FORTH AMENDED COMPLAINT

FOREWORD ON THE THIRD AMENDED COMPLAINT
The plaintiff Ruggero Maria Santilli, a senior, U. S. scientist acting pro se with curriculum appended in Exhibit A, followed the requests by the Honorable Judge Steven D. Merryday contained in the Order dated January 7, 2008 and filed the Third Amended Complaint before the due date January 25, 2008. Besides the defendants listed in this Forth Amended Complaint, the Third Amended Complaint listed the additional defendants F. Cardone, R. Mignani, A. Marrani, Consiglio Nazionale Ricerche, Universita' di Roma Tre.

2. Subsequently, the Honorable Judge Steven d. Merryday issued an Order to Show Cause dated July 10, 2008. On July 16, 2007, the plaintiff answered by providing diversified evidence that said defendants had indeed been properly and repeatedly served. On july 18, 2008, the Honorable Judge released an order dealing specifically with defendants Cornell University, Istituto nazionale Fisica Nucleare and Universita' dell'Aquila, without any referral to defendants F. Cardone, R. Mignani, A. Marrani, Consiglio Nazionale Ricerche, Universita' di Roma tre, in which Order the Honorable Judge suggested the filing of a Forth Amended Complaint.

3. Because not requested for inclusion in the order dated July 18, 2008, defendants F. Cardone, R. Mignani, A. Marrani, Consiglio Nazionale Ricerche, Universita' di Roma Tre have not been included in this Forth Amended Complaint also to prevent the annulment of the Court Judgment by Default in the plaintiff's favor currently under proceedings. In relation to due process for the above identified five defendants, the plaintiff elects that the Third Amended Complaint is and remains in full force and effect until the release of said Court Judgment by Default. Plaintiff then elects proper action thereafter.

FOREWORD ON THE FORTH AMENDED COMPLAINT
4. This Forth Amended complaint is filed following the Order by the Honorable Judge Steven D. Merryday dated July 18, 2008 in relation to defendant Cornell University (CU). Its president David J. Skorton is added as a defendant in view of its excessive subservience to the alleged wrongdoings perpetrated by his employees, thus allowing sufficient grounds for claims under the Rules of Respondeat Superior and other statutes. In fact, CU would have no longer be listed as a defendant in all compliants, including this forth one, in the event CU electronic archives called arXiv would have allowed the plaintiff to list his paper in the same section in which copyright infringing paper have been easily accepted. All attempts to reach an out of court settlement along thse lines via the intermediary action of CU attorney if the time Bryant BoydStun failed, thus leaving no other option than the recourse at law.

5. Said order dated 18, 2008, dismissed without prejudice defendants Istituto Nazionale Fisica Nucleare (INFN) and Universita' dell'Aquila (QdA) for lack of jurisdiction due to alleged lack of business in the State of Florida. On July 31, 2008, the plaintiff filed a Motion for Reconsideration containing substantial documentary evidence that, contrary to the Affidavits by their presidents, INFN and UdA are indeed substantial business in the State of Florida. hence, this Fourth Amended Complaint is filed by maintaining INFN and UdA as defendants while amending the Complaint so as to identify and include the evidence missing in the Third Complaint.

6. Additionally, Roberto Petronzio president of INFN and Ferdinando di Orio, president of UdA, are added as individual defendants not only because of lies in denying business in the state of Florida, but also because of their excessive subservience to the alleged wrongdoings by their employees. In fact, none of the defendants Roberto Petronzio, INFN, Ferdinando di Orio and UdA would have been listed as defendants in the preceding and in this Forth Amended Complaint in the event they would have merely written a letter to defendants F. Cardone, R. Mignani and A. Marrani calling them to scientific ethics and the implementation of the historical duty of quoting prior directly relevant reference in chronological order, since such a proper quotation would have voided copyright infringements. Lies in their affidavits plus blatant siding for blatantly unethical conduct then left no other choice than to list Roberto Petronzio and Ferdinando di Orio as defendants under the rule of Respondeat Superior and other Statutes.

7. The honorable Judge Steven D. merryday has not yet acted on defendant World Scientific that, consequently, is included as a defendant on this fourth Amended Complaint. Additional, its president K. K. Phua is added as a defendant for evasion of service since he has evaded all servings by local sheriffs to date, thus forcing the serving of the State of Florida and the initiation of separate proceedings for illegal operations in the U.S.A.

8. Since the Forth Amended Complaints has been limited by the Judge's Order to a reduced number of defendants, with consequential reduction of content, in order to avoid un-necessary repetitions and excessive length the plaintiff assumes the Third Amended Complaint as an integral part of and//or complement to this Forth Amended Complaint.

PLAINTIFF'S JURISDICTION
9. As requested by Rule 8(a) of the FRCP, the plaintiff hereby presents a short statement of the grounds for jurisdiction. Rule 28 U.S.C.S. paragraph 1338 states that "the Federal District Court shall have the original jurisdiction of any civil action arising under any act of Congress relating to patents, plant variety protection, copyrights and trademarks..." Hence, the jurisdiction of the U. S. Federal District Court is beyond doubt in this case.

10. The plaintiff is a senior, 72 years old, retired U. S. scientist residing in the town of Palm Harbor, Florida. Hence, the U. S. Federal Court, the Middlesex District in Tampa Florida, is the correct jurisdiction and venue applicable for the plaintiff.

DEFENDANTS JURISDICTION
11. The jurisdiction for the defendant CU has been established in preceding Compliants, particularly in view of vast business conducted in the State of Florida for the recruiting of students, a large number of business collaborations with various universities in Florida and various other evidence the plaintiff reserves the right to document during the discovery process.

12. The plaintiff reaffirms his Constitutional Right to to defend his claims in court; reaffirms the subordinance of the Federal Rules of Civil Procedures to the U. S. Constitution; and recalls the incontrovertible fact that the U. S. Federal Court, the District of Tampa, Florida, is the ONLY court on a world wide basis in which the plaintiff can defend his rights. Hence, the dismissal of INFN and the UdA would constitute an internationally valid authorization and patent of complete impunity by scientists in the world and all related academic and governmental conduits to infringe any and all existing copyright and other laws, with catastrophic consequences for science and mankind.

13. The dominance of the U. S. Constitution over the Federal Rules of Civil Procedure, as well as the local Florida Statute has been rendered much more important by the advent of the internet, to such an extent that said rules are essentially obsolete vis a vis the current way of conducting business so as to verify the requirement for jurisdiction.

