Axl vs Activision

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***Disclaimer!***

I am not attorney. Everything below is my opinion and not at all legal advice. The writing below is purely for discussion and not to be viewed as factual. I could be wrong about my sources, quotes, names etc. My words are only for discussion purposes and not to be taken as fact. I could be completely wrong about everything written. This thread is purely for discussion purposes and no comments or sources are to be taken as fact. Enjoy. I apologize if this looks sloppy but I tried to organize my thoughts as best I could.

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I read through Rose's complain and found some defects in the arguments presented. Primarily, Rose argument appears weak without substantial evidence. Moreover, his arguments are contradicted by his own actions in a hypocritical way. In sum, I see that Activision could use Rose's own behavior, words, and writings against him. Rose will lose.

Defects in Complaints:

[1] Fraud Intentional Misrepresentation; [2] Fraud - Concealment;

If anyone could be viewed as concealing and misrepresenting information, it is Rose. Rose in paragraph 11.

11. Rose is Currently the only original member of Guns N' Roses. Rose is the majority owner of and controls (i) Guns N' Roses business and assets; (ii) the rights to the Guns N' Roses name, (iii) trademarks and copyrights associated with the band; and (iv) the right to license and exploit the Guns N' Roses name and music. Rose's permission, consent and authority are required to use Guns N' Roses intellectual property.

Rose is failing disclose in clear terms exactly how much of "Guns N' Roses" he controls. Part (i),(ii),(iii),(iv) are extremely vague. This section does not indicate nor acknowledge what parts of Guns N' Roses are controlled by Slash and Duff. Moreover, Activision should ABSOLUTELY make a demand for Rose to PROVE and show exactly what parts of Guns N' Roses he absolutely does and does not control. Any contracts from 1992 and later would finally see the light of day.

Rose is claiming that Guitar Hero III would "confuse" the public as to what is and what isn't Guns N' Roses while at the same time he is attempting to intentionally mislead potential judges and jurors as to what of "Guns N' Roses" he actually controls. Since the spirit of this lawsuit is based on concealing and misrepresentation, paragraph 11 should absolutely be used against him by Activision.

This is painful but true. Rose recently allowed a former member of Guns N' Roses, Duff McKagan to play on stage with rest of "Guns N' Roses". If dilution of brand name is as important as he claims, Rose would not have allowed this event to happen. Activision should absolutely use this fact against him.

Moreover, the burden is on the trademark owner to prevent the mark from falling into genericide or abandonment. Guitarists Buckethead and Robin Finck for instance is not a member of Guns N' Roses yet a photograph was still provide on the Guns N' Roses facebook page under a photo album "Chinese Democracy".

[3] Negligent Misrepresentation

Rose is suing not just activision but also DOES 1 - 10 (as in John Doe) that he won't name. These parties are probably the agents/representatives that work for Activision and I doubt it was his own representatives such as Milligan from Sussman & Associates that failed to get desired agreements in writing nor Beta Lebeis that also didn't get desired agreements in writing. I believe Rose's team is using negligence a catch-all since they may believe conflicting contracts were signed by Slash and Rose. They may not be able to determine "why" Activision allegedly behaved the way they did whether intentionally or negligently until trial.

The

6. Plaintiffs are informed and believe, and on that basis allege, that Defendants Does 1 through 10, inclusive, are individually and/or jointly liable to Plaintiffs for the wrongs alleged herein. The true names and capacities, whether individual, corporate, associate or otherwise of Defendants DOES 1 through 10, inclusive are uknown to Plaintiffs at this time. Accordingly, Plaintiffs sue Defendants DOES 1 through 10, inclusively, by fictitious names and will amend this Complaint to allege their true names and capacities after they are ascertained.

55. On February 14, 2010, Guns N' Roses played a Valentine's Day show at the Rose Bar in Gramercy Park Hotel in New York City. Tim Riley from Activision was in attendance and approached Rose after the show. In tears, he apologized for the ways in which Rose and Guns N' Roses had been mistreated by Activision. He said "I can't sleep at night" and asked Rose to forgive him.

Two years into the issue at hand, Rose provides evidence that he could have been deceived but this does not matter at this point. Whether Mr. Riley was crying or not does not change the fact that Rose's team was sophisticated enough to review the contract in good faith and agree to the terms. Business would come to a screeching halt if matters of hearsay would supersede what is and isn't in a complete contract.

[4] Unjust Enrichment

This is a contingency factor based on the alleged tort committed by Activision and Does 1 - 10. Axl in his part alleges that there was unjust enrichment. The only additional paragraphs under this complaint are 72,73, and 74. The paragraphs don't lend any additional argument or show ho Activision was made "unjustly enriched". Rose notes that more will be determined at trial under paragraph 74. Paragraph 73 reflects the weakness in his argument.

73. Activision has received and retained a substantial benefit by using the Guns N' Roses brand and "Welcome to the Jungle" in GH III to the detriment and at the expense of Plaintiffs and it would be inequitable and/or unconscionable for Activision to retain that benefit under the circumstances..

It would be difficult to "to the detriment and at the expense of Plaintiffs" since there was no consideration from Rose as I can see other than license to use a song. In this article, Rose does not appear to aware of the issue until the product hit the stores. This negligence on his part invalidates his statements about the Activision's profit from a product being unconscionable. I cannot see how Rose would be able to substantiate the detriment.

[5] Breach of Contract

Rose alleges a breach of contract. In the scope of the complaint, Rose does not indicate that the material breach was based on a contract made in writing other than the email.

30. In May 2007, Milligan spoke with Young regarding Roses's concerns. Young again reassured Milligan that no Slash images or VR songs would be used in GH III or in connection with "Welcome to the Jungle." In a follow up confirmatory email, he wrote: "In light of our earlier conversation, this email serves to confirm that given the approval for "Welcome to the Jungle', we have no intention of using Velvet Revolver in Guitar Hero 3."

This confirmation is in writing but still during the period of negotiations. This is not the point where contracts were actually signed. For good reason, this email should not be consider a contract nor part of a contract as it is still incomplete.

[6] Promissory Estoppel

This is the kicker. This is the issue that is really going to fall apart fast. Promissory Estoppel should not apply. Rose and his agents/representative acting on behalf of him and his entities shoudl have been at arms length with other parties involved at all times. If issues with Slash imagery in GH III was as important as Rose alleges, they could have and should have demanded that clause be included in the contract. Promissory Estoppel is being referenced here as an extreme because the statute of frauds invalidate the verbal contract. This is not a case that should involve Promissory Estoppel given the lack of consideration from Rose's side. Rose waited years before bringing this lawsuit to life on 11/23/2010. Rose claims that he gave forebearance of not suing for additional promises--so his camp forgot to ask for the new additional agreement in writing...again???

