clare response to exhibit 3

8/16/2019 Clare Response to Exhibit 3

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RESPONSE TO CLAIMS IN EXHIBIT 3 OF THE COMPLAINT

I. OVERVIEW

Kenyon published the first book in her Young Adult series, Chronicles of Nick

(“CoN”), in May 25, 2010. As demonstrated repeatedly below, the vast majority of thedetails about Kenyon’s characters in the Exhibit represent material from CoN.Clare’sCity of Bones (“CoB”), City of Ashes (“CoA”) and City of Glass (“CoG”) were publishedin 2007, 2008, and 2009 respectively, and thus could not have taken any material fromthe CoN books, which did not yet exist.

Email from Clare to her editor, Karen Wojtyla, at Simon & Schuster, confirms that thefirst submitted complete draft of City of Glass was turned in on Dec 10, 2007. Therefore,all discussion of Kenyon’s characters in this document reflects how they are describedand how they behave in books published by Kenyon prior to that date (the last of whichis Upon the Midnight Clear, published October 30, 2007 (according to

http://www.sherrilynkenyon.com/book/upon-the-midnight-clear/ ).

As a result, this document repeatedly refers to things not being present in Kenyon’spublished work prior to the end of 2007. This statement indicates that by no meanscould Clare have possibly been influenced by these aspects of Kenyon’s work in City ofBones, City of Ashes, or City of Glass, since all three were completed by that time.

There is one example below in which Clare’s character note came from Clockwork An-gel, the book published after City of Glass. This was turned in as a completed draft onSeptember 28, 2009, so this, too, could not have been affected or influenced by any ofthe CoN books.

All original publication dates for Kenyon’s books are taken fromhttp://www.sherrilynkenyon.com.

Italicized passages are quotes from Kenyon’s Exhibit 3.

A. Int roductory Claims:

Kenyon’s Claim: Response:

Both Series employ a line of warriors whoprotect the normal world from demons.

True, but part of long-standing literary and folk-loric tradition self-evidently not originating with

Kenyon.

The Hunters (whether “shadow” or “dark”)operate in a high tech world…

False. Clare’s Shadowhunters operate in aworld without contemporary high technology; amajor aspect of the worldbuilding of thesebooks is that Shadowhunters do not use mod-ern technology or modern weapons.

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…that is hidden from everyday mortals… True, but part of long-standing literary and folk-loric tradition self-evidently not originating withKenyon.

…and deal with demons who come and

go through portals…

Per later discussion of specific comparisons, in

Clare’s books demons are not seen to travelthrough portals to a “Veil World.”

The term “Veil World” never appears in Clare’swork (or, as near as we can find, in Kenyon’s!).Clare’s books describe demons as originatingin alternate demonic dimensions.

In both Series, a young person becomespart of the Dark-Hunters (or Shad-owhunters) world after being saved by a

gorgeous blond Dark-Hunter (or Shad-owhunter). The protagonists learn theirpurpose and how to fight various demonsand their own personal inadequacies,while dealing with intricate family andfriend issues.

Other than two characters both being blond,this describes the traditional Hero’s Journeythat represents almost all fantasy and adven-

ture fiction, folklore, and mythology ever writ-ten. It is so fundamental to humanity that wecannot successfully trace its origin, as it ap-pears to have begun before written history. Itdoes not originate with Kenyon’s Dark-Huntersseries.

They face the constant threat of beingconsumed or being converted to evil.

This is never an aspect of Clare’s protagonistClary’s character or story. Also, it does not oc-cur in Kenyon’s books published prior to theend of 2007.

They each must kill their demonic father. This does not occur in Kenyon’s books prior tothe end of 2007.

Both Series feature mortal or normal objects (referred to as “instruments” by theDEFENDANT), including without limita-tion a cup, a sword, and a mirror, eachimbued with magical properties to helpbattle evil and protect mankind.

This too is self-evidently part of our sharedhuman folkloric and mythological tradition. Aquick glance at even something as unofficialas Wikipedia’s article “List of magical weap-ons” will quickly indicate several hundred“normal objects…imbued with magical proper-

ties to help battle evil and protect mankind”from mythological traditions all over the worldand throughout the history of fiction. It islaughable to imagine Clare as having stolenfrom Kenyon the idea of a magic sword or amagic mirror.

The inspiration for Clare’s “Mortal Instruments”

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are the Three Sacred Treasures of Japan, partof Japanese mythology, which include theSword, Kusanagi, the Mirror Yata Nokagami,and the Cup. As early as 690 CE and for cen-turies after, these were involved in the Imperial

ceremony of enthroning the Japanese emper-or.

For purposes of accuracy, there is no magicmirror in Clare’s books. What is believed to bea mirror by the fictional folklore within Clare’sworld is revealed to in fact be a magical lake.In any event there is no magic mirror in Ken-yon’s work through 2007 either.

The character’s powers are heightened or

restrained by the use of supernaturalmarkings.

This is the basis of the magic used by the

Shadowhunters in Clare’s books, true, but it isnot to be found in Kenyon’s work prior to theclose of 2007. The closest thing we can find isa demon who lives as a kind of tattoo on an-other character’s skin and can help that char-acter, but this is not even a little similar. This isdiscussed in more detail below.

Both Dark-Hunters and Shadowhuntershave enchanted swords that are divinelyforged, imbued with otherworldly spirits,

have unique names, and glow like heav-enly fire.

Again, magical swords are a part of folkloregoing back its very beginnings in human histo-ry. The most well-known predecessors would

be the swords of English and French medievalliterature — the Excalibur of King Arthur; Du-rendal, the legendary sword of Charlemagne’spaladin Roland; and Cortana, said to havebeen the sword of the legendary knight Tristan.Glowing and named swords can be foundthroughout literature and folklore and do notoriginate with Kenyon.

Both Series feature “regular humans” whoare oblivious to the supernatural world.

They are called “Baretos” or “Ords” in theDark-Hunter Series and “Mundanes or“Mundies” in the Shadowhunter Series.

We look forward to Kenyon’s suit against J. K.Rowling for stealing her idea of regular people

oblivious to the supernatural world (“Muggles”).This, too, obviously is not an idea originatingwith Kenyon, but an incredibly common featureof all fantasy featuring a hidden magical world.

They can be “turned” by various demonicbeasts into like creatures or servantswhen bitten or fed blood.

This does not describe anything that ever hap-pens in Clare’s books specifically. If Kenyonrefers here to people becoming vampires or



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werewolves by being bitten by vampires orwerewolves, she has drawn from virtually allfantasy horror fiction ever written. Just to takean obvious pop culture example, Kenyon indi-cates at one point in her books an enjoyment

of the character of “Buffy” from the TV showBuffy the Vampire Slayer (Seize the Night,163), which features this same piece ofworldbuilding, a number of years before Ken-yon’s first published novel. But of course weare not claiming that this originated there, ei-ther. It originated, at latest, hundreds of yearsearlier in European folklore, and probably longbefore that.

