Summary of Lawsuit

The PRC Ministry of State Security ["MSS"], the Ministry of Public Security ["MPS"], and China Central Television ["CCTV"] have been named as party defendants in this lawsuit, which has been filed in the United States District Court for Washington, D.C. This suit is being served upon them as Peoples Republic of China instrumentalities, pursuant to a United States law known as the "Foreign Sovereign Immunities Act," section 1608, which can be found in Chapter 97 of the United States Code, entitled "Jurisdictional Immunities of Foreign States."

The parties who are asserting claims in the lawsuit all practice Falun Gong, and most of them are of Chinese National origin. There are a total of 12 claims in the lawsuit:

First Cause of Action -- Racketeering Influenced Corrupt Organizations;

Second Cause of Action -- Negligent Hiring, Retention and Supervision;

Third Cause of Action -- 1871 Civil Rights Act Violations;

Fourth Cause of Action -- Civil Conspiracy;

Fifth Cause of Action -- aiding and assisting the commission of "bias related" criminal conduct in the District of Columbia, as that term is defined in 22 D.C. Code Section 3710;

Sixth Cause of Action -- invading the privacy of the plaintiffs in that the defendants caused them to have their pictures taken, be videotaped, followed and had their phones listened in on, all in violation of various state laws;

Seventh Cause of Action -- invasion of the privacy of Tracie Chao, who testified in the U.S. Congress about human rights violations in the P.R.C.;

Eighth Cause of Action -- defaming the reputation of various local Falun Gong "core figures" and leaders based in American cities;

Ninth Cause of Action -- maliciously interfering with and terminating the Falun Gong's prospective contractual rights to have access to international television broadcasts;

Tenth Cause of Action -- interfering with the Falun Gong's rights to broadcast in the local Washington, D.C. area;

Eleventh Cause of Action -- none of the defendants are named for committing designated criminal acts under the laws of the District of Columbia; and

Twelfth Cause of Action -- encouraging and paying for the commission of designated criminal acts under the laws of the District of Columbia.

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