14. LONG-ARM STATUTE JURISDICTION. Robert Petronio, in his capacity of president of INFN [Ferdinando di orio, president of UdA] states in his Affidavits (herein attached as Exhibits P and Q) that �INFN [UdA] does not conduct regular routine, or substantial business activity in the state of Florida.� These statements are documented lies.

15. The conduction of vast business by defendants INFN and UdA in the state of Florida is so internationally well known, that the plaintiff felt no need for documentation in the Third Amended Complaint. As a mere indication, the plaintiff attaches in Exhibit R a very small number of documents providing beyond doubt the conduction of business by INFN and UdA in the State of Florida. The plaintiff reserves the right of providing much more documentation during the due discovery process.

16. For example, the INFN is funding the the Gran Sasso Laboratory and the University of Florida is one of the major participant to this project and so is the UdA, as recipient of funds as well (see exhibit R) Additionally the UdA is known to have an international research project and university degree with the collaboration of the University of Miami as per agreement signed precisely by di Orio (see again Exhibit R), thus demonstrating that the statement of the defendant UdA and di Orio are not true .

17. In reality there are pages and pages of documentation of continued, routine business between defendants INFN and the Uda and the State of Florida. They are so many not to require any additional documentation because internationally known and because they would require loads of pages presented to the Court.

18. As a result of the advent of the internet, physics is today a global business for which any exclusion of the State of Florida is equivocal at best, or just flatly immoral. hence, the Affidavits by Petronio and di Orio are a clear reflection of their extremely unethical conduct in denying the plaintiff�s request for intervention with their employees Cardone, Mignani and Marrani to just quote the plaintiff�s directly relevant copyrighted works. To understand the ethical status of Petronio and di Orio, the Honorable Judge Steven D. Merryday should know that Petronio and di Orio denied said plaintiff request under full knowledge that it would have caused the withdrawal of this lawsuit.

19. Independently from the above, it is important to indicate that, when Section 48.19391)(a) was written, the internet did not exist. Hence, at that time, there was the need for physical activity, specifically, in the State of Florida in order to verify said rule. The internet has dramatically and substantially altered this legal scenario since there is no need whatsoever to have an office in Florida to conduct vast business in Florida. One website somewhere in the world is nowadays sufficient to conduct very large business in Florida without ever visiting Florida or ever having an office in Florida.

20. In the light of new rules caused by the advent of the internet, the INFN and the UdA have numerous web sites and, consequently, they do conduct daily business in Florida via resident from Florida contacting the defendants web sites for their services and vice versa.

21. Additionally, copyrights infringing works by the INFN and the UdA have been purchased by all libraries of Universities in Florida with a graduate school, such as the University of Miami, Florida Atlantic University, the various Universities of Central Florida, the various universities of Northern Florida, the University of Tampa, and others. The fact that the books and articles by defendants Cardone, Mignani and Marrani, written under the auspices and support of Defendants INFN and UdA are in all the libraries of the Universities of Florida, and in all computer terminals of the libraries in Florida has caused a direct damage to plaintiff since that has caused a severe limitation on the part of the plaintiff to obtain grants and participate to projects at the departments of Physics and Mathematics of said Florida Universities. The ability of a physicist to obtain funding is based on published work, this was denied by the defendants who appropriated the plaintiff�s work. Thus this establishes that the defendants� INFN and UdA activity in Florida was essential to the completion of the tort.

22. The plaintiff reserves the constitutional rights to secure under the discovery process from the INFN and the UdA the list of their employees who have visited any of the several universities in Florida, as well as the list of scientists from Florida who have visited said defendants. For instance, it is notorious that the INFN has financed at least in part the travel to Florida of scores of Italian scientists for participation to conference, particularly in the winter and, vice versa, scores of Floridian scientists are known internationally to participate to conferences in Italy under at least partial support of the INFN and or the UdA. Detailed and ample documentations with specific names,and dates can be obtained but only under due process via interrogatories.

23. Hence, the verification of Florida�s Long Arm Stature, and the verification of the Personal Jurisdiction are simply beyond any possible doubt. The plaintiff prays the Honorable Judge to reconsider his stand in the field ([pages 5, 6 of the Order).

24. Alternatively, the dismissal of INFN and UdA prior to the plaintiff constitutional rights to prove his case during the discovery process would subordinate the U. S. Constitution to Federal and/or Local Florida Rules of Civil procedures.

25. DUE PROCESS. The plaintiff alleges that full due process with defendants INFN and UdA have had the privilege of doing business in Florida for many years, as per exhibit R.

26. When the INFN and the UdA initiated their financial and academic support for defendants Cardone, Mignani and Marrani, the latter were in good scientific stand, and were indeed properly quoting the copyrighted contributions by the plaintiff. Hence, there was no possible way to predict that said financial and academic support would lead later on to INFN and UdA being sued.

27. In regard to fair play and Florida interest in adjudicating the suit, the plaintiff respectfully prays the Honorable Judge to consider the fact that INFN and UdA are vast organizations with vast resources and that the Plaintiff is a mere senior scientist who is an American citizen and a Florida resident and has nowhere else to go to obtain relief. It is in the interest of the State of Florida to defend its residents and it is in the interest of the Federal Court to defend an American citizen.

28. The plaintiff additionally prays the Honorable Judge to reconsider his stand in the second paragraph of page 7. The defendants in this lawsuit have caused, by far, the biggest scientific, financial, academic, emotional and other damages to plaintiff via the attempted fraud of the paternity of his most important scientific contributions. Also, the plaintiff does not seek $\$15$ million judgment against INFN and UdA, but, as previously indicated, the judgment �deemed appropriated by this Honorable Court�.That is a value given by the Honorable Judge to a lifetime of the work of the plaintiff being copied , to the lack of academic standing caused by the copying of the plaintiff published work, to the severe limitation on the ability of the plaintiff to receive grants and academic positions caused by the defendants� reckless copying of the plaintiff�s scientific and copyrighted work.

UNLAWFUL ETHICAL DECAY IN PHYSICS
29. A fundamental rule of scientific ethics is the quotation of all directly relevant prior art in the proper chronological order. This lawsuit has been filed because defendant F. Cardone, R. Mignani and A. Marrani violated this fundamental rule, infringed the copyrights duly filed by the plaintiff decades ago by copying ad litteram copyrighted material since 1992, and carefully avoided the quotation of the originating copyrighted papers by the plaintiff. The copyright infringement is proved beyond doubt by comparing the plaintiff's copyrighted works, such as exhibit D and the infringing works such as that in exhibit F, in which one can see the reproduction ad litteram of entire sentences, notions, concepts, etc. including the use of exactly the same symbols.

