Ellis campaign: Lightner stole website, infringed copyright

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From: Taylor Bloom, Ray Ellis for San Diego Council 2016

To: Bruce Lightner


Re: Unauthorized Exploitation of Intellectual Property and Copyright Infringement

Dear Mr. Lightner:

I represent Ray Ellis in his campaign for San Diego City Council, District 1. This letter concerns your misappropriation of my client’s intellectual property for use on your campaign website. Please direct all future correspondence concerning this matter to my attention.

The Ray Ellis for Council 2016 campaign has a website at http://www.ellisforcouncil.com (the “Ellis website”). We have recently become aware that the content and code of the Ellis website, which was created and paid for by the Ellis campaign, has been misappropriated and appears on the website for Bruce Lightner for District 1 (http://www.brucelightner.org) (the “Lightner website”). The Ellis campaign hired a website designer to develop a unique campaign website for Mr. Ellis. The Ellis website was paid for by the Ray Ellis for Council 2016 campaign and is customized with features that signify the owner of the underlying code.

Federal copyright infringement is blatantly apparent when comparing the underlying code and content of the Lightner website with that of the Ellis website.

You stole the code and content from the Ellis website and used it to create the Lightner website. When conducting a side-by-side comparison of the Ellis and Lightner Ray Ellis for Council 2016 websites, they are nearly identical in appearance, content, design, layout, and overall outlook. Further, the underlying CSS and HTML of the two websites is nearly identical and code containing identifying information unique to the Ellis website is present in numerous places on the Lightner website. This proves beyond doubt that the content and code on the Lightner website was misappropriated from the Ellis website.

The Ellis website has a link to the Facebook page for Ray Ellis’ District 1 campaign and the unique Facebook Identification number assigned to the Ray Ellis for District 1 Facebook page is included in the underlying code on the Ellis website. The code on the Lightner website contains this unique Facebook Identification number assigned to the Ray Ellis for District 1 Facebook page. The inclusion of the Ellis unique identification number in the Lightner code is evidence enough to support a federal copyright infringement claim.

Differential testing
To confirm that the content and code of the Lightner website was taken from the Ellis website, a differential assessment was conducted. A differential assessment is a tool that can be used to compare two versions of the same webpage to see the differences between the two. This is a vital tool for programmers to use to debug their software and see who changed what code and when. For example, a common question answered by differential tests is “This code used to work, but now it doesn’t. What was changed?”

Before discussing the changes found by the differential test ran on the Ellis and Lightner websites, it is important to note the fact that the test was even possible to run on these two websites is undeniable evidence that these two HTML files are simply two versions of the same file (the first being Ray Ellis’ original website, the second being the copied and pasted version that you published under your own name). To illustrate, if I run a differential test on the homepage for Google and the homepage for Facebook, the test will fail, as those two websites have no overlap whatsoever. The Ellis website contains 1,081 lines of code, and the differential test run on the Ellis and Lightner websites only uncovered 66 changes to Ellis’ original codebase. All of these changes are minor content changes to names and images.

There is no possible explanation for the overwhelming similarities between the Ellis and Lightner websites, other than the Lightner website was copied and pasted from the Ellis website. This is blatant intellectual property infringement.

Class names
The Ellis website contains unique class names that indicate who created the underlying code and content. These class names begin with the name of the Ellis website’s designer, Efund. The class names located in the Lightner website begin with the name of the website designer Efund. Efund has confirmed that it was never hired by the Lightner campaign to develop a campaign website and has no relationship to the Lightner campaign whatsoever. The presence of the class name of the designer who was paid by the Ellis campaign to create the Ellis website on the Lightner website is evidence enough to support a federal copyright infringement claim.

Thus, as the overwhelming evidence described above shows, you have violated the intellectual property rights of the Ellis campaign. We request that the Bruce Lightner for District 1 website be taken down within 72 hours or we will be forced to take further legal action. Should you wish to discuss this matter further please feel free to contact me.


