UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
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MICROSYSTEMS SOFTWARE, INC., a Massachusetts corporation, 	
and MATTEL, INC., a Delaware corporation, 
			
	Plaintiffs,			
						
        vs.				
					
SCANDINAVIA ONLINE AB, a Swedish corporation; ISLANDNET.COM, a Canadian corporation; EDDY L. O. JANSSON, a Swedish citizen; and MATTHEW SKALA, a Canadian citizen, 

	Defendants.			

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CIVIL NO. 













 PLAINTIFFS' EX PARTE MOTION FOR TEMPORARY
RESTRAINING ORDER AND EXPEDITED DISCOVERY

	Upon the Verified Complaint, this Ex Parte Motion and the attached Memorandum of Law, plaintiffs Microsystems Software Inc. and Mattel, Inc. (collectively, "Microsystems") move pursuant to Federal Rules of Civil Procedure Rules 4, 30(a), 34(b) and 65(b) that the Court issue a Temporary Restraining Order and order defendants Scandinavia Online AB and Islandnet.Com to respond to the limited discovery requested by Microsystems.  In support of its motion, Microsystems relies on the Memorandum of Law submitted herewith and states as follows:
	1.	Microsystems develops, markets and licenses the "Cyber Patrol" software program, which is designed to filter out certain designated material on the Internet.  Defendants Eddy L. O. Jansson and Matthew Skala ("Jansson and Skala") willfully and knowingly violated the copyright laws (17 U.S.C. §101 et. seq.) and wrongfully converted Cyber Patrol, by reverse engineering the software, developing source code and binaries to bypass its protections and then posting that bypass information on the Internet in downloadable form.  Jansson and Skala touted their unlawful conduct in a March 11, 2000 press release that they circulated widely on the Internet, including through web sites in Massachusetts and elsewhere in the United States.  The corporate defendants host Jansson's and Skala's Web sites that contain links to download the illegally-created source code and binaries. 
	2.	Microsystems seeks in this action, among other things, immediate injunctive relief ordering defendants to take down the links on Jansson's and Skala's Web sites that post the Cyber Patrol bypass source code and binaries, and to enjoin all defendants from further disseminating such information. 
	WHEREFORE Microsystems respectfully requests that this Court: 
	(1)	issue a Temporary Restraining Order requiring the defendants to: take down the links posted on Jansson's and Skala's Web sites to the Cyber Patrol bypass source code and binaries, and cease from further disseminating any such information; 
	(2)	grant Microsystems leave to request that the corporate defendants immediately produce the documents as described in Plaintiffs' First Requests for Production of Documents attached as Exhibit A to the (Proposed) Order, submitted herewith; 
	(3)	indefinitely preserve inviolate all such Web sites, source or object code and documents relating to Cyber Patrol as well as all records which reflect the identity or number of persons who have accessed such Web site and/or downloaded information from the Web sites; and
	(4)	grant any other relief the Court deems just and proper.	ORAL ARGUMENT REQUESTED
	Plaintiffs respectfully request oral argument on this Motion.		

						Microsystems Software, Inc.
and Mattel, Inc.

						By their attorneys,


							

						_________________________________
						Irwin B. Schwartz BBO#548763
						Joel G. Beckman BBO#553086
						Laura N. Kling BBO#638313
						SCHWARTZ and NYSTROM, LLC
						419 Boylston Street
						Boston, Massachusetts  02116
						(617) 421-1800
						(617) 421-1810 (fax)
						
Dated:  March 15, 2000