Promissory Estoppel can be a legitimate reason to validate a verbal contract, especially when one party has provided substantial consideration as Irving Azoff had in services, on the contingency that he would be compensated in a future date. It would be unconscionable for someone to work for nothing.

If Rose could sue anyone, it would be his own attorneys and representatives that would have reviewed the GH III agreements. Rose claims ignorance in paragraphs 59 and 70 but Rose and his parties are sophisticated enough not be viewed as ignorant. For a reasonable person standard, given Rose past involvement with contracts he has no one to blame but himself.

Rose in his chats describing the point where Slash signed his name away stated:

"It was added to the contract and everyone signed off on it. It wasn’t hidden in fine print etc as you had to initial the section verifying you had acknowledged it."

Activision, you can find that quote here:

Defects in Paragraphs:

Paragraph 43. Rose acknowledges what defines Slash's image and likeness:

43. The centerpiece of the box cover of the GH III features an animated depiction of Slash, with his signature black top hat, long dark curly hair, dark sunglasses and nose-piercing. The appearance of Slash on the cover of GH III was never disclosed to Rose or his representatives. The television and Internet commercial accompanying the game's release features special effects of the real-life Slash emerging from the body of another young man to play a guitar solo form a VR song along with the tag line "Is there a guitar hero in you?"

Great, now it is in writing, as a permanent record, what is officially Slash's signature image, as acknowledged by Rose's lawsuit. The best thing Activision could present at trial is Axl's disregard for using Slash's image and likeness--hiring a guitarist with top hat and dark sunglasses. This really is as important here but would be paramount in future cases. For this case though, it may be fun to joke around on message boards but it would be in Activision interest to use this contradiction against Rose.

Paragraphs 21-25: are unconscionable and impossible to enforce and the paragraphs do not present valid arguments.

21. Given the continuing importance of "Welcome to the Jungle" to the band Guns N' Roses and to Rose personally, who is the primary writer and originator of the song and it's co-author. Rose is very cautious in his approval of any license for its use. Rose has always acted vigilantly to preserve the integrity of the GUns N' Roses name and reputation and to ensure its ongoing success and this includes

the use of its signature song.

"Its" signature song? From what I have read, Axl was allowed to start a band called "Guns N' Roses" and he does not own Guns N' Roses in all capacities. The possessive "Its" signature song is very vague semantics when Rose is attempting to make a clear distinction between the old and new Guns N' Roses. As this was a song written by Slash and Rose, Rose has not made it clear that "Welcome to the Jungle" was not written by his new band after 1996.

22. In order to promote Guns N' Roses, Rose dilegently attempts to channel fan and media attention to the current status of the band including its current lineup, and focus on the bands current endeavors and plans for the future. Rose and Guns N' Roses pursue a forward-looking outlook rather than one that dwells on the past. Nonetheless, members of the tabloid media have tended to focus and mythologize a rift within the band that occurred in 1996, when one of the band's best guitarists, Saul Hudson, aka "Slash" and Guns N' Roses parted ways.

Rose once referred to Slash as "Vargas" with respect to boxer "De La Hoya". This paragraph shows that Rose may be acting disingenuously and this undermines his complaint when Slash is referred to as "one of the band's best guitarists". Activisiion can refer to this video clip

for evidence and should also use it.

23. A preoccupation on the part of some members of the media with the right between Slash and Guns N' Roses has led to a distorted public perception between the images and careers of Slash and Guns N' Roses. Despite the fact that Slash has had nothing to do with Guns N' Roses' ongoing popularity and success since 1996, his association with the band lingers, at least as far as certain members of the media are concerned.

This is false and will be disproved easily. This paragraph can also be used against him for Rose appears to be lacking respect for the facts.

24. Therefore, Rose is careful not to license any use of the band's name and intellectual property that would further perpetuate confusion in the public mind between Slash and Guns N' Roses or promote the individual interests of Slash and his projects, including his band Velvet Revolver ("VR"). Simply put, the association between Slash and Guns N' Roses ended almost fifteen years ago; in furtherance of Guns N' Roses and to avoid confusion and dilution of the brand, Rose resists any attempts to revive or strengthen this past association.

The association between Slash and Guns N' Roses still persists depending on the semantics involved. Activision should be able to use words here against Rose once again.

25. Activision was keenly aware of Rose's concerns in these regards. Therefore, it began spinning a web of lies and deception to conceal its true intentions to not only feature Slash and VR prominently in GH III, but also promote the game by emphasizing and reinforcing an association between Slash and Guns N' Roses and the band's song "Welcome to the Jungle."

Roses's attempt to compete against any pre 1997 Guns N' Roses partnership. Rose will have difficulty substantiating segregating Slash from a Guns N' Roses song and ask that to be incorporated into a contract whereby it would be unconscionable.

Here is a rough transcription of the complaint:

W. AXL ROSE, an individual and on behalf of a band

known as Guns N' Roses; Black Frog Music, INC., a

California corporation. Black Frog Entities Inc, a

Delaware corporation; and DOEs 1 through 10,

inclusive

Complaints

(1) Fraud - Intentional Misrepresentaiton

(2) Fraud - Concealment

(3) Negligent Misrepresentation

(4) Unjust Enrichment

(5) Breach of Contract

(6) Promissory Estoppel

Jury Trial Demanded

Plaintiffs W. Axl Rose ("Rose"), individually and on behalf of a band knowns as Guns N' Roses, Black Frog Music, Inc. and Black Frog Entities, Inc. (collectively, "Plaintiffs") allege against Activision Blizzard, Inc. and Activision Publishing, Inc. (together, "Activision"), and DOES 1 through 10, inclusive, and each of them (collectively, "Defendants"), as follows:

1. At all times mentioned herin, Plaintiff Rose was an individual residing in Los Angeles County, California.

2. At all times mentioned herein, Plaintiff Black Frog Music, Inc. was and is a California corporation with its principal place of business in Los Angeles County, California. Black Frog Music, Inc. is a party to Rose artist recordng agreement.

3. At all times mentioned herein, Plaintiff Black Frog Entities, Inc. was and is a California corporation with its principal place of business in Los Angeles County, California. Black Frog Entities, Inc. is a party to Rose's publishing administration agreement.

