govinfo:USCOURTS-ncmd-1_25-cv-00782-0

IN THE UNITED STATES DISTRICT COURT 
FOR THE MIDDLE DISTRICT OF NORTH CAROLINA 
 
JAMES CURTIN, ) 
 ) 
 Plaintiff, ) 
 ) 
v. ) 1:25CV782 
 ) 
CHUCK WATTS, et al., ) 
 ) 
 Defendants. ) 
 
MEMORANDUM OPINION AND ORDER 
THOMAS D. SCHROEDER, District Judge. 
In this case, Plaintiff James Curtin, who proceeds pro se, 
asserts claims against Defendants Chuck Watts (“Watts”), his law 
firm, Watts Law PLC (“Watts Law”)1, Cyberlux Corporation 
(“Cyberlux”), and HII Mission Technologies Corporation (“HII”), 
alleging various acts of misconduct relating to federal defense 
contracts, as well as a conspiracy to retaliate against Curtin for 
exposing the alleged misconduct on his blog. Before the court are 
motions by Defendants HII (Doc. 20), Watts (Doc. 32), and Cyberlux 
(Doc. 44) to dismiss the claims against them in the amended 
complaint (Doc. 7)(the “complaint”) pursuant to Federal Rules of 
Civil Procedure 12(b)(1) and (6). All three motions are fully 
briefed and ready for decision. (Docs. 21, 29, 34; Docs. 32, 35, 
40; Docs. 45, 48, 51.) For the reasons set forth below, the 
 
1 The complaint does not allege any conduct by Watts Law separate from 
Watts. Therefore, the court will construe Watts ’s pro se motion to 
dismiss (Doc. 32) as a motion on behalf of both Watts and Watts Law. 

2 
 
motions will be granted and the complaint dismissed. 
I. BACKGROUND 
The well-pleaded allegations in the complaint, viewed in the 
light most favorable to Curtin as the non-moving party, show the 
following: 
 Curtin is the owner and principal of Carotank Road Holdings 
Inc, a Virginia corporation engaged in consulting and technology 
development, as well as an author publishing under the pen name 
“Jackson Holt.” (Doc. 7 at 6.) In 2023, executives of Defendant 
Cyberlux approached Curtin “for joint ventures and technical 
partnerships involving one of [Curtin’s] clients.” (Id. at 10.) 
While conducting diligence on Cyberlux for his client, Curtin 
uncovered “legal, regulatory, and financial red flags including 
judgments, liens, lawsuits, and questionable public 
representations.” (Id.) Curtin communicated his findings to his 
client as well as Cyberlux executive Bill Maadarani and Cyberlux 
principal Denis Kalenja.2 (Id.) In November 2024, Curtin began 
publishing a series of articles under his “Jackson Holt” alias, 
accusing Cyberlux of “compliance irregularities” and misuse of 
foreign military financing (“FMF”) funds. (Id. at 8.) 
Curtin alleges that he “observed an individual photographing 
him” On May 10, 2025, around the same time that he received a 
 
2 Neither Kalenja nor Maadarani is named as a D efendant in the present 
action. 

3 
 
message from Maadarani. (Id. at 11.) On May 27, 2025, an anonymous 
X (formerly Twitter) account published tweets “doxxing and 
harassing [Curtin] and his family” as well as “referencing 
investigators”, once again around the same time that he received 
a message from Maadarani. (Id.) In June 2025, Maadarani contacted 
one of Curtin’s clients. (Id.) Curtin alleges without elaboration 
that in May 2025 and June 2025, “[m]ultiple partners withdrew from 
negotiations or cancelled deals [presumably with Curtin’s company] 
tied to the harassment campaign [against him].” (Id.) 
 Based on the foregoing, Curtin asserts claims against 
Defendants Cyberlux, Watts, and Watts Law for “tortious 
interference with business expectancy” (Count 1) and civil 
conspiracy (Count 2), claims against all Defendants for “breach of 
fiduciary duty/misuse of public office” (Count 3), and claims 
against HII and Cyberlux for negligent supervision (Count 4). 
II. ANALYSIS 
Federal Rule of Civil Procedure 8(a)(2) provides that a 
complaint must contain “a short and plain statement of the claim 
showing that the pleader is entitled to relief.” Fed. R. Civ. P. 
(8)(a)(2). Under Federal Rule of Civil Procedure 12(b)(6), “a 
complaint must contain sufficient factual matter . . . to ‘state 
a claim to relief that is plausible on its face.’” Ashcroft v. 
Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. 
v. Twombly, 550 U.S. 544, 570, (2007)). A claim is plausible “when 

