TAB___ossaz2g07 11:12 FAK 310 850 St.8 eee a "angeles, Cali apg stor 2 2906 Ag) 350-550 10) 356- ae row! Sharcholdes of Stan Lee corporation) ios Se SB ED PRODUCTIONS, LLC, a Delavrare lumited Hebility company Ponware coperstions STAN Ee, an individual am individual 15 [capaci a ; suing na aera on oe ohe corporation, Plaintiffs, ; ove JAMES NBS! FIELD, an individual 9 JALLOWAY, on incividual; BG ugAsc. COGAN: 20|| Individuals and DOES 1 through 10, inclusive, Defendants. 28 PO SELEUTST AMENDED COMPLAINT AS LAVELY AND SINGER JOBN & SORREEL TR SBN BS) i atsots FROWESSIONAL CORPORATION Attorneys for F for Pleintite Seek TROT H ONE and paren "AN OAL CHAMPION (ain dena PA Gehl Eor lees of Sfcata Incr Colorado UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA ‘Plaintiffs QED Productions; LLC, a Delaware lit Tovz CASE NO. CV07-225-SVW (SSx) [Honorable Stephen V. Wilson] EIRST AMENDED COMPLAINT FOR: COPYRIGHT ) NIOLATION Or 15 U.S.C. §1125 ee RELATIONS; RROSPECHIVE ECONOMIC VANTA UNFAIR BUSING ESS Ce RACTe & PROF. REREAD [VERIFICATION OF OF (OLDER DERIVATIVE CLAIMS DEMAND FOR JURY Tad] Exhibit A, p. 504/37/2007 11 © @ wa Wa ON 1 12 1: 14 16 Xr 4S -18 19 20. 2 22 25 26 27 112 FAX 910 586 7 LAVELY AND SINGER Boos POW! Entertainment, Inc., a Delaware corporation; Stan Lee, an individual; and Gill Champion, an individual suing in a derivative capacity on behalf of sharcholders of Stan Lee Media, Inc., a Colorado corporation (sometimes referred to herein as “Plaintifis”), allege as follows: (AT! 01 IN 1 ‘This action is brought to address Defendants’ attempts to unlawfully take control of Stan Lee Media, Inc. throirgh improper, ineffective and invalid shareholders meetings and appointment of officers and thereby to try (a) to misappropriate valuable copyrights, trademarks, other intellectual properties and business opportunities developed by pop-culture icon Stan Lee, the creator and co- creator of such classic super hero characters as Spiderman, Fantastic Four, Incredible Hulk and X-Men, and (b) to claim co-ownership of other valuable copyrights that Stan Lee Media, Inc. does not own. More'specifically, Defendants have; arnong other things, conspired to falsely and fraudulently masquerade as controlling officers of Stan Lee Media, Inc., a Colorado corporation (“SLMI”) in ‘violation of the legal requirements governing corporate actions and in contravention of federal bankruptcy laws, misappropriated, inffingéd and interfered with copyrights, trademarks, publicity rights and contract rights owned exclusively by Stan Lee and his companies, and asserted bogus claims in the name of SLMI yogarding co-ownership of other valuable copyrights, such as copyrights in the characters Spiderman, The Incredible Hulk, The Fantastic Four, end many others, claims that Defendants should, on information and belief, know through one of their co-conspirators are false. Defendants’ malicious and wrongful conduct has necessitated the filing of this action for compensatory and punitive damages as well as for injunctive and declaratory relief to prohibit Defendants from continuing this wrongful scheme. tt ‘EIO9ELTWURVIRST AMENDED COMELADST O507 72 2 FIRST AMENDED COMPLAINT Exhibit A, p. 6