that causes [his posts] to lack First Amendment protection.<\/em>\u00a0 SACB at page 17 (emphasis added). There was no evidence, however, that Appellant intended to place Appellee in fear of her life; all the evidence pointed to the opposite \u2013 that Appellant was discussing Appellee\u2019s business practices and wanted to publicly embarrass and expose her for engaging in them.<\/p>\n

At worst, Appellant was engaging in a relatively new Internet phenomenon called \u201cdoxing.\u201d Internet encyclopedia Wikipedia defines the term as follows:<\/p>\n

Doxing (spelling variant doxxing) is an abbreviation of document tracing, the Internet-based practice of researching and publishing personally identifiable information about an individual. The methods employed in pursuit of this <\/em>information range from searching publicly available databases and social media websites like Facebook, to hacking, and social engineering. <\/em><\/p>\n

https:\/\/en.wikipedia.org\/wiki\/Doxing<\/em><\/p>\n

A prominent recent example of \u201cdoxing\u201d occurred when journalists with the Westchester County, New York newspaper, The Journal News, were accused of publishing the home addresses of gun owners in the region in a story the paper published in December 2012.\u00a0 While \u201cdoxing\u201d can often involve illegal hacking to retrieve the information posted, in Appellant\u2019s case, all the information was publicly available and there was no hacking or even allegations of hacking.<\/p>\n

Doxing is one form of \u201csocial shaming\u201d another Internet phenomenon that uses social media to expose conduct that the poster of the information believes to be immoral, illegal or worthy of contempt. See, e.g., \u201cSocial Shaming Works Faster Than Legal Recourse\u201d<\/em> published on TechDirt.com on July 30, 2012 and available at https:\/\/www.techdirt.com\/articles\/20120730\/07105419881\/social\u00adshaming-works-faster-than-legal-recourse.shtml; \u201cWhy Social-Media Shaming is Okay\u201d<\/em> published on BuzzFeed.com on November 13, 2012 and available at http:\/\/www.buzzfeed.com\/mattbuchanan\/why-social-media-shaming-is-okay.<\/p>\n

The trial court even stated as part of its basis in granting the Lifetime Protective Order that the Appellant\u2019s purpose was to intimidate Appellee about her copyright infringement program. At pages 122-123 in the transcript, the court states:<\/p>\n

There’s no question that The Dash is a constitutionally-copyrighted document, and the illegal use of –a violation of the copyright certainly gives her the right to enforce all the copyright infringement laws, and that is not a grounds or basis to give the Respondent in this case the constitutional right to use the website to intimidate her, which he says has been his intent. <\/em><\/p>\n

T. at pages 122-123.<\/em><\/p>\n

While Appellant denies that the record supports a finding that it was his intent to intimidate Appellee, even were that the case, such conduct may be immoral but it is not illegal or even outside the confines of Constitutionally-protected speech. It cannot constitute \u201cstalking\u201d under the statute as the intent must be to place someone in fear of physical harm. There is simply no evidence that this was Appellant\u2019s intent.<\/p>\n

The Eleventh Circuit also requires that true threats be \u201ca serious expression of an intention to inflict bodily harm.\u201d U.S. v. Alaboud, 347 F.3d 1293 (11th Cir. 2003). There was no evidence that these posts constituted a serious expression of an intention to inflict bodily harm or that it was Appellant; intent to make Appellee fear bodily harm.<\/p>\n

.<\/p>\n

C. APPELLANT HAS NOT WAIVED HIS RIGHTS<\/strong><\/p>\n

The SACB then presents the circular argument that because Appellant was \u201cconvicted of stalking\u201d he \u201chas waived his First Amendment protections of such activity.\u201d Appellant was not convicted of stalking as he never faced any criminal charges.\u00a0 Secondly, Appellant is appealing the order restricting his speech on First Amendment grounds, so he has not waived those rights. That is one of the main purposes of the appeal -to determine if the order amounts to an improper restraint on Appellant\u2019s First Amendment rights. This position of Amicus for Appellee further demonstrates that the Lifetime Protective Order is a prior restraint on speech.<\/p>\n