Humans can also be turned by drinking

divine blood from a sacred cup. They canuse and perform magic. They cannot seethrough demon “glamour” (a term used byboth authors).

Glamour is a term used by both authors be-

cause it is a word in the English language. Theuse of it to mean “enchantment” is an archaicone, certainly, but common in modern fantasyfiction. It dates to at least the early 18th centu-ry and was not invented or popularized byKenyon.

It seems self-evident that, even without con-sidering the entire panoply of mythological tra-dition, the Christian folklore of the Holy Grailand the powers attributed to it throughout the

centuries are the antecedent of Clare’s cupand, presumably, Kenyon’s.

Ords and Mundies can become “forsak-en” (a condition referred to as “shade” inthe Dark-Hunter Series). Once in thisstate, they do not eat or sleep, are in ag-ony and cannot be seen or heard.

This is an inaccurate description of the For-saken in Clare’s work. They can easily be bothseen and heard. They also are mindless inhu-man creatures driven by rage, whereas inKenyon’s books Shades hold normal conver-sations and have human-like personalities.

Obviously, though, the idea of humans cor-rupted by magic into monsters is not an ideaoriginating with Kenyon or Clare.

When regular humans mix with supernat-ural beings (whether Dark-Hunters orShadowhunters), the divine blood is dom-inant and the children will inherit those

This, of course, is the key plot line in the 1968movie, Rosemary’s Baby, among countlessother supernatural works Even here there is awillful misrepresentation, though: Kenyon’s



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powers. In both works, demons often se-duce humans to produce offspring withpowers.

books state clearly multiple times that Dark-Hunters are sterile (Night Pleasures, 139; Kissof the Night, 165). There is one exception, thecharacter named Wulf, who does have chil-dren, but they do not appear prior to the end of

2007 and thus could not have inspired this as-pect of the Shadowhunter world.

Shadowhunter, like Dark-Hunters, can befreed from their lives but each supernatu-ral character must first figure out his orher own unique path to freedom.

This statement is so vague that we cannot tellwhat it is meant to mean. It seems to us thatthe statement that every character must figureout his or her own unique path is a generalstatement that applies to every story aboutpeople ever written. There is nothing in Clare’sbooks in which leaving the Shadowhunters de-pends on figuring out a “unique path to free-

dom.”

B. Setting:

Both works take place in an urban worldthat is not what it seems. Theirs is a worldbehind the veil with portals that lead toheaven realms and hell realms. There aresegregated wards used as walls to holdback demons and neutral grounds that

are safe zones. Different dimensions ex-ist. Supernatural beings break through tothe world of man. These worlds are notreadily accessible to mortals.

This statement is mostly true of both series, asit is true of thousands of fantastical stories andlegends throughout history. Even here thereare some basic inaccuracies stated: there areno portals leading to “heaven realms” inClare’s books. The “neutral grounds that are

safe zones” in Clare’s books are just normalplaces not specially protected by magic.

In general, this describes the setting of thegenre known as “urban fantasy,” and involvesstory elements going back to the birth of fan-tastical fiction. These ideas were obviously notcreated by Sherrilyn Kenyon in 2002. To takeour one earlier example, if we must, the abovedescription also accurately describes the TVshow Buffy the Vampire Slayer, which aired

from March 1997 to May 2003. It would beequally ridiculous for the creators of that showto claim they invented its worldbuilding ele-ments and storytelling tropes, and they havebeen wise enough not to do so. That Kenyonhas done so in this suit represents a solipsisticview of human storytelling, fantastical fiction,and the archetypes that make up our religious,



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mythological, and folkloric traditions that is tru-ly astonishing to behold.

C. Characters:

Clare’s character: Clary Fray (debut City of Bones (2007)).Kenyon’s character: Nick Gautier (debut Night Pleasures (2002)

Although a character named Nick Gautier, may have appeared as early as 2002, how-ever, most of the specific character traits attributed to him first appeared in Infinity,2010, the first of the CoN series, despite the fact that Kenyon claims that they were cop-ied by traits attributed to Clary Fray in the pre-existing Mortal Instruments Trilogy, City ofBones, City of Ashes, and City of Glass.

Kenyon’s Claim About Nick Gautier Response

a. Believes himself a normal human untilthe night when a mysterious Dark‐ Huntersaves his life.

According to Kenyon’s books prior to the endof 2007, Nick believes himself to be a normalhuman long after a Dark-Hunter saves his life.He works for that Dark-Hunter running errands,unaware of the supernatural world, for severalyears until he graduates from high school, atwhich point he is told about it (Night Pleasures,186).

In addition, he is not saved from a supernatural

attack, but from being attacked by his own,non-supernatural, street gang. (ibid)

b. Has his supernatural pow-ers bound and doesn’t know about themuntil after his mother is kidnapped by de-mons.

c. Discovers the psychic mys-tic who lives next door is not what sheseems.

d. He becomes a Dark‐ Hunteronly to learn he has the blood of angels inhim.

e. His mother, who also hasangel blood, is put into a trance.

None of these events or facts about Nick occurin any of Kenyon’s work published prior to Cityof Bones (or in fact prior to City of Glass).



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f. Has a childhood friend inlove with him.

g. His father is a demon hehas to destroy.

h. Events cause him to mis-trust the hero of the story who was oncehis best friend. He wants to trust him, butcan’t.

Kenyon’s Claims About Clary Fray Response

a. Is at a club with friends when they areattacked by a group of demons. Amysterious Shadowhunter saves her

life.

Factually inaccurate. Clary is at a club inChapter 1 of CoB, but she is only with onefriend and they are not attacked by demons.

The fight in the club, on pages 10-14, takesplace entirely between three Shadowhuntersand a demon. Clary is not physically at risk inthe combat, and her life is not ‘saved.’ In fact,she inadvertently helps the demon by distract-ing the Shadowhunters.

b. Has supernatural powers and does notknow about them until after her mother iskidnapped by demons.

The appearance of Clary's powers:CoB 10-12: Clary is proven to have the Sight(this occurs prior to Clary’s mother’s disap-pearance/kidnapping)

CoB 55: Clary is able to tolerate a runeCoB 322-326: Clary’s own rune powersemerge

c. Discovers the psychic next door is notwhat she seems.

Dorothea is revealed to know about the Shad-ow World on CoB 95-109

d. She becomes a Shadowhunter andlearns she has angel blood in her.

Factually inaccurate. Clary doesn’t ‘become’ aShadowhunter, she already is one. She justisn’t aware of it before. She learns what she is

on CoB 107, though she begins to suspect iton CoB 71-72.

e. Her mother, who also has angel blood,is put into a trance.

Factually inaccurate. Jocelyn is revealed to bein a magically induced coma on CoB 471, nota trance.

f. Has a childhood friend in love with her. Simon tries to tell Clary how he feels on CoB



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39. He succeeds in telling her on CoB 320.

g. Her father is a demon she has to des-troy.

