(Cleveland) - Cleveland Browns season ticket holder Ken Lanci has filed a revised complaint against the National Football League and its member organizations, including the Cleveland Browns, in the Cuyahoga Court of Common Pleas.

Lanci also filed two motions with the court seeking to end the lockout and prevent the Browns from collecting Lanci’s ticket money during the lockout.

The suit alleges that the Browns are not meeting the commitments of their contract with Lanci per the Permanent Seat License Agreement. The suit also alleges that the NFL and other NFL teams are interfering with Lanci’s contract rights.

"Since the NFL has not listened to reason, my aim is to pressure them through litigation to respond," Lanci said. "These amendments ask the Court to strike down the Browns' Lockout Ticket Policy as unconscionable because it requires season ticket holders to pay their ticket money up front, even though the Browns are participating in a lockout that prevents games from being played."

"The litigation asks that the Browns live up to their end of the bargain and provide us games to watch this fall," Lanci said. "Any damages collected would be donated to charity. We need to remind the NFL that the only reason they have dollars to fight over is because of the fans," he added.

The amendments also add a count to prevent the Browns from using a clause in the PSL which the Browns could argue excuses them from playing games in the event of a strike or labor disturbance.

"We believe the Browns should not be able to take advantage of a Strike Clause when they and other NFL Teams are the ones responsible for the work stoppage. These amendments are necessary because the players' litigation in Federal Court has stalled and the Court has ordered mediation, rather than ruling on whether the lockout will be lifted," Lanci said.

The lawsuit, originally filed on March 25th, asks for in excess of $25,000 in damages. "Other season ticket holders would need to file their own actions in order to receive damages, but success here almost certainly would result in success in similar actions," Lanci said, "creating financial pressure for the NFL to settle with the players."

Lanci, a successful entrepreneur and weekend talk show host on Newsradio WTAM 1100, says he plans to continue to "work for the greater good of all."

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