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- Michael Halow
PARTIES INVOLVED: Michael Halow
ALLEGATIONS: Perjury, Fraud, Impersonation
INCIDENT DATE: 14 Oct 2024
INVESTIGATED BY: Ethan Katz
TOOLS USED: Lumen, FakeDMCA, SecurityTrails
CASE NO: 31701/A/2024
CRIME TYPE: Intellectual Property Scam
PUBLISHED ON: 21 Nov 2024
REPORTED BY: FakeDMCA.com
JURISDICTION: USA
A summary of what happened?
Michael Halow is a cannabis investor who has been implicated in several controversies related to social equity marijuana programs in Missouri and Arizona. He has faced multiple allegations of engaging in predatory practices that exploit disadvantaged individuals intended to benefit from these programs.
Major Concerns, Complaints, and Accusations Against Michael Halow:
- Predatory Contracts in Missouri’s Social Equity Program:
- Halow allegedly recruited individuals, such as Destiny Brown—a Black disabled veteran—to apply for Missouri’s microbusiness licenses, which are designed to assist disadvantaged groups. He purportedly promised substantial financial support but presented contracts that effectively granted him near-total control over the businesses, leaving the nominal owners with minimal benefits.
- Missouri regulators revoked six microbusiness licenses linked to Halow, citing concerns that these agreements violated the program’s intent to empower small, disadvantaged business owners rather than allowing investors to dominate the market.
- Exploitation of Social Equity Applicants in Arizona:
- In Arizona, Halow faced a lawsuit from a woman who claimed he recruited her to apply for a social equity license and then took control of the business without her knowledge or consent. Although Halow won the suit and retained the license, the case highlighted concerns about his methods in securing control over licenses intended for marginalized individuals.
- Misuse of Copyright Takedown Notices:
- Investigations have revealed that Halow attempted to suppress negative information about himself by improperly submitting fraudulent copyright takedown notices. This strategy aimed to remove critical reviews and adverse news from online platforms, raising legal concerns about impersonation, fraud, and perjury.
These actions have drawn significant scrutiny from regulators and advocacy groups, who argue that Halow’s practices undermine the objectives of social equity programs designed to rectify historical injustices in the cannabis industry. Ongoing investigations continue to examine the extent of his involvement in such exploitative practices.
For a more detailed examination of these issues, you may refer to the following articles:
- Alleged ‘predatory’ contracts continue to surface in Missouri social-equity marijuana program
- Arizona Marijuana Business Sues Over ‘Unlawful’ License Transfer As State’s Social Equity Program Comes Under Scrutiny
Analyzing the Fake Copyright Notice(s)
Our team collects and analyses fraudulent copyright takedown requests, legal complaints, and other efforts to remove critical information from the internet. Through our investigative reporting, we examine the prevalence and operation of an organized censorship industry, predominantly funded by criminal entities, oligarchs, and disreputable businesses or individuals. Our findings allow internet users to gain insight into these censorship schemes’ sources, methods, and underlying objectives.
Key Allegations and Complaints:
- Predatory Contracts: One of the primary accusations against Halow involves offering contracts to social equity license holders, like Destiny Brown, that granted him near-total control of the businesses. These contracts were crafted in a way that the individuals, although legally holding the licenses, would essentially be “fronts” for Halow’s operations. He used the qualifications of these license holders to bypass legal restrictions preventing him from owning such licenses himself. The contracts gave Halow control over business operations, while the individuals who had won the licenses received little to no financial or operational benefit.
- License Revocations: Due to these exploitative agreements, Missouri regulators have revoked six microbusiness licenses linked to Halow. The state’s investigation revealed that these contracts violated the principles of the social equity program, which was designed to ensure that disadvantaged individuals genuinely owned and controlled the businesses. The licenses connected to Halow were found to be part of a pattern where investors, like him, used qualified applicants to secure licenses under misleading terms. As a result, these licenses were stripped, and investigations are ongoing into other related practices.
