benefit he would receive through this litigation, and therefore fails to show a personal stake in the outcome.
Defendant does not doubt Newdow's sincerity in bringing this action.  Defendant does not doubt that Newdow is highly offended by references to God.  Indeed, Newdow has worked relentlessly over the last few years to try to convince federal courts to agree with his view that government should be wiped clean of all references to God or any Supreme Being.1   However, "the state has no legitimate interest in protecting any or all religions from views distasteful to them...."  Joseph Burstyn, Inc. v. Wilson, 343 U.S. 495, 505, 72 S.Ct. 777, 782.
Moreover, where a party seeks injunctive relief, establishing standing includes demonstrating a real and immediate threat of irreparable injury. Cole v. OroviIIe Union High School District, 228 F.3d 1092, 1100 (9th Cir. 2000)(dismissing complaint regarding prayer at graduation ceremony for want of standing because plaintiffs had not shown a probability of imminent recurrence).  "Past exposure to illegal conduct does not in itself show a present case or controversy regarding injunctive relief if unaccompanied by any continuing, present adverse effects."  O'Shea v. Littlekon, 414 U.S. 488, 495-496, 94 S.Ct.
1    In addition to this action, Newdow has challenged the inclusion of "under God" in the Pledge of Allegiance in Newdow v. Congress, et a2.. Civ. S-00-495 MLS/PAN PS (the dismissal of which is now on appeal to the 9th Circuit), and in Newdow v. United States, et a2.. Case No. 98-6585-CIV-UNGARO-BENAGES (S.D. Fla.), the dismissal of which was affirmed on appeal by the 11th Cir. on March 1, 2000.  In addition, at the hearing on the motion to dismiss in the Newdow v. Congress case Newdow advised the court that he is-highly offended every time he spends U.S. currency bearing the words "In God We Trust."