4. Plaintiffs are informed and believe, and on that basis allege, that at all times relevant for purposes of this Complaint Defendant Activision Blizzard, Inc. was a Delaware corporation duly authorized to conduct business in the State of California, with its principal business in the city of Santa Monica, Los Angeles County, California.

5. Plaintiffs are informed and believe and on that basis allege, that at all times relevant for purposes of this Complaint Defendant Activision Publishing, Inc. was a Delaware corporation duly authorized to conduct business in the State of California, with its principal place of business in the City of Santa Monica, Los Angeles County, California. Plaintiffs are informed and believe that Activision Publishing, Inc. is a wholly owned subsidiary of Activision Blizzard, Inc.

6. Plaintiffs are informed and believe, and on that basis allege, that Defendands Does 1 through 10, inclusive, are individually and/or jointly liable to Plaintiffs for the worngs alleged herein. The true names and capacities, whether individual, corporate, associate or otherwise of Defendants DOES 1 through 10, inclusive are uknown to Plaintiffs at this time. Accordingling, Plaintiffs sue Defendants DOES 1 through 10, inclusively, by fictitious names and will amend this Complain to allege their true names and capacities after they are ascertained.

7. Plaintiffs are informed and believe, and on that basis allege, that except as otherwise alleged herein, each of the Defendants is, and at all times relevant to this Complaint was, the agent employer, partner, joint venture, alter ego, affiliate, and/or co-conspirator of the other Defendants and, in doing the things alleged herein, was acting within the course and scoep of such positions at the direction of, and/or with the permission, knowledge, consent, and/or ratification of the other Defendants.

JURISDICTION AND VENUE

8. The Superior Court for the State of California in the County of Los Angeles is the proper jurisdiction and venue for this action because substantial portion of the acts giving rise to Defendants's liability occurred in the County of Los Angeles.

FACTS COMMON TO ALL CAUSES OF ACTION

GUNS N ROSES AND AXL ROSE

9. Guns N' Roses is one of the most popular and famous rock bands of all times. The band has sold more than 100 million records, had numerous Top 10 hits, sold out arenas and stadiusm worldwide, won numerous awards and accolades, and by all accounts redefined rock music. Guns N' Roses has reached iconic status.

10. Rose is the legendary lead vocalist and songwriter of Guns N' Roses and one of the band's founders and original members. Rose has been heralded as one of the "100 Greatest Singers of All Time" by the periodical Rollling Stone magazine and is widley regarded as one of rock's all-time greatest "front men."

11. Rose is Currently the only original member of Guns N' Roses. Rose is the majority owner of and controls (i) Guns N' Roses business and assets; (ii) the rights to the Guns N' Roses name, (iii) trademarks and copyrights associated with the band; and (iv) the right to license and exploit the Guns N' Roses name and music. Rose's permission, consent and authority are required to use Guns N' Roses intellectual property.

ACTIVISION and GUITAR HERO III

12. Activision Blizzard, Inc. is a publicly traded company incorporated in Delaware and headquartered in Santa Monica, California. Activision Blizzard, Inc., along with its wholly owned subsidiary Activision Publishing, Inc. (together, with Activision Blizzard, Inc., "Activision"), is in the business of developing, publishing, and distributing interactive entertainment software, peripheral products, and online games. One of Activision's most successful intellectual properties is the "Guitar hero" gaming franchise, a series of music-related video games first published in 2005 and aquired by Activision in 2006. Guitar Hero has generated well over a billion dollars in revenue for activision.

13. The Guitar Hero format requires players to depress colored buttons on the "fret" of a guitar-shaped game controller (slung over the shoulder like a real guitar) to match notes that scroll-on screen in time to popular rock guitar songs, which are played in sequence throughout the game to a virtual audience of cheering fans.

14. The novelt of prentending to play rock guitar along with popular hard rock songs to throngs of adoring virtual fans is the key to Guitar Hero's appeal. As the name implies, the game taps into the myth and fantasy of "guitar hero/rock superstar" and relies heavily on the proven allure and popularity of the hit rock songs utilized. This formula has proven to be immensely lucrative for Activision. Activison has touted its 2009 sequel in the "Hero" franchise as the highest grossing new intellectual property in the United States and Europe for all that year.

15. Given that popular music content is an essential component to Guitar Hero. Activision actively pursues licenses to use popular rock songs as content for each sequel of the game.

"WELCOME TO THE JUNGLE"

16. In or around February of 2007, Activision contacted Guns N' Roses' licensing administrator, Sussman & Associates, to request permission to use the Guns N' Roses song "Welcome to the Jungle" in its yet-to-be released sequel to the Guitar Hero franchise.

17. "Welcome to the Jungle" is a highly renowned rock song of immense popularity. The song is regarded by fans and critics alike as one of the greatest hard rock songs of all time; in 2009 it was named the greatest hard rock song of all time by VH1 music. "Welcome to the Jungle" was the first single from Guns N' Roses debut album, "Appetite for Destruction", which has become the highest selling debut album of all time, with sales to date approaching 30 million.

18. Activision understood the extraordinary value of Guns N' Roses and "Welcome to the Jungle" could add to the Guitar Hero platform. "Welcome to the Junlge" was and is a perfect fit for Activision's Guitar Hero franchise and especially for its third installment, "Guitar Hero III: Legends of Rock" ("GH III"). GH III was set for release in 2007 and is the first game in the series to feature a storyline in which the band starts as a local sensation playing local venues and struggles through a series of challenges to achive worldwide fame performing at venues around the world. Along the way, the band has to overcome an evil music producer named Lou who forces the band to sign a recording contract that is actually a contraact for their souls. The band has to battle Lou in a battle for their souls in "Lou's Inferno" in order to return to the mortal world as "Rock Legends."

19. No other rock song could more perfectly capture this transformative spirit and Faustian bargain them of GH III than "Welcome to the Jungle." The song itself is about the struggle to overcome in a figurative jungle where "you can taste the bright lights but you won't get them for free" and the ambition that "if you got a hunger for what you see you'll take it eventually." When "Welcome to the Jungle" was released, it instantly elevated Guns N' Roses from and up-and-coming band in the Hollywood, California local rock scene into one of the most popular rock groups in the world.

20. Guns N' Roses and its members were transformed into true "Rock Legends" as a result of the song. Activision understood this connection and the enormous potential success of a GH III that included "Welcome to the Jungle" and was willing to do whatever it took to get the song.