30. The knowledge by said defendants of said copyrighted works is beyond credible doubt because said infringing papers were fully identified in the defendants papers prior to 1992 as documented in exhibits E to F. All requests for proper ethical conduct filed by the plaintiff to defendants Cardone, Mignani and Marrani turned out to be useless since said defendants are clearly aiming at defrauding the plaintiff of the paternity of his most important scientific contributions.

31. The plaintiff then contacted Roberto Petronio, president of the INFN, the Italian funding agency as well as Ferdinando di Orio, president of UdA (Universita� dell�Aquila), the academic conduit, requesting their intervention to compel their employees to stop violating copyrights and other laws. To the plaintiff�s enormous surprise, rather than implementing the above recalled fundamental rule of scientific ethics and copyright laws, Petronio and di Orio acted in such a support of the suppression of the ethical misconduct by their employees to the extreme of forcing the plaintiff to secure a judgment by the U. S. Federal Court in the plaintiff's favor as a condition for requesting the implementation of said ethical rules by their employees. This blatant ethical misconduct and violation of the law left no other recourse than that in Court.

32. Cornell University electronic archives "arXiv" published several of the copyright infringing papers by Cardone, Mignani and Marrani, some of which have been appended in exhibit G. The publication occurred in the archiv section "hep-th" meaning high energy physics - theory,, namely, the sections squarely and only pertinent for the field of the infringing papers.

33. Alerted by this violation of his copyright works by various colleagues such as Prof. Horst Wilhelm and others (expected to testify in court in due time), the plaintiff attempted to upload in the same hep-th section some of his works so that readers at least had a chance to identify the proper paternity. The uploading was attempted after full compliance with the rules of the arxiv, such as the authorization by a colleagues regularly uploading in that section, Prof. V. Dvoeglazov.

34. To his extreme surprise, the uploading was rejected by the anonymous editors of CU arXiv in a vulgar, offensive and discriminatory way in view of the fact that the plaintiff is a U. S. citizen paying taxes used in part to finance the arXiv, while Cardone, Mignani and marrani are foreign citizens; the plaintiff has a scientific reputation and achievement (including numerous nominations for the Nobel Prize in physics and mathematics, see, for instance, the web site http://www.scientificethics.org/Nobel-Foundation.htm) vastly superior to that of said defendants; and other reasons. It is evident to all in good faith that such a rejection violated a number of U. S. laws, besides being blatantly unethical.

35. At that point, the plaintiff contacted David Skorton, president of CU requesting his intervention so that his employees, the anonymous editors of the arXiv, would stop violating federal and other laws, and implement scientific ethics via the respectful letter in exhibit J, that was ignored also in a vulgar, offensive and discriminatory way by Skorton. Additional attempts to bring Skorton to his duty as CU president were attempted via CU attorney Boystood as per exhibit L resulting in a complete vacuum, thus confirming beyond reasonable or otherwise credible doubt the total complicity of Skorton with the misconduct of his anonymous editors.

36. Cornell University initiated the arxiv in 1992 as a way for physicists to share preprints fairly, democratically and efficiently. Since then it has evolved into an archive of more than 330,000 articles and it is now one of the primary means of scholarly communication and has changed the way scientists work (see attachment S). CU received for its arxiv $\$300,000$ in annual funding from various Federal Agencies and that funding has continued and increased every year (exhibit T).

37. According to the Laws of the Land, the above Federal Funds were given to CU for a democratic access to the arXiv by all scientists without discrimination for race, religion or affiliation. By denying my uploading in the arxiv despite my scientific qualifications identified in my curriculum, exhibit A, and despite the requested authorization by colleagues regularly uploading in arXiv, I was denied my access to a federally funded resource because of my lack of affiliation at the moment to an academic conduit and other reasons. Consequently, I have been the victim of a discrimination under federal funds.

38. An additional violation of our laws caused by the blatantly immoral behavior of CU and its president is given by the use of public funds in committing willful violations of the Copyright Act.

39. The above documented illegal unethical conduct is only a very small part of the widespread decay of ethics in science and consequential illegal conduct that continues to remain unchallenged, let alone unpunished to this day, because of the inability by judges and attorneys alike to understand the background motivations of lawsuits due to their general post P. D. character in mathematics, physics and chemistry. This occurrence is the very reason the plaintiff could not secure representation by a law firm until now. hence, the plaintiff reaffirms with the Honorable Judge Steven D. merryday his plea for leniency due to unavoidable procedural insufficiencies of this Forth Amended Complaint cause by lack of sufficient knowledge by the plaintiff, of course, here referring to fully warranted and proper leniency within the boundaries of the U. S. Constitutions and the federal and local Rules of Coivil procedure.

40. Since this is one of the extremely few scientific lawsuits in existence today, the lawsuits is being monitored by scientists and administrators the world over. Hence, any unwarranted acquittal without due punitive compensation will constitute a patent of impunity for illegal acts by scientists and administrators the world over with very serious consequences for mankind due to the expected ensuing impossibility of solving the serious climactic problems afflicting our planet, since their solution notoriously squires an ethically sound scientific environment.

41. Additionally, the plaintiff prays the Honorable Judge Steven D. Merryday to take into consideration that this lawsuits has been filed against Cornell University because the anonymous editors of the arXiv routinely perpetrate their immoral, illegal and offensive discriminations under U. S. federal Funds against scores of scientists around the world, most of whom have to supinely accept such abuses, in order not to lose their academic job, or lack of possibility to initiating legal action against CU, o other reasons. Hance this lawsuit is a plea for justice not only for the plaintiff but also for suppressed dignity of the science of the United States of America around the world.

THE ANONYMOUS CHARACTER OF THE ILLEGAl CONDUCT OF CU ARXIV
42. An unlawful and immoral conduct by Cornell University in the conduction of its federal money providing business with the electronic listings in the arXiv, that has caused immense damage to the credibility of the science of the United States of America throughout the world, is the conduction of said business under the total anonymity of the editors legally responsible for the uploading and their denial in said arXiv. Such a conduct is in clear violation of serious,. internationally accepted scientific conduits requesting the physical identification of all editors responsible for decisions.

