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FILED Brett L, Gibbs, Esq. (SBN 25 1000) nta erp bh | | : a9 Of Counsel to Prenda Law Inc. 2012SEP 27 Al 38 Miller Avenue, #263 CLERK U.S, DISTRICT COURT Mill Valley, CA 94941 CENTRAL DIST, OF CALIF 415-325-5900 LOS ANGELES

blgibbs@wefightpiracy.com Attorney for Plaintiff

IN THE UNITED STATES DISTRICT COURT FOR THE

CENTRAL DISTRICT OF CALIFORNIA

wOV 12-8333

INGENUITY 13 LLC, ) ) : Plaintiff, Judge: | 7 ainti g SVW [ PYWy\ ) JOHN DOE ) COMPLAINT ) Defendant. ) ) DEMAND FOR JURY TRIAL EE REET |

Plaintiff Ingenuity13 LLC (“Plaintiff”), through its undersigned counsel, hereby files this

Complaint requesting damages and injunctive relief, and alleges as follows: NATURE OF THE CASE

Ie Plaintiff files this action for copyright infringement under the United States Copyright Act and related contributory infringement and negligence claims under the common law to combat the willful and intentional infringement of its creative works. Unidentified Defendant John Doe (“Defendant”), whose name Plaintiff expects to ascertain during discovery, knowingly and illegally reproduced and distributed Plaintiff's copyrighted Video by acting in concert with others via the BitTorrent file sharing protocol and, upon information and belief, continues to do the same. In using BitTorrent, Defendant’s infringment actions furthered the efforts of numerous others in infringing on

Plaintiff's copyrighted works. The result: exponential viral infringment. Plaintiff seeks a permanent

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injunction, statutory or actual damages, award of costs and attorney’s fees, and other relief to curb

this behavior. THE PARTIES

es Plaintiff Ingenuity!3 LLC is a limited liability company organized and existing under the laws of the Federation of Saint Kitts and Nevis. Plaintiff is a holder of rights to various copyrighted works, and is the exclusive holder of the relevant rights with respect to the copyrighted creative work at issue in this Complaint.

3, The copyrighted work at issue in this complaint is one of Plaintiff's adult entertainment videos, “A Peek Behind the Scenes at a Show” (the “Video”).

4, Defendant’s actual name is unknown to Plaintiff. Instead, Defendant is known to Plaintiff only by an Internet Protocol address (“IP address”), which is a number assigned to devices, such as computers, that are connected to the Internet. In the course of monitoring Internet-based infringement of its copyrighted content, Plaintiff's agents observed unlawful reproduction and distribution occurring over IP address 108.13.119.253 via the BitTorrent file transfer protocol. Plaintiff cannot ascertain Defendant’s actual identity without limited expedited discovery.

JURISDICTION AND VENUE

ai This Court has subject matter jurisdiction over Plaintiff's copyright infringement claim under 17 U.S.C. §§ 101, et seg., (the Copyright Act), 28 U.S.C. § 1331 (actions arising under the laws of the United States), and 28 U.S.C. § 1338(a) (actions arising under an Act of Congress relating to copyrights). This Court has supplemental jurisdiction over Plaintiffs contributory infringement and negligence claims under 28 U.S.C. § 1367(a) because they are so related to Plaintiff's copyright infringement claim, which is within this Court’s original jurisdiction, that the claims form part of the same case and controversy under Article III of the United States

Constitution.

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6. This Court has personal jurisdiction because, upon information and belief, Defendant either resides in or committed copyright infringement in the State of California. Plaintiff used geolocation technology to trace the IP address of the Defendant to a point of origin within the State of California. Geolocation is a method for ascertaining the likely geographic region associated with a given IP address at a given date and time. Although not a litmus test for personal jurisdiction, the use of geolocation gives Plaintiff good cause for asserting that personal jurisdiction is proper over the Defendant. |

7. Venue is properly founded in this judicial district pursuant to 28 U.S.C. §§ 1391(b) and 1400(a) because Defendant resides in this District, may be found in this District, or a substantial

part of the events giving rise to the claims in this action occurred within this District.

BACKGROUND 8, BitTorrent is a modern file sharing method (‘protocol’) used for distributing data via the Internet. 9, Traditional file transfer protocols involve a central server, which distributes data

directly to individual users. This method is prone to collapse when large numbers of users request data from the central server, in which case the server can become overburdened and the rate of data transmission can slow considerably or cease altogether. In addition, the reliability of access to the data stored on a server is largely dependent on the server’s ability to continue functioning for prolonged periods of time under high resource demands.