21. Given the continuing importance of "Welcome to the Jungle" to the band Guns N' Roses and to Rose personally, who is the primary writer and originator of the song and it's co-author. Rose is very cautious in his approval of any license for its use. Rose has always acted vigilantly to preserve the integrity of the GUns N' Roses name and reputation and to ensure its ongoing success and this includes

the use of its signature song.

22. In order to promote Guns N' Roses, Rose dilegently attempts to channel fan and media attention to the current status of the band including its current lineup, and focus on the bands current endeavors and plans for the future. Rose and Guns N' Roses pursue a forward-looking outlook rather than one that dwells on the past. Nonetheless, members of the tabloid media have tended to focus and mythologize a rift within the band that occurred in 1996, when one of the band's best guitarists, Saul Hudson, aka "Slash" and Guns N' Roses parted ways.

23. A preoccupation on the part of some members of the media with the right between Slash and Guns N' Roses has led to a distorted public perception between the images and careers of Slash and Guns N' Roses. Despite the fact that Slash has had nothing to do with Guns N' Roses' ongoing popularity and success since 1996, his association with the band lingers, at least as far as certain members of the media are concerned.

24. Therefor, Rose is careful not to license any use of the band's name and intellectual property that would further perpetuate confusion in the public mind between Slash and Guns N' Roses or promote the individual interests of Slash and his projects, including his band Velvet Revolver ("VR"). Simply put, the association between Slash and Guns N' Roses ended almost fifteen years ago; in furtherance of Guns N' Roses and to avoid confusion and dilution of the brand, Rose resists any attempts to revive or strengthen this past association.

25. Activision was keenly aware of Rose's concerns in these regards. Therefore, it began spinning a web of lies and deception to conceal its true intentions to not only feature Slash and VR prominently in GH III, but also promote the game by emphasizing and reinforcing an association between Slash and GUns N' Roses and the band's song "Welcome to the Jungle."

ACTIVISION BEGINS ITS CAMPAIGN OF LIES AND DECEPTION TO OBTAIN WELCOME TO THE JUNGLE

26. On February 26, 2007, Brandon Young, Activision's Music Supervisor and Licensing Coordinator, requested approval through Wayne Milligan of Sussman & Associates, Guns N' Roses' licensing representative and administrator to use "Welcome to the Jungle" in GH III.

27. Rose and his team carefully deliberated the request. A key concern of ROse was the way in which the song "Welcome to the Jungle" would be depicted in GH III. Rose anticipated the possibility that imagery of Slash and VR might be used in GH III. As part of his image Slash generally wears a black top hat and dark sunglasses when he plays onstage and he is easily recognizable by those feature, as well as by his long curly dark hair and nose-piercing.

>>> McDonalds?

28. In order to avoid conflation of the images and reputations of Guns N' Roses and Slash and VR, Rose reasonbly did not want any imagery of Slash or the songs or VR to be used in association or conjunction with Guns N' Roses material. At the initial request for inclusion of "Welcome to the Jungle" in GH III, Rose inquired as to whether Activision intented to use [underline]any[/underline] images of members of the old GUns N' Roses lineup, the then-current lineup, or VR in the game. Rose told Activision that he would consider its request if Activision would confirm that no images, avatars or other characters of any of the old lineup or then-current lineup of Guns N' Roses or VR would be used. Activision verified that no images, avatars or other characters of any of the old lineup or then-current lineup of Guns N' Roses or VR would be used and "Welcome to the Jungle" would not be used in any way that would indicate an association between SLash and Guns N' Roses or promote Slash's separate and post-Guns N' Roses interests.

29. However, before giving his approval, Rose began learning through online sources that Activision was planning to use the songs of VR and prominently feature Slash in GH III. This greatly increased the apprehension that Guns N' Roses and "Welcome to the Jungle" were going to be misused and/or misrepresented in GH III.

30. In May 2007, Milligan spoke with Young regarding Roses's concerns. Young again reassured Milligan that no Slash images or VR songs would be used in GH III or in connection with "Welcome to the Jungle." In a follow up confirmatory email, he wrote: "In light of our earlier conversation, this email serves to confirm that given the approval for "Welcome to the Jungle', we have no intention of using Velvet Revolver in Guitar Hero 3."

31. Activision thereafter stepped up its efforts to deceive Rose. Tim Riley is Executive Vice-President of Music Affairs, amde further misrepresentations in an effort to conceal Activision's plans to prominently feature Slash and VR in GH III, and associate Slash with Guns N' Roses and "Welcome to the Jungle."

32. Riley sought to reassure Rose, through his representative Beta Lebeis, that in no uncertain terms, if given the authorization to use "Welcome to the Jungle."

33. In numerous conversations occurring in May 2007, Riley reassured and represented to Lebeis that none of the "rumors" Rose was reading on the Internet regarding the planned use of Slash and VR in GH III were true. For example, in one conversation, Riley flatly denied the rumors, stating "Come on Beta, you know you can't believe everything you read on the Internet."

34. While the form and substance of these conversations may have occasionally varied the central message and operative language used did not: Riley "guaranteed" that, provided Rose agreed to approve Activision's use of "welcome to the Jungle," there would be no use of Slash in association with Guns N' Roses and "Welcome to the Jungle" and no VR in GH III.

35. On June 5, 2007, relying on these numerous guarantees of Riley, as well as the representation of Young and their prior agreement, Rose authorized Sussman & Associates to sign approval for Universal Music Enterprises to release the master of "Welcome to the Jungle" and for the publishing synch license of the song. With these licenses Activision was free to use "Welcome to the Jungle" in GH III under the terms and conditions agreed to by Activision and Rose.

ACTIVISION'S LIES CONTINUE

36. In or around July 2007, press releases and other media reports began circulating indicating that Slash and Velvet Revolver songs would be featured in Guitar Hero III.

37. One of these releases, dated July 10, 2007, included a quote from an executive vice president of Activision publishing stating that "Guitar legend Slash, combined with Guitar Hero III: Legends of Rock's robust soundtrack and innovative new game feature, will continue to solidify the brand's leadership in the rhythm-action genre..."

38. Upon learning that Activision had lied and his representatives, Rose, who was in Japan as part of an extensive Guns N" Roses tour of Asia acted immediatedly to rescind the authorization he had given under false pretenses. Rose remained adamant that any use of Slash or his likeness in GH III would be contrary to his understanding and agreement to authorize any use of "Welcome to the Jungle".

