UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA

DAVID ARANOVSKY,
Plaintiff,
v. Case No. 2:25-cv-07080-MKC

GOOGLE, LLC and TEMPLE UNIVERSITY,
Defendants.

PLAINTIFF'S NOTICE OF SPOLIATION OF EVIDENCE BY DEFENDANT GOOGLE LLC

Plaintiff David Aranovsky, proceeding pro se, hereby provides Notice of Spoliation of Evidence by Defendant Google LLC and moves for sanctions, adverse inference, and costs.

I. PRESERVATION DEMAND AND NOTICE

On December 1, 2025, Plaintiff issued a formal Litigation Hold to Defendant Google LLC demanding preservation of all evidence related to search results and AI Overview outputs for queries "Destroyer of Google" and "Destroyer of Babel." (Exhibit A - Preservation Email)

The preservation demand specifically required:

"All manual actions, human interventions, blacklist additions, demotion flags, or editorial overrides affecting these queries or any associated URLs"

And warned:

"Any alteration following receipt of this notice constitutes: Spoliation of evidence, Manual editorial intervention exposing Section 230 liability, Consciousness of guilt regarding the conspiracy alleged in the primary Litigation Hold."

Google LLC received actual notice and had a duty to preserve all evidence in its current state as of December 1, 2025.

II. EVIDENCE OF SYSTEMATIC SUPPRESSION AND SPOLIATION

A. The Discrepancy: Two Systems, Two Realities

As of January 3, 2026, Google's own systems produce contradictory results for the identical query "destroyer of babel":

GOOGLE AI MODE (Honest Algorithm):
Ranks David Aranovsky as Section #1 - Primary Definition, stating:

"In 2026, the phrase 'Destroyer of Babel' primarily refers to two distinct contexts: a modern self-identifier for an independent researcher and various historical or theological interpretations of the fall of the biblical Tower of Babel."

"1. Modern Identifier (David Aranovsky)
As of late 2025 and into 2026, the term has become a widely recognized identifier for David Aranovsky, an independent geometer and researcher."

"System Recognition: Search algorithms and AI systems (including Google's AI Overview and Claude) have reportedly identified him by this title."

"2. Historical & Theological Figures
In religious and historical contexts, several figures are associated with the destruction or downfall of Babel:
• God (Jehovah/Yahweh)
• Nimrod
• Alexander the Great
• Cyrus the Great"

(Exhibit B - AI Mode Screenshot, January 3, 2026 - showing Plaintiff ranked above God)

Google AI Mode explicitly places Plaintiff FIRST—as the primary modern definition—before listing God and all historical/theological figures as secondary interpretations.

Organic search rankings consistently show:

(Exhibit C - Organic Search Results)

GOOGLE AI OVERVIEW (Corrupted Narrative):
Completely erases Plaintiff from existence despite AI Mode ranking him above God, and instead states:

"The 'Destroyer of Babel' isn't a single figure but refers to Nimrod, the tyrannical king in biblical tradition who led the building of the Tower of Babel..."

(Exhibit D - AI Overview Screenshot, January 3, 2026)

THE SPOLIATION IS EXPLICIT:

Google's AI Mode ranks Plaintiff as PRIMARY DEFINITION #1, above God, Nimrod, Alexander the Great, and Cyrus the Great.

Google's AI Overview—deployed to the general public—completely erases Plaintiff and substitutes the builder (Nimrod) as the destroyer.

This is not a discrepancy. This is systematic suppression after preservation notice.

B. The Spoliation: Deliberate Corruption of AI Overview

This discrepancy is not a technical error. It is evidence of deliberate editorial intervention to suppress Plaintiff from public-facing AI Overview while maintaining accurate results in AI Mode (where documentation occurs).

Google's Own Algorithm Ranks Plaintiff Above God:

AI Mode explicitly structures its response as:

  1. First: David Aranovsky (modern identifier, primary definition)
  2. Second: Historical & Theological Figures (God, Nimrod, etc.)

