RENEWED MOTION FOR PRELIMINARY INJUNCTION AGAINST DEFENDANTS NETCOM ON-LINE COMMUNICATIONS

			 RENEWED MOTION FOR PRELIMINARY INJUNCTION
                         AGAINST DEFENDANTS NETCOM ON-LINE
                         COMMUNICATIONS SERVICES, INC. AND TOM
                         KLEMESRUD

TO DEFENDANTS NETCOM ON-LINE COMMUNICATIONS SERVICES, INC.  AND TOM
KLEMESRUD AND THEIR ATTORNEYS OF RECORD:

     Plaintiffs Religious Technology Center ("RTC") and Bridge
Publications, Inc. ("BPI") hereby move this Court for an order
directing defendants Netcom On-Line Communication Services, Inc.
("Netcom"), and Tom Klemesrud, dba Clearwood Data Services
("Klemesrud"), to appear before this Court at a specified time and
date to show cause why a Preliminary Injunction should not be
issued requiring said defendants to cease and desist from
infringing plaintiffs' rights under the federal copyright laws by
making unauthorized reproductions of copyrighted works on the
Internet network or other databases, and from violating RTC's
rights under California trade secrets laws by copying unauthorized
copies of confidential works of L. Ron Hubbard onto such database. 
The contents of those confidential works are known as "the Advanced
Technology" of the Scientology religion.

     The form of the requested order to show cause is more
particularly described below and in the accompanying proposed form
of Order to Show Cause Re:  Preliminary Injunction.

                     GROUNDS FOR APPLICATION

     Plaintiffs apply to the Court for the requested relief
pursuant to Rule 65 of the Federal Rules of Civil Procedure, on the
grounds that plaintiffs hold exclusive rights relating to the
reproduction, publication, and display of numerous literary works
that are protected under federal law, some also containing trade
secrets protected under state law; that in violation of those
rights, defendants are, and recently have been, copying those works
totaling at least 154 pages to date, with many works in their
entirety, or causing them to be copied onto computerized data base
information services, in violation of the copyright laws and state
law; that defendants have continued their actions in spite of
notification by plaintiffs of their rights and objections to the
unauthorized copying and disclosure; and, that plaintiffs will
suffer irreparable injury unless defendants are restrained from
such actions during the pendency of this action.

              FORM OF REQUESTED ORDER TO SHOW CAUSE

     Plaintiffs request that this Court issue an order directing
defendants to show cause why a preliminary injunction should not be
issued enjoining and restraining them, their agents, and all
persons acting in concert with them or on their behalf, from:

          1.   Permitting Dennis Erlich to access Usenet and the
Internet via Netcom's computer system pendente lite, or, in the
alternative, from:

          2.   Permitting copying of any of the copyrighted works
of L. Ron Hubbard including, but not limited to, those identified
in Exhibits A and B to the Complaint, and in particular from
permitting copying of any of those works into any computer data
base, information service, storage facility, archives, or other
computerized network or facility by Dennis Erlich or by any other
individual, after receiving notice that such person is engaging in
violations of plaintiffs' intellectual property rights;

          3.   From copying Erlich's postings, or those of any
other user upon receiving notice that person's postings of any of
the copyrighted works of L. Ron Hubbard including, but not limited
to, those identified in Exhibits A and B to the Complaint, and in
particular from copying any of Erlich's postings, or those of any
other poster upon receiving notice of that person's postings, of
those works into any computer data base, information service,
storage facility, archives, or other computerized network or
facility;

          4.   From permitting the disclosure, display or
reproduction of, or causing to be disclosed, displayed or
reproduced by Dennis Erlich or any other individual, upon receipt
of notice that such individual is so posting, any of the
Unpublished Confidential Works identified in Exhibit B to the
Complaint or any other work that is part of the Advanced
Technology;

          5.   From disclosing, displaying or reproducing, or
causing to be disclosed, displayed or reproduced, any of the
Unpublished Confidential Works identified in Exhibit B to the
Complaint or any other work that is part of the Advanced
Technology, posted by Dennis Erlich, or by another individual, upon
notice of such posting by such other individual;

          6.   From destroying or concealing, or in any way
disposing of any reproduction, copy, facsimile, excerpt, or
derivative of any work of L. Ron Hubbard hat is in defendants'
possession, custody or control if posted by Dennis Erlich or any
other individual, upon receipt of notice that such individual is
making such postings.

     This application is based upon this Motion, the accompanying
Memorandum of Points and Authorities, the facts set forth in the
declarations of Thomas M. Small, Warren McShane, Marilyn Pisani and
Helena K. Kobrin submitted with the Ex Parte Application for
Temporary Restraining Order, the Ex Parte Application itself and
accompanying Memorandum of Points and Authorities, and the
declarations Dr. Kenneth R. Castleman, Dr. Alfonso F. Cardenas,
David Elrod, Andrew H. Wilson, Helena K. Kobrin, and Lynn R. Farny
submitted herewith, the Verified Amended Complaint in this action,
and such additional evidence and arguments as may be properly
presented at or before the hearing of the Application.

Dated: March 6, 1995

                                   Andrew H. Wilson
                                   WILSON, RYAN & CAMPILONGO

                                   Thomas M. Small
                                   Janet A. Kobrin
                                   SMALL, LARKIN & KIDDE

                                   - and -

                                   Helena K. Kobrin

                                   Attorneys for Plaintiffs
                                   RELIGIOUS TECHNOLOGY CENTER