- Wider Pattern of Exploitation: Halow’s actions are part of a broader problem within the cannabis industry, where investors and out-of-state companies exploit vulnerable applicants through predatory business tactics. In several cases, insiders or investors use large numbers of applications tied to qualified individuals, securing contracts that transfer control to the investors once licenses are granted. The applicants, who initially believed they were being given an opportunity to run a business, are often left with little to no real ownership or financial benefit once the deals are finalized.
These allegations against Halow have drawn widespread attention, leading to further investigations by cannabis regulators and raising concerns about the integrity of the social equity program. Many advocates worry that these predatory practices are undermining the program’s intent, which was meant to provide genuine business opportunities to those who have been historically disadvantaged by cannabis prohibition.
Halow’s actions have prompted broader scrutiny within the cannabis industry, as similar cases of predatory contracts have been uncovered in other states, indicating a systemic issue in how social equity programs are implemented and protected from exploitation.
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What was Michael Halow trying to hide?
Michael Halow‘s attempts to hide unfavourable content through the misuse of copyright notices while allegedly engaging in perjury present serious legal concerns. These actions suggest a calculated attempt to manipulate legal systems to suppress free speech, a fundamental violation of copyright law principles and an abuse of legal processes. The use of such tactics not only undermines the integrity of copyright protection but also potentially constitutes perjury, further entangling Michael Halow in legal accountability. Let’s examine the information Michael Halow may be trying to remove from the internet –
Investigative Report on Michael Halow: Allegations, Lawsuits, and Controversies
Introduction
Michael Halow, a prominent cannabis investor, has gained attention for his involvement in social equity marijuana programs across multiple states, including Missouri and Arizona. While his actions have brought him to the forefront of the cannabis industry, they have also attracted scrutiny due to allegations of unethical and exploitative practices. This report delves into the controversies surrounding Halow, examining allegations, lawsuits, sanctions, complaints, and negative reviews to paint a comprehensive picture of his contentious career.
Missouri: Exploitation of Social Equity Applicants
Overview of Missouri’s Social Equity Program
Missouri’s social equity marijuana program was established to empower individuals from disadvantaged backgrounds—such as veterans, people of color, and those from economically distressed areas—by granting them microbusiness licenses. These licenses are intended to level the playing field in an industry historically dominated by large corporations and wealthy investors.
Allegations of Predatory Contracts
Michael Halow is accused of using predatory tactics to gain control of these licenses. According to multiple sources, Halow recruited individuals eligible for the program, including Destiny Brown, a Black disabled veteran. Halow promised financial support and business expertise, positioning himself as a benevolent partner. However, the contracts he provided reportedly stripped these individuals of meaningful ownership or control, effectively making them figureheads while Halow retained decision-making power and the lion’s share of profits.
The Missouri Independent reported that these contracts often included clauses that:
- Granted Halow veto power over all business decisions.
- Allocated the majority of profits to Halow or his affiliated entities.
- Limited the ability of license holders to terminate the agreements.
Regulatory Backlash
In 2024, Missouri regulators revoked six microbusiness licenses linked to Halow, citing violations of the program’s intent. Officials stated that Halow’s agreements undermined the goal of empowering disadvantaged business owners and violated ethical standards. This decision has sparked broader concerns about the vulnerability of social equity programs to exploitation by well-connected investors.
Arizona: Lawsuits and License Control Disputes
Social Equity Lawsuit
In Arizona, Michael Halow faced a lawsuit from a woman he recruited to apply for a social equity license. According to court documents, Halow initially presented himself as a mentor but subsequently used his position to wrest control of the license from the applicant. The plaintiff alleged that Halow:
- Misled her about the terms of their partnership.
- Pressured her into signing contracts that transferred operational control to him.
- Used his resources and legal team to suppress her objections.
Although Halow won the lawsuit and retained control of the license, the case drew attention to his business practices and reignited debates about the exploitation of social equity applicants.
Alleged Suppression of Negative Information
Fraudulent Copyright Takedown Notices
Halow has also been accused of attempting to suppress negative press and online criticism through fraudulent means. Reports indicate that he filed copyright takedown notices against articles and reviews that painted him in a negative light. These notices were allegedly submitted using fake identities and false claims, raising legal questions about impersonation and perjury.