Factually inaccurate. Clary’s father is not ademon. He’s a Shadowhunter like her, which is

revealed on CoB 77.

h. Events cause her to mistrust the heroof the story who was once her best friend.She wants to trust him, but can’t.

Factually inaccurate. Clary is the protagonistand hero of the story. If the plaintiff’s ‘hero’ re-fers to Jace, Clary just met him. They werenever best friends, and Clary mistrusts him be-cause he is antagonistic to her. If this refers toSimon, Clary never loses her trust in him. Ifthis refers to Luke, he is not Clary’s best friendor the hero of the story.

Clare’s Character: Valentine Morgenstern (City of Bones, 2007)Kenyon’s Character: Adarian Malachai (Infinity, 2010)

Kenyon’sclaims about

AdarianMalachai:

Response:

The claims are irrelevant. This character does not appear, and is not referenceany time by name or otherwise in any of Kenyon’s work prior to the publicationCity of Glass.

Kenyon’sclaims aboutValentineMorgenstern:

Response:

a. Clary’sfather.

Valentine is revealed to be Clary’s father on CoB 404.

b. Has anoth-er paranormal

son.

CoG 402-403

c. Tries tomake his sonsmore evil andstrengthenhimself.

Factually inaccurate. Valentine was not trying to strengthen himself, or create aevil child. He was trying to create “a kind of superwarrior, stronger and faster abetter than other Shadowhunters.” (CoG 402)

“It wasn’t a son I needed,” Valentine said. “It was a soldier. I had thought Jonamight be that soldier, but he had too much of the demon nature in him. He was



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savage, too sudden, not subtle enough. I feared even then, when he was bareout of infancy, that he would never have the patience or the compassion to follme, to lead the Clave in my footsteps.” (CoG 485)

d. Escapes

and goes intohiding.

Valentine doesn’t just escape, he fakes his own death (CoB 77) and impersona

another Shadowhunter. (CoB 442)

e. Tall andvery hand-some.

Valentine is described as being ‘good-looking’ and ‘handsome’ when he wasyoung on CoB 199 and 395, but on CoB 367: “(Valentine) bore little resemblanto the handsome boy in the photograph, though his eyes were still black. His fawas not what she had expected: It was a restrained, closed, interior face, the fof a priest, with sorrowful eyes.”

f. He uses

demon bloodto converthumanity.(CoG 201)

g. Had abrother ‐ likefriend he be-trayed whonow despiseshim.

(CoB 392-393)

h. Tries toburn the hu-manity fromhis children.

Factually inaccurate. Valentine was not attempting to remove his children’s hu

manity. Quite the opposite: “It wasn’t a son I needed,” Valentine said. “It was asoldier. I had thought Jonathan might be that soldier, but he had too much of thdemon nature in him. He was too savage, too sudden, not subtle enough. I feaeven then, when he was barely out of infancy, that he would never have the patience or the compassion to follow me, to lead the Clave in my footsteps.” (CoG485)

Further, changing the fundamental nature of children to imbue them with supernatural powers is an ancient trope in mythology. Examples include the story of

Achilles (whose mother anointed him with ambrosia and placed him in a fire inburn away his mortality), Aristaeus (who was fed necter and ambrosia to make

immortal), and Heracles (who gained supernatural powers from the divine milkHera).

http://www.greekmythology.com/Myths/Heroes/Achilles/achilles.htmlhttp://classicalwisdom.com/heracles-and-hera/http://www.greekmythology.com/Other_Gods/Minor_Gods/Aristaeus/aristaeus.h

Clare’s Character: Jocelyn Fray (misspelled “ Joceylyn” in the Exhibit, City of

Bones, 2007)Kenyon’s Character: Cherise Gautier (Night Pleasures, 2002)

Cherise is, indeed, Nick’s mother, just as Clary also does have a mother. A characterhaving a mother does not strike us as a unique facet of Kenyon’s work.

Kenyon’s Claims About CheriseGautier

Response:



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a. Lives next door to an Afri-can‐ American psychic whose home isdecorated with protection symbols andancient artifacts.

b. Was a young mother whohas the blood of angels and humans inher.

c. Gets kidnapped [by de-mons, in Cherise’s case] and goes into a“magical coma.”

Though Cherise as a character is present inKenyon’s early books, none of the claimedevents or facts about Cherise in the Exhibit oc-cur in any of Kenyon’s work published prior to

the end of 2007.

Kenyon’s Claims About Jocelyn Fray: Response:

a. Clary’s mother. CoB 18

b. Lives next door to an African‐ Americanpsychic whose home is decorated withprotection symbols and ancient artifacts.

CoB 29Factual inaccuracy: Dorothea is not African-

American in City of Bones. She was cast withan African-American actress, C.C.H. Pounder,in the movie adaptation of City of Bones; per-haps that is what Kenyon is thinking of.

c. Was a young mother who has theblood of angels and humans in her.

CoB 107

d. Gets kidnapped. Goes into a “magicalcoma.”

Kidnapped: (CoB 48-49) Coma: (CoB 425)Jocelyn induces her own magical coma. (CoA453) She’s kidnapped once she’s unconscious.

Clare’s Character: Jonathan Morgansterrn/Sebastian Verlac (City of Glass, 2009) Kenyon’s Character: Urian/Galan (Kiss of the Night, 2004)

Kenyon’s Claims About Urian Response:

a. Nekoda’s brother. No character named “Nekoda” occurs in Ken-yon’s work prior to the acceptance of the Cityof Glass manuscript. She seems to be a char-acter from Chronicles of Nick, which again,was published long after City of Glass was re-leased, much less submitted to Wojtyla.

b. He has one name but goes This does not occur — in fact the word “Galan”



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events take place. If this refers to some otherevent, it does not occur in books published pri-or to the end of 2007.

j. He threatens to raise anarmy of demons to destroy the world andcannot be killed without it killing the hero.

This does not occur in Kenyon’s books pub-lished prior to the end of 2007.

k. Said to be the spitting im-age of his father.

Not actually stated in Kenyon’s books pub-lished prior to the end of 2007. However, evenif true, does not line up with Clare’s allegedlyanalogous character. Also, we would questionwhether “closely resembles a parent” is ameaningfully distinguishing characteristic of

any character or indeed actual person.

Kenyon’s Claims About JonathanMorganstern/Sebastian Verlac

Response

a. Clary’s brother. (CoG 405)

b. He has one name but goes by another. (CoG 405)This is a common event in fiction that involvesany sort of subterfuge. Jonathan doesn’t justuse an alias, he killed the real Sebastian

Verlac and stole his entire identity.

c. Can be sadistic as a result of feedingon demon blood and has lost most of hishumanity.