43. A primary reason for the filing of this lawsuit is to secure all names of all individuals directly responsible for said illegal and immoral acts at the arXiv, securing expected under the Discovery Process of this lawsuit, action at the Federal Agencies funding the arXiv on founds of the Freedom of Information Act, and other lawful mean.

44. The primary responsibility of this vile, unethical, illegal and immoral conduct by Cornel University of a public service in the United States of America rests with the president of Cornell University, David J. Skorton, because of his excessively blatant excessive complicity and subservience to his brothers running the arXiv, rather than loyalty to Cornell University, the United State of America and its Laws, which subservience is a primary reason for listing Skorton as a individual defendant in this Forth Amended Complaint.

45. The only names listed in the arXiv under a somewhat hidden page studiously not listed in the main page and identifiable only by experts in web searches, is that on the "Scientific Advisors" of the arXiv given by the following individuals (exhibit U):

46. Currently listed, general advisory board: Steven Beckwith, Eberhard Bodenschatz, Paul Fendley, Paul Ginsparg, Steven Gottlieb, Joe Halpern, Terence Hwa, Peter Kahn, Greg Kuperberg, N. David Mermin, David Morrison, David Nelson, Nickolas Solomey, Karen Vogtmann, Ira Wasserman

47. General advisory board for physics, mathematics, computer science, quantitative biology, and statistics: Andrew Connolly, Bruno Nachtergaele, Gerd Schon, Brian Maple, Debbie Jin, Jacques Distler, Nick Solomey (chair), Paul Ginsparg (staff ex officio).

48. Advisory board for mathematics: Robert Bryant, Bill Casselman, Paul Ginsparg (staff ex officio), Greg Kuperberg (chair), David R. Morrison, Kapil Paranjape, Mark Steinberger, Terence Tao.

49. Advisory board for computer science: Krzysztof Apt, CWI, Amsterdam, Ron Boisvert, Carol Hutchins, Jon Doyle, North Carolina State, Ed Fox, Virginia Tech, Lee Giles, Penn State, Joseph Halpern, Cornell (chair), Carl Lagoze, Cornell, Bernard Lang, Michael Lesk, Andrew McCallum, U. Massachusetts, Steve Minton, Andrew Odlyzko, U. Minnesota, Michael O'Donnell, U. Chicago, Bernard Rous, Jerome Saltzer, Erik Sandewall, Stuart Shieber, Harvard, Jeff Ullman, Stanford, Ian Witten, Waikato, New Zealand

50. Advisory board for quantitative biology: Bill Loomis, Chuck Stevens, Gary Stormo, Diethard Tautz, Terence Hwa (chair), Michael L�ssig

51. Advisory board for statistics: Larry Wasserman (coordinator), David Banks, Chad Schafer, Dave Higdon, Rob Strawderman, Susan Holmes, Jim Pitman

52. The vulgar, offensive, and unlawful conduct by Cornell University of its business in the arXiv under public support is sealed, not only by the lack of release of the editors actually responsible for all decisions, but also by the following statement released in exhibit U that studiously voids any legal responsibility by said advisors:

The arXiv advisory board members serve as consultants to the Cornell University Library staff.

in fact, such a statement has evidently prevented the plaintiff from the listing of the above identified advisors as defendants in this lawsuit.

53. The immoral conduct by Cornell University, David Skorton, and the rest of CU administration is finally sealed by the following additional statement also released in exhibit U

Please note that all arXiv policy decisions are ultimately made by Cornell University Library.

which statement studiously and, unlawfully and unethically attempts the diversification of the responsibility for the conduct at the arXiv to "Cornell University Library", namely, a body that by internationally accepted practice has no editorship capacity or qualification, thus. Since the plaintiff cares for ethics, he abstained from listing the director of CU library as a defendant because his/her innocence could be readily proved, thus mandating the filing of this lawsuit with David J. Skorton and CU as temporary defendants for the primary purpose of uncovering the names of the people actually responsible for the unlawful conduct at the CU arxiv and their subsequent listing as defendants at the appropriate time.

FORTH COMPLAINT COUNT 1: COPYRIGHT INFRINGEMENT
[against defendant Cornell University (CU)]
54. The plaintiff realliges and reaffirms all preceding statements. In particular, the plaintiff reaffirms and realliges that CU published in their electronic archives "arXiv" works by Cardone, Mignani and Marrani as per exhibit G infringing the plaintiff's copyrights as listed in exhibit C. Plaintiff states that:

1) The plaintiff is the sole owner of the copyrights;

2) The copyrights were properly filed and secured in 1999, thus years before the indicated infringement;

3) Defendant CU was fully, properly and repeatedly informed of the infringement;

4) The copyright infringement perpetrated by CU was willful, continuous and malicious because intended in support of others, thus implying an additional violation of the Digital Millennium Copyright Act:

5) CU arXiv has a license on all uploaded papers as per document in exhibit V, hence CU publishes all papers for business;

6) Cardone, Mignani and Marrani had to accept the legal statement reproduced in said exhibit V stating that they had the right to publish the papers in questions and grant a license on them to CU;

7) Plaintiff informed CU president (see exhibit J) and the anonymous editors of the arXiv that the papers by Cardone, Mignani and Marrani violated the plaintiff copyrighted works, thus having no right to grant such a license, Additional communications to the same effect were done via CU attorney Boystood (exhibit L), but turned out to be useless.

55. Wherefore, plaintiff respectfully prays the Honorable Judge Steven D. Merryday to enter a judgment in his favor for statutory damages according to Section 1203(c) of said act, including the payment of all costs incurred for this lawsuit, and all gains, advantages lost by the plaintiff because of said infringement, as well as any other relief deemed just.

FORTH COMPLAINT COUNT 2: CONVERSION
[against defendant Cornell University (CU)]
56. The plaintiff realliges and reaffirms all preceding statements. This is an action against defendant CU for conversion. Beginning from the year 2004, defendant CU converted for its own financial and other benefits the works by Cardone.,. Mignani and Marrani that infringed copyrighted work by the plaintiff, therefore depriving the plaintiff of his own property.

57. Section 301(a) of the Copyright Act does not prevent the plaintiff's conversion claim because the copyright violation is not limited to one copyrighted page, but encompasses the entire scientific production and body of works by the plaintiff, thus causing the plaintiff serious damages and injuries. Hence, by conversion of the copyright infringing works, defendant CU has caused to plaintiff severe scientific, financial, academic, emotional and other damages .

