Declaration of Mark Changizi — Changizi v. HHS (S.D. Ohio)

Record facts

U.S. District Court for the Southern District of Ohio, Eastern Division · No. 2:22-cv-01776-EAS-CMV · Doc. 1-4 · 2022-03-24 · Docket on CourtListener

Full text

EXHIBIT C 
 
 
 
 
 
Case: 2:22-cv-01776-EAS-CMV Doc #: 1-4 Filed: 03/24/22 Page: 1 of 10  PAGEID #: 54

IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF OHIO 
COLUMBUS DIVISION 
) 
) 
MARK CHANGIZI,
MICHAEL P. SENGER,  
DANIEL KOTZIN, 
) 
Plaintiffs, 
   ) 
COMPLAINT 
   ) 
FOR DECLARATORY AND 
v. 
) 
INJUNCTIVE RELIEF 
   ) 
VIVEK MURTHY, United States 
   ) 
Surgeon General, and  
) 
XAVIER BECERRA,  
) 
Secretary of the Department 
) 
JURY TRIAL DEMANDED 
of Health and Human Services, 
) 
) 
Defendants.  
) 
DECLARATION OF MARK CHANGIZI 
1.
I, Mark Changizi, am over the age of 18 and make this Declaration in support of
the motion for a Preliminary Injunction in my case against the United States Surgeon General, et 
al. 
2.
I make this Declaration based on personal knowledge.
3.
I am a broadly trained scientist (math/physics undergrad, PhD in math, postdocs in
psychology and theoretical neuroscience) and have been a researcher in a variety of fields for 25 
years. For more than 15 years I have been a public-facing scientist -- I write for magazines, appear 
on science TV shows, speak worldwide, do a YouTube series, and have six books on my research. 
Historically apolitical, when Covid entered the picture I realized there were many deep 
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misunderstandings of the data and evidence leading to panicked decisions being made, and I 
endeavored to explain what the evidence actually says. Furthermore, as someone with expertise 
on psychology and the evolution of culture, I have also been spending considerable effort 
communicating emergent societal phenomena, the illogical biases humans have (on both sides of 
the Covid debate), and the importance of free expression in society (the subject of my institute, 
Free Expression Group). 
4. 
I live in Columbus, Ohio. 
5. 
I have approximately 37,000 followers on Twitter, having created my account in 
April 2013. 
6. 
On April 20, 2021, I received a 12-hour suspension for linking to an article on the 
safety and efficacy of face masks, an article housed at the NIH web site. The following tweet was 
cited as cause: 
New Review: Masks Ineffective, Harmful. “The existing scientific 
evidences challenge the safety and efficacy of wearing facemask as 
preventive intervention for COVID-19. 
 
7. 
On approximately June 25, 2021, I received a 7 -day suspension, and the email from 
Twitter just had blank spaces where the usual offending material would be, so I was never sure 
why I was suspended. 
8. 
Around December 1, 2021, I learned my account was being heavily censored and 
deboosted (this means, among other things, that the user’s tweets are de-platformed—they appear 
in Twitter feeds much less frequently and replies to other posts may be hidden). First, I had noticed 
that I was no longer gaining followers, and my engagement had fallen precipitously. Second, 
followers reported to me that they were no longer seeing my tweets, and that when they searched 
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on me I would either not come up or appear only when the final letter was added, and -- if they did 
find me via a search -- that my account was labeled as “sensitive”.  
9. 
I was permanently suspended on December 18, 2021, again for “spreading 
misleading and potentially harmful information related to COVID-19.”  The following two tweets 
were cited as the cause: 
a. “Covid is 10 to 20 times less dangerous than flu for kids.  Get. A. Grip.  There is 
NO long term data for the shot.  And even the short and medium term data for that 
age group are ambiguous at best.” 
b. “Asymptomatics rarely spread it ~ Vaccinations don’t slow spread ~ unvaxed pose 
no threat to vaxxed ~ Risks are broadly flu like (and safer than flu for < 40) ~ 
Huge % of unvaxxed have superior natural immunity via recovery.” 
10.   The email warned me that any “attempt to evade a permanent suspension by creating new 
accounts” would result in suspension of those accounts. 
11. I appealed the suspension on Christmas Day of 2021.  I wrote that: 
You have permanently suspended me for speaking out as a 
scientist concerning the evidence-based dangers of Covid and the 
efficacy & ethics of the interventions. 
 
Ironically, I am one of the few scientists studying the importance 
of free expression, and how it is an absolutely crucial part of the 
mechanism society — and science — uses to stumble toward the 
truth. 
 
I am an academic with a number of well-known discoveries, my 
sixth book appearing in a few months, and am also perhaps the only 
person arguing against the interventions that understands there was 
no “plandemic,” and has tried to educate people against their bias 
toward conspiracy-theory thinking. 
 
You have made a huge mistake in suspending so many voices, 
including mine. 
 
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And, that is true whether or not what we’re saying is true! Of course, 
I believe my statements are true, and always provide argument & 
evidence. Remember: nearly every journal article in the academic 
literature is false. But that doesn’t mean it gets cancelled. It is part 
of the truth-discovery process itself. 
Don’t become part of the problem by encouraging censorship and 
groupthink. 
 
12. On December 27, 2021, Twitter unsuspended me without explanation, although I had to 
delete two Tweets (see 9a and 9b) to regain access to my account. 
13. Nevertheless, my account is heavily censored: my Tweets are typically labeled “age-
restricted adult content” that require an explicit effort to read them (in contrast to the vast majority 
of Twitter accounts). I still do not occur in a search unless my name is fully typed, and the same 
is true of my Instagram account.   
14. My monthly Twitter impressions can be seen below, from January 2020 until the time of 
this writing. Although I began noticing my general de-platforming around December of 2021, it 
Case: 2:22-cv-01776-EAS-CMV Doc #: 1-4 Filed: 03/24/22 Page: 5 of 10  PAGEID #: 58

had 
actually 
begun 
significantly 
earlier, 
around 
May 
of 
2021.
 
15. Both my follower-ships on YouTube and Twitter accounts have plateaued, despite the fact 
that I am very active, and prior to the censorship period had steadily gained followers. 
16. I have become very careful about what I say on Twitter to avoid suspension.   
17. For example, I never discuss early treatments, as that leads to immediate suspensions.   
18. I avoid linking to studies and make very general statements when referring to the vaccines, 
which make my Tweets more difficult to comprehend.   
19. I fear engaging with the opposition because angry opponents may report me to Twitter, 
increasing the chances of suspension. 
20.  Twitter notoriously suspends only those who question the wisdom and efficacy of 
government restrictions, or who cast doubt on the safety or efficacy of the vaccines. 
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21. Upon information and belief, there are no examples of Twitter suspending individuals who 
have spread misinformation from the other side—by, for example, exaggerating the efficacy of 
masks or the threat the virus poses to children. 
 
I declare under penalty of perjury that the foregoing is true and correct.  
 
 
Executed On: March 18, 2022 
 
 
 
 
 
 
 
 
Mark Changizi 
 
 
 
 
 
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