Factually inaccurate. While lacking humanity(CoG 402, 485), Jonathan never feeds on de-mon blood. Instead, his mother was given po-tions that included demon blood when she waspregnant (CoG, 394-5), thus giving him a pow-erful but demonic nature. That nature does notchange based on his behavior; he has beenthe same barely-human demonic creaturesince birth, unlike his supposed analogue in

Kenyon’s work.

d. He can be charming when he wants. (CoG 405)

Villains in literature and folklore are frequentlycharming and charismatic. This was not a newcharacter concept invented by Kenyon.



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e. He attacks the heroes, killing the sib-ling of the main characters, severelywounding others and is eventually killedhimself.

(CoG 234, 436, 455, 458-466, CoHF 613)

f. His body is never recovered by his fa-ther. Factually inaccurate. Jonathan’s father is killedshortly after Jonathan is. (CoG 495). After this,Jonathan’s body is recovered by the demonLilith. (CoFA 330)

g. He is brought back to life by the herowho puts his mark on him to control him.

Factually inaccurate. The hero (Jace) does notbring Jonathan back to life. A demon (Lilith)does. Jace does not put his mark on Sebas-tian. Using power granted by Lilith, Sebas-tian/Jonathan is able to possess Jace and con-trol him.

(CoFA 421-424, CoLS 120-121)

h. He plays a double agent. (CoG 405)This is a common trope in adventure stories.

i. Because of the way he is broughtback, his life force is tied to the mainhero.

(CoFA 424, CoLS 120-121)

j. He raises an army of “Dark Shad-owhunters” and demons to destroy the

world and cannot be killed without it killingthe hero.

(CoLS 469-470, 476), (CoLS 119)

k. Said to be the spitting image of his fa-ther.

Factual inaccuracy. Jonathan did not only looklike his father, but resembled his mother aswell. “(Jonathan)’s face tempered her father’shard features with her mother’s prettiness; hewas tall but less broad-shouldered, more litheand catlike. He had Jocelyn’s cheekbones andfine soft mouth, Valentine’s dark eyes andwhite-blond hair.” (CoLS 180)

Clare’s Character: Madame Dorothea (City of Bones, 2007)Kenyon’s Character: Menyara Chartier

Kenyon’s Claims About MenyaraChartier

Response



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These claims are moot. This character doesnot appear in any of Kenyon’s books publishedprior to the end of 2007. We believe she is acharacter from Chronicles of Nick, but again,this postdates Madame Dorothea’s appear-

ance in published work by Clare by severalyears.

Kenyon’s Claims About Madame Dor-othea

Response

a. African‐ American psychic and clair-voyant.

Factual inaccuracy: Dorothea is not African- American in the book. (CoB 345)

b. She shields Clary and her mother fromthe powers of darkness and watches.

Factual inaccuracy: Dorothea did not go out ofher way to shield the Frays from their enemies.

Jocelyn paid Dorothea to let them live abovethe Sanctuary, with a portal downstairs foreasy escape if necessary. (CoB 180-109) Dor-othea kept an ear out for gossip about Valen-tine, but that was the only active assistanceshe rendered. (CoB 107)

c. She wants to protect them and keepthem safe from the demon world. Shelives next door to them.

Factually inaccurate. Dorothea does not livenext door to them. She lives in an apartmentdownstairs.Factually inaccurate. While Dorothea has a

fairly good relationship with Jocelyn, she is notparticularly protective of the Fray family. WhenJocelyn goes missing, Dorothea’s advice toClary is to “forget about your mother. She’sgone.” (CoB 97)

Clare’s Character: Luke Garroway a/k/a Lucian Graymark (City of Bones, 2007)Kenyon’s Character: Michael Tyler “ Big Bubba” Burdette

Kenyon’s Claims About Michael Tyler

“Big Bubba” Burdette:

Response

These claims are moot. The character doesnot appear in any of Kenyon’s books publishedprior to the end of 2007. We believe he is acharacter from Chronicles of Nick, but again,this postdates Luke’s appearance, biography,and backstory in published work by Clare by at



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least a year.

Kenyon’s Claims About LukeGarroway:

Response

a. Clary’s best friend. Factual inaccuracy: Simon is Clary’s bestfriend. (CoB 1)

b. Blue eyes with dark hair. (CoB 201, 466, CoG 9)

c. The only father Clary has ever known. (CoB 452)

d. Owns books and oddities store thatbears his name.

Factual inaccuracy. Luke owns a bookstore.(CoB 112) He does not sell ‘oddities.’

e. A former human hunter of paranormal

beasts because he fell victim to one.

Factual inaccuracy. Luke is a Shadowhunter-

turned-werewolf, not a former human. He wasborn a Shadowhunter. He did not become oneafter being attacked. (CoB 382, 385, 390-393)

f. Wears flannel shirts (inconsistent withcity setting in which CLARE sets hercharacter).

Factual inaccuracy. The implication that peoplein urban areas do not wear flannel shirts is un-founded. Even if that were the case, it is statedthat Luke has a country house upstate (CoB26)

Clare’s Character: Jace a/k/a Jonathan Christopher Way-land/Lightwood/Morgenstern/ Herondale (City of Bones, 2007)

Kenyon’s Character: Ash a/k/a Acheron Parthenopaeus, Acheron of Didymos, Apos-tolos, Ash Parthenopaeus, The Elekti, The Harbinger (Night Pleasures, 2002)

Kenyon’s Claims About Acheron ASH (AKA ACHERON, ET AL)

Response

a. Orphaned at a young age,he’s raised in adoptive homes.

b. Sends a note to his enemythat says, “I am coming for you.”

Neither of these pieces of information occur inKenyon books published before the end of

2007.

c. He has characters who call himdifferent names and often has to correctthem.

Though it is true that Ash has several differentnames, we could find no examples of him cor-recting an incorrect use of his name in Kenyonbooks prior to 2008.



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d. Tattooed, blond, “goth” andsarcastic.

In his first appearance (Night Pleasures, p.248) Acheron is described as having “…ever-changing hair color. He changed it so often,many of the Dark-Hunters made bets on what

color he was going to dye it for the week. To-night, he wore his long, dark green hair pulledback….” He does have tattoos. He is not de-scribed as “Goth” — his clothes may some-times resemble those considered “Goth” buttwo other characters are described as dressingin a Goth style — Tabitha and Eric — in NightPleasures, while Acheron is not.

In his second appearance, in a flashback sce-ne, he is described as having “hair that was an

unearthly jet-black which the man wore inthree long braids” (Night Embrace, p. 4). Laterthat book he is described as having “long me-tallic purple hair” (84). He has black hair againin Seize the Night (9).

He does have tattoos — although as explainedabove, Clare’s allegedly analogous characterdoes not — and he is described again as “al-ways finding new places to pierce his body,and his hair color changed faster than the un-

predictable Louisiana weather” (ibid). Alongwith his “silvery, shimmering eyes,” he seemsto bear almost no physical resemblance toClare’s character, although here language hascarefully been chosen to incorrectly suggestthat he does.

e. Generally aloof but bondedto the protagonist saved by a Dark‐ Hunter.