39. Activision then redoubled its effors to conceal the truth and again deceive Rose into believing that they would abide by their guarantees and agreements with Rose. In a conversation between Milligan and Riley on July 13, 2007, Riley explained that the press releases from the prior week had only included Slash for purposes of a trade show. Activision re-confirmed, again in a conscious disregard of the truth that Slash's avatar would not appear in GH III or at any time "Welcome to the Jungle" was being played.

40. In August 2007, Riley told Rose's representatives that because of Rose's concerns, Activision had agreed to pull any VR songs from GH III and made certain that no Slash imagery would appear in the game.

41. Relying on Activion's representations, Rose did not pull the license for use of "Welcome to the Jungle" in GH III.

GUITAR HERO III IS RELEEASED AND PROMOTED IN DIRECT VIOLATION OF THE AGREEMENTS AND GUARANTEES MADE BY ACTIVISION

42. On October 28t, 2007, Activision released GH III. The game prominently features Slash in direct connection with the use of "Welcome to the Jungle," exploits the prior association between Slash and Guns N' Roses, promotes Slash's and VR's separate interests, and includes VR tracks as available downloads, all in direct contravention of Activision's prior representations and agreement.

43. THe centerpiece of the box cover of the GH III features an animated depiction of Slash, with his signature black top hat, long dark curly hair, dark sunglasses and nose-piercing. The appearance of Slash on the cover of GH III was never disclosed to Rose or his representatives. The television and Internet commercial accompanying the game's release features special effects of the real-life Slash emergin from the body of another young man to play a guitar solo form a VR song along with the tag line "Is there a guitar hero in you?"

44. When the song "Welcome to the Jungle" is selected for play in GH III, an avatar of Slash is depicted throughout the entire approximately four-minute song (none of the other avatars are designed to depict any of the real then-current members of Guns N' Roses). Virtual camera angles focus in on the Slash avatar at points in the song and it is featured prominently throughout. When playing "Welcome to the Jungle" on GH III, a fret board appears on the screen containing images of what appear to be Slash's top had as well as drawings of guns and roses.

45. Upon informaiton and belief, the Slash avatar was created using a special technology called mostion capture, in which real life individuals are outfitted with sensors that capture their movements so that the animated characters that depict them have more life-like movements. This special effects technology takes a long time to implement, confirming that Activision knew well in advance that it was going to use the Slash Avatar extensively and during "Welcome to the Jungle," while at the same time deceiving Rose and his agents.

46. The Slash avatar is one of the three "boss" characters in the game; during any particular song, including "Welcome to the Jungle," a player who has earned enough points can choose Slash as their own avatar. A player can thus easily choose the Slash avatar and play in time to "Welcome to the Jungle." When Slash is selected as an avatar, a paragraph appears stating: "As a member of Guns N' Roses, Slash's Snakepit, and Velvet Revolver, Slashhas established himself as a true guitar hero..."

47. Another special feature of the game is a "Battle Mode," in which a player can challenge the Slash avatar to a guitar duel. After defeating Slash in the guitar battle, the user is offered the choice to play an encore of "Welcome to the Jungle" alongside the Slash avatar. While the famous opening riff of "Welcome to the Jungle" begins sounding, the game's camera angle zoom's in on Slash playing guitar.

48. On Activision's official GH III website, users can find an animated depiction of Slash above an animated guitar amplifier icon. When the user clicks on the icon, an audio clip "Welcome to the Jungle" is played. In addition, on the website's "Song List" for GH III, the "Guitar Battle vs. Slash" and "Welcome to the Jungle" are listed in sequence.

49. Activision also includes VR tracks as downloadable additional songs for GH III.

ACTIVISION USES ANOTHER GUNS N' ROSES SONG, "SWEET CHILD O' MINE," WITHOUT ANY AUTHORIZATION TO PROMOTE GH III.

50. Adding insult to injury, Activision used another famous Guns N' Roses song, "Sweet Child O' Mine," for an exteneded period of time in connection with an Internet promotion of GH III, again featuring Slash as part of the promotion. Although Sweet Child O' Mine had been licensed to use in Guitar Hero II, there was no authorization at all to use it in GH III and a request for authorization had never even been made.

51. When confronted with this fact, Activision simply pointed the finger at the Internet website Yahoo!, stating that it was entirely to blame for unauthorized use of the song.

ACTIVISION ACKNOWLEDGES ITS GUILT AND NEGOTIATES IN AN ATTEMPT TO FORESTALL OR PREVENT LEGAL ACTION

52. On November 26, 2007, Young admitted wrongdoing; he stated that Activision had been attempting to "make good with [VR] given Slash was included as a character in the game" and had decided to make Velvet Revolver available as a download for GH III, "several months following our initial discussion." This was at the same time when Activision was representing precisely the opposite to Rose and his representatives: that no VR material would be used in connection with the game.

53. As a result, Rose and his representatives at that time discovered that Activision had been deceiving them all along and never intended to abide of its "guarantees and agreements."

54. Starting in December 2007 and continuing in 2008. Activision engaged in negotiations with Guns N' Roses' manager at the time, in a calculated efford to forestall or prevent a lawsuit. As a means of compensating Rose and Guns N' Roses for the wrong it perpetrated. Activision floated the idea of a video game with a theme based on "Chinese Democracy," Guns N' Roses' new album.

55. On February 14, 2010, Guns N' Roses played a Valentine's Day show at the Rose Bar in Gramercy Park Hotel in New York City. Tim Riley from Activision was in attendance and approached Rose after the show. In tears, he apologized for the ways in which Rose and Guns N' Roses had been mistreated by Activision. He said "I can't sleep at night" and asked Rose to forgive him.

FIRST CAUSE OF ACTION

(Fraud - Intentioinal Misrepresentation)

(Against All Defendants)

56. Plaintiffs re-allege and incorporate by reference Paragraphs 1 through

55 of this Complaint as set forth herein in full.

57. Defendants made misrepresentations of material fact as described in the preceding paragraphs including, but not limited to, falsely representing that there would be no use in GH III of Slash imagery in association with Guns N' Roses and, more specifically, in association with "Welcome to the Jungle" and no use of VR tracks in conjunction with GH III.

58. Defendants knew that its statements were false when they made them and made representations with the intent to deceive and defraud Plaintiffs and to fraudulently induce them into authorizing the use of "Welcome to the Jungle" in conjunction with GH III.

59. Plaintiffs were ignorant of the falsity of the representations made by Defendants and reasonably relied on Defendant's misrepresentations to their detriment when they authorized the use of "Welcome to the Jungle" in conjunction with GH III.