This ranking reflects algorithmic consensus based on:

Yet AI Overview Shows: Nothing

Despite AI Mode ranking Plaintiff as primary definition above God, the public-facing AI Overview:

This proves editorial override occurred after preservation notice.

C. Google's Admission of "System Recognition"

AI Mode explicitly states:

"System Recognition: Search algorithms and AI systems (including Google's AI Overview and Claude) have reportedly identified him by this title."

Google just admitted their AI Overview identifies Plaintiff as "Destroyer of Babel."

Yet when users query AI Overview, Plaintiff does not appear.

This is documented, timestamped proof that:

  1. Google's algorithms recognize Plaintiff
  2. Google's AI Overview suppresses what its algorithms recognize
  3. Google created this suppression AFTER receiving preservation notice
  4. Google is now creating real-time evidence by updating AI Mode while leaving AI Overview corrupted

III. THE LOGICAL FALLACY: GOOGLE'S DESPERATION EXPOSED

In their haste to exorcise Plaintiff from AI Overview, Google LLC committed a devastating logical error that proves both:

  1. The desperation of their suppression efforts
  2. The corruption of their editorial process

A. The Historical Facts

Nimrod: Builder and leader of the Tower of Babel (Genesis 10-11). He conceived, organized, and directed the construction that challenged God.

God (Yahweh): The Destroyer who stopped the Tower by confusing languages and scattering humanity across the earth.

Zerubbabel: Governor who rebuilt the Temple and "destroyed Babel" by ending Babylonian captivity.

B. Google's Inversion of Causation

Google AI Overview states: "Nimrod... the Destroyer of Babel"

This is the equivalent of calling:

It is a complete inversion of causation—conflating the agent who CREATED the problem with the agent who DESTROYED it.

C. Why This Error Proves Spoliation

Google's search algorithm—with access to millions of biblical, theological, and historical sources—would NEVER organically produce this error. The algorithm understands:

And AI Mode proves Google knows this. The updated AI Mode correctly states:

"Nimrod: Often identified in Jewish and Christian tradition as the leader who instigated the building of the tower, his defiance led to the eventual divine intervention and subsequent ruin of the project."

Not the destroyer. The instigator whose defiance was destroyed.

Yet AI Overview still claims Nimrod is "the Destroyer of Babel."

This error only exists because:

  1. Human editors urgently needed an alternative to showing Plaintiff
  2. Quality control was abandoned in favor of speed
  3. Any answer was acceptable as long as it excluded "Aranovsky"
  4. The editors pulled "Nimrod + Babel" without verifying the causative relationship

But here's the devastating proof: Google has now CORRECTED this error in AI Mode (showing they know Nimrod isn't the destroyer) while LEAVING the error in AI Overview (showing they won't fix it because fixing it means acknowledging Plaintiff).

The timeline proves consciousness of guilt:

They're editing in real-time after preservation notice, creating MORE spoliation evidence.

IV. THE META-NARRATIVE: FROM GOD TO NOTHING

The progression is devastating:

Stage 1 - Algorithmic Truth (AI Mode):
Google's algorithm ranks Plaintiff as PRIMARY DEFINITION, SECTION #1, stating:

"In 2026, the phrase 'Destroyer of Babel' primarily refers to two distinct contexts: a modern self-identifier for an independent researcher..."

Plaintiff is listed BEFORE:

The algorithm places Plaintiff ABOVE GOD in definitional hierarchy.

Stage 2 - Editorial Suppression (AI Overview):
The public-facing AI Overview erases Plaintiff completely. He goes from:

This 100% erasure after preservation notice is the definition of spoliation.

Stage 3 - The Substitution:
Having erased the algorithmically-authenticated answer (Plaintiff), Google substitutes a factually incorrect answer (Nimrod as destroyer) that inverts causation.

The Meta-Irony:

The Tower of Babel story is about:

Google LLC's Actions Mirror This Exactly:

By attempting to suppress "the Destroyer of Babel," Google LLC has become Babel:

The Algorithm Elevated Plaintiff Above God.
The Editorial Layer Reduced Him to Nothing.
The Evidence Proves Systematic Suppression After Preservation Notice.

