Looks possible, based on this report from Stacy McCain:
A Democrat political consultant with ties to convicted terrorist Brett Kimberlin has accused Breitbart.com contributor Brandon Darby of making fake SWAT calls against conservative bloggers.
In a thousand-word document sent to government officials, Kimberlin associate Neal Rauhauser accuses Darby of conspiring with a number of others — including employees of Republican consulting firm Hynes Communications — in an elaborate criminal scheme involving illegal so-called “SWATting” incidents aimed at four conservative bloggers: Mike Stack, Patrick “Patterico” Frey, Erick Erickson of Red State and Aaron Walker. The document (see full text below) describes Rauhauser’s accusations that the SWATting calls are “tied to an extortion attempt by Mike Grimm, Congressman from NY-13, an obstruction of justice attempt intended to deflect attention from James O’Keefe, and the whole thing is being wrapped up by Hynes Communications in an attempt to create another ‘Bill Ayers’ for the 2012 election.”
Furthermore, Rauhauser forwarded to an associate of Darby copies of e-mails he sent to a Republican member of Congress. In the e-mails he sent to the office of Rep. Sandy Adams (R-Fla.) in June and July, Rauhauser charges that Darby and others were engaged in a “conspiracy to obstruct justice.” The full text of those e-mails is also appended below.
Go to Stacy’s link for the full paranoid and bizarre theory. Instapundit says that “the libel suit should be interesting” and adds, regarding Rauhauser’s theory: “That doesn’t even make sense. But the discovery process should be productive. . . .”