4 
 
the plaintiff pleads factual content that allows the court to draw 
the reasonable inference that the defendant is liable for the 
misconduct alleged.” Id. In considering a Rule 12(b)(6) motion, 
a court “must accept as true all of the factual allegations 
contained in the complaint,” Erickson v. Pardus, 551 U.S. 89, 94 
(2007) (per curiam), and all reasonable inferences must be drawn 
in the plaintiff’s favor, Ibarra v. United States, 120 F.3d 472, 
474 (4th Cir. 1997). However, mere legal conclusions are not 
accepted as true, and “[t]hreadbare recitals of the elements of a 
cause of action, supported by mere conclusory statements, do not 
suffice.” Iqbal, 556 U.S. at 678. 
 “[D]etermining whether a complaint states a plausible claim 
for relief is a ‘context-specific task.’ ” Langford v. Joyner, 62 
F.4th 122, 126 (4th Cir. 2023) (quoting Iqbal, 556 U.S. at 679). 
There is no categorical rule that a complaint cannot make 
allegations collectively against multiple defendants. Id. 
However, if a plaintiff employs a “global manner of pleading,” he 
must still allege “sufficient facts to allow the court to infer 
liability as to each defendant.” Id. (internal citations omitted). 
Defendants have identified myriad problems with Curtin’s 
lawsuit. Relevant to the motions to dismiss, Curtin’s complaint 
fails to state a claim because the federal statutory violations he 
alleges do not give rise to a private right of action, he has not 
alleged any legally cognizable duty that the Defendants breached, 

5 
 
and his claims are not otherwise cognizable under Virginia law. 
A. No Federal Private Right of Action 
HII, Cyberlux, and Watts all argue that Curtin’s claims rest 
on federal statutes that do not create a private right of action.3 
(Doc. 21 at 8-9; Doc. 45 at 11-15; Doc. 32 at 2-3.) In Count 1, 
Curtin alleges that Defendants Watts and Cyberlux violated 18 
U.S.C. §§ 2261A, 875(c)¸and 1030 in a way that interfered with his 
“business expectancy.” (Doc. 7 at 15.) In Count 2, he alleges 
that Watts and Cyberlux conspired to commit violations of 18 U.S.C. 
§§ 1343, 2261A, 875(c), and 1512. (Id. at 17.) In Count 3, he 
alleges that all Defendants breached “fiduciary duties” in ways 
that implicate 41 U.S.C. § 4712 and 18 U.S.C. §§ 1001 and 1343 as 
well as unspecified “provisions of the [Federal Acquisition 
Regulations (“FAR”)], [Defense Federal Acquisition Regulations 
Supplement (“DFARS”)], and [International Traffic in Arms 
Regulations (“ITAR”)] governing the allowability of costs, ethical 
conduct, and contractor responsibility.” (Id. at 22.). In Count 
4, he likewise alleges that HII and Cyberlux were negligent in 
their supervision of Watts in ways that implicate 41 U.S.C. § 4712, 
18 U.S.C. §§ 1343 and 1512, and “applicable FAR, DFARS, and ITAR 
provisions.” (Id. at 24.) 
 