58. Wherefore, the plaintiff requests a financial remuneration of $\$15,000,000$ (fifteen million dollars) or whatever the Honorable Judge deems appropriate and just.

FORTH COMPLAINT COUNT 3: BREACH OF FIDUCIARY DUTY
[against defendant Cornell University (CU)]
59. The plaintiff realliges and reaffirms all preceding statements. CU arXiv is a federally funded resource with related contractual and fiduciary obligations between CU and the individual scientists uploading their works. By wilfully violating the Copyrights Act and the Digital Millennium Copyright Act. with the publication of the fraudulent papers by Cardone, Mignani and Marrani (exhibit G) and by denying the plaintiff the uploading of his own papers in the same section of the arXiv, CU has perpetrated a Breach of Fiduciary Duty toward the plaintiff. An additional breach of Fiduciary Duty has been perpetrated by CU by the publication of copyright infringing works that is prohibited by federal funds. Consequently, CU is liable for damage.

60. The above occurrences prevented the plaintiff from obtaining federal and/or state research grants on his copyrighted works, because the obtaining of said grants is well known to be basically dependent on publications. Consequently, CU has caused a scientific, financial, academic, emotional and other damages to plaintiff via the fraud of the paternity of his most important scientific contributions.

61. Wherefore, the plaintiff requests from CU a financial compensation for damage of $\$15,000,000$ (fifteen million dollars) or whatever deemed appropriate by the Honorable Judge, that is, a value given by the Honorable Judge to the loss of the plaintiff lifetime work.

FORTH COMPLAINT COUNT 4: DISCRIMINATION UNDER PUBLIC SUPPORT
(against defendant Cornell University (CU)]
62. The plaintiff realliges and reaffirms all preceding statements. As documented above, the plaintiff has been a victim of severe discrimination by defendant CU, which discrimination constitutes a violation of the laws against discrimination when operating under public financial support. This discrimination has caused severe damages to the plaintiff also documented above. By depriving the plaintiff an equal opportunity under federal funds, CU violated the U. S. Equal Employment Opportunity, 5 u. s. c. 2302.

63. Wherefore, the plaintiff requests from CU a financial compensation for damage of $\$15,000,000 $ (fifteen million dollars) or whatever deemed appropriate by the Honorable Judge, that is, a value given by the Honorable Judge to the plaintiff lifetime work.

FORTH COMPLAINT COUNT 5: MISUSE OF PUBLIC FUNDS
[against defendant Cornell University (CU)]
64. The plaintiff realliges and reaffirms all preceding statements. In particular, the documented discrimination of the plaintiff in preventing the uploading of his works in the desired section of the arXiv, CU perpetrated a clear misuse of public funds, an act violating Section 112.313 of the Florida Stature which prohibits the use of public funds to favorably treat one person over another.

65. As one can see in Exhibit I, said public funds were granted under the condition of defendant CU verifying the highest possible academic standards, which standards require, first and above all, the strict implementation and verification of the highest possible levels of scientific ethics and accountability, at the basis of which is the avoidance of publications infringing copyrights. On the contrary, defendant CU has perpetrated a number of violations of said requirements, such as:

66. A. CU has allowed the publication in their electronic business of copyright infringing works to the extreme of avoiding any quotation whatsoever of the plaintiff's prior works, which occurrence constitutes a gross violation of the most elementary rules of high scientific standards, to which defendant CU is bound by the use of public funds.

67. B. Additionally, CU has published in their electronic business works by defendants Cardone, Mignani and Marrani that are catastrophically inconsistent in the sense of violating basic laws in physics, as treated in details in Count 10 below, catastrophic inconsistencies that are expected to be known by experts to qualify as such, thus perpetrating a second gross violation of the most elementary rules of high academic standards, and

68. C. Defendant CU has refused to implement any corrective measures when informed in writing of gross misconducts A and B above, this confirming the perpetration of gross misconduct perhaps originating from an excessive and excessively protracted impunity due to complete lack of federal or state, governmental or judicial control. of their operations to date, despite a world wide chorus of protests.

69. The plaintiff has received severe damages and injuries from the above misuse of public funds by defendant CU, both in reputation as well as financial incomes, and similar dam,ages have been suffered by numerous scientists the world over.

70. Wherefore, plaintiff respectfully requests that the Honorable Judge Steven D. Merryday enters a judgment for \$15,000,000.000 (fifteen million dollars) financial relief to be paid by defendant Cornell University to plaintiff Santilli as compensation for misuse of public funds, or whatever financial relief the Honorable Judge deems appropriate and just.

FORTH COMPLAINT COUNT 6: PRELIMINARY INJUNCTION
[against defendant Cornell University (CU)]
71. The plaintiff realliges and reaffirms all the preceding allegations, and additionally brings to the attention of this Honorable Court, the unwillingness of defendant CU to remove from their archives the fraudulent works by defendant cardone, Mignani and Marrani as listed in Exhibit G.

72. In fact, defendant CU has continued to advertise and promote plagiarizing work as in Exhibit G following the reception of the respectful request as per Exhibit I, and has additionally continued the advertisement and promotion of plagiarized works as in Exhibit G following the filing of the first Complaint as well as of the Amended Complaint.

73. Plaintiff has suffered irreparable harm and is suffering irreparable harm as a consequence of the copyright infringing works published by defendant CU that continues to defraud the plaintiff of his copyrighted scientific paternity. Since CU university rejected any plea by the plaintiff for corrections, the continuation of the violations of various laws by CU as identified above will cause additional damage to plaintiff.

74. Hence, plaintiff respectfully request the Honorable Judge Steven D. merryday to issue the below identified preliminary injunction because: 1) Plaintiff will suffer irreparable harm if CU arxiv is continued to allowed copyright infringements; 2) Plaintiff has no other remedy at law; 3) Plaintiff has a substantial likelihood of success on the merits; 4) A temporary injunction will serve the public interest because it would mandate CU to honor laws on copyrights, public funds and the Millennium Digital; Copyright Act.

75. Wherefore, plaintiff respectfully requests that the Honorable Judge Steven D. Merryday provides a Preliminary Injunction in accordance with Rule 65(a) of th federal Rules of Civil procedure, (see Reed v. Cleveland and Bod Educ. 581 F.2D 570,573) against defendant Cornell University mandating the removal from their archives of all works authored by defendants Cardone, Mignani and Marrani, and mandating the halting of the listing of any and all additional works by said and other defendants for at least the duration of this lawsuit. Unless this Preliminary Injunction is issued and implemented, the plaintiff will continue to suffer unjust professional and financial damages and his activity will be greatly curtailed, including the inability to apply for research support.