60. As a direct and proximate result of Activision's misrepresentations, Plaintiffs have suffered damages in an amount according to proof at trial and are also entitled to an award including but not limited to, disgorgement of Activision's wrongfully acquired profits believed to be in excess of twenty million dollars ($20,000,000).

61. Defendant's intentional misrepresentations were oppressive and malicious and made in willful and conscious disregard of Plaintiff's rights, thus justifying punitive damages under the California Civil Code.

SECOND CAUSE OF ACTION

(Fraud -- CONCEALMENT)

(AGAINST ALL DEFENDANTS)

62. Plaintiffs re-allege and incorporate by reference Paragraphs 1 through 55 of this Complaint as set forth herein in full.

63. Defendants concealed material facts from Plaintiffs as described in the preceeding paragraphs including, but not limited to, the facts that it intended to use Slash imagery in association with Guns N' Roses and, more specifically, in association with "Welcome to the Jungle," and to use VR tracks in conjunction with GH III.

64. Defendants concealed and suppressed the true facts with the intent to deceive and defraud Plaintiffs and to fraudulently induce them into authorizing the use of "Welcome to the Jungle" in conjunction with GH III.

65. As a direct and proximate result of Activision's fraudulent concealment, Plaintiffs have suffered damages in an amount according to proof at a trial and are entitled to an aware including, but not limited to, disgorgement of Activision's wrongfully-acquired profits believed to be in excess of twenty million dollars ($20,000,000).

66. Defendant's concealment was oppressive and malicious and made in willful and conscious disregard of Plaintiff's rights, thus justifying punitive damages under the California Civil Code.

THIRD CAUSE OF ACTION

(Negligent Misrepresentation)

(Against All Defendants)

67. Plaintiffs re-allege and incorporate by reference Paragraphs 1 through 55 of this complaint as set forth herein in full.

68. Defendants made misrepresentations of material facts as described in the preceding paragraphs including, but not limited to, falsely representing that there would be no use in GH III of "Welcome to the Jungle" and no use of VR tracks in conjunction with GH III.

69. Defendants had no reasonable basis for believing that suc representations were true. Activision should have known of their falsity because, among other things, a the time it made the false representaitons it was actively planning and negotiating a deal with Slash and VR that included Slash imagery and VR tracks in a manner contrary to the representations made to Plaintiffs.

70. Plaintiffs were ignorant of the falsity of the representations made by Activision and reasonably relied on Defendants' misrepresentations to their detriment when they authorized the use of "Welcome to the Jungle" in conjunction with GH III.

71. As a direct and proximate result of Defendents's misrepresentations, Plaintiffs have suffered damages in an amount according to proof at trial.

FOURTH CAUSE OF ACTION

(Unjust Enrichment)

(Against Defendant Activision)

72. Plaintiffs re-allege and by this reference incorporate each and every allegation contained in paragraphs 1 through 55, inclusive, of this Complaint as if set forth in this cause of action in full.

73. Activision has received and retained a substantial benefit by using the Guns N' Roses brand and "Welcome to the Jungle" in GH III to the detriment and at the expense of Plaintiffs and it would be inequitable and/or unconscionable for Activision to retain that benefit under the circumstances.

74. Activision has been unjustly enriched in an amount according to proof at trial, but believed to be in excess of twenty million dollars ($20,000,000) and Plaintiffs are entitled in equity to disgorgement of and/or imposition of a contructive trust on the amount to which Activision has been unjustly enriched.

FIFTH CAUSE OF ACTION

(Breach of Contract)

(Against Defendant Activision)

75. Plaintiffs re-allege and by this reference incorporate each and every allegation contained in paragraphs 1 through 55, of this Complaint as if set forth in this cause of action in full.

76. In or around May 2007, Activision and Plaintiffs entered into a written agreement through a series of emails, the terms of which were as follows. Plaintiffs agreed to license the use of "Welcome to the Jungle" in conjunction with GH III in exchange for Activision's promises and guarantees that VR tracks would not be used in conjunction with GH III, Slash imagery would not appear in GH III and, more specifically, Guns N' Roses and "Welcome to the Jungle" would not be associated in GH III with Slash or VR or be used in a manner to promote Slash and VR.

77. Plaintiffs performed all of their obligations under the contract by authorizing the use of "Welcome to the Jungle" in GH III.

78. Activision breached the contract when it released GH III, which prominently features Slash imagery in direct connection with the use of "Welcome to the Jungle," exploits the prior association between Slash and Guns N' Roses, promotes Slash's and VR's separate interests, and includes VR tracks as available downloads, all of which was and is directly contrary to the contractual obligations of Defendants.

79. Activision's breach was both material and opportunistic and a source of unjust enrichment at the expense of the plaintiffs.

80. As as direct and proximate result of Activisions's fraudulent concealment, Plaintiffs have suffered damages in an amount according to proof at trial and are entitled to an award including, but not limited to, disgorgement of Activision's wrongfully acquired profits believed to be in excess of twenty million dollars ($20,000,000).

SIXTH CAUSE OF ACTION

(Promissory Estoppel)

(Against All Defendants)

81. Plaintiffs re-allege and by this reference incorporate each and every allegation contained in paragraphs 1 through 55, inclusive, of this Complaint as if set forht in the cause of action in full.

82. Defendants made clear and unambiguous promises that there would be no use of VR tracks in conjunction with GH III and no use of Slash imagery in GH III or in association with Guns N' Roses and, more specifically, in association with "Welcome to the Jungle".

83. In reasonable reliance on the promises, Plaintiffs agree to license the use of "Welcome to the Jungle" in conjunction with GH III.

84. Defendants breached their promises when Activision released GH III, which prominently featured Slash imagery in direct connection with the use of "Welcome to the Jungle," exploits the prior association between Slash and Guns N' Roses, promotes Slash's VR's separate interests, and includes VR tracks as available downloads.

85. As a direct and proximate result of their reliance on Activision Defendant's promises, Plaintiffs have suffered damages in an amount according to proof at trial.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgement as follows:

1. For disgorgement of profits unlawfully and/or inequitably obtained by Defendants in a sum to be proven at trial, but believed to be in excess of twenty million dollars ($20,000,000); and/or

2. for other restitution in the form of imposition of a constructive trust on the profits unlawfully and/or inequitably obtained by Defendants in a sum to be proven at trial, but believed to be in excess of twenty million dollars ($20,000,000);

3. for compensatory and consequential damages according to proof at trial;

4. for punative damages in amount appropriate to punish the Defendants and deter others from engaging in similiar conduct;

5. for costs herein; and

6. for such other relief as the court may deem proper.