10. Standard P2P protocols involve a one-to-one transfer of whole files between a single uploader and single downloader. Although standard P2P protocols solve some of the issues associated with traditional file transfer protocols, these protocols still suffer from such issues as scalability. For example, when a popular file is released (e.g. an illegal copy of the latest blockbuster

movie) the initial source of the file performs a one-to-one whole file transfer to a third party, who

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then performs similar transfers. The one-to-one whole file transfer method can significantly delay the spread of a file across the world because the initial spread is so limited.

Il. In contrast, the BitTorrent protocol is a decentralized method of distributing data. Instead of relying on a central server to distribute data directly to individual users, the BitTorrent protocol allows individual users to distribute data among themselves. Further, the BitTorrent protocol involves breaking a single large file into many small pieces, which can be transferred much more quickly than a single large file and, in turn, redistributed much more quickly than a single large file. Moreover, each peer can download missing pieces of the file from multiple sources—often simultaneously—which causes transfers to be fast and reliable. After downloading a piece, a peer automatically becomes a source for the piece. This distribution method contrasts sharply with a one- to-one whole file transfer method.

12; In BitTorrent vernacular, individual downloaders/distributors of a particular file are called peers. The group of peers involved in downloading/distributing a particular file is called a swarm. A server which stores a list of peers in a swarm is called a tracker. A computer program that implements the BitTorrent protocol is called a BitTorrent client. Each swarm is unique to a particular file.

13, The BitTorrent protocol operates as follows. First, a user locates a small “torrent” file. This file contains information about the files to be shared and about the tracker, the computer that coordinates the file distribution. Second, the user loads the torrent file into a BitTorrent client, which automatically attempts to connect to the tracker listed in the torrent file. Third, the tracker responds with a list of peers and the BitTorrent client connects to those peers to begin downloading data from and distributing data to the other peers in the swarm. When the download is complete, the BitTorrent client continues distributing data to other peers in the swarm until the user manually disconnects from the swarm or the BitTorrent client otherwise does the same.

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14. | The degree of anonymity provided by the BitTorrent protocol is extremely low. Because the protocol is based on peers connecting to one another, a peer must broadcast identifying information (i.e. an IP address) before it can receive data. Nevertheless, the actual names of peers in a swarm are unknown, as the users are allowed to download and distribute under the cover of their IP addresses,

15. The BitTorrent protocol is an extremely popular method for transferring data. The size of swarms for popular files can reach into the tens of thousands of unique peers. A swarm will commonly have peers from many, if not every, state in the United States and several countries around the world. And every peer in the swarm participates in distributing the file to dozens, hundreds, or even thousands of other peers.

16. The BitTorrent protocol is also an extremely popular method for unlawfully copying, reproducing, and distributing files in violation of the copyright laws of the United States. A broad range of copyrighted albums, audiovisual files, photographs, software, and other forms of media are available for illegal reproduction and distribution via the BitTorrent protocol.

17, Efforts at combating BitTorrent-based copyright infringement have been stymied by BitTorrent’s decentralized nature. Because there are no central servers to enjoin from unlawfully distributing copyrighted content, there is no primary target on which to focus anti-piracy efforts. Indeed, the same decentralization that makes the BitTorrent protocol an extremely robust and efficient means of transferring enormous quantities of data also acts to insulate it from anti-piracy measures. This lawsuit is Plaintiff's only practical means of combating BitTorrent-based infringement of the Video.

ALLEGATIONS COMMON TO ALL COUNTS 18. Plaintiff is the exclusive rights holder with respect to BitTorrent-based reproduction

and distribution of the Video.

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19. | The Video is currently registered in the United States Copyright Office (Copyright No. PA0001802629). (See Exhibit A to Complaint.)

20. The torrent file used to access the copyrighted material was named in a manner that would have provided an ordinary individual with notice that the Video was protected by the copyright laws of the United States.

i, Plaintiff employs proprietary peer-to-peer network forensic software to perform exhaustive real time monitoring of the BitTorrent-based swarm involved in distributing the Video, This software is effective in capturing data about the activity of peers in a swarm and their infringing conduct.

