He notably appeared to dox the pregnant Manhattan hospital worker who was smeared as a "Karen" by users on social media after an incident where a group of five young men prevented her from utilizing a Citi Bike to ride home, claiming it was theirs to take.
A lawsuit filed by plaintiffs Jennifer Couture and Ralph Garrmone on May 22 alleges that Noshirvan uses his TikTok account with 1.6 million followers as "a fee-for-service online and telephonic cyberstalking service to enrich himself with illicit profits, to humiliate his victims, and to mete out consequences that he deems appropriate."
They accuse Noshirvan of being a "prolific cyberstalker" who often intentionally posts a chosen target's personal information to the public, including their name, employer, and contact information with the intention of getting others to go after them. The lawsuit notes that he promotes his "cyberstalking service" on his TikTok profile with a header reading "Need someone identified?" beside a link one can follow to pay him.
Noshirvan has doled out numerous labels to his targets in attempts to send his followers after them, including, "anti-vaxer," "anti-masker," and "white supremacist."
The suit alleges that just after Noshirvan posted a video targeting her around January 27, 2020, Couture "immediately received hundreds of abusive and threatening text messages," no fewer than 728, in addition to numerous vicious phone calls to her personal and professional phone numbers alike. The lawsuit also says that Couture was the target of phony allegations of child abuse, resulting in an investigation in which the Florida Department of Children and Families made an unannounced visit to her home. Noshirvan was discovered to be the person who filed the anonymous allegations that triggered the visit.
Couture's mother is said to have received unwelcome visits to her home on three separate occasions, with all of the strangers looking for Jennifer.
After posting the video targeting Couture, Noshirvan’s follower count rose from around 702,000 to more than 1 million.
After she began receiving the abusive messages, Couture began deleting social media accounts and comments. "Danesh immediately discovered her deletions and became enraged," the lawsuit states.
The lawsuit says Noshirvan messaged Couture directly, stating the "fun hasn’t even started yet."
Noshirvan sent a message under the fictitious identity "Erica Sabonis," posing as a Facebook user supportive of Couture. "The message was a fishing expedition to capture Couture’s reaction, which he used in a new video, wherein he admitted he was Erica Sabonis and mocked Couture for falling for his ruse."
Noshirvan posted subsequent videos targeting Couture on January 28, 2022, January 30, 2022, January 31, 2022, February 1, 2022, May 8, 2022, and May 13, 2022, each filled with more personal information regarding Couture.
At the same time, Noshirvan "purchased other forms of media to promote and expand the reach of his videos and cyberstalking campaign against Couture," the lawsuit said, adding that around February 22, 2022, he purchased native content sponsored advertisements, which are designed to look like real news articles, and continued publishing Couture’s personal information.
Noshirvan also discovered that there were familial ties between Couture and the company she worked at, Garramone, which resulted in hundreds of "rage-filled calls, text messages, emails, and fictitious negative reviews posted on professional review sites." Garramone then became the target of Noshirvan.
"The attack was akin to brute force computer hacking attack, and paralyzed Garramone’s surgical practice," the lawsuit states.
"Danesh’s cyberstalking campaign against Garramone severely damaged their reputation and caused significant financial harm. Garramone was forced to prematurely terminate contracts with surgeons, who became fearful of reputational harm by being swept into Danesh’s net, and many patients terminated scheduled procedures and ended their relationship," the lawsuit states.
The lawsuit seeks damages in excess of $75,000 for Couture and Garramone each for civil conspiracy. The lawsuit also seeks damages in excess of $75,000 for Garramone for interference with prospective economic advantage.Per the lawsuit, Noshirvan is one of the few select TikTok creators to have been invited to participate in its relatively new subscription service, which launched in May 2022.
The lawsuit notes that Noshirvan’s subscription fee is $5.99 per month, and that TikTok takes a 35 percent cut of these monthly subscription fees.
"Danesh is a high-volume in-app revenue producer, who has exploited TikTok’s in-app revenue to earn hundreds of thousands of dollars documenting his cyberstalking campaigns and inciting Danelanders to join his cyberstalking campaigns," the lawsuit states.
The lawsuit also notes that TikTok can record users' location, IP address, search history, message content, interactions with advertisers, biometric data, and more.
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