It is not specified to whom this refers, especial-ly since Acheron is described as the “main he-ro” on several other occasions in Kenyon’s ex-hibit. Perhaps she refers to Nick? Even so,

“aloof but friendly with the protagonist” de-scribes a near infinitude of characters from theearliest days of human storytelling to the pre-sent.

f. Knows who and what thepsychic is who bound Nick’s powers themoment they meet.

Acheron and Nick’s meeting is not dramatized,and any business about Nick’s “bound powers”does not occur, in any of Kenyon’s books pub-



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lished prior to the end of 2007. (And again, thiscomparison is based on an inaccurate descrip-tion of Clare’s character.)

g. Is told he has one father,

but his father is someone else.

This information is also not revealed in any of

Kenyon’s books published prior to the end of2007.

h. Has powers greater thanother Dark‐ Hunters. His abilities are aresult of his parent’s actions while he wasa fetus.

This information is also not revealed in any ofKenyon’s books published prior to the end of2007.

i. Stealthy. j. Body covered in scars.l. Is left handed.

[out of sequence in Exhibit 3]

These are extremely broad character traitsfound in literally thousands of charactersacross the entire history of fiction. Kenyon ob-

viously does not own the concepts of beingleft-handed, scarred, or being stealthy, or in-deed the combination of the three.

k. Tattoos that come and goand serve as protection.

In the Dark-Hunter books, Acheron’s protective“tattoos” are not actually tattoos, but ratherdemons who reside within his skin and appearto be tattoos until they are released as physicaldemons to defend him. This is fine as far as itgoes, but bears no resemblance to the waythat the marks on the skin of the Shad-

owhunters (and of course, all the Shad-owhunters, not just the one character who ismeant to be the analogue of Acheron) tie intothe fantasy world of the Shadowhunter books.The existence of “marks of skin bestowingpowers” is one that belongs to an ancientmythological tradition preceding both these au-thors’ works by thousands of years.

m. Had a sister not really relat-

ed to him

This is not revealed about Acheron in any of

Kenyon’s books published prior to the end of2007.

n. Has a friend named Alexionwho is like a brother to him and they arebonded together for life.

o. Ash takes care of Alexion.

First, obviously, Alexion and Alec are not thesame name, and similar character names oc-cur across all of literature. In addition, nobodyever refers to the character named Alexion as“Alec” or even “Alex” (he is nicknamed “Lex”



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on a couple of occasions, e.g. Sins of the Nightp. 122.) In addition, Alexion is not the charac-ter’s name, but rather his title -- he is referredto as “The Alexion” multiple times, including hisvery first appearance (Sins of the Night, 5; also

see ibid, 55).

In addition, this is a deliberate misrepresenta-tion of the relationship of Acheron and Alexionas it is actually described in Kenyon’s books(prior to the end of 2007). Alexion serves Ach-eron (ibid, 8; ibid, 54), because Acheronbrought him back from the dead (ibid, 87), butwas unable to bring him back as a living hu-man (ibid, 171). As a result, he is forced to re-side in Acheron’s domain, which is why Acher-

on takes care of him (ibid, 330). In Upon theMidnight Clear — again, published after theacceptance of the manuscript of City of Glass

— Alexion is described as “Ash’s servant”(272). At no point is he indicated to be “like abrother” to Acheron.

Kenyon’s Claims About Jace: Response

a. Orphaned at a young age, and growsup with an adoptive family.

(CoB 60)

b. Sends a note to his enemy that says, “Iam coming.”

Factual inaccuracy: Jace never does this. Jon-athan/Sebastian does. (CoLS 537)

c. He has characters who call him differ-ent names and often has to correct them.

(CoB 447)

d. Tattooed, blond, “goth” and sarcastic. Factual inaccuracy. Jace is not ‘goth.’ Hewears black because that’s the color of

Shadowhunter gear. (CoB 40, 62) Simon evenmakes a joke about Jace being goth which isfunny precisely because Jace isn’t goth.

Factual inaccuracy. Jace is not tattooed. Hebears magical Marks that give him certainpowers and disappear after use. They are nottattoos. (CoB 43)



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e. Generally aloof but bonded to theprotagonist saved by a Shadowhunter.

This is not a clear statement. If it refers to therelationship between Jace and Clary, Jace isdrawn to Clary, but not bonded to her. (CoG350-351)

f. He knows who and what the psychic isthe instant they meet.

Factual inaccuracy: Jace does not know whoDorothea is and is confused by how she knowsabout the Shadow world. (CoB 96)

g. Is told he has one father, but his fatheris someone else.

(CoB 438, CoG 461)

h. Has powers greater than other Shad-ow‐ hunters. His abilities are a result of hisparent’s actions while he was a

fetus.

(CoA 320, 338, CoG 404)

i. Stealthy. This descriptor of Jace is not found in the se-ries

j. Body is covered in scars. (CoB 433)It is not uncommon for warrior characters tohave scars.

k. Tattoos that come and go and serve asprotection.

The rune marks used by Shadowhunters arenot tattoos. They are not ink. (CoB 43)

l. Is left handed. (CoB 336)

m. Has a sister not really related to himwho nagged him.

While Clary and Jace are thought to be sib-lings for a period of time (CoB 441), there is nouse of the word “nag” in the context of Claryand Jace in any of the books of TMI. The nag-ging of one step-sibling by another is not acharacter trait that originated with Kenyon.

n. Has a friend named Alec who is like abrother to him and they are bonded to-

gether for life.

(CoB 87)

o. Jace takes care of Alec. Factually inaccurate. Jace is prone to self-destructive behavior, and Alec is more often inthe role of protector. (CoB 142, 298-299)

Clare’s Character: Isabelle Lightwood



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Kenyon’s Character: Tabitha Devereaux (misspelled in the Exhibit, even!) Magnus(Night Pleasures, 2002)

Kenyon’s Claims About Tabitha: Response

a. Rebellious and beautiful. Broad character attributes to be found in tan-dem in literally thousands of other charactersthroughout the history of literature, folklore,and mythology.

b. Stalks demons and vam-pires, anything that preys on humans.

Tabitha is an independent vampire hunter un-affiliated with any of the major organizations ofthe Dark-Hunter books (Seize the Night, 8),where Isabelle shares these traits in commonwith every single other Shadowhunter charac-ter in Clare’s books.

c. Her cooking is mocked. This does not occur in books of Kenyon’s pub-lished before the end of 2007.

d. She wears tall boots and isknown to be dangerous and heavilyarmed at all times.

e. She always has weapons inher boots.

f. Wears heels or platformboots (even though she is tall).

