1 In 1974, Dale Cox, an attorney, wrote on his firm’s letterhead to the Cleveland Browns — an American football team in Ohio — complaining about a fad of paper planes being thrown by fans during Browns’ games. He threatened to sue unless this risk of “serious injury” to eyes and ears was stopped. He received this reply with his own letter attached: “Dear Mr Cox: Attached is a letter that we received on November 19, 1974. I feel that you should be aware that some asshole is signing your name to stupid letters. Very truly yours, James N Bailey, General Counsel, Cleveland

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