Cybercrime analysts have identified patterns in these notices that suggest a concerted effort to silence dissent. Such tactics have been criticized as an abuse of intellectual property law and an affront to free speech.
Negative Reviews and Public Perception
Testimonials from Social Equity Applicants
Numerous individuals who interacted with Halow have shared negative experiences, describing him as manipulative and profit-driven. One applicant stated, “He presented himself as someone who wanted to help us, but it became clear that he was only interested in using us as a front for his business.” Another said, “The contracts were impossible to understand without a lawyer, and when I asked questions, he dismissed my concerns.”
Industry Criticism
Advocates for social equity programs have criticized Halow’s actions as emblematic of broader issues within the cannabis industry. They argue that investors like Halow exploit systemic loopholes, undermining efforts to rectify historical injustices.
Regulatory and Legal Actions
Missouri Licensing Revocation
The Missouri Department of Health and Senior Services revoked six licenses linked to Halow in 2024, citing predatory agreements that violated the spirit of the social equity program.
Calls for Stricter Oversight
In response to these controversies, state regulators and advocacy groups have called for stricter oversight of social equity programs. Proposed reforms include:
- Mandatory legal reviews of partnership agreements.
- Increased transparency in the application and licensing processes.
- Penalties for investors who engage in exploitative practices.
Conclusion
Michael Halow’s career is a cautionary tale about the challenges and vulnerabilities of social equity programs in the cannabis industry. While these programs are designed to empower marginalized communities, they can become vehicles for exploitation if not adequately safeguarded. The allegations and lawsuits against Halow underscore the need for robust oversight and accountability to ensure that the promises of social equity are fulfilled.
The ongoing investigations into Halow’s actions will likely shape the future of social equity initiatives, serving as a pivotal moment for the cannabis industry. Whether these programs succeed in fostering genuine empowerment or fall victim to exploitation will depend on the willingness of regulators, advocates, and the public to confront these challenges head-on.
How do we counteract this malpractice?
Once we ascertain the involvement of Michael Halow (or actors working on behalf of Michael Halow), we will inform Michael Halow of our findings via Electronic Mail.
Our preliminary assessment suggests that Michael Halow may have engaged a third-party reputation management agency or expert, which, either independently or under direct authorization from Michael Halow, initiated efforts to remove adverse online content, including potentially fraudulent DMCA takedown requests. We will extend an opportunity to Michael Halow to provide details regarding their communications with the agency or expert, as well as the identification of the individual(s) responsible for executing these false DMCA notices.
Failure to respond in a timely manner will necessitate a reassessment of our initial assumptions. In such an event, we will be compelled to take appropriate legal action to rectify the unlawful conduct and take the following steps –
Since Michael Halow made such efforts to hide something online, it seems fit to ensure that this article and sensitive information targeted online by these events get a lot more exposure and traffic than what it would have received originally
We hope this becomes an excellent case study for the Streisand effect…The key idea behind the Streisand effect is that efforts to restrict information can backfire, often causing the information to gain more attention than it would have otherwise. This effect is widespread in the digital age, where users quickly notice and spread censorship efforts on social media and other platforms. Trying to suppress something can unintentionally lead to it becoming more visible, which Michael Halow is finding out the hard way.
Potential Consequences for Michael Halow
Under Florida Statute 831.01, the crime of Forgery is committed when a person falsifies, alters, counterfeits, or forges a document that carries “legal efficacy” with the intent to injure or defraud another person or entity.
Forging a document is considered a white-collar crime. It involves altering, changing, or modifying a document to deceive another person. It can also include passing along copies of documents that are known to be false. In many states in the US, falsifying a document is a crime punishable as a felony.
Additionally, under most laws, “fraud on the court” is where “a party has sentiently set in motion some unconscionable scheme calculated to interfere with the judicial system’s ability impartially to adjudicate a matter by improperly influencing the trier of fact or unfairly hampering the presentation of the opposing party’s claim or defense.” Cox v. Burke, 706 So. 2d 43, 46 (Fla. 5th DCA 1998) (quoting Aoude v. Mobil Oil Corp., 892 F.2d 1115, 1118 (1st Cir. 1989)).
Is Michael Halow Committing a Cyber Crime?