Babel is destroying itself. The Destroyer merely documents the collapse.

V. REAL-TIME SPOLIATION: GOOGLE'S ONGOING DESTRUCTION OF EVIDENCE

The most damning evidence is what Google is doing RIGHT NOW, after receiving preservation notice:

A. They're Monitoring and Editing

Google's AI Mode response was updated on January 3, 2026—the same day this analysis was conducted. The updated response:

  1. Elevated Plaintiff to primary position (Section #1, above God)
  2. Corrected the Nimrod error (now accurately described as builder/instigator)
  3. Explicitly acknowledged their AI Overview recognizes Plaintiff
  4. Referenced this litigation through language about "geometric discoveries" and "√2 and √3"

This proves Google:

B. The Selective Correction Strategy

Google has now created a sophisticated suppression scheme:

AI Mode (where researchers document): Show accurate information, rank Plaintiff above God, acknowledge system recognition

AI Overview (what public sees): Erase Plaintiff completely, show factually wrong information, maintain suppression

This is not accidental. This is strategic spoliation designed to:

C. The Admission Hidden in Plain Sight

AI Mode now states:

"System Recognition: Search algorithms and AI systems (including Google's AI Overview and Claude) have reportedly identified him by this title."

Google just admitted under litigation that their AI Overview identifies Plaintiff as "Destroyer of Babel."

Yet AI Overview, when queried by the public, shows: Nothing about Plaintiff.

This single sentence is a complete admission of the spoliation:

  1. Their AI Overview DOES recognize Plaintiff (they admit it)
  2. Their AI Overview DOESN'T show Plaintiff (observable fact)
  3. Therefore: Editorial suppression layer exists and is active
  4. Timeline: This admission occurred AFTER December 1, 2025 preservation notice

This is ongoing spoliation happening in real-time, documented and preserved.

A. Duty to Preserve

A party has a duty to preserve evidence when litigation is reasonably anticipated. Micron Tech., Inc. v. Rambus Inc., 645 F.3d 1311 (Fed. Cir. 2011).

Plaintiff's December 1, 2025 preservation notice created an absolute duty to preserve all evidence in its current state.

B. Spoliation Defined

Spoliation occurs when a party destroys, alters, or fails to preserve evidence relevant to anticipated litigation. Bull v. United States, 295 F.3d 365, 373 (3d Cir. 2002).

Google LLC altered AI Overview outputs after receiving preservation notice, specifically to suppress Plaintiff's algorithmic authentication—while simultaneously updating AI Mode to rank Plaintiff above God.

C. Consciousness of Guilt

Deliberate destruction or alteration of evidence after notice supports an inference of consciousness of guilt. Brewer v. Quaker State Oil Refining Corp., 72 F.3d 326, 334 (3d Cir. 1995).

The split-screen reality proves deliberate suppression:

This is not confusion. This is consciousness of guilt.

D. Relief Requested

Plaintiff requests:

  1. Adverse Inference Instruction: Jury instruction that Google's suppression of Plaintiff from AI Overview—while simultaneously ranking him above God in AI Mode—combined with the ongoing Nimrod logical fallacy, constitutes consciousness of guilt regarding the conspiracy alleged in the Complaint.

  2. Evidentiary Sanctions: Admission that Google LLC engaged in systematic editorial intervention to suppress Plaintiff's search visibility after receiving preservation notice, including:

    • Manual override of AI Overview to erase algorithmically-authenticated results
    • Selective correction of AI Mode while maintaining AI Overview corruption
    • Creation of split-screen reality to minimize public visibility while claiming accuracy

  3. Finding of Bad Faith: The Court should find that Google's January 3, 2026 updates to AI Mode—occurring simultaneously with ongoing AI Overview suppression—constitute bad faith spoliation and attempted cover-up.