.<\/p>\n

D. THE COMMUNICATIONS DECENCY ACT MAKES APPELLANT IMMUNE FROM LIABILITY FOR POSTS MADE BY OTHERS<\/strong><\/p>\n

The SACB raises the argument that because Appellant commented on some of the posts made by others, Appellant cannot claim the immunity provided by the Communications Decency Act of 1996 (CDA).<\/p>\n

This issue is fully briefed in the Appellant\u2019s Brief and Reply Brief; the Appellant\u2019s Supplemental Brief in Response to Amicus Curiae Brief on Behalf of Appellee; Appellant\u2019s Supplemental Brief regarding recent case law in this arena; and in the Amicus Curiae Brief filed in Support of Appellant.<\/p>\n

To summarize, the Appellant did not actively participate in illegal conduct like the defendant in Fair Housing Council of San Fernando Valley v. Roomates.com<\/em>, 521 F.3d 1157 (9th Cir. 2008) (creating online questionnaire to help users violate the Fair Housing Act) or actively participate in posting allegedly defamatory content about a person like the defendant in\u00a0 Jones v. Dirty World Entertainment Recordings, LLC<\/em>. 840 F. Supp 2d 1008 (ED Ky. 2012) (website allegedly posted libelous and defamatory content about schoolteacher). Instead, the Appellant\u2019s case fits squarely in the protection afforded by the CDA: He is a provider of an interactive computer service being treated as a speaker for the content posted by another speaker.<\/p>\n

.<\/p>\n

E. THAT APPELLANT CAN POSSIBLY SPEAK ABOUT APPELLEE ON OTHER OUTLETS HAS NO BEARING ON WHETHER THIS ORDER IS CONSTITUTIONAL<\/strong><\/p>\n

The SACB makes the argument that there may be other outlets on which Appellant can talk about Appellee and that therefore the order is narrowly tailored and not overbroad. The SACB, however, makes no argument why this speech would not violate the Lifetime Protective Order which required Appellant to remove \u201call posts\u201d about Appellee regardless of their content. The SACB even contradicts its position that Appellant is free to discuss Appellee anywhere else but ELI when it claims that Appellant has \u201cmoved the Ellis content to another website.\u201d Not only does the SACB offer no proof of this alleged fact but it immediately states thereafter \u201cWhether this activity violates the Protective Order has not been litigated yet.\u201d SACB at page 24 fn 1. This statement alone reflects the chilling effect and prior restraint on speech that the Protective Order has had and will have on Appellant\u2019s right to free speech.<\/p>\n

The US Supreme Court has long-ago decided that whether the speaker has another alternative outlet for their speech is not relevant to First Amendment analysis. See, e.g. Southeastern Promotions Ltd. v. Conrad, 420 U.S. 546 (1979)(municipal theater\u2019s ban on play was impermissible prior restraint even though play could be performed elsewhere).<\/p>\n

As the Court stated in that case \u201cOne is not to have the exercise of his liberty of expression in appropriate places abridged on the plea that it may be exercised in some other place.\u201d Id.<\/p>\n

.<\/p>\n

IV. CONCLUSION<\/strong><\/p>\n

The Supplemental Amicus Brief on Behalf of Appellee does not bring to the court\u2019s attention any arguments that support or justify the broadly restrictive order below. The PPO must be reversed.<\/p>\n

Dated:\u00a0 September 25, 2014<\/p>\n

.<\/p>\n

\/S\/ Oscar Michelen<\/span>
\nOscar Michelen
\nNY State Bar No.: 2058477
\nCUOMO LLC
\n9 East 38th Street
\nNew York, NY 10016<\/p>\n