3 HII and Cyberlux also argue that this deficiency deprives the court of 
subject matter jurisdiction as to Counts 3 and 4. (See Doc. 45 at 13-
15.) However, a statute may support federal question jurisdiction 
without creating a private right of action. See Grable & Sons Metal 
Products, Inc. v. Darue Engineering & Mfg., 545 U.S. 308, 317 (2005). 

6 
 
As Cyberlux notes, none of these federal statutes or 
regulations provides a right of action for plaintiffs in Curtin’s 
position. (Doc. 45 at 11.) As for Defendants’ alleged violations 
of FAR, DFARS, and ITAR, these cannot provide a private right of 
action unsupported by statute. See Alexander v. Sandoval, 532 
U.S. 275, 291 (2001)(“Language in a regulation may invoke a private 
right of action that Congress through statutory text created, but 
it may not create a right that Congress has not.”). Curtin’s 
complaint does not identify which specific regulatory provisions 
Defendants allegedly violated, much less any underlying statutes 
that would authorize him to bring a private suit. As for the 
alleged violations of 18 U.S.C. §§ 2261A, 875(c), 1343, and 1001, 
these are all criminal statues whose enforcement “has been 
entrusted exclusively to the federal government.” State of Ga. v. 
Pennsylvania R. Co., 324 U.S. 439, 447 (1945). 
Only two of the federal statutes cited by Curtin contain any 
private right of action. First, the Computer Fraud and Abuse Act, 
18 U.S.C. § 1030 (the “CFAA”), creates a limited civil cause of 
action, but the plaintiff must plead a qualifying loss “by reason 
of a violation of this section.” See 18 U.S.C. § 1030(g). But as 
Cyberlux notes, Curtin has not alleged any particular violation of 
§ 1030. (Doc. 45 at 12.) Second, 41 U.S.C. § 4172 provides a cause 
of action for employees of government contractors, subcontractors, 
grantees, subgrantees, or personal service contractors who have 

7 
 
suffered retaliation for protected disclosures and exhausted 
administrative remedies. See 41 U.S.C. § 4172(a) and (c)(2). 
Curtin represents in his brief that he filed whistleblower 
disclosures with the General Services Administration and 
Department of Defense in 2024, and that 210 days have elapsed 
without a determination, which he contends “satisf[ies] the 
exhaustion requirement under 41 U.S.C. § 4712.” (Doc. 48 at 11.) 
But as Cyberlux points out, Curtin does not allege that he is or 
ever was an employee of any Defendant, and thus the anti-
retaliation protections of § 4712 simply do not apply to him. 
(Doc. 45 at 14.) 
In sum, Defendants are correct that none of the federal 
statutes or regulations in the complaint provides Curtin with a 
private right of action for his claims. Thus, Defendants’ motion 
to dismiss these claims will be granted. 
B. Failure to State a Claim under Virginia Law 
The court next considers whether Curtin has stated a claim 
under applicable state law. “A federal court sitting in diversity 
is required to apply the substantive law of the forum state, 
including its choice-of-law rules.” Francis v. Allstate Ins. Co., 
709 F.3d 362, 369 (4th Cir. 2013). The Supreme Court of North 
Carolina’s “jurisprudence favors the use of the lex loci test in 
cases involving tort or tort-like claims.” SciGrip, Inc. v. Osae, 
838 S.E.2d 334, 343 (N.C. 2020). Pursuant to the lex loci test, 

