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Plaintiffs Gravel Farms Racing, LLC (“GFR”) and Ken Block (“Block”)(jointly “Plaintiffs”), for their Complaint against Defendant Mad Media LLC(“Mad Media”), allege as follows:
INTRODUCTION
1.
 
Mad Media breached its legal and ethical obligations to its former clients, Plaintiffs Ken Block and Gravel Farms Racing, by improperly usingknowledge that Mad Media gained from its contractual relationship withPlaintiffs to misappropriate, interfere with and unfairly profit from Plaintiffs.2.
 
Plaintiffs are pioneers in the autocross motor sports industry andhave spent considerable resources since at least as early as 2008 successfully promoting the GYMKHANA brand, for which they have a tremendous fanfollowing. In the course of promoting their brand, Plaintiffs contracted withMad Media to record some of Plaintiffs’ popular GYMKHANA videos.Plaintiffs paid Mad Media over $300,000 and disclosed to Mad Mediaconfidential information relating to the GYMKHANA brand. It is universallyaccepted, practiced, understood and implicit in every filming agreement that thefilming company cannot use, profit or usurp rights, opportunities or propertyfrom its client.3.
 
Mad Media flagrantly disregarded its legal and ethical obligationsand the accepted standards of professional conduct by registering the domainname GYMKHANA.COM to usurp Plaintiffs’ legitimate business opportunitiesand unfairly competing directly with their now former client. Plaintiffs havetried to address Mad Media’s bad faith, but Mad Media has insisted oncontinuing to take advantage of and harm its former clients. Mad Media’sdecision leaves Plaintiffs no choice but to seek resolution through the courts.
THE PARTIES
4.
 
Plaintiff Gravel Farms Racing, LLC is a California Limited LiabilityCompany organized and existing under the laws of the State of California,
 
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having a principal place of business at 4250 Wilshire Blvd, Los Angeles,California, 90010.5.
 
Plaintiff Ken Block is an individual resident of Utah.6.
 
Upon information and belief, Defendant Mad Media LLC is aLimited Liability Company organized and existing under the laws of the State of California, having a principal place of business at 2554 Pahvant Street,Oceanside, CA 92054.7.
 
Upon information and belief, Mad Media is regularly engaged in the business of video production and advertising services in the State of California.
JURISDICTION AND VENUE
8.
 
This is an action for false designation of origin and dilution arisingunder the Lanham Act of the United States, 15 U.S.C. § 1125(a) & (c), violationof the Anticybersquatting Consumer Protection Act (“ACPA”) of the UnitedStates, 15 U.S.C. § 1125(d), and for various causes of action arising under California state law
.
 9.
 
This Court has subject matter jurisdiction pursuant to at least 15U.S.C. § 1121 and 28 U.S.C. §§ 1331 and 1367(a). This Court hassupplemental jurisdiction over the California statutory and common law claims pursuant to 28 U.S.C. § 1367(a) because the state law claims are so related tothe federal claim that they form part of the same case or controversy.10.
 
This Court has personal jurisdiction over Mad Media by virtue of itssystematic and continuous contacts with California and by the actions inCalifornia giving rise to this Complaint, including in this Judicial District.11.
 
Venue is proper in this Judicial District pursuant to 28 U.S.C. § 1391(b) and (c), and by Plaintiffs’ choice of venue./ / // / // / /
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