Taylor A. Bloom, Esq.

cc: Tony Manolatos, Ray Ellis


Comments 7

  1. If these allegations are accurate, Lightner has incredible nerve. The leftists in San Diego think they can get away with anything. Good for Ray Ellis for calling Lightner on this cute little trick.

    This is only the opening shot in what will be a knock down, drag out fight for control of the City Council. It will only get worse.

    Democrat thug tactics are the norm in San Diego. Look what they did to CD in his Mayoral and Representative campaigns, Scott Peters “magically” coming into possession of his campaign strategy book, and Scott Peters “allegedly” getting a fired staffer to accuse CD of sexual harassment (which was later proved false).

    Watch out Ray. The long knives are out.

  2. Conspiracy theories aside, I am a Republican, and always have been.

    On Monday I received a “lawyer letter” email—no doubt paid for by Rays’ campaign manager(?) Tony Manolatos (http://tinyurl.com/jffymqb). Note the “cc” block in the letter.

    Anyway, Monday evening after my “real” work was done I took a couple of hours and rewrote the mechanisms behind the “look and feel” part of my single parody Web page from scratch. Tony is probably still upset, but there’s nothing left to complain about legally.

    In layman’s terms Tony’s intellectual property attorney didn’t like three things:

    (1) The fact that I had a link to this (obnoxious) 1×1 pixel Facebook “tracking” image…


    Don’t click on it or Tony will surely know! 🙂

    (2) That I used the following variables, beginning with “efund”, in my HTML code…


    I’m told that they actually have no claim to that, but I changed all 9 names in my HTML code anyway.

    (3) I was using the “copyrighted”, automatically-generated HTML code from their “rented” Adobe Muse Webpage generation software—basically “human unreadable” code which embodies the “look and feel” of the Webpage. This HTML code is not longer in use.

    BTW: The Ray Ellis Webpage that I used to insert photos of me, Sherri, my kids and dog in place of Ray’s was not copyrighted at the time that I did that. Look here on the “Wayback Machine” from March 5th…


    As far as I’m concerned this matter is resolved. I took action within 12 hours after someone with Ray’s campaign actually asked me to change the Webpage.

    As someone with 33 granted U.S. Patents (and counting) I know what “intellectual property” is—and it’s not Ray’s Website! 🙂

    Can we talk about something that actually matters to San Diego’s taxpayers now?

    Be sure to visit my Website at http://www.brucelightner.org/ and see for yourself what’s there.

    Best regards,


  3. Just for the record: Bruce Lightner is not a Democrat, in fact he is not even a liberal, and his wife took his family name, not the other way around.

  4. Bruce: I and many others can’t help thinking you and Sherri’s staffer, Kyle Heiskala entered the race at a very late date solely as an unkind trick to split the vote and force Ray Ellis into a needless run-off.

    If you are a real Republican and want to help fight for conservative principles, why don’t you drop out and support Ray in his fight against Barbara Bry for the City Council seat? Nobody can match Ray’s record of public service for great organizations like Second Chance that give people who made a mistake, a real chance at success in life. As you know, Ray is the real deal.

    Don’t let the Democrats use you. In the meantime, get to know and support the local Republicans by coming to the monthly meetings, joining a Republican donor club and getting a ticket for the Lincoln Reagan Dinner on March 26.

    Ray and the other Republicans support fixing the streets in San Diego, supporting small businesses by drastically reducing regulations, and saving money for the citizens of San Diego by supporting Prop. B, the sensible pension reform. Help us to help the citizens of San Diego. We welcome you to actively participate in the local Republican Party but do it the right way.

  5. Hypocrisy: Bruce’s lack of an answer speaks volumes. So as thought, his running for the City Council seat is only a cynical attempt to preserve the leftists 5-4 majority on the City Council. Sadly, a Republican in name only (a RINO).

  6. Dan,

    You may be right, but I assume that Ray Ellis should be able to get a majority of the votes when most people vote which will be in November. Shouldn’t the best candidate be able to earn the support of the majority of all registered voters?

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