8 
 
the court should apply the substantive law of the state “where the 
injury or harm was sustained or 
suffered.” Id. (quoting Harco Nat’l Ins. Co. v. Grant Thornton 
LLP, 698 S.E.2d 719, 724 (N.C. Ct. App. 2010)). HII and Cyberlux 
both contend, and Curtin does not dispute, that Curtin suffered 
his alleged injuries in Virginia, where his company is located. 
(Doc. 21 at 12-13; Doc. 45 at 9 n.8; see Doc. 7 at 4-6.) Thus, 
Virginia substantive law governs his claims. 
1. Tortious Interference (Count 1) 
Watts argues that Count 1 fails to state a claim because the 
complaint fails to allege that he engaged in any conduct that would 
be actionable in Virginia under a recognized theory of tort 
liability. (Doc. 32 at 4-5.) Meanwhile, Cyberlux argues that 
Carotank Road Holdings, Inc., and not Curtin, is the true party in 
interest for this claim.
4 (Doc. 45 at 2.) Responding to Watts, 
Curtin argues that unspecified Cyberlux officers “circulated false 
espionage claims and disclosed [his] private information,” and 
that this occurred “while Watts directed legal affairs,” which he 
contends is sufficient conduct to support tort liability. (Doc. 
35 at 16.) To Cyberlux, Curtin responds that he is willing to 
stipulate to the joinder of Carotank Road Holdings, Inc., but only 
 
4 Curtin’s complaint and accompanying declaration do indeed suggest that 
Carotank Road Holdings, Inc., is the true party in interest for any claim 
pertaining to Curtin’s “business.” (See Doc. 7 at 6; Doc. 7-1.) The 
court need not reach this issue, however, because the claim suffers from 
more fundamental defects. 

9 
 
if certain Cyberlux shareholders will consent to be joined in their 
individual capacities because they “are the company’s largest 
Series B shareholders, control insiders, and beneficiaries of the 
conduct at issue.” (Doc. 48 at 2.) 
In Virginia, the elements of a prima facie case of tortious 
interference with business expectancy are (1) the existence of a 
valid business expectancy; (2) knowledge of the expectancy on the 
part of the interferer; (3) intentional interference inducing or 
causing a breach or termination of the relationship or expectancy; 
and (4) resultant damage to the party whose relationship or 
expectancy has been disrupted. Dunlap v. Cottman Transmission 
Systems, LLC, 754 S.E.2d 313, 318, (Va. 2014). Defendants argue 
that Curtin’s allegations fail to state a plausible claim. (Doc. 
45 at 5-9; Doc. 32 at 4-5.) 
Here, Defendants are correct. While a complaint need not 
make out a prima facie case, it must still “allege facts to satisfy 
the elements of a cause of action.” McCleary-Evans v. Md. Dep't 
of Transp., 780 F.3d 582, 585 (4th Cir. 2015). A “formulaic 
recitation” of the necessary elements does not suffice to render 
a claim plausible. Id. (quoting Iqbal, 556 U.S. at 678–79). 
Here, the complaint fails to state a plausible claim of intentional 
interference. It alleges generally that “Defendants,” acting 
“individually and in concert,” committed the following acts of 
interference: 

10 
 
(a) Public “doxxing” of [Curtin] by releasing personal 
identifying information without consent; 
 
(b) Retaliatory statements; 
 
(c) Direct, inappropriate contact by Cyberlux officer 
Bill Maadarani with one of [Curtin’s] clients, intended 
to disrupt that business relationship; 
 
(d) False accusations and reputational attacks 
communicated to third parties with the intent and 
knowledge they would damage [Curtin’s] credibility; 
[and] 
 
(e) Threats, both explicit and implicit, designed to 
deter third parties from associating with [Curtin.] 
 
(Doc. 7 at 14.) Because Curtin employs a “global manner of 
pleading,” he must allege “sufficient facts to allow the court to 
infer liability as to each defendant.” Langford, 62 F.4th at 126. 
The only conduct attributed to a specific Defendant is the 
“[d]irect, inappropriate contact” between Cyberlux officer 
Maadarani and one of the clients of Curtin’s business (which is 
not a party). But the record is devoid of any facts to support 
the conclusory allegations that this conduct was “inappropriate” 
or “intended to disrupt [Curtin’s] business relationship.” On the 
contrary, the screenshot of the communication (Doc. 7-12), which 
Curtin attached to his complaint,
5 shows that Maadarani was merely 
asking if the client (with whom he was evidently already 
acquainted) knew why Curtin had been posting anonymous criticisms 
 
5 In evaluating a motion to dismiss, the court may consider documents 
attached to the complaint without converting the motion to one for 
summary judgment. Fed. R. Civ .P. 10(c); see Philips v. Pitt Cty. Mem’l 
Hosp., 572 F.3d 176, 180 (4th Cir. 2009). 

