Defendants bring the following Counter-Complaints: 1) extortion in violation of 18 U.S.C. § 876 by attempting to defraud and/or extort money through a settlement scam via a mass mailing scheme, 2) conspiracy to extort in violation of 18 U.S.C. §876, 3) racketeering through a “settlement scam” in violation of RICO, 18 U.S.C. § 1962, 4) deceptive trade practices violation of the Michigan Consumer Protection Act, and 5) fraud and misrepresentation regarding DirecTV’s statements that smartcard technology is illegal to purchase and possess. Exhibit 1: Demand letter notifying recipient that “DirecTV recently obtained evidence demonstrating that [recipient’s] client purchased and used an illegal signal theft device” to pirate DirecTV. The letter urges a settlement payment. Exhibit 2: Employment ad posted at www.waspc.org/employment/erp.html. Advertises a DirecTV End-user Recovery Project investigator position to retired or experienced law enforcement. The job summary and method describe the End-User Campaign’s tactics in “go[ing] after the end-users.” Exhibit 3: Copy of a corporate registration search showing the “End User Recovery Project, LLC” listing.