Northwest Adventures was a federally registered trademark, owned by Northwest Adventures, Inc. The company was based in the State of Washington and conducted "adventure excursions" that featured whitewater rafting, hiking, camping and getting in touch with nature. Not all of Northwest Adventure’s customers were happy with the treatment that they received from Northwest. Several disgruntled customers got together and paid for a web site with the domain name NorthwestAdventuresSuckBigtime.com. Northwest Adventures was a client of Simple because they often hosted "blue grass" concerts and occasionally collected a lot of cash at those events. Northwest Adventures demanded that Simple "do something" about the NorthwestAdventuresSuckBigtime.com web site, but Simple explained that he was not in charge of domain names on the Internet. Simple did say that Securex.com would represent Northwest Adventures before ICANN (the Internet Corporation for Assigned Names and Numbers), a private, not for profit, corporation.
On behalf of Northwest Adventures, Simple filed a complaint to ICANN, which then gave Simple of a list of four Online Dispute Resolution companies. Simple demanded that ICANN immediately reassign the NorthwestAdventuresSuckBigtime.com name to Northwest Adventures, but ICANN refused again recommending that Simple pursue the matter before one of ICANN's Online Dispute Resolution companies such as WIPO (World Intellectual Property Organization). An arbitrator recommended by WIPO recommended that ICANN reassign the disputed web site to Northwest Adventures, but the owners of NorthwestAdventuresSuckBigtime.com web site appealed the decision of the WIPO arbitrator to a federal court in the U.S.
The owners of NorthwestAdventuresSuckBigtime.com web site all lived in Jackson Hole, Wyoming. Simple directed one of computer “geek” employees to sabotage the NorthwestAdventuresSuckBigtime.com web site so that whenever a browser clicked on that web site, it would be transported to a Northwest Adventures web page that showed satisfied customers hiking and catching fish under the supervision of a Northwest Adventures guide.
Meanwhile, Simple sent several of his largest henchmen including Guido, Hook, and Mr. Flea to the State of Washington to provide security for an outdoor concert sponsored by Northwest Adventures featuring Neil Young, among other performers. At the concert, apparently Neil had been in contact with the owners of NorthwestAdventureSuckBigtime.com web site and started to harangue the audience about what a “sellout” Northwest Adventures was. A fight broke out when Guido and Hook tried to take the microphone from Neil Young. Mr. Flea viciously assaulted a customer who tried to come to the aid of Neil Young and the customer suffered a broken arm and a serious concussion. Neil Young was also injured in the altercation.
Finally, Governor Easley was advised of the content of Simple’s Securex.com web site and stated that was an embarrassment to the State and that it should be dismantled. The Governor sent the police as well as a programmer from the state’s Information Technology Division to either takedown the Securex.com web site that had the anti-Arab