Hadnagy v. Moss

CourtDistrict Court, W.D. Washington
DecidedMarch 28, 2024
Docket2:23-cv-01932
StatusUnknown

This text of Hadnagy v. Moss (Hadnagy v. Moss) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hadnagy v. Moss, (W.D. Wash. 2024).

Opinion

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5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 CHRISTOPHER J HADNAGY, SOCIAL ENGINEER LLC, 8 CASE NO. 2:23-cv-01932-BAT Plaintiffs, 9 ORDER GRANTING IN PART AND v. DENYING IN PART DEFENDANTS’ 10 MOTION TO DISMISS JEFF MOSS, DEF CON 11 COMMUNICATIONS INC, 12 Defendants.

13 Defendants Jeff Moss (“Moss”) and Def Con Communications, Inc. (“Def Con”) move to 14 dismiss the Complaint of Plaintiffs Christopher J. Hadnagy (“Hadnagy) and Social-Engineer 15 LLC (“Social-Engineer”). Dkt. 37. Plaintiffs assert seven causes of action against Defendants. 16 Dkt. 1-1. 17 For the reasons stated herein, the Court grants Defendants’ motion to dismiss Plaintiffs’ 18 claims of Alter Ego, Business Disparagement; Unjust Enrichment, Quantum Meruit, and 19 Injunction; denies Defendants’ motion to dismiss Plaintiffs’ Defamation claims (2/9/22 20 Transparency Report and 1/13/23 Update); and grants Defendants’ motion to dismiss, with 21 leave to amend, Plaintiffs’ claims of Defamation (“Injurious Falsehoods” by Defendant Moss); 22 Tortious Interference with Contractual Relations; and Prospective Business Relations. 23 1 FACTUAL AND PROCEDURAL BACKGROUND 2 A. Plaintiffs’ Allegations – Dkt. 1-1 Complaint 3 Defendants Moss and Def Con have held an annual hacker conference in Las Vegas, 4 Nevada (the “Event”) in August for the past thirty years. Dkt. 1-1 ¶¶ 32–36. The Event is one of

5 the largest, is highly regarded in the industry, and is attended by members of law enforcement 6 agencies and large corporations. Id. ¶¶ 37-38. In 2025, Def Con implemented an Event Code of 7 Conduct (“Code of Conduct”). Dkt. 1-1, ¶ 60 (Dkt. 37, Ex. 1). The Code of Conduct prohibits 8 “harassment,” which includes “deliberate intimidation and targeting individuals in a manner that 9 makes them feel uncomfortable, unwelcome, or afraid.” Id. The Code of Conduct applies to 10 “everyone,” and Def Con reserves the “right to respond to harassment in the manner we deem 11 appropriate, including but not limited to expulsion.” Id. In 2017, Def Con began to publicly share 12 a summary of incidents which occurred at the Event for a given year (the “Transparency 13 Report”). 14 The Event hosts a multitude of “villages,” inviting smaller groups of attendees to

15 participate in cybersecurity challenges and demonstrations related to different topics. Id. ¶ 40. In 16 the past, Plaintiff Hadnagy hosted a village focused on social engineering (the “SEVillage”). Id. 17 ¶¶ 45–46. In January 2022, Def Con informed Plaintiff Hadnagy that he could no longer attend 18 the Event based on reported violations of the Code of Conduct. Id. ¶¶ 58–59. On February 9, 19 2022, Def Con published a Transparency Report announcing Plaintiffs’ ban from future Events: 20 We received multiple [Code of Conduct] reports about a DEF CON Village leader, Chris Hadnagy of the SE Village. After conversations with the reporting 21 parties and Chris, we are confident the severity of the transgressions merits a ban from DEF CON. 22 23 1 Id. ¶ 58 (the “2/9/22 Transparency Report”).1 On July 28, 2022, Defendants published an 2 Updated Transparency Report explaining treatment of Code of Conduct violations, including 3 meeting with parties, witnesses, and victims; reviewing evidence; and determining permanent 4 bans for repeat offenders and egregious offenses. Defendants based their safeguards on