22. Defendant, using IP address 108.13.119.253, without Plaintiff's authorization or license, intentionally downloaded a torrent file particular to Plaintiffs Video, purposefully loaded that torrent file into his BitTorrent client—in this case, libtorrent/0.15.10.0—entered a BitTorrent swarm particular to Plaintiff's Video, and reproduced and distributed the Video to numerous third parties.

23. Plaintiff's investigators detected Defendant’s illegal download = on 2012-08-21 at 19:49:43 (UTC). However, this is a simply a snapshot observation of when the IP address was observed in the BitTorrent swarm; the conduct took itself place before and after this date and time.

24, Defendant was part of a group of BitTorrent users or peers in a single swarm—a process generally described above—whose computers were collectively interconnected for the sharing of a particular unique file. The particular file a BitTorrent swarm is associated with has a unique file “hash”—i.e. a unique file identifier generated by an algorithm. The unique hash value in this case is identified as 7571E2F7C1972FC5A383A4D87DA00CC3333FB32E (hereinafter “Hash Tag.”), and common to all of the participants in the swarm.

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| COUNT I —- COPYRIGHT INFRINGEMENT 2 25. Plaintiff hereby incorporates by reference each and every allegation contained in the 3

preceding paragraphs as if fully set forth fully herein. 26. Defendant’s conduct infringes upon Plaintiff's exclusive rights of reproduction and 4 distribution that are protected under the Copyright Act. 7 27. | Defendant knew or had constructive knowledge that his acts constituted copyright g || infringement of Plaintiff's Video. 9 28. Defendant’s conduct was willful within the meaning of the Copyright Act: 10 |} intentional, and with indifference to the Plaintiff's rights.

29. Plaintiff has been damaged by Defendant’s conduct, including but not limited to

os economic and reputation losses. Plaintiff continues to be damaged by such conduct, and has no : adequate remedy at law to compensate the Plaintiff for all of the possible damages stemming from 15 the Defendant’s conduct.

16 30. Plaintiff hereby reserves the right, pursuant to 17 U.S.C. § 504(c), to elect to recover

17 || statutory damages for each infringement, in lieu of seeking recovery of actual damages.

18 31. As Defendant’s infringement was intentional and willful, Plaintiff is entitled to an - award of statutory damages, exemplary damages, attorneys’ fees, and the costs of the suit.

on COUNT II - CONTRIBUTORY INFRINGEMENT

7 32. Plaintiff hereby incorporates by reference each and every allegation contained in the 22

93 preceding paragraphs as if fully set forth fully herein.

44 a2, When users in this unique swarm all possess the same infringing work with the same

25 ||exact hash value, it is because each infringer possesses an exact digital copy, containing the exact 26 || bits and pieces unique to that specific file of Plaintiff's original copyrighted work. They only way

this happens in a BitTorrent swarm is through the sharing of these bits and pieces of each same

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unique file, with the same unique hash value, between the users in the swarm. In essence, although hundreds of users may be uploading the copyrighted work, a single user will receive only the exact parts of a singular upload through that exact swarm, not a compilation of available pieces from various uploads,

34. | Defendant published the Hash Tag to the BitTorrent network.

35. Defendant downloaded, uploaded and distributed the Video to other BitTorrent users through use of the hash-specified protocol in the unique swarm.

36. Aseach of the thousands of people who illegally downloaded the movie accessed this illegal publication, they derived portions of their illegal replication of the file from multiple persons, including, but not limited to, Defendant.

37. Defendant knew of the infringement, was conscious of his own infringement, and Defendant was fully concsious that his actions resulted in multiple other persons derivatively downloaded the file containing Plaintiff's Video.

38. The infringement by the other BitTorrent users could not have occurred without Defendant’s participation in uploading Plaintiffs copyrighted works. As such, Defendant’s participation in the infringing activities of others is substantial and contributed, for profit, to the infringing activity of thousands of other peers over the Internet across the world.

39. Defendant profited from this contributory infringement by way of being granted access to a greater library of other infringing works, some of which belonged to Plaintiff and some

of which belonged to other copyright owners.

COUNT III - NEGLIGENCE

40. Plaintiff hereby incorporates by reference each and every allegation contained in the

preceding paragraphs as if fully set forth fully herein.

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bho

4}. Defendant accessed, or controlled access to, the Internet connection used in performing the unauthorized copying and sharing of Plaintiff's Video, proximately causing financial harm to Plaintiff.