FORTH COMPLAINT COUNT 7: RESPONDEAT SUPERIOR
[against defendant David J. Skorton]
76. The plaintiff realliges and reaffirms all the preceding allegations, and additionally claim that, in his capacity as president of Cornell University, defendant David J. Skorton must assume the primary responsibility for the above identified illegal acts under the doctrine of Respondeat Superior that makes an employer liable for the torts and illegal actions committed by its employees unless duty corrected, which Statute establishes the liability of defendant Skorton.

77. Additionally, Skorton supported the illegal actions by his anonymous editors of the arXiv, to such an extent to be vulgar, dishonest and offensive to the plaintiff, a fellow academician his senior, by not even acknowledging the very respectful plea to ethics and laws by the plaintiff (exhibit J), thus establishing his complicity beyond credible doubt, a complicity confirmed by the dismissal of the additional plea by the plaintiff to implement ethics and laws filed via Skporton�s attorney of the time, Boystood (exhibit L). As a result of such a vulgar, dishonest and offensive complicity with unethical and unlawful conduct, the plaintiff has suffered severe financial and emotional damages.

78. To appraise the gravity of Skorton�s misconduct, the Honorable Judge Steven D. Merryday is respectfully requested to consider the fact that this lawsuit and its unreassuring international repercussion would not have been filed in the event Skorton had exercised his authority as president of Cornell University and imposed his corrupt employees to implement indeed democracy in the use of the arXiv as requested by federal funds and allowed the plaintiff equal uploads as provided to other privileged scientists.

79. Wherefore, the plaintiff respectfully prays the Honorable Judge Steven D. merryday to grant a judgment in the plaintiff's favor for a financial compensation from defendant David J. Skorton of $\$30,000,000$ (thirty million dollars) or whatever the Honorable Judge deems appropriate to prevent other college presidents from continuing the ongoing violations of ethics and the law under the current illusion of impunity due to lack of prosecution.

FORTH COMPLAINT COUNT 8: RESPONDEAT SUPERIOR
[against defendant Istituto Nazionale Fisica Nucleare (INFN)]
80. The plaintiff realliges and reaffirms all the preceding allegations, and additionally states that defendant INFN is the largest state agency funding physics research in Italy. Said agency has been listed as defendant because all violations of plaintiff copyrights, paternity fraud and plagiarisms herein considered were perpetrated by defendants Cardone, Mignani and Marrani under partial or full financial support by defendant INFN, as clearly stated in the very headings of all works, such as the works in Exhibit G.

81. Respondeat Superior is an important statute at law because it establishes the responsibility of the funding institution for the action(s) conducted under its funding, particularly when documentedly not corrected for personal or other gains. The jurisdiction and venue are also evident because defendant INFN conducts routine business, specifically, in the state of Florida, including the sale, promotions and advertisement of published work, exchange of students and faculty and participation to conferences and meetings, specifically, in the State of Florida. The jurisdiction additionally holds because the plaintiff, a local resident, has suffered severe harm and damage because of the action by defendant INFN.

82. Wherefore plaintiff respectfully requests that the Honorable Judge Steven D. Merryday enters a judgement for \$30,000,000.00 (thirty million dollars) financial relief to be paid by defendant Istituto Nazionale Fisica Nucleare to plaintiff Santilli as compensation under the rule of respondeat superior, or whatever financial relief the Honorable Judge deems appropriate.

FORTH COMPLAINT COUNT 9: RESPONDEAT SUPERIOR
[against defendant Roberto Petronzio]
83. The plaintiff realliges and reaffirms all the preceding allegations, and additionally states that, in the hope of preventing the listing of this Italian institution as defendant, on August 23, 2007, the plaintiff contacted its president Roberto Petronzio (see Exhibit N), and requested the signature of a simple and honest letter stating that said institution will not provide any additional financial support and/or academic backing to defendants Cardone., Mignani and Marrani unless they properly quote the plaintiff originating works, jointly with any pertinent additional quotation, but in chronological order, as requested by ethics and accountability under public funding and/or academic support.

84. In the event Petronzio had released such a simple letter, the plaintiff would have abstained from filing this Second, Third and Forth Amended Complaints with said Italian institution as defendant, without any financial compensation whatsoever despite the severe damages, injuries and losses suffered by the plaintiff (see Exhibit N). Petronzio to arrogantly refused such a simple, honest, lawful and ethical letter, under such a generous waiving by the plaintiff of any financial compensation, thus confirming the complicity of said italian institution as well as of its officers in the violation of international laws, and leaving the plaintiff no other option then the listing again of said Italian institution as a defendant in this lawsuit.

85. Additionally, ROBERTO PETRONZIO HAS PERPETRATED PERJURY DURING THESE FORMAL PROCEEDINGS AT THE U. S. FEDERAL COURT BY STATING IN HIS AFFIDAVIT REPRODUCED IN EXHIBIT P THAT INFN CONDUCTS NO BUSINESS IN FLORIDA, WHILE HE HAS PERSONALLY SIGNED A NUMBER OF BUSINESS CONTRACTS BETWEEN INFN AND FLORIDA, AS DOCUMENTED IN EXHIBIT R.

86. Wherefore, the plaintiff respectfully requests the Honorable Judge Steven d., merryday to issue an order requesting defendant Roberto petronzio to pay personally to the plaintiff the sum of $\$30,000$ (thirty million dollars) under the statute of Respondeat Superior as well as other law, or grant any other financial relief the Honorable Judge deems appropriate, not only for misconduct under the statute of Respondeat Superior, but also for perjury in a formal lawsuit at the U. S. federal Court.

FORTH COMPLAINT COUNT 10: RESPONDEAT SUPERIOR
[against defendant Universita� dell�Aquila (UdA)]
87. The plaintiff realliges and reaffirms all the preceding allegations, and additionally states that defendant UdA is the largest state agency funding physics research in Italy. Said agency has been listed as defendant because all violations of plaintiff copyrights, paternity fraud and plagiarisms herein considered were perpetrated by defendants Cardone, Mignani and Marrani under partial or full financial support by defendant UdA, as clearly stated in the very headings of all works, such as the works in Exhibit G.