“Wearing boots” and “carrying weapons” arecharacter attributes to be found in tandem inthousands upon thousands of characters infiction. It is not clear why Tabitha wearingboots is so uniquely defining of a characterthat another character wearing boots shoulddeserve three separate notes complaining

about it. Countless fantasy-adventure heroesacross all time, men and women (and evencats) sometimes are seen to wear boots andcarry weapons. In addition, Clare’s characterIsabelle wears boots not as a fashion choicebut because they are standard parts of thefighting gear worn by Shadowhunters, andthus she has these attributes in common with,again, every other Shadowhunter character inClare’s books.

g. Unique signature weaponshe is skilled with. Dresses well and loansother characters her clothes.

h. Seems flamboyant andloud, but is generous and tender ‐ hearted.

Again, these are broad character attributes tobe found in so many other characters that it isimpossible to list them here.



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i. Extremely caring and re-sponsible for all those around her. Alwaystakes responsibility.

j. When a loved one is killed

she feels responsible even though shewas unconscious at the time.

k. She is friends with Nick and Ash.

l. Is fiercely protective of hergay roommate.

Tabitha is friends with Nick in Kenyon’s bookspublished prior to the Mortal Instruments se-ries, but certainly not with Ash. She does nothave a gay roommate in any of Kenyon’sbooks published prior to the Mortal Instrumentsseries.

m. Has amber/gold eyes.

n. Has long dark auburn hairshe dyes jet black.

In Tabitha’s first appearance, she is described

as follows: “Her thick, wavy dark auburn hairwas pulled into a long ponytail, and her paleblue eyes glowed” (Night Pleasures, 7). Whenshe appears as a protagonist in Seize theNight, her hair is also not dyed (7). She doesnot appear to either have amber/gold eyes ORto dye her hair black in Kenyon’s books pub-lished before 2007.

o. Thinks of Ash as a brother. This is not the case in Kenyon’s books pub-lished before the end of 2007. In fact, in thefirst detailed interaction between Acheron and

Tabitha, in Seize the Night, a full page of textis spent describing how much Tabitha is sex-ually attracted to Acheron, saying that he has“worm[ed] his way into her guarded heart” (8)and while she notes that she would not touchhim, it is not because she thinks of him as abrother.”

p. Loses a sibling she’s closeto early in the series.

This is, indeed, true of both Tabitha, who losesher sister Tia in Seize the Night, and Isabelle,who loses her brother Max in City of Glass.

Kenyon’s Claims About Isabelle: Response

a. Rebellious and beautiful. (CoB 6)

b. Stalks demons and vampires, anythingthat preys on humans.

(CoB 63,142)



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c. Her cooking is mocked. (CoB 137, 141)

d. She wears tall boots and is known tobe dangerous and heavily armed at alltimes.

(CoB 4, 212)

e. She always has weapons in her boots. Factually inaccurate. Isabelle does not alwayshave weapons in her boots. Only sometimes.

f. She wears high heels (even though sheis tall).

(CoB 158)

g. Unique signature weapon she is skilledwith. Dresses well and loans other char-acters her clothes.

Isabelle only loans another character clothestwice in the series. (CoB 60, 208)

h. Seems flamboyant and loud, but isgenerous and tender ‐ hearted.

(CoA 101, CoG 323-327)

i. Extremely caring and responsible forall those around her. Always takes re-sponsibility.

Factually inaccurate. While she cares a lotabout her friends and family (CoB 354, CoA101), Isabelle does not always follow rules,and is not always quick to take responsibilitywhen she breaks them. (CoA 290, 292)

j. When a loved one is killed she feels re-

sponsible even though she was uncon-scious at the time.

(CoG 323-327)

k. Friends with Simon. Isabelle is more than just friends with Simon;they’re romantically involved. (CoG 47)

l. Fiercely protective of her gay friend. Factual inaccuracy. Alec is Isabelle’s brother,not her friend (CoB 211)

m. Has brown eyes with gold/amber. Factual inaccuracy. Isabelle’s eyes are black(CoB 68).

n. Has long ink black hair. (CoB 3)

o. Thinks of Jace as her brother. (CoA 290)

p. Loses a sibling she’s close to early inthe series.

(CoG 234)



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f. Regrets her decision to banish ashapeshifter who became distrustful ofher.

Factual inaccuracy. There is no situation likethis described in TMI.

g. In City of Glass (2009), werewolves

take refuge in her home after a battlewith demons and Shadowhunters wherethey’re wounded. Helps Shadowhuntersbattle Dark Shadowhunters.

Factual inaccuracy. Werewolves do not shelter

in Amatis’s house during CoG. Luke staysthere years before, prior to the Uprising. (CoG146)

Factual inaccuracy. Amatis never helps battleShadowhunters who have been turned evil. Infact, she is the first Shadowhunter turned evil.(CoLS 476-478)

h. Is seen for a time as an enemy. Factual inaccuracy. Amatis is not just seen asan enemy after she is turned evil. She is an

enemy.

i. Dies in battle while passing one lastlonging look at her family she lovesand redeems herself.

Factual inaccuracy. Amatis does give Luke alast look, but she has no opportunity to redeemherself. (CoHF 610)

Clare’s Character: Alexander “ Alec” Gideon Lightwood (City of Bones, 2007)Kenyon’s Character: Ias of Groesia AKA Alexion

Kenyon’s Claims About Alexion: Response

Apart from the general facts, not mentioned inKenyon’s Exhibit, that Alexion:

- has died and been resurrected twice (Sins ofthe Night, 5)

- is a Shade — “more or less a ghost” (SotN260) and therefore does not sleep (260) oreat (274)

- is so old he predates the Bronze Age (152)- can only remain in the human world for a

short time before he must return to being aShade again (14)- is indestructible, and his body will reform after

two seconds or so if he is killed (17)

None of these describe Alec or indeed resem-ble even vaguely any character from Clare’s



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{01378276.1 }25

books, the fact that Alexion is the friend of ahero and fights with him describes a funda-mental relationship of humans found in all sto-ries throughout history, starting as early asabout Achilles and Patroclus in The Iliad. And

Jonathan and David in The Bible (actuallystated as the inspiration for the warrior-bondthat the Shadowhunters have, in the Shad-owhunter’s Codex).

With respect to the claim that in both cases thecharacters are bonded for life, Alexion is clear-ly depicted as Acheron’s servant and literallydependent on him for existence, whereas Alecand Jace are friends and are dependent oneach other in the more usual and common way

that human beings are dependent on eachother when they are friends. These are obvi-ously not identical or even similar situations,even if vague enough language can causethem to sound that way.

Kenyon’s Claims About Alec: Response

a. Highly protective of Jace. (CoB142, 298-299)

b. He is bound to Jace for life and de-pends on him. (CoB 87)

c. They fight together. (CoB 87)

Clare’s Character: Magnus Bane (City of Bones, 2007)Kenyon’s Character: Eric St. James (Night Pleasures, 2002), but rose to much moreprominence in the Chronicles of Nick series

Kenyon’s Claims About Eric: Response

While it is true that in his first appearance, inNight Pleasures, Eric has black hair spikedwith color (8), this is not true of Magnus. In ad-dition, Magnus is depicted as romantically at-tracted to men from his first appearances,where Eric is depicted as romantically attract-ed to women in his appearance in Night



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{01378276.1 }26

Pleasures (where he is Tabitha’s boyfriend)and his mention in Seize the Night where hehas married an unnamed woman.

