Even the picture that the defendant reproduced and distributed, the same image of an anonymous person who is suitable for the portrayal of the fat man in the film that will be produced according to the book, is not an ordinary picture of a person that was randomly pulled from the depths of the Internet. A search of the same image that the defendant displayed on the Google search engine links the image to the image of an Indian businessman whose name is the same as the plaintiff's name: "Amit". In other words, the plaintiff argues, this picture also expresses the defendant's subterfuge in an attempt to identify the plaintiff with the villain's character.
The plaintiff therefore argues that an objective examination of the book and the publications made by the defendant in connection with the book makes it easy to identify the plaintiff with the same character, "the villain", and thus also presents the plaintiff in a negative light. As he is, he is the same crook who engages in world-wide conspiracies and acts of deception. And of course, the plaintiff continues, this is not a matter of mere coincidence, but of intentional intent. In a clear attempt by the defendant to harass the plaintiff against the background of the same disputes that arose between them and were clarified in the previous lawsuit.
The identification of the plaintiff as the same character in the book, together with the details of the information about the plaintiff's privacy, expresses, according to him, the torts of defamation and the violation of privacy.
As a result of those publications, the plaintiff claims, his life was in danger and he was forced to leave Bulgaria to protect his good name. The same publications also caused the cancellation of a real estate transaction that the plaintiff had worked on in Bulgaria, and as a result of that cancellation, he suffered damage estimated at ILS 770,000. The same publications will also force the plaintiff to hire the services of a professional body that will remove from the Internet all those malicious links of his name to that character, the villain, at an estimated cost of about ILS 250,000.