88. Respondeat Superior is an important statute at law because it establishes the responsibility of the funding institution for the action(s) conducted under its funding, particularly when documentedly not corrected for personal or other gains. The jurisdiction and venue are also evident because defendant UdA conducts routine business, specifically, in the state of Florida, including the sale, promotions and advertisement of published work, exchange of students and faculty and participation to conferences and meetings, specifically, in the State of Florida. The jurisdiction additionally holds because the plaintiff, a local resident, has suffered severe harm and damage because of the action by defendant UdA.

89. Wherefore plaintiff respectfully requests that the Honorable Judge Steven D. Merryday enters a judgement for $\$30,000,000.00$ (thirty million dollars) financial relief to be paid by defendant Universita� dell�Aquila to plaintiff Santilli as compensation under the rule of respondeat superior, or whatever financial relief the Honorable Judge deems appropriate.

FORTH COMPLAINT COUNT 11: RESPONDEAT SUPERIOR
[against defendant Ferdinando di Orio]
90. The plaintiff realliges and reaffirms all the preceding allegations, and additionally states that, in the hope of preventing the listing of this Italian institution as defendant, on August 23, 2007, the plaintiff contacted its president Ferdinando di Orio (see Exhibit N), and requested the signature of a simple and honest letter stating that said institution will not provide any additional financial support and/or academic backing to defendants Cardone., Mignani and Marrani unless they properly quote the plaintiff originating works, jointly with any pertinent additional quotation, but in chronological order, as requested by ethics and accountability under public funding and/or academic support.

91. In the event di Orio had released such a simple letter, the plaintiff would have abstained from filing this Second, Third and Forth Amended Complaints with said Italian institution as defendant, without any financial compensation whatsoever despite the severe damages, injuries and losses suffered by the plaintiff (see Exhibit N). Di Orio to arrogantly refused such a simple, honest, lawful and ethical letter, under such a generous waiving by the plaintiff of any financial compensation, thus confirming the complicity of said italian institution as well as of its officers in the violation of international laws, and leaving the plaintiff no other option then the listing again of said Italian institution as a defendant in this lawsuit.

92. Additionally, ferdinando DI ORIO HAS PERPETRATED PERJURY DURING THESE FORMAL PROCEEDINGS AT THE U. S. FEDERAL COURT BY STATING IN HIS AFFIDAVIT REPRODUCED IN EXHIBIT Q THAT UDA CONDUCTS NO BUSINESS IN FLORIDA, WHILE HE HAS PERSONALLY SIGNED A NUMBER OF BUSINESS CONTRACTS BETWEEN UDA AND FLORIDA, AS DOCUMENTED IN EXHIBIT R.

93. Wherefore, the plaintiff respectfully requests the Honorable Judge Steven d., merryday to issue an order requesting defendant Fendinando di Orio to pay personally to the plaintiff the sum of $\$30,000,000$ (thirty million dollars) under the statute of Respondeat Superior as well as other law, or grant any other financial relief the Honorable Judge deems appropriate, not only for misconduct under the statute of Respondeat Superior, but also for perjury in a formal lawsuit at the U. S. federal Court.

FORTH COMPLAINT COUNT 12: COPYRIGHT INFRINGEMENT
[against defendants K. K/ Phua (Phua) and World Scientific (WS)]
94. The plaintiff realliges and reaffirms all the preceding allegations contained in the Third and Forth Amended Complaint and additionally the plaintiff states that defendants Phua and WS published in the year 2004 the book entitled "Energy and Geometry, an Introduction to Deformed Special Relativity," with main parts reproduced in Exhibit F, which book contains a verbatim copy of the plaintiff works in Exhibits D copyrighted as per documentation in Exhibit C, thus perpetrating a plagiarism as well as a paternity fraud.

95. The jurisdiction in this case is established beyond credible doubt by the fact that defendants Phua and WS secures a financial income and other benefits via its sales, promotions and advertisements, specifically, in the state of Florida via booksellers, electronic sales and direct sales to individuals and institutions.

96. The infringements of copyrights, plagiarism and paternity fraud by defendants Phua and WS begins with the title of the work in Exhibit F since it alleges novelty with the words "Deformed Special Relativity" that should have been instead "Santilli Isotopies of Special Relativity" as admitted by the very same defendants in works up to 1992, as one can read beginning from the abstract of work E1 that, when speaking of the same theories, states"Santilli Lie-isotopic lifting of special relativity".

97. The infringements of copyrights, plagiarism and paternity fraud then continues with the content of the book in Exhibit F. For instance, the section entitled "Deformed Minkowski space" is a copy of the corresponding section in plaintiff's works such as those in (but not limited to) Exhibit D, including the use of the same symbols "b" to represent deviations from the Minkowski space, as one can see with a comparison with copyrighted work D1, equation (2) page 546. The words used for the "deformation" of the Minkowski space are also identical to those used in copyrighted works. A clear additional violation of the plaintiff copyrights also occurs for the "deformed Lorentz symmetry (or transformations)" (Exhibit F, page 21 on) that are identical, symbol by symbol, to the plaintiff "isotopies of the Lorentz symmetry (or transformations)" (Exhibits D), including the verbatim copy of the text used for their derivation.

98. The infringements of copyrights, plagiarism and paternity fraud is also perpetrated as follows. in the plagiarizing work in Exhibit F, page 7, when introducing the "deformation" of the Minkowski metric, equation (2.2), defendants Cardone and Mignani quote works 3-5 that, as one can see in the references of Exhibit F, solely relates to works by the defendants in the 1990s, while they should have quoted the plaintiff copyrighted work D1 of 1983, work D2 of 1993, that is universally acknowledge as the origination of the theory. Hence, the infringement of copyrights, plagiarism and paternity fraud has been perpetrated by defendants Phua and WS by allowing defendants Cardone and Mignani, by usurping and stealing the paternity of the theory via the quotation on that central and initiating point of their own works 3-5, rather than plaintiff original work D1 of 1983 and D2 of 1993.

99. This honorable Court should be aware that defendants Phua and WS has additionally assisted defendants Cardone and Mignani to publish further fraudulent papers, such as the paper authored by said defendants in the journal "Modern Physics A", Vol. 14, page 3799 (1999), since the journal "Modern Physics A" is owned, published and sold by Phya and WS in Florida, as well as all over the world.