42. Defendant had a duty to secure his Internet connection. Defendant breached that duty by failing to secure his Internet connection.

43. Reasonable Internet users take steps to secure their Internet access accounts preventing the use of such accounts for an illegal purpose. Defendant’s failure to secure his Internet access account, thereby allowing for its illegal use, constitutes a breach of the ordinary care that a reasonable Internet account holder would do under like circumstances.

44, In the alternative, Defendant secured his connection, but permitted an unknown third party to use his Internet connection to infringe on Plaintiff's Video. Defendant knew, or should have known, that this unidentified individual used Defendant’s Internet connection for the aformentioned illegal activities. Defendant declined to monitor the unidentified third-party infringer’s use of his computer Internet connection, demonstrating further negligence.

45. In the alternative, Defendant knew of, and allowed for, the unidentified third party infringer’s use of his Internet connection for illegal purposes and thus was complicit in the unidentified third party’s actions.

46, Upon information and belief, Defendant’s failure to secure his Internet access account directly allowed for the copying and sharing of Plaintiffs Video over the BitTorrent protocol through Defendant’s Internet connection, and interfered with Plaintiff's exclusive rights in the copyrighted work.

47. Upon information and belief, Defendant knew, or should have known of, the unidentified third party’s infringing actions, and, despite this, Defendant directly, or indirectly, allowed for the copying and sharing of Plaintiff's Video over the BitTorrent protocol through

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Defendant’s Internet connection, and interfered with Plaintiff's exclusive rights in the copyrighted Video.

48, By virtue of his unsecured access, Defendant negligently allowed the use of his Internet access account to perform the above-described copying and sharing of Plaintiff's copyrighted Video.

49. Had Defendant taken reasonable care in securing access to this Internet connection, or monitoring the unidentified third-party individual’s use of his Internet connection, such infringements as those described above would not have occurred by the use of Defendant’s Internet access account,

50. Defendant’s negligent actions allow others to unlawfully copy and share Plaintiffs copyrighted Video, proximately causing financial harm to Plaintiff and unlawfully interfering with Plaintiff's exclusive rights in the Video.

JURY DEMAND

51. Plaintiff hereby demands a jury trial in this case.

PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests Judgment and relief as follows:

1) Judgment against Defendant that he has: a) willfully infringed Plaintiff's rights in federally registered copyrights pursuant to 17 U.S.C. § 501; and b) otherwise injured the business reputation and business of Plaintiff by Defendant’s acts and conduct set forth in this Complaint;

2) Judgment in favor of the Plaintiff against Defendant for actual damages or statutory damages pursuant to 17 U.S.C. § 504, at the election of Plaintiff, in an amount to be ascertained at

trial;

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3) Order of impoundment under 17 U.S.C. §§ 503 & 509(a) impounding all infringing copies of Plaintiff's audiovisual works, photographs or other materials, which are in Defendant’s possession or under his control;

4) On Count II, an order that Defendant is jointly and severally liable to the Plaintiff in the full amount of Judgment on the basis of a common law claim for contributory infringement of copyright; for an award of compensatory damages in favor of the Plaintiff and against Defendant, jointly and severally, in an amount to be determined at trial;

5) On Count III, an order that Defendant is jointly and severally liable to the Plaintiff in the full amount of Judgment on the basis of Defendant’s negligence in allowing an unidentified third party access his Internet account and, through it, violate Plaintiff's copyrighted works; for an award of compensatory damages in favor of the Plaintiff and against Defendant, jointly and severally, in an amount to be determined at trial;

6) Judgment in favor of Plaintiff against the Defendant awarding the Plaintiff attorneys’ fees, litigation expenses (including fees and costs of expert witnesses), and other costs of this action; and

7) Judgment in favor of the Plaintiff against Defendant, awarding Plaintiff declaratory and injunctive or other equitable relief as may be just and warranted under the circumstances.

Respectfully Submitted, PRENDA LAW INC. DATED: September 24, 2012 By: /s/ Br sibb

Brett L. Gibbs, Esq. (SBN 251000) Of Counsel to Prenda Law Inc. 38 Miller Avenue, #263 Mill Valley, CA 9494] blgibbs@wefightpiracy.com Attorney for Plaintiff 11 COMPLAINT CASE NO.

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I DEMAND FOR A JURY TRIAL

Plaintiff hereby demands a jury trial as provided by FRCP 38(a).