After these two appearances Eric does not ac-

tually appear again at all in Kenyon’s work untilthe Chronicles of Nick, whose first book waspublished May 25, 2010. As mentioned in theintroduction, Clare’s Clockwork Angel, in whichMagnus is first confirmed as bisexual, was ac-cepted by her editor in its first completed draftSeptember 28, 2009.

In addition, it is ludicrous and not a little offen-sive to suggest that Clare would have takenthe inspiration to have a bisexual character

from another author’s work, rather than fromher own experiences living in the real worldand having friends, colleagues, and acquaint-ances across all parts of the sexual identityspectrum. Unlike Kenyon’s Dark-Hunter series,which contains no queer characters of any kindat least through the end of 2007, queer charac-ters and same-sex romances have been a partof Clare’s work since her very first novel.

Kenyon’s Claims About Magnus: Response

a. Jet black hair spiked with color. Factual inaccuracy. Magnus often spikes hisblack hair (CoB 219), but he does not color it.

b. Bisexual (CA 198)

Clare’s Character: Maia Roberts (City of Ashes, 2008)Kenyon’s Character: Simone DuBois

Kenyon’s Claims About Simone: Response

These claims are moot. This character doesnot appear at any time in Kenyon’s work pub-lished prior to the end of 2007, long after thecharacter of Maia was established in City of

Ashes and City of Glass.

Kenyon’s Claims About Maia: Response



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a. Jace loves him like a little brother. (CoA 13, 176-177)

b. He passes a toy along to him. (CoG 325)

c. Max’s death devastates Jace. (CoG 290)

Clare’s character: Raziel (City of Bones, 2007) Kenyon’s character: Wulf (Kiss of the Night, 2004)

Kenyon’s Claims About Raziel: Response

Memory of Raziel’s appearances “fledfrom mind and memory as quickly asthey were seen.”

Factual inaccuracy. The quote above is from a fic-tional archaic text. (Codex 119) It does not agreewith (and is not meant to agree with) the actualexperiences the characters have with Raziel.

Those who encounter him, Clary (CoG 491-497)and Simon (CoLS 425-430) have perfect recall oftheir experiences with the angel.

Moreover, Raziel is based on the archangel Ra-ziel, angel of secrets and knowledge from the an-cient Jewish Kabbalistic tradition. The Book of Ra-ziel is thought to date to the 13th century. Furtherbackground can be found here:http://www.jewishencyclopedia.com/articles/12606-raziel-book-of

and here:http://robert-zucker.com/qabalah/seferraziel/

Kenyon’s Claims About Wulf: Response

Cursed so that no one can rememberhim after he leaves their presence.

In the case of Wulf it is a curse laid upon him by aspecific other character, and is modified by Acher-on so that he can be remembered by any bloodrelatives (73, 91), so actually the statement pre-

sented here in the exhibit misrepresents that as-pect of the character to make the resemblance toClare’s work seem more than it is. In addition, perabove, even this broader statement is not actuallytrue of the character of Raziel in Clare’s work, andis instead a piece of angelic folklore presented in afictional archaic text which the characters of thebooks learn to be untrue.



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Clare’s Character: Moloch (City of Ashes, 2008)Kenyon’s Character: Malachai

Kenyon’s Claims AboutMalachai:

Response

These claims are moot. The word “Malachai” does not appearin any of Kenyon’s work prior to the end of 2007, so even ifClare’s character wasn’t, in fact, a character from the HebrewBible rather than an original creation, it is irrelevant to Ken-yon’s work where no such character or “order of demon” ap-pears prior to its use by Clare.

Kenyon’s Claims About

Moloch:

Response

The highest order of de-mon.

Factual inaccuracy. From the Shadowhunter’s Codex:

Somewhat confusingly, the name “Moloch” refers bothto a Greater Demon known as one of the most fear-some demon warriors, a being of smoke and oil, andalso to a species of lesser demons (“ Molochs” )that are minions and foot soldiers of the GreaterDemon Moloch. Individuals of the species are man-size, dark, and made of thick roiling oil, with arms but

only a formless liquid appendage instead of legs. Theirprimary weapon is the flames that stream from theirempty eye sockets, and they are usually seen in largenumbers rather than in isolation. (72)

It is the lesser Moloch demons that appear in TMI.

In ancient texts including the Bible, Moloch was an Ammonitedeity or demon who demanded child sacrifice:http://www.jewishencyclopedia.com/articles/10937-moloch-molech

http://www.jewishvirtuallibrary.org/jsource/History/moloch.html

D. Scene Similarit ies:

From Clare’s work: “Clave Council”From Kenyon’s work: “Squire’s Council”



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The Squire Council does not appear at all in Kenyon’s books prior to the end of 2007.

Kenyon’s Claims About the ClaveCouncil:

Response

a. The political body that oversees theShadowhunters.

Partial inaccuracy. “Clave Council” is not aphrase used in TMI. The Clave is made up ofall active Shadowhunters who are 18 or older.The Council (CoA 99) is a smaller group ofrepresentatives, which deals with matters ofimmediate import that are not large enough forthe entire Clave to become involved in. Theydo this under the supervision of the highestranking member of the Clave, the Consul.

b. Local branches and regions. (Codex 8)

c. The Clave Council incorporates all re-lated supernatural beings, not onlyShadowhunters.

Partial inaccuracy. Representatives of the oth-er groups of supernatural beings (vampires,werewolves, faeries and warlocks) did nothave seats on the Council until City of Glass(337, 407). Faeries lost their seat on theCouncil in City of Heavenly Fire (635)

d. Entire Council may be summoned, oronly those who are necessary or involved

in the matter at hand.

(Codex 9)

e. Particular meetings have distinctnames.

(Unclear statement)

f. A particular group lost its seat at thecouncil.

(CoHF 635)

g. Round chamber ‐ hall with a magicalportal entrance.

Factual inaccuracy. The Clave does meet in around chamber, but the entrance is not a mag-ical portal.

From Clare’s Work: “Daimons" (maybe meant to be “demons?”)From Kenyon’s Work: “Were-Hunters”

Kenyon’s representation of Clare’s demons are almost entirely incorrect. What sheseems to be trying to describe is warlocks, so the citations for their appearance inClare’s work under warlocks.