100. The plaintiff contacted Mr. K. K. Phua, president of WS with a respectful letter in attached in Exhibit H requesting the immediate cessation of the sale, advertisement and promotion of the plagiarizing work reproduced in Exhibit F as well as halting the publication in his scientific journal of additional papers by defendant Cardone, Mignani and Marrani constituting clear paternity fraud. Unfortunately, Mr. K. K. Phua elected to ignore completely the plaintiff respectful request, and continue to sell, advertise and distribute the plagiarizing work ion Exhibit F in Florida as well as in the rest of the world, thus leaving the plaintiff with no other choice than that of filing this lawsuit.

101. In view of this action plaintiff has suffered severe injuries and damages in his professional standing in the scientific community as well as, lack of the income that plaintiff derives from his work and in other matters.

102. The Honorable Judge Steven D. Merryday should be informed that K. K. Phua, president of defendant WS, has evaded the service by the local sheriff of the Summon of the first Complaint, as filed in the case, and evaded the service of the Amended Complaint, as documented in Exhibit O (see the section of Certificate of Service). Consequently, the plaintiff is forced to serve the Summon for this Third Amended Complaint to the New Jersey Business Service Bureau. with copies to defendants Phiua and WS at their working addresses. In the event of additional evasion of service and additional lack of election by defendants Phua and WS of a legal representative for this lawsuit, the plaintiff reserves the option of filing a Motion for the addition as defendants all booksellers, distributors and promoters of World Scientific Publications in the world. Additionally, it is not clear as to whether defendant WS is operating legally in the U. S. A., that is, via a duly recorded and legally responsible company. In fact, it is possible that defendant Phua has evaded service on grounds that his company is not in good standing for the State of New Jersey, as the discovery process will ascertain in due time, yet it remains fully operational in selling plagiarizing works. These and other equivocal occurrences have requested the addition of defendant K. K. Phua as an individual.

103. Wherefore, plaintiff respectfully requests that the Honorable Judge Steven D. Merryday enters a judgment of \$15,000,000.00 (fifteen million dollars) financial relief to be paid by defendant K. K. Phua and/or defendant World Scientific to plaintiff Santilli as financial compensation for copyright infringements, and/or plagiarism and/or paternity fraud, or whatever financial relief the Honorable Judge deems appropriate.

104. Moreover, the above and the following Counts are here filed under the proviso that the plaintiff may elect filing a Motion for their extension and application to said booksellers, distributors and promoters of World Scientific Publications due to the evasion of service perpetrated by the defandant to date.

FORTH COMPOLAINT COUNT 13: CONVERSION
[against defendants K. K. Phua and World Scientific (WS)]
105. The plaintiff realliges and reaffirms all the preceding allegations contained in the Third and Forth Amended Complaint and additionally states that this is an action against defendants Phua and WS for conversion. Beginning from the year 2004, defendants Phua and WS converted for its own financial and other benefits the copyrighted work by the plaintiff, therefore depriving the plaintiff of his own property.

106. Wherefore, plaintiff respectfully requests that the Honorable Judge Steven D. Merryday enters a judgment of \$15,000,000.00 (fifteen million dollars) financial relief to be paid by defendant K. K. Phus and defendant World Scientific to plaintiff Santilli as financial compensation for conversion, or whatever financial relief the Honorable Judge deems appropriate.

FOIRTH COMPLAINT COUNT 14: TEMPORARY INJUNCTION
(against defendants Phua and World Scientific (WS)]
107. The plaintiff realliges and reaffirms all the preceding allegations contained in the Third and Forth Amended Complaint and additionally brings to the attention of the Honorable Judge the unwillingness of defendants Phua and WS to halt the advertisement, promotion and sale of the plagiarizing works as per Exhibit F.

108. In fact, defendants Phua and WS has continued to advertise, promote and sell plagiarizing work as in Exhibit F following the reception of the respectful request as per Exhibit H, and has additionally continued the advertisement, promotion and sale of plagiarized works as in Exhibit F following the filing of the first Complaint as well as of the second, both filings being fully known to Mr. K. K. Phua, WS president, because of copies of said complaints being mailed to defendant WS at its business address, the local sheriff attempting to serve the Summons twice at the same business address and according to eyewitnesses the plaintiff contemplates to call for testimonial in the event the preceding substantial evidence is deemed insufficient..

109. Plaintiff has suffered irreparable harm and continued to suffer irreparable harm as a consequence of the plagiarizing works published by defendant WS that continues to be sold, promoted and advertised in Florida as well as all over the world in bookstores,. electronic and direct advertising and direct sales.

110. Wherefore, plaintiff respectfully requests that the Honorable Judge Steven D. Merryday issues a Temporary Injunction against defendants K. K. Phua and World Scientific mandating the termination of any and all publications of works by defendants Cardone, Mignani and Marrani as well as mandating the termination of any and all sales, advertisement and promotion of their works for at least the duration of this lawsuit.

In faith

Ruggero Maria Santilli
U. S. Citizen acting pro se
35246 US 19 North, PMB 215
Palm Harbor, FL 34684, U.S.A.
Tel. +1-727-934 9593
fax +1-727-934 9275
email "ibr at verizon dot net"

CERTIFICATE OF SERVICE
Plaintiff pledges that the Summons will be served to the following U. S. defendants via the sheriff's office of their town

David J. Skorton
300 Day Hall
Ithaca, NY 14853-6902

James Mingle
Head Council of
Cornell University
300 CCC
Ithaca, NY 14853-6902

Plaintiff pledges that the summons to the following Italian defendants shall be served via Attorney Andrea Pontecorvo, Viale Carso 77, 00195 Roma, Italy

Roberto Petronzio
, Piazza dei Caprettari, 70
I-00186 Roma, Italy

Istituto NaZionale Fisica Nucleare
Piazza dei Caprettari, 70
I-00186 Roma, Italy

Ferdinando di Orio
Piazza Vincenzo Rivera, 1
I - 67100 L'Aquila, Itally

Universita' dell'Aquila
Piazza Vincenzo Rivera, 1
I - 67100 L'Aquila, Italy

The following U. S. defandants have evaded two poreceding serving of the Summons via the local sheriff, hence the evasion is reported to the State ofd New jersey

K. K. Phua
508 Manning Ct,
River Edge, NJ 07661
and
State of New Jersey,
Business Service Bureau,
Division of Revenues,
225 West State Street, Third Floor,
Trenton, NJ 08608,

Wold Scientific Co.
27 Warrent Street
Hackensack, NJ 076101
and
State of New Jersey,
Business Service Bureau,
Division of Revenues,
225 West State Street, Third Floor,
Trenton, NJ 08608,