By: /si Brett L. Gibbs Brett L. Gibbs, Esq. (SBN 251000) Attorney for Plaintiff

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EXHIBIT A

Case 2:12-cv-08333-ODW-JC Document1 Filed 09/27/12 Page 14o0f17 Page ID #:38

9/17/12 WebVoyage Record View 1

United States Copyright Office

“Help Search History Titles —>—s Start Over

Public Catalog

Copyright Catalog (1978 to present) Search Request: Left Anchored Copyright Number = PA0001 802629 Search Results: Displaying | of | entries

A Peek Behind the Scenes at a Show.

Type of Work: Motion Picture Registration Number / Date: PA0001802629 / 2012-08-24 Application Title: A Peek Behind the Scenes at a Show. Title: A Peek Behind the Scenes at a Show. Description: Electronic file (eService) Copyright Claimant: Ingenuity]13 LLC. Address: Springates East, Government Road, Charlestown, Saint K itts- Nevis. Date of Creation: 2012 Date of Publication: 2012-07-25 Nation of First Publication: United States Authorship on Application: Ingenuity] 3 LLC, employer for hire; Domicile: United States; Citizenship: United States, Authorship: entire motion picture, production/producer, direction/director, script/screenplay, cinematography/cinematographer, editing/editor.

Names: | uity |

Select Download Format Ful Record ly]

Enter your email address: [

Help Search History Titles Start Over

C:/Users/User/Desktop/.../1-1 EXHIBIT A - COPYRIGHT TO A PEEK BEHIND THE SCENES ATA SHOW.htm 1/2

Case 2:12-cv-08333-ODW-JC Document1 Filed 09/27/12 Page 15o0f17 Page ID #:39

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY

This case has been assigned to District Judge Stephen V. Wilson and the assigned discovery Magistrate Judge is Patrick J. Walsh.

The case number on all documents filed with the Court should read as follows:

Cv12- 8333 SVW (PJWx)

Pursuant to General Order 05-07 of the United States District Court for the Central

District of California, the Magistrate Judge has been designated to hear discovery related motions.

All discovery related motions should be noticed on the calendar of the Magistrate Judge

NOTICE TO COUNSEL

A copy of this notice must be served with the summons and complaint on all defendants (if a removal action is filed, a copy of this notice must be served on all plaintiffs).

Subsequent documents must be filed at the following location:

Western Division L] Southern Division Eastern Division 312 N. Spring St., Rm. G-8 411 West Fourth St., Rm. 1-053 3470 Twelfth St., Rm. 134 Los Angeles, CA 90012 Santa Ana, CA 92701-4516 Riverside, CA 92501

Failure to file at the proper location will result in your documents being returned to you.

CV-18 (03/06) NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY

Case 2:12-cv-08333-ODW-JC Document1 Filed 09/27/12 Page 16 o0f17 Page ID #:40

UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA CIVIL COVER SHEET

f(a) PLAINTIFFS (Check box if you are representing voursell ) DEFENDANTS INGENULTY IF LLC JOHN DOF

(b) Attorneys (Firm Name, Address and Telephone Number [1 you are represenung Attomeys (If Known) yoursell, provide same.)

Brett L. Gibbs, OF Counsel to Prenda Law, Inc

38 Miller Avenue, #263 Mill Valley, CA 9494) (415) 325-$900

Ul. BASIS OF JURISDICTION (Place an X in ong box only ) 11. CITIZENSHIP OF PRINCIPAL PARTIES ~ For Diversity Cases Oniy (Place an X in one box for plainuff and one for defendant.) JIUS Government Piamult ¥3 Federal Question (US vrk DEF PTF DEF Government Nota Party) Ciuzen of This State Cl} 1 Incorporated or Principal Place = O4 Od

of Bussiness in this State

LDS Governmem Detendant 4 Diversity (Indicate Ctuzensmp | Citizen of Another State 2 (2. Incorporated and Principal Place OS 5 of Parties in hem I) of Business in Another State Ciuzen or Subject of a Forengn Country D3 03 Foreign Nation 6 Uo (V. ORIGIN (Place an X in one box gnly ) i Onginal (02 Removed fiom [3 Remanded from 4 Reinsutedor (3 § Transferred from another district (specity) [26 Multi- [7 Appeal to District Proceeding State Court Appellate Court Reopened District Judge from Lingation Magistrate Judge