11 
 
of Maadarani as “Jackson Holt,” and noting his intention to seek 
legal advice regarding the posts. (See id. at 2.) It does not, 
contrary to Curtin’s allegation, contain anything that could be 
described as a “veiled threat.” (Doc. 7 at 11.) 
Because Curtin’s allegations fail to set forth specific facts 
to support a claim of interference by any Defendant, Count 1 fails 
to plausibly state a claim against any specific Defendant and will 
be dismissed without prejudice. 
2. Civil Conspiracy (Count 2) 
Cyberlux argues that Curtin has failed to state a claim for 
civil conspiracy because he offers only a conclusory allegation 
that the Defendants conspired for purpose of “[i]njuring Plaintiff 
in his business, reputation, and creative work.” (Doc. 45 at 9-
10; see Doc. 7 at 16.) Curtin does not respond to this argument. 
In Virginia, civil conspiracy is a statutory claim that arises 
when “two or more persons . . . combine, associate, agree, mutually 
undertake or concert together . . . for the purpose of willfully 
and maliciously injuring another in his reputation, trade, 
business or profession by any means whatever.” Va. Stat. Ann. 
§§ 18.2-499 and 18.2-500; see Simmons v. Miller, 544 S.E.2d 666, 
676-77 (Va. 2001.) “To recover in a civil conspiracy action both 
under the common law and under Virginia Code § 18.2-499, a 
plaintiff must establish that at least one member of the 
conspiracy, in agreement with another member, committed an act 

12 
 
that was itself wrongful or tortious, and that such act damaged 
the plaintiff.” L-3 Commc'ns Corp. v. Serco, Inc., 926 F.3d 85, 
92 (4th Cir. 2019) (citing Gelber v. Glock, 800 S.E.2d 800, 821 
(Va. 2017)). For a statutory business conspiracy claim, a 
plaintiff must also plausibly allege legal malice, or that one of 
the conspiracy's purposes was to injure “Plaintiff's reputation, 
trade, or business.” Schlegel v. Bank of America, N.A., 505 F. 
Supp. 2d 321, 326 (W.D. Va. 2007) (citing Simmons, 544 S.E.2d at 
677). 
The Federal Rules of Civil Procedure govern the requirements 
for pleading “in all civil actions and proceedings in the United 
States district courts.” Fed. R. Civ. P. 1; see Iqbal, 556 U.S. 
at 684. Rule 9(b) provides that “[m]alice, intent, knowledge, and 
other conditions of a person's mind may be alleged generally.” 
Fed. R. Civ. P. 9(b). However, because a civil conspiracy claim 
in Virginia requires proof of some underlying unlawful conduct, a 
plaintiff must still adequately plead the underlying act or acts. 
Aimbridge Hospitality, LLC v. Provident Group – Radford 
Properties, LLC, No. 7:24-cv-00262, 2024 WL 3534150, at *8 (W.D. 
Va. July 24, 2024). Here, the complaint fails to allege sufficient 
facts to make plausible that any Defendant committed a wrongful or 
tortious act in furtherance of the conspiracy. It alleges that 
undifferentiated “Defendants” engaged in various acts in 
furtherance of the conspiracy, but the only act attributed to a 