5 recommendations from the National Network to End Domestic Violence and the Violence 6 Against Women Office at the US Department of Justice. Dkt. 37, Ex. 2 at 2-4 (7/28/22 Update). 7 Plaintiffs deny violating the Code of Conduct, meeting or discussing allegations of code 8 violations with Defendants, and alleges Defendant Moss ignored his attempts to meet and 9 provided no reason for the lifetime ban. Dkt. 1-1, ¶ 61, ¶ 62. Defendants ignited a firestorm 10 within the information technology and security communities across social media platforms and 11 prominent media outlets after posting the Transparency Report. These outlets quoted Defendants' 12 statements and asserted Plaintiff Hadnagy was a sexual predator. Id. ¶ 66-72. 13 Defendants were aware that presenting the Transparency Report would lead the public to 14 understand it in this manner as Defendants’ past lifetime bans were exclusively due to extreme

15 sexually predatory behavior. Dkt. 1-1, Compl. ¶¶ 100-101, 103-104, 107-108. False rumors 16 about Plaintiff Hadnagy spread rapidly, tarnished his reputation, and he was likened to the 17 “Harvey Weinstein” of the information security industry in a public post. Id. ¶ 108. 18 In January 2023, Plaintiffs sued Defendants in the Eastern District of Pennsylvania. 19 Following dismissal of that lawsuit for lack of personal jurisdiction, Defendant Moss published 20 an update to Def Con’s website (the “Update”): 21 “During our investigation we spoke directly with Mr. Hadnagy about claims of his violations of our Code of Conduct. He confirmed his behavior and agreed to 22 stop. Unfortunately, the behavior did not stop […] Our investigation also revealed

23 1 Defendants refer to this publication as the Ban Announcement. 1 that DEF CON is not the only security conference to receive complaints about Mr. Hadnagy’s behavior. For example, Black Hat received complaints, conducted 2 their own investigation, and removed Mr. Hadnagy from their Review Board.”

3 Id. ¶¶ 80, 98. Plaintiff Hadnagy denies Defendants ever spoke with him about the alleged Code 4 violations and he never “confirmed his behavior.” Id. ¶¶ 61-62, 84. Most of Plaintiffs’ business 5 associates in Las Vegas, including Black Hat, terminated their contracts with Plaintiffs based on 6 Defendants’ statements in the Transparency Report. Id., Compl. ¶¶ 42-43; ¶¶ 73-76. Defendant 7 Moss published these statements (and additional statements that Plaintiff’s employment practices 8 were racially discriminatory and fostered a hostile work environment based on gender) in private 9 to “other industry leaders who host similar annual conventions in Las Vegas, Nevada, including 10 the organizers of Black Hat.” Id. ¶ 113. 11 Around February of 2022, Black Hat representatives issued a ban of Plaintiffs from Black 12 Hat’s conference, citing Defendants’ Transparency Report. Dkt. 1-1, Compl. ¶¶ 73-76. Black 13 Hat’s website lists Defendant Moss as a director of Black Hat. Id., ¶ 77. Defendant Moss 14 continued to make disparaging and false statements to other Black Hat representatives, including 15 allegations that Plaintiff Hadnagy perpetrated repeated sexual harassment and admitted to these 16 acts. Id. ¶¶ 78-79. Defendant Moss intended to “entangle Plaintiffs in controversy and thwart 17 Plaintiffs’ efforts to conduct a standalone version of the SEVillage, and benefit from Plaintiffs’ 18 SEVillage by using a replica village (the “Social Engineering Community Village”) meant to 19 attract the same audience and goodwill Plaintiffs had cultivated for years. Id. ¶¶ 94, 140. 20 B. Procedural History 21 Plaintiffs sued Defendants in the Eastern District of Pennsylvania, and on January 5, 22 2023, Judge Wendy Beetlestone dismissed the case for lack of personal jurisdiction. See 23 Hadnagy v. Moss, No. CV 22-3060, 2023 WL 114689 (E.D. Pa. Jan. 5, 2023). 1 On August 9, 2023, Plaintiffs filed a Complaint in the Eighth Judicial District Court, 2 Clark County, Nevada. See Christopher J. Hadnagy et al. v. Jeff Moss et al., Case No. A-23- 3 875618-C. Defendants removed the action to the Federal District Court of Nevada on August 29, 4 2023 (Dkt. 1) and thereafter, filed a motion to dismiss, or in the alternative, a motion to transfer

5 venue to the Western District of Washington. Dkt. 15. Judge Cristina D. Silva granted the motion 6 to transfer venue to this Court and did not reach the merits of Defendants’ motion to dismiss. 7 Dkt. 21 at 1, n.1 (“Transfer Order”).

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Hadnagy v. Moss, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hadnagy-v-moss-wawd-2024.