VV. REQUESTED IN COMPLAINT | JURY DEMAND: Yes 0) No (Check “Yes? only i demanded in complaint )

CLASS ACTION under F.R.C.P, 23: 2 Yes No MONEY DEMANDED IN COMPLAINT: $

VI. CAUSE OF ACTION (Cite the US. Civil Statute under which you are tiling and write @ brief statement of cause. Do not cite junsdigtional statutes unless diversity ) 17 USC. Sections 12) et al

Vil, NATURE OF SULT (Place aa X in one bes oaly )

cd ak

Sate Reapportionment Jf) 110) Insurance

(2710 Fair Labor Standards

PERSONAL INJURY

Motions ta

C2410 Antitrust 120 Marine C310) Aurplane Act

13430) Banks and Banking 130 Miller Act (2313) Airplane Product 17 370 Other Fraud Vacate Sentence [0 720 Labor/Mgmt

{) 450 CommerewlCC 3140 Negotiable Instrument Laabilicy (137) Truth in Lending Habeas Corpus Relations Ratewel Ci 190) Recover of C320 Assault, Label & tr 380 Other Personal Cieneral U1 730 Labor/Mgmt

1) 465 Deponation Overpayment & Slander Propeny Damage Death Penalty Reporting &

C) 479 Racketwer Intluenced and Corrupt Organizations

480 Consumer Credit

2490 Cable/Sat TV

[1 810 Selective Service

©) 880 Securiies/Commodines/

330 Fed Employers Laability

(340) Manne

(1348) Marne Product Liability

350 Motor Vehicle (1388 Motor Vehicie Product Liability

Disclosure Act Other 3740 Railway Labor Act Cwil Rights £}790 Other Labor Priyon Condition Litigation

791 Enppl. Ret Inc Security Act

7 820 Copyrights

Enforcement of Mandamus’ Judgment

(0 151) Medicare Act

152 Recovery of Defaulted Student L.oan (Excl Veterans)

C) 153 Recovery of

() 385 Propeny Damage Product Liability

(3422 Appeal 28 USC 158

(2423) Withdrawal 28 USC 157

Agriculture

Exchange Overpayment of £360 Other Personal Other Food & 1 878 Customer Challenge 12 Veteran's Benefits Injury O44) Voung Drug C) 830 Paten USC 3410 (5 160 Stockholders’ Suits 2362 Personal Injury: {2/442 Employment Drug Related == |. 840 Trademark

O s¥o Other Statutory Actions 389) Agricultural Act hoonomie Stabtiization AMS

D883) Lev wonmental Matters B44 bourgy Allocation Agt 9% Freedom of Into Act

(3190) Other Contract

C1i9s Contract Product Liwbility

1190 branchise

(0443 Housing/Acco-

mimodations

(444 Welfare

(445 American with Disabilities - Linploymem

“} 446 American with

Seizure of Property 21 USC 841

Med Malpractice

(1365 Personal injury- Product ( iability

. 368 Asbestos Personal Injury Product Liability

O86) HIA(i3Ss1) } $62 Black Lung (923) 63) Liquor Laws (1863 DIWC'DIWW 640 KR & Truck (405(g))

CJ 650 Aarling Regs [3 864 SSID Tite XVI 660 Occupational 3 8e5 RSI (405(2))

jz C)2i0 Land Condummauon

}220 boieclosure

5900 Appeal of Fee Dewerm: {C1 230 Rent Lease & Eyecument | 402 Naturalizauion Disabilities - safety “Health nation Under Equal C1240 Tons to land Application Other (690 Other (9870 Taxes(U S. Plamull Access w Justice (245 Tort Product Liability ]463 Habeas Corpus- fe) 440 Other Civil or Defendant) (5.950 Constutanonality of © 290 All Other Real Property Alien Detainee Rights £1871 IRS-Third Party 26

(1.465 Other Immigration Actions

State Statutes LSC 7609

eeereereseren centers SST SS SET

FOR OFFICE USE ONLY: Case Number esd SPTER COMPLETING THE FRONT SIDE OF FORM CV-71, COMPLETE THE INFORMATION REQUESTED BELOW.