Dated: November 23, 2010

Louis R. Miller.

[bacardimayne]

cool

[gunsguy]

STORY BRO

"I am not attorney"

/thread

[Azazel]

As a trainee lawyer, your analysis is bullshit.

If I had the time, I'd be happy to go over it with you. But I Don't.

[plonker88]

HighVoltage, help us!!!!

[SunnyDRE]

I applaud your effort.

At least you took the time to explain your arguements, unlike so many here, and to those who posted above me, SUCK A DICK......Geezuz!!

Only Axl Rose could single-handedly, turn his fanbase against each other. **shakes head in disgust**

Edited November 25, 2010 by SunnyDRE

[AbominableHoman]

Nice summary and breakdown.

I'm not really familiar with law verbiage and such, yet it does seem like this is far from a shoe-in case for Axl Rose. We haven't heard any counter-arguments or even a statement from Activision so we really have an unfair assessment of the entire thing. I'm sure a company worth $11 billion probably has some decent lawyers.

[gunsguy]

I applaud your effort.

At least you took the time to explain your arguements, unlike so many here, and to those who posted above me, SUCK A DICK......Geezuz!!

Only Axl Rose could single-handedly, turn his fanbase against each other. **shakes head in disgust**

That is a weird statement then the same can be said for the other band members of Guns past no? Only Axl? nice try...

and as far as explaining arguments mine goes like this: I am not a lawyer either and I am sure most cases are less than perfect by anyone yet this explanation right here is very loose IMO. No biggy dude is entitled to it.

[SunnyDRE]

I applaud your effort.

At least you took the time to explain your arguements, unlike so many here, and to those who posted above me, SUCK A DICK......Geezuz!!

Only Axl Rose could single-handedly, turn his fanbase against each other. **shakes head in disgust**

That is a weird statement then the same can be said for the other band members of Guns past no? Only Axl? nice try...

and as far as explaining arguments mine goes like this: I am not a lawyer either and I am sure most cases are less than perfect by anyone yet this explanation right here is very loose IMO. No biggy dude is entitled to it.

Sure it can, but that isn't the point.

I'm not saying the dude is right, but that "Cool Story Bro" "/thread" shit is stupid and childish. If you think the guy is wrong tell him why?

[gunsguy]

I applaud your effort.

At least you took the time to explain your arguements, unlike so many here, and to those who posted above me, SUCK A DICK......Geezuz!!

Only Axl Rose could single-handedly, turn his fanbase against each other. **shakes head in disgust**

That is a weird statement then the same can be said for the other band members of Guns past no? Only Axl? nice try...

and as far as explaining arguments mine goes like this: I am not a lawyer either and I am sure most cases are less than perfect by anyone yet this explanation right here is very loose IMO. No biggy dude is entitled to it.

Sure it can, but that isn't the point.

I'm not saying the dude is right, but that "Cool Story Bro" "/thread" shit is stupid and childish. If you think the guy is wrong tell him why?

here simply we are all wrong. Yup ALL of us!

[James Bond]

I applaud your effort.

At least you took the time to explain your arguements, unlike so many here, and to those who posted above me, SUCK A DICK......Geezuz!!

Only Axl Rose could single-handedly, turn his fanbase against each other. **shakes head in disgust**

That is a weird statement then the same can be said for the other band members of Guns past no? Only Axl? nice try...

and as far as explaining arguments mine goes like this: I am not a lawyer either and I am sure most cases are less than perfect by anyone yet this explanation right here is very loose IMO. No biggy dude is entitled to it.

Sure it can, but that isn't the point.

I'm not saying the dude is right, but that "Cool Story Bro" "/thread" shit is stupid and childish. If you think the guy is wrong tell him why?

Couldn't agree more. It's become very monotonous and old from seeing it in so many threads.

The point of a discussion forum is to, well, have a discussion. Kind of hard to do that with "/thread" kind of comments which don't ignite further discussion or lead to any good arguments. Granted, some threads really do deserve comments like that (Axl's shoe size, anyone?) but in general, a well thought out thread like this could have good discussion going with the reasoning behind our thoughts of the lawsuit.

I didn't read everything as it was this comment I wanted to reply to, but here's my input:

Slash wrote Jungle (well, they all had a hand in it), so why shouldn't he be able to be associated with the song? Either way Axl and the rest of the original line-up are getting their royalties for it. Whether Axl likes it or not, people will always associate Slash with Guns N' Roses. It's a big waste of time to sue a video game company because they included Slash as a playable character in their GUITAR game where you could battle out to Jungle. Bottom line - who cares?

[gunsguy]

my mistake, I was just getting it over with before there were three or four posts in succession

[volcano62]

The OP needs to get laid lol

[SunnyDRE]

I applaud your effort.

At least you took the time to explain your arguements, unlike so many here, and to those who posted above me, SUCK A DICK......Geezuz!!

Only Axl Rose could single-handedly, turn his fanbase against each other. **shakes head in disgust**

That is a weird statement then the same can be said for the other band members of Guns past no? Only Axl? nice try...

and as far as explaining arguments mine goes like this: I am not a lawyer either and I am sure most cases are less than perfect by anyone yet this explanation right here is very loose IMO. No biggy dude is entitled to it.

Sure it can, but that isn't the point.

I'm not saying the dude is right, but that "Cool Story Bro" "/thread" shit is stupid and childish. If you think the guy is wrong tell him why?

here simply we are all wrong. Yup ALL of us!

I think you understand my point GG. Noone is trying have jab at you specifically, but to me, that "CSB" stuff is ridiculous, and I think it discourages people from "keeping the discussion going."

On topic: Just read through the complaint again. I'm wondering if Axl and/or his associates only got verbal agreements that Slash/VR wouldn't be in or associated with the game.

I'm not seeing anything that says it was specifically written in the contract? Maybe I missed something?

[sweetness]

I applaud your effort.

At least you took the time to explain your arguements, unlike so many here, and to those who posted above me, SUCK A DICK......Geezuz!!

Only Axl Rose could single-handedly, turn his fanbase against each other. **shakes head in disgust**

That is a weird statement then the same can be said for the other band members of Guns past no? Only Axl? nice try...