13 
 
specific Defendant is the same communication from Count 1 between 
Cyberlux’s Maadarani and the “client” of Curtin’s business. (Doc. 
7 at 16-17.) As discussed above, this communication is innocuous 
on its face. It is not a wrongful or tortious act that can support 
the civil conspiracy claim. Thus, Defendants’ motion will be 
granted and Count 2 will be dismissed without prejudice. 
3. Breach of Fiduciary Duty (Count 3) 
HII, Watts, and Cyberlux all argue that Count 3 must be 
dismissed because Curtin does not allege that Defendants owed any 
fiduciary duty to him specifically. (Doc. 21 at 14-15; Doc. 32 at 
3; Doc. 45 at 10.) In response, Curtin reiterates that Defendants 
had a general duty to comply with federal laws and regulations. 
(Doc. 29 at 8-9.) 
To state a plausible breach of fiduciary duty claim under 
Virginia law, a plaintiff must allege facts to show (1) the 
existence of a fiduciary duty, (2) the breach of that duty, and 
(3) resulting damages. Carstensen v. Chrisland Corp., 442 S.E.2d 
660, 666–67 (Va. 1994); Broadhead v. Watterson, No. 5:15-cv-00020, 
2016 WL 742127, at *6 (W.D. Va. Feb. 24, 2016) (applying Virginia 
law). Here, the complaint alleges that Defendants breached duties 
owing to “the public,” “the U.S. government,” and “foreseeable 
persons impacted by non-compliance” with various federal and state 
laws and regulations. (Doc. 7 at 18-22.) As Cyberlux notes, none 
of these allegations describes a fiduciary duty owed to Curtin. 

14 
 
(Doc. 45 at 10.) Thus, Count 3 fails to state a claim under 
Virginia law, and it will be dismissed. 
4. Negligent Supervision (Count 4) 
As HII and Cyberlux both note, Virginia courts do not 
recognize an independent cause of action for negligent 
supervision. See Elrod v. Busch Entertainment Corp., Nos. 
4:09cv164, 4:09cv165, 4:09cv166, 2010 WL 5620918, at *6 (E.D. Va. 
Dec. 14, 2010) (collecting cases), report and recommendation 
adopted 2011 WL 166636 (E.D. Va. Jan 19, 2011). Curtin appears to 
concede this, as his briefs in opposition do not address the 
negligent supervision claim in Count 4. It will thus be dismissed. 
C. Rule 11(b) and Fabrication of Legal Authority 
Finally, Curtin points to reprimands issued against Cyberlux 
in other litigation, specifically an order to pay attorneys’ fees 
and a show-cause order for fabricating or misrepresenting legal 
authorities. (Doc. 48 at 9.) He contends that Cyberlux has 
engaged in a “persistent pattern of deception and obstruction” 
that undermines Cyberlux's argument that the complaint’s “well-
documented facts” are implausible. (Id.) 
There is a certain irony in all of this. Curtin’s brief 
contains fabricated quotations that directly contradict the actual 
holdings of the cited cases – the same misconduct he invokes to 
discredit Cyberlux. Cyberlux’s conduct has already been addressed 

15 
 
by those courts.6 Meanwhile, this court must address Curtin’s 
conduct in the present case. 
Curtin represents that in Sinochem International Co. Ltd. v. 
Malaysia International Shipping Corp., 549 U.S. 422, 430 (2007), 
the United States Supreme Court held that “[a] court lacking 
jurisdiction . . . must dismiss, it cannot transfer.” (See Doc. 
29 at 7.) This quotation is a fabrication. On the contrary, the 
court in Sinochem reaffirmed that a case may be transferred 
“whether the court in which it was filed had personal jurisdiction 
over the defendants or not.” 549 U.S. at 430 (quoting Goldlawr, 
Inc. v. Heiman, 369 U.S. 463, 466 (1962)). Similarly, in 
Christianson v. Colt Industries Operating Corp., 486 U.S. 800, 817 
(1988), the Supreme Court never stated that a transferee court 
“should not revisit a jurisdictional ruling made by a coordinate 
court unless it is clearly erroneous,” as Curtin represents. (See 
Doc. 29 at 7.) Rather, it noted that a court “has the power to 
revisit prior decisions of its own or of a coordinate court in any 
circumstance, although as a rule courts should be loathe to do so 
in the absence of extraordinary circumstances such as where the 
initial decision was ‘clearly erroneous and would work a manifest 
injustice.’” Christianson, 486 U.S. at 817 (quoting Arizona v. 
 
