On March 27, the complaint alleges, Allen, on The Today Show, broadcast a fourth, slightly-different edited version of the call, in which Zimmerman could be heard saying, "'This guy looks like he's up to no good. He looks black.'"
In the actual conversation, according to the complaint, Zimmerman told the dispatcher, "'This guy looks like he's up to no good or he's on drugs or something. It's raining and he's just walking around, looking about,'" at which point the dispatcher asked Zimmerman whether Martin was "'black, white or Hispanic,'" to which Zimmerman responded, "'He looks black.'"
The complaint on the website alleges NBC's airing of what the plaintiffs are calling "doctored" audio made it appear that "Zimmerman's actions were motivated by racial stereotypes, rather than by concern for his safety and the safety of his neighbors."
"NBC created this false and defamatory misimpression using the oldest form of yellow journalism: manipulating Zimmerman's own words, splicing together disparate parts of the recording to create the illusion of statements that Zimmerman never actually made," the complaint alleges.
The complaint also alleges that, along with the multiple edited versions of the 911 call that were aired by NBC, Burnside and Luciano, another NBC reporter misrepresented the call in a March 20 broadcast.
According to the complaint, Allen reported that Zimmerman described Martin to the 911 dispatcher "using a racial epithet."
"The defendants knew that Zimmerman did not use a 'racial epithet' to describe Martin, yet they maliciously and conclusively stated that he did, for the purposes of portraying Zimmerman as a hostile racist," the complaint alleges, adding that the defendants made this statement in part to "encourage an investigation and prosecution of Zimmerman."
According to the complaint appearing on the website, Luciano and Burnside were both terminated, but not until after other news outlets reported on the edited audio aired by NBC.
Allen still works for NBC, according to the complaint.
"To this day, the defendants have never apologized to Zimmerman for deliberately portraying him as a hostile racist who targeted Martin due to his race; instead, NBC's president Steve Capus, in a feeble attempt at damage control, falsely claimed this manipulated audio was merely a 'mistake' and 'not deliberate,'" the complaint alleges. "By then, the damage was done, the indelible image of Zimmerman stalking Martin because 'he looks black' fixed in the public consciousness."