The only people who hysterically defend their idol and sling mud are the obsessive Axl fans... they even try to make it seem like there's GNR fans who HATE Axl Rose, like theres this two sided war between SLASH FANS and AXL FANS, but really its just other GNR fans responding to their stupidity.

Nobody really hates Axl, a lot of GNR fans just think he's an idiot

[Encore]

lol what is this fuckery?

[Vincent Vega]

I applaud your effort.

At least you took the time to explain your arguements, unlike so many here, and to those who posted above me, SUCK A DICK......Geezuz!!

Only Axl Rose could single-handedly, turn his fanbase against each other. **shakes head in disgust**

That is a weird statement then the same can be said for the other band members of Guns past no? Only Axl? nice try...

The only people who hysterically defend their idol and sling mud are the obsessive Axl fans... they even try to make it seem like there's GNR fans who HATE Axl Rose, like theres this two sided war between SLASH FANS and AXL FANS, but really its just other GNR fans responding to their stupidity.

Nobody really hates Axl, a lot of GNR fans just think he's an idiot

That is the biggest pile of BS ever said in this forum. Plenty of people like you, Sunny, BBA, and quite a few others make your seething hate of Axl pretty clear in nearly every post you guys make in this section.

[SunnyDRE]

I applaud your effort.

At least you took the time to explain your arguements, unlike so many here, and to those who posted above me, SUCK A DICK......Geezuz!!

Only Axl Rose could single-handedly, turn his fanbase against each other. **shakes head in disgust**

That is a weird statement then the same can be said for the other band members of Guns past no? Only Axl? nice try...

The only people who hysterically defend their idol and sling mud are the obsessive Axl fans... they even try to make it seem like there's GNR fans who HATE Axl Rose, like theres this two sided war between SLASH FANS and AXL FANS, but really its just other GNR fans responding to their stupidity.

Nobody really hates Axl, a lot of GNR fans just think he's an idiot

That is the biggest pile of BS ever said in this forum. Plenty of people like you, Sunny, BBA, and quite a few others make your seething hate of Axl pretty clear in nearly every post you guys make in this section.

You read and put your own tone/attitude on whatever you want.

It's not my problem.

I like GNR just fine, don't like CD (or Slash's record), but I like everything else the "brand" gnr has put out.

In fact, I'm listening to SPI right now.

[LaRocker]

STORY BRO

"I am not attorney"

/thread

You blindly defend Axl Rose, which in most times leads to poor content of your own posts.

Edited November 25, 2010 by LaRocker

[AbominableHoman]

I applaud your effort.

At least you took the time to explain your arguements, unlike so many here, and to those who posted above me, SUCK A DICK......Geezuz!!

Only Axl Rose could single-handedly, turn his fanbase against each other. **shakes head in disgust**

That is a weird statement then the same can be said for the other band members of Guns past no? Only Axl? nice try...

The only people who hysterically defend their idol and sling mud are the obsessive Axl fans... they even try to make it seem like there's GNR fans who HATE Axl Rose, like theres this two sided war between SLASH FANS and AXL FANS, but really its just other GNR fans responding to their stupidity.

Nobody really hates Axl, a lot of GNR fans just think he's an idiot

That is the biggest pile of BS ever said in this forum. Plenty of people like you, Sunny, BBA, and quite a few others make your seething hate of Axl pretty clear in nearly every post you guys make in this section.

BBA is the only one that really stands out.

Plenty of people have just become disenfranchised with his antics. When you look at things objectively, that's not really an unlikely conclusion. He used a little spurt of activity to make a quick jab at a moderator, defend himself, answer some inane bullshit questions in a midnight chat, and make a bunch of empty promises.

[Jakey Styley]

I miss Rancid Punks.

[downzy]

Slash wrote Jungle (well, they all had a hand in it), so why shouldn't he be able to be associated with the song? Either way Axl and the rest of the original line-up are getting their royalties for it. Whether Axl likes it or not, people will always associate Slash with Guns N' Roses. It's a big waste of time to sue a video game company because they included Slash as a playable character in their GUITAR game where you could battle out to Jungle. Bottom line - who cares?

I don't believe the issue is the use of 'Welcome to the Jungle,' it's more pertaining to the fact that Axl owns and manages the name, brand and likeliness of "Guns N' Roses." As it is my understanding, Axl's objection is the use of a Guns N' Roses song that requires the use of the Guns N' Roses brand that ties in any way to former members such as Slash. The argument isn't whether Slash or other former members have rights to material that they're responsible for - the issue is the use of the Guns N' Roses moniker and how it is applied.

Axl's contention is that he signed off on using 'Welcome to the Jungle,' and by proxy the use of the Guns N' Roses name and brand, only on condition that former members not be associated with it. Since he owns the name Guns N' Roses, he can do as he likes. If Activision agreed to this, and then subsequently included and used Slash in GH3, then they are in violation of their agreement with Axl and are thus held financially responsible. Owning Guns N' Roses allows Axl to use the name and brand as he sees fit. Whether you, Slash or Activision disagrees with his use of the brand isn't relevant. He could have said, "I don't want any dancing bananas included if you are to use the Guns N' Roses name in your game" and Activision would have to comply if they were to agree to his terms. That the object of Axl's objection is Slash is irrelevant.

I can't speak for Axl, but I think it's assured that he isn't interested in padding Slash's pocket any more than he already has to through shared song royalties. What Axl is arguing here is that his agreement to allow Welcome to the Jungle to be used in GH3 allowed both Slash and Velvet Revolver to financially benefit; something he would not have lent the Guns N' Roses brand had he known that Slash would become the de facto mascot and VR would be allowed to sell their songs for financial gain.

What I find more interesting is how little the public realizes how much vitriol there exists within Axl towards Slash. I think most people think they went their separate ways and aren't fully aware that Axl wants absolutely nothing to do with his former bandmate. Anyone here who's followed this band and Axl knows that this lawsuit wasn't a complete surprise. Axl will always object to any further association of Slash with Guns N' Roses and anyone attempting to do so will likely face his wrath via a rant or litigation.

Cheers,

Andrew

[gunsguy]

STORY BRO

"I am not attorney"

/thread

You blindly defend Axl Rose, which in most times leads to poor content of your own posts.

That is your opinion, I don't believe that is true though I am not blindly defending anyone here. This could have been anyone suing anyone, I think he has a case, will he win? Fucked if I know but I think he has grounds for sure...

[Guest Satanisk_Slakt]

Of course Axl will lose. He'll just make a fool out of himself as usual.

[realpoti]

I really like your post Maximum. Agree with you in various points.