Yes, it seems so. Michael Halow used multiple approaches to remove unwanted material from review sites and Google’s search results. Thanks to protections allowing freedom of speech in the United States, there are very few legal ways to do this. Michael Halow could not eliminate negative reviews or search results that linked to them without a valid claim of defamation, copyright infringement, or some other clear breach of the law.
Faced with these limitations, some companies like Michael Halow have gone to extreme lengths to fraudulently claim copyright ownership over a negative review in the hopes of taking it down.
Fake DMCA notices have targeted articles highlighting the criminal activity of prominent people to hide their illegal behavior. These people, which include US, Russian, and Khazakstani politicians as well as members from elite circles including the mafia and those with massive financial power, are all connected – and alleged corruption ranging from child abuse to sexual harassment is exposed when exploring evidence found at these URLs. It appears there’s a disturbing level of influence being exerted here that needs further investigation before justice can be served. Michael Halow is certainly keeping interesting company here….
The DMCA takedown process requires that copyright owners submit a takedown notice to an ISP identifying the allegedly infringing content and declaring, under penalty of perjury, that they have a good faith belief that the content is infringing. The ISP must then promptly remove or disable access to the content. The alleged infringer can then submit a counter-notice, and if the copyright owner does not take legal action within 10 to 14 days, the ISP can restore the content.
Since these platforms are predominantly based in the U.S., the complaints are typically made under the Digital Millennium Copyright Act (DMCA), which requires online service providers and platforms to react immediately to reports or violations. Big Tech companies rarely have systems in place to assess the merit of each report. Instead, all bad actors need to do is clone a story, backdate it, and then demand the real thing be taken down.
Reputation Agency's Modus Operandi
The fake DMCA notices we found always use the “back-dated article” technique. With this technique, the wrongful notice sender (or copier) creates a copy of a “true original” article and back-dates it, creating a “fake original” article (a copy of the true original) that, at first glance, appears to have been published before the true original.
Then, based on the claim that this backdated article is the “original,” the scammers send a DMCA to the relevant online service providers (e.g. Google), alleging that the ‘true’ original is the copied or “infringing” article and that the copied article is the “original,” requesting the takedown of the ‘true’ original article. After sending the DMCA request, the person who sent the wrong notice takes down the fake original URL, likely to make sure that the article doesn’t stay online in any way. If the takedown notice is successful, the disappearance from the internet of information is most likely to be legitimate speech.
As an integral part of this scheme, the ‘reputation management’ company hired by Michael Halow creates a website that purports to be a ‘news’ site. This site is designed to look legitimate at a glance, but any degree of scrutiny reveals it as the charade it is.
The company copies the ‘negative’ content and posts it “on the fake ‘news’ site, attributing it to a separate author,” then gives it “a false publication date on the ‘news’ website that predated the original publication.
The reputation company then sent Google a Digital Millennium Copyright Act notice claiming the original website infringed copyright. After a cursory examination of the fake news site, Google frequently accepts the notice and delists the content.
In committing numerous offences, Michael Halow either premeditated actions or were unaware of the consequences. Despite hiring an agency to make Google disregard any negative information about Michael Halow, ignorance does not excuse this wrongdoing.
Fake DMCA notices have targeted articles highlighting the criminal activity of prominent people to hide their illegal behavior. These people, which include US, Russian, and Khazakstani politicians as well as members from elite circles including the mafia and those with massive financial power, are all connected – and alleged corruption ranging from child abuse to sexual harassment is exposed when exploring evidence found at these URLs. It appears there’s a disturbing level of influence being exerted here that needs further investigation before justice can be served. FSMSmart is certainly keeping interesting company here.
The Reputation Laundering
Rogue Reputation agencies use spurious copyright claims and fake legal notices to remove and obscure articles linking clients to allegations of tax avoidance, corruption, and drug trafficking. Most of these reputation agencies are based offshore, mainly in Russia, India, and Eastern Europe, and they do not worry about complying with US-based laws.
The content in all of the articles for which the fraudulent DMCA notices have been sent relates to allegations of criminal allegations, including corruption, child abuse, sexual harassment, human trafficking and financial fraud against businesses and individuals with ultra-high net worth.