6 See Atlantic Wave Holdings, LLC v. Cyberlux Corporation, No. 25-1689, 
2025 WL 3493221 (S.D. Tex. May 14, 2025); HII Mission Technologies Corp. 
v. Cyberlux Corp., No. 3:25-cv-483-JAG, Doc. 118 (E.D. Va. December 15, 
2025). 

16 
 
California, 460 U.S. 605, 618, n.8 (1983)). 
All litigants, whether pro se or represented, are bound by 
the Federal Rules of Civil Procedure. See, e.g., McNeil v. United 
States, 508 U.S. 106, 113, (1993); Hansan v. Fairfax Cty. Sch. 
Bd., 405 F. App'x 793, 794 (4th Cir. 2010) (per curiam). 
Rule 11(b)(2) states that by signing a filing, an attorney or 
unrepresented party certifies that, to the best of his knowledge 
and after a reasonable inquiry, “the claims, defenses, and other 
legal contentions are warranted by existing law or by a 
nonfrivolous argument for extending, modifying, or reversing 
existing law or for establishing new law.” The rule permits courts 
to sanction litigants for citations to non-existent case law, 
misrepresentations of case law, or frivolous legal arguments, 
regardless of the filer’s pro se status. See, e.g., Ferris v. 
Amazon.com Services, LLC, 778 F. Supp. 3d 879, 881-82 (N.D. Miss. 
2025) (ordering a pro se plaintiff to pay the defendant’s costs 
incurred in responding to fabricated citations). “Courts across 
the country have issued sanctions against attorneys and pro se 
parties for submitting fictitious case citations, fictitious 
quotations, and related misrepresentations to the court.” United 
States v. Hayes, 763 F. Supp. 3d 1054, 1071 (E.D. Cal. 2025) 
(collecting cases) (emphasis added). 
It is not clear whether Curtin’s complaint and briefs are the 
product of artificial intelligence. To be sure, this court has 

17 
 
seen an uptick in the use of artificial intelligence in complaints 
and briefs, especially by pro se filers. Whether or not Curtin 
used such tools, he is admonished that every filer, including a 
pro se filer, is “obligated to read the legal authority he intends 
to rely upon, confirm its existence and validity, and confirm that 
it supports his legal contentions, before citing to that authority 
in any submission to this Court.” Allen v. Western Governors 
University, No. 2:25-cv-00325-RFB-NJK, 2026 WL 893368, at *1 (D. 
Nev. Mar. 31, 2026). Obviously, Curtin did not do that. Curtin 
is thus warned that any future filings containing fabricated legal 
authority may result in sanctions under Rule 11. 
III. CONCLUSION 
For the reasons stated, therefore, 
IT IS ORDERED that Defendant HII’s motion to dismiss (Doc. 
20) is GRANTED, Defendant Watts’s motion to dismiss (Doc. 32) is 
GRANTED as to both Defendant Watts and co-Defendant Watts Law, and 
Defendant Cyberlux’s motion to dismiss (Doc. 44) is GRANTED, and 
the complaint is dismissed: all claims founded on violation of 
statutes for which the court has held there is no private right of 
action are DISMISSED WITH PREJUDICE, Counts 3 and 4 are DISMISSED 
WITH PREJUDICE, and the remaining claims in Counts 1 and 2 are 
DISMISSED WITHOUT PREJUDICE. 
Curtin is hereby WARNED that any future filings containing 
fabricated legal authority may result in sanctions under Rule 11. 

18 
 
 
 /s/ Thomas D. Schroeder 
 United States District Judge 
May 20, 2026 

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