im sorry, i wrote that incorrectly. IN discovery i found a concrete link between a spyware manufacturer, whose head designer is billed as an ex security agency programmer, and continuing coordination with the government agency he worked for. This is a means to skirt constitutional protections with a hybrid relationship that does not answer to constitutional protections. I am now asserting that this defendant continues to act as a quasi agent of the government, and this is why im now including constitutional violations in the amended omplaint.
so assuming i can indeed establish this quasi agency (and i am sure i can with further discovery) then I would be correct to assert the constitutional violations that usually only apply to government entities? I am not including the government itself for now, until the 60 days waiting period, but I do speak of their role in the complaint.
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