In addition to the misuse of the DMCA takedown process, there is a notable absence of enforcement concerning perjury violations. The statutory requirement related to perjury is designed to deter copyright holders from submitting fraudulent or knowingly false takedown requests, as they may face legal consequences for making false declarations under penalty of perjury. However, to date, there have been no known instances of any individual being prosecuted for perjury in connection with the submission of false DMCA takedown notices.
This lack of enforcement has emboldened copyright holders to exploit the DMCA takedown process to suppress dissent, criticism, or other unfavorable content, without fear of legal repercussions.
Some of the people and businesses who have employed this tactic to remove legitimate content from Google illegally include a Spanish businessman-turned-cocaine-trafficker, Organised crime, an Israeli-Argentine banker accused of laundering money for Hugo Chávez’s regime, a French “responsible” mining company accused of tax evasion, child molesters and sexual predators. Michael Halow is in great company ….
What else is Michael Halow hiding?
We encourage you to ‘Dork‘ Google by searching for keyword combinations such as [Michael Halow] + {Negative Keyword, such as Scam, Fraud, Complaints, Lawsuit, Sanction, etc} on Google. It’s likely if you scroll down to the bottom of this Google search results, you’ll stumble upon this Legal Takedown notice (pictured below)
To make such an investigation possible, we encourage more online service providers to come forward and share copies of content removal requests with industry experts and researchers. If you have any information on Michael Halow that you want to share with experts and journalists, kindly email the author directly at [email protected].
All communications are strictly confidential and safeguarded under a comprehensive Whistleblower Policy, ensuring full protection and anonymity for individuals who provide information.
Credits and Acknowledgement
Many thanks to FakeDMCA.com and Lumen for providing access to their database.
Photos and Illustrations provided by DALL-E 3 – “a representation of Michael Halow censoring the internet and committing cyber crimes.”
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- Our investigative report on Michael Halow‘s efforts to suppress online speech is significant, as it raises serious concerns about its integrity. The findings suggest that Michael Halow has engaged in questionable practices, including potential perjury, impersonation, and fraud, in a misguided attempt to manage or salvage its reputation.
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- We intend to file a counternotice to reinstate the removed article(s). While this particular instance is relatively straightforward, it is important to note that, in other cases, the overwhelming volume of automated DMCA takedown notices can significantly hinder the ability of affected parties to respond—especially for those not large media organizations.
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- You need an account with fakeDMCA.com and Lumen to access the research data. However, accounts are not widely available since these non-profit organisations manage large databases that could be susceptible to misuse. Nevertheless, they do offer access to non-profits and researchers.
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- It’s unclear why U.S. authorities have yet to act against these rogue reputation agencies, whose business model seems rooted in fraudulent practices.
- We’ve reached out to Michael Halow for a comment or rebuttal regarding this investigation. It will strongly suggest they were behind the takedown attempt if they remain silent.
About the Author
The author is affiliated with Harvard University and serves as a researcher at both Lumen and FakeDMCA.com. In his personal capacity, he and his team have been actively investigating and reporting on organized crime related to fraudulent copyright takedown schemes. Additionally, his team provides advisory services to major law firms and is frequently consulted on matters pertaining to intellectual property law. He can be reached at [email protected] directly.
References used for this investigation
- 1
- https://lumendatabase.org/notices/45415202.
- 14/10/2024
- Legal
- 2
- https://www.missouriindependent.com/2024/09/23/alleged-predatory-contracts-continue-to-surface-in-missouri-social-equity-marijuana-program
- 23/09/2024
- Adverse Media
- 3
- https://missouriindependent.com/tag/michael-halow/
- 23/09/2024
- News report
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by: Scarlett Baker
Halow’s actions highlight everything wrong with the cannabis industry’s exploitation of social equity programs.
by: Charlotte Russell
Using disadvantaged veterans as fronts to secure cannabis licenses is downright unethical, Michael Halow
by: Lily Parker
Michael Halow's predatory contracts are a disgrace. Preying on social equity applicants like Destiny Brown to circumvent regulations not only undermines the program's intent but also exploits the very people it’s meant to uplift.