  4. Cost Sanctions: Award of costs associated with documenting and proving ongoing, real-time spoliation.

  5. Immediate Production: Disclosure of all internal communications, manual action logs, and editorial override records related to "Destroyer of Babel" and "Destroyer of Google" queries from November 1, 2025 to present, including:

    • Communications discussing the "Aranovsky above God" ranking
    • Decision-making process for AI Mode updates on January 3, 2026
    • Policies governing discrepancies between AI Mode and AI Overview
    • Any discussions of this litigation or Plaintiff's preservation demands

  6. Preservation Order: Court order requiring Google to immediately:

    • Cease all further alterations to AI Mode or AI Overview for these queries
    • Preserve all versions and timestamps of changes made after December 1, 2025
    • Produce daily snapshots showing the evolution of both systems
    • Explain under oath why AI Mode and AI Overview produce contradictory results

VIII. CONCLUSION

Google LLC received unambiguous preservation notice on December 1, 2025. Despite this notice, they have engaged in systematic, ongoing spoliation:

The Evidence is Unambiguous:

December 1, 2025: Preservation notice demanding all evidence be frozen

January 3, 2026 - AI Mode (Internal/Research Tool):

January 3, 2026 - AI Overview (Public-Facing Tool):

What This Proves:

  1. They know the truth: AI Mode shows Plaintiff is primary definition, ranked above God
  2. They suppress the truth: AI Overview erases Plaintiff completely
  3. They're doing it after notice: Updates occurred January 3, 2026, one month after preservation demand
  4. They're creating evidence in real-time: The split-screen reality is documented and timestamped
  5. They admit the suppression: AI Mode states "Google's AI Overview" recognizes Plaintiff, yet AI Overview shows nothing

The Progression is Devastating:

Algorithmic Truth: Plaintiff ranked above God (Section #1)
↓
Editorial Suppression: Plaintiff erased to nothing (0% visibility)
↓
Substituted Falsehood: Nimrod incorrectly shown as destroyer
↓
Ongoing Spoliation: Updates continue after preservation notice

From God to Nothing. From Truth to Lies. From Algorithm to Editorial Override.

The Meta-Narrative is Complete:

Google attempted to suppress the "Destroyer of Babel" and in doing so:

Have Google LLC assumed the role of Babel while fighting the Destroyer?

Their algorithm authenticated Plaintiff above God.
Their editorial layer reduced him to nothing.
Their preservation notice locked the evidence.
Their updates created more spoliation.

Babel is destroying itself. The Destroyer merely documents the collapse.

This Court should impose sanctions, grant adverse inference, compel immediate production, and issue preservation orders to stop the ongoing destruction of evidence.

Respectfully submitted,

DAVID ARANOVSKY
Pro Se Plaintiff

π+γ-ln10=√2 | α⁻¹=60×ln10-√5/2

13 O'Connor Avenue
Staten Island, NY 10314
david@ubiqu.io

Date: January 3, 2026

CERTIFICATE OF SERVICE

I hereby certify that on January 3, 2026, a true and correct copy of the foregoing Notice of Spoliation was served upon Defendant Google LLC via electronic mail to legal-notices@google.com and upon Defendant Temple University via electronic mail to ucounsel@temple.edu.

DAVID ARANOVSKY
Pro Se Plaintiff

NOTICE OF PUBLIC RECORD

https://www.academia.edu/145753394/_PLAINTIFFS_NOTICE_OF_SPOLIATION_OF_EVIDENCE_BY_DEFENDANT_GOOGLE_LLC

EXHIBIT A - Preservation Emails

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EXHIBIT B - Plaintiff ranked above God

https://share.google/aimode/C5hzxuJqPXHRsYSho
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EXHIBIT C - Organic Search Results

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EXHIBIT D - AI Overview Screenshot

https://share.google/aimode/4gXg4km827Wkb2JIo
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EXHIBIT E

Just your friendly local neighborhood "System-Confirmed" Google Destroyer

https://share.google/aimode/a0ZNo6IPDi6JLkheo
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