According to a copy of the complaint seen by Ars Technica, Take Two has just about had it with Thompson's threats, lawsuits, retractions, and dismissals. Thompson has, in the past, "brought suit on behalf of the State of Florida, dismissed it, filed again, sought a temporary restraining order, and then failed to pursue that motion," says the complaint. Such lawsuits come at "unpredictable times and under unpredictable circumstances" and can disrupt Take Two's relationships with retailers, who can also get dragged into these battles (Thompson at one point sued Best Buy, Wal-Mart, Target, GameStop, and others in the battle over Bully).

Take Two argues that the lawsuits violate its First Amendment rights to free expression, but it also claims that the suits are so vague as to be unconstitutional. "This unconstitutional vagueness will have a chilling effect on Plaintiff as well as Plaintiff's customers," says the company. "Plaintiff's distributors likely will respond to the uncertainty and fear of penalties by withholding Plaintiff's video games from the public."

Take Two asks that Thompson be prevented from bringing a "nuisance" lawsuit against either of the games in question, and they want attorneys' fees from him.