RET

CV-71 (09:08) CIVIL COVER SHEET Page | of 2

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UNTERD STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA CIVEL COVER SHEET

Via). LOE NPICAL CASES: Has this action been previously filed in Unis court and dismissed, remanded or closed’ aNo (2 Yes Hi yes. list case number(s):

cere nn ean nn eee

Vili(b), RELATED CAS If ves, list case sumber(s)

eer arent manera ner eer nema

> Have any cases been previously filed in this court that are related to the present case? tno C1 Yes

Civil cases are deemed related ifs previously fled case and the present cane: (Check all dures that apply) CTA Arise from the sume or closely related transactions, happenings, or events, ur Is Cali tor detemmnaben of the same or substantally related at similar questions of law aad fact, of SC) Por oiber reasons would entail substantial dupheation of labor wf heard by different judges, oF

1) lavulve the same patent. rademairk Gr copyright aad One of the factors dented above ina. bore also is present pyright ang

exten emanate eesti ane han am em eg iawn mentee et reset i em i tren renner mre ret ramet RA

INOVENULB: (When compleung the following information, use an additional sheet if necessary }

(4) Listthe County an dis District, California County outside of tis Distriet: State df odier than California, or Foreign County, i which EACH named piaintit resides (i Check here il the government, its agenvies or employees isa named plaintiff. [1 this hon is checked, go to item (>)

erence

County in this Distrier * California County outside of this Distriet, State. uf other than Calitormia, or Foreign Country

St. Kitts and Nevis

a fe ne a A I No nw

(Db) Lastthe County in this District. California County outside of Gus District State Wf other than Califomiay or Foreign Country, in which EACH named delendant resides i Cheek here al the government, ity sgencics at emplovees is a named defendant If this box is checked. go to item (eo)

(outs an this Disttietn®

California County outside of this Oismet, Stale of other than California: er Foreign Country

ernest

Lrknown - Geolocation tacks (P address to Los Angeles County

(¢) Last the County inthis District. Calvforma County outside of this District, State if other than California, or Foretgn Country. in which EACH claim arose. Note: In land condemnation cases, use the location of the tract of land involved.

| atecneanasr een mnmsentinms pny ates ae

County i this Desteret *

Unknown - Geolocation tracks 1P address to Los Angeles County

Cahfornia County outside of this Distriet, Suite, if vibe: than Caiifoonia. ct Foreign Country

* Los Angeles, Orange, San Bernardino, Riverside, Ventura, Santa Barbara, or San Luis Obispo Counties

nerve macerentnienier di oo mee ener eects astm mie cen et een tte etm ttertneettegitnemennn ee

Date eptember 24, 2012

X SONATURE OF ATTORNEY (OR PRO PER)

emseetane macarrerarenean emer atmenneminsie eet

Natice to Counsel/Parties: The CV-71 JS-44) Civil Cover Sheet and the uiformation contained herem neither replage nor supplement the filing and service of pleadings or other papers as reqinred by law “This form, approved by the Judicial Conference of the United States in Sepiember 1974. 1s required pursuani to Local Rure 3-1 1s not fled bul is used by the Clerk of the Court for the purpose of statistics, venue and mitiating the civil docket sheet. (For more detailed mstruchions, see separate matructions sheet.)

lo Stulstival codes relapng to Social Secuuty Cases

nee snmeeemeeaencape emcee

Nature of Sait Code \bbreviation Substantive Statement of Cause of Action

Sol HIA All claims for health insuranee benefits (Medicare) under Vile 18, Part A, af the Social Security Act, as amended Also, include claims by hospnals, skilled nursing faites, etc . for certification as providers of services under the program. (42 USC. 193SFV(b))

ko? BL All clams foe “Black Lung” benefits ander Title 4, Part B of the Federal Coal Mine Health and Safety Act of 1969 0 US.C 923)

ROS DIWC All chums filed by insured workers for disability insurance benelits under Title 2 of the Social Securny Act, as amended, plus al! claims fled tor child's insurance benelits based on disability (42 U.S.C 405¢¢))

8o3 DIMW Ali claims filed for widows or widowers insurance benefis based on disability under Title 2 of the Soca! Security Agt as aimendyd (92 S.C 4035(29)

god SSID Ali clams for supplemental secunty income payments based upon disability tled under Tile 16 af the social Security

Aci as amended

8G5 KSI All claims for retirement (old age) and survivors benctis under Titic 2 af the Social Security Act as amended. (42 USC ibn

OV-7) (88-08) CIVIL COVER SHEET