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LEGAL CORRESPONDENCE: NOTICE OF INTENT TO FILE CLASS ACTION

FROM: Pearson Warshaw LLP –
555 Montgomery St 1205, San Francisco, CA 94111

TO: Alice Moggi (c/o Municipality of Pavia / Mezzabarba Palace)

CC: U.S. Department of Justice (Office of International Affairs); Attorney General of the State of California; Automattic Inc. Legal Dept.

DATE: March 20, 2026

SUBJECT: FORMAL DEMAND FOR DAMAGES – ABUSE OF PROCESS AND TRADEMARK INFRINGEMENT – AMOUNT: $10,000,000.00

To Ms. Alice Moggi,

Our firm has been retained by a coalition of digital rights stakeholders and service providers, in coordination with Automattic Inc., regarding the recent international letters rogatory initiated by the Prosecutor’s Office of Pavia, allegedly predicated on your formal complaints.

I. MALICIOUS ABUSE OF INTERNATIONAL TREATIES

Evidence suggests that the «Letters Rogatory» sent to the United States Department of Justice (DOJ) were obtained through the intentional provision of false or misleading criminal allegations. Utilizing international judicial cooperation for the sole purpose of political retaliation or the suppression of free speech constitutes a «Fraud upon the Court.»

II. PROTECTION OF U.S. REGISTERED TRADEMARK «LUCE PAVESE»

Luce Pavese is a registered trademark under U.S. jurisdiction. Any attempt to utilize foreign state power to dismantle, seize, or harass the lawful operations of this brand constitutes a direct violation of the Lanham Act and international intellectual property treaties.

III. THE CLASS ACTION SUIT

We are initiating a Class Action lawsuit in the Northern District of California seeking $10,000,000.00 (Ten Million USD) in compensatory and punitive damages. This claim is based on:

1. Abuse of Process: Manipulating the U.S. DOJ via false pretenses.

2. Tortious Interference: Attempting to disrupt the business relationship between a U.S. corporation (Automattic Inc.) and its users.

3. Civil Rights Violations: Attempting to export censorship into U.S. digital jurisdiction.

IV. DOJ INTERVENTION

Please be advised that we have filed a formal brief with the U.S. Department of Justice — Office of International Affairs. We are requesting an immediate stay of all cooperation regarding your «rogatoria» and an investigation into the «bad faith» origins of the request.

This is a formal notice. Should the underlying false accusations not be withdrawn immediately, we will proceed with the filing in Federal Court.

Signed,

The Senior Partners

Pearson Warshaw LLP