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Kenyon’s Claims About Were-Hunters:

Response

Kenyon’s Were-Hunters seem very clearly tohave been inspired by folklore and mythology

about humans who magically transform intoanimals or otherwise have animal natures;such creatures and characters can be found innumerous folklore and mythological traditionsand, of course, also in thousands of works ofmodern horror and fantasy fiction publishedlong before Kenyon or Clare had written aword. As previously stated, there ARE no“Daimons” in Clare’s books. Kenyon seems tobe describing Clare’s warlocks, but Clare’swarlock characters have none of this animal-

nature or shapeshifting quality. Perhaps Ken-yon is thinking of the werewolves in Clare’sbooks, which again, come from the samelongstanding folkloric tradition that Kenyonherself draws from. But even here, the com-parisons do not make sense. Clare’s were-wolves do not practice magic, do not havemarkings that reveal their nature, are not im-mortal, do age, and are rarely referred to de-rogatorily by other characters.

Kenyon’s Claims About Daimons(Demons?) Response

a. Practice magic they inherit throughbirth.

Factual inaccuracy. It is not known where de-mons come from, and the nature of their magicis also unknown.

b. Have to make their own way in theworld. Have been betrayed by Shad-owhunters.

Factual inaccuracy. There is no such relation-ship between demons and Shadowhunters,

c. Have their own special markings from

subtle to obvious.

Factual inaccuracy. Demons don’t just have

markings, they are of a wide range of differentspecies.

d. Can hide their marks with their powers. Partial inaccuracy. Only demons with the abil-ity to use glamours can disguise themselves,and even then individuals with the Sight canusually see their true nature.



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e. Originally created through deceit. Factual inaccuracy. There is no such mytholo-gy in the Mortal Instruments. It is not knownhow demons were created.

f. They were immortal beings who

stopped aging.

Factual inaccuracy. This is not a trait of the

demons of the Shadowhunter world.

g. They are unable to have children. Factual inaccuracy. In the world of the MortalInstruments, demons can procreate. The off-spring they produce with humans are warlocks.

Kenyon’s Claims About Warlocks: Response

Practice magic they inherit through birth. (CoB 101)

b. Have their own special markings from

subtle to obvious.

(CoB 229, CA 60)

c. They can hide their marks with powers. (CoB 229-230)Partial inaccuracy. Warlocks have the ability touse glamours can disguise themselves, butindividuals with the Sight can usually see theirtrue nature.

d. Immortal beings who stop aging. (C0A 407, CoG 239, CoFA 253)

e. They are often referred to by derogato-

ry terms.

Factual inaccuracy. Warlocks are mostly re-

ferred to as Warlocks or Lilith’s Children.

From Clare’s Work: “Warlocks”From Kenyon’s Work: “Adoni”

Kenyon’s exhibit also compares Clare’s warlocks to her “Adoni.” Adoni are not present

in the Dark-Hunter series from which all of Kenyon’s other claims arise, but rather arefrom her Lords of Avalon series, originally published under the pseudonym Kinley Mac-Gregor. It is true that the Adoni were first introduced before Clare’s work was published(Sword of Darkness, March 28, 2005). However, Adoni are clearly the inheritors of along-standing traditions of elves and elf-like creatures whose modern common fantasyelements date back at least to JRR Tolkien’s work, and more properly to Northern andWestern European folklore going back more than a thousand years. Kenyon describesthe Adoni as follows:



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Kenyon’s Claims About Adoni : Response

“a beautiful race of elflike creatures”(Sword of Darkness, “Vocabulary”)

“…tall, fair of form, and agile.”“Humans oft called them elves…”“The Adoni were a separate, vicious racethat preyed on mankind whenever theycould.” (23)

None of these statements are true of warlocks,who come in all shapes and sizes and levels of

beauty, are not a separate “race” from hu-mans, and are not ever thought of or describedas elves or as elven. They are also not the en-emies of mankind, but rather their allies.

In addition, in Kenyon’s work, “Merlins” are de-scribed as being bred from Adoni (SoD 206);Clare’s warlocks are sterile and cannot bearchildren.

And actually, while we are at it, NONE of the

aspects of the Adoni that are described in thisexhibit are actually expressed in Sword ofDarkness — not the marks, not the immortality,not the lack of aging, not the practicing of mag-ic. The second book containing the Adoni,Knights of Darkness, was published November01, 2006. Advance Reader Copies of City ofBones were circulating among the publishingindustry several months before this publicationdate, and so could not have been inspired bythis or any later Kenyon work.

From Clare’s Work: The Praetor Lupus From Kenyon’s Work: Sanctuary

Kenyon’s Claims About the PraetorLupus:

Response

a. Founded over one hundred years agoafter the death of shape‐ shifter rela-tive to provide a place of refuge orSanctuary for other preternatural be-ings.

This comparison represents a major misunder-standing of the Praetor Lupus in Clare’s books.In Kenyon’s books, Sanctuary is a place. ThePraetor Lupus, however, is an organizationwith members across the globe. Although itdoes have a headquarters, that headquartersis more of a military academy and office build-



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ing and never acts as a sanctuary or hideoutfor anybody in Clare’s books. (CoFA 142-143)

b. A place where others can learn theirpowers and have protection.

(CoFA 142-143)

Again, the Praetor Lupus is not a place. In ad-dition, of course, the concept of a refuge for

unusual people to learn about their unusualpowers did not originate with Kenyon or Clarebut rather also speaks to folklore going backcenturies before the modern era. This essen-tially describes the “school for magic,” foundedin hundreds of works of fantasy, but also re-flected in, say, the Scholomance, the folkloricschool of black magic run by the Devil that ispart of Transylvanian folklore and was broughtto the attention of English readers by Scottishauthor Emily Gerard in the 19th century.

A particular disease can turn humans intodemons.

(CP2 26)This does not occur in Kenyon’s work prior tothe end of 2007, although we will stipulate thatit does take place in Clockwork Princess, pub-lished much later. It is, however, an idea well-known in folklore. Vampirism and lycanthropywere both frequently thought of as diseasesthat could turn humans into demonic creaturesin folklore going back hundreds of years; infact during the historical persecution of witches

in late medieval Europe, people were often ex-ecuted for being “werewolves,” since that wasconsidered a similarly demonic status.

From Clare’s and Kenyon’s Work: Portals

Kenyon’s Claims About Portals: Response

a. Demons come and go from the

human world through secret por-tals.

Factual inaccuracy. Demons in the Shad-

owhunter universe have their own methods oftravel between dimensions, and do not typical-ly use portals.

b. Shadowhunters do not know the layoutof the demon realm.

Misleading. There is not only one demonrealm, but many. (CoB 176)

c. “Humans cannot return from the demon Factually incorrect. In CoHF (602), Sebastian



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realm…” closes the realm of Edom, destroying the exitsto prevent Clary and her companions fromleaving. Up until he did that, they could haveleft.

“…but demons who are killed can return.” Ambiguous. In Clare’s work, demons who arekilled do return, involuntarily, to their home di-mensions (CoB 15). It is not clear what theanalogous material in Kenyon’s work is meantto be here.

clare response to exhibit 3

Documents