\/S\/ William J. McKenney<\/span>
\nWilliam J. McKenney
\nGA State Bar No.: 494725
\nMCKENNEY & FROEHLICH
\n50 Polk Street NW
\nMarietta, GA 30064<\/p>\n

.<\/p>\n

.<\/p>\n

CERTIFICATE OF SERVICE<\/strong> <\/span><\/p>\n

This is to certify that in accordance with Georgia Supreme Court Rule 14, I have on this day served this Supplemental Brief of Appellant in Response to Second Amicus Curiae Brief of Timothy B. McCormack before filing with the Court by mailing a copy of same to the opposing counsel listed below in a properly addressed envelope with adequate postage:<\/p>\n

Page, Scrantom, Sprouse, Tucker, Ford
\nAttorneys for Appellee
\n1111 Bay Avenue
\nThird Floor
\nColumbus, GA 31901<\/p>\n

Mr. Timothy B. McCormack
\nAmicus Filer on Behalf of Appellee
\n167 Lee Street
\nSeattle, WA 98109<\/p>\n

This 25th day of September 2014<\/p>\n

\/s\/ Oscar Michelen<\/span>
\nOscar Michelen
\nGeorgia Bar No.: H10048
\nCuomo LLC
\nAttorneys for Appellant
\n9 East 38th Street
\nThird Floor
\nNew York, NY 10016
\n(212) 448-9933<\/p>\n","protected":false},"excerpt":{"rendered":"

IN THE SUPREME COURT OF THE STATE OF GEORGIA Case No.: S14A1652 Lower Court No.: SU13DM409 MATTHEW CHAN, Appellant -against- LINDA ELLIS, Appellee . SUPPLEMENTAL BRIEF OF APPELLANT IN RESPONSE TO SECOND AMICUS CURIAE BRIEF OF TIMOTHY B. MCCORMACK . Respectfully Submitted, Oscar Michelen (Courtesy Admission) NY State Bar No.: 2058477 CUOMO LLC 9 East […]<\/p>\n","protected":false},"author":1,"featured_media":157,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":true,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_feature_clip_id":0,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","default_image_id":0,"font":"","enabled":false},"version":2},"jetpack_post_was_ever_published":false},"categories":[67],"tags":[44,133,23,68,49,143,29,21,72,134,102,41,135],"class_list":["post-366","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-chan-v-ellis-appeal","tag-amicus-brief","tag-doxing","tag-extortionletterinfo","tag-first-amendment-2","tag-georgia-supreme-court","tag-internet-free-speech","tag-linda-ellis","tag-matthew-chan","tag-prior-restraint-abuse","tag-social-shaming","tag-supplemental-brief","tag-timothy-b-mccormack","tag-true-threats","has-post-title","has-post-date","has-post-category","has-post-tag","has-post-comment","has-post-author",""],"jetpack_publicize_connections":[],"jetpack_featured_media_url":"https:\/\/defiantly.net\/wp-content\/uploads\/2014\/09\/ga-supreme-court-150px.jpg","jetpack_sharing_enabled":true,"jetpack_shortlink":"https:\/\/wp.me\/p4xEap-5U","builder_content":"","_links":{"self":[{"href":"https:\/\/defiantly.net\/index.php?rest_route=\/wp\/v2\/posts\/366","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/defiantly.net\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/defiantly.net\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/defiantly.net\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/defiantly.net\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=366"}],"version-history":[{"count":1,"href":"https:\/\/defiantly.net\/index.php?rest_route=\/wp\/v2\/posts\/366\/revisions"}],"predecessor-version":[{"id":2725,"href":"https:\/\/defiantly.net\/index.php?rest_route=\/wp\/v2\/posts\/366\/revisions\/2725"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/defiantly.net\/index.php?rest_route=\/wp\/v2\/media\/157"}],"wp:attachment":[{"href":"https:\/\/defiantly.net\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=366"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/defiantly.net\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=366"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/defiantly.net\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=366"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}