Loeb & Loeb
Limited Liability Partnership
Plaintiffs Columbia Pictures Industries, Inc. (“Columbia”), DisneyEnterprises, Inc. (“Disney”), Paramount Pictures Corporation (“Paramount”),TriStar Pictures, Inc. (“TriStar”), Twentieth Century Fox Film Corporation (“Fox”),Universal City Studios LLLP (“Universal”), Universal City Studios ProductionsLLLP (“Universal Productions”), and Warner Bros. Entertainment Inc. (“Warner Bros.”) hereby allege as follows:
Jurisdiction And Venue
This is a civil action seeking damages and injunctive relief for copyright infringement under the copyright laws of the United States, and thereforethe Court has jurisdiction under 17 U.S.C. § 101
; 28 U.S.C. § 1331 (federalquestion jurisdiction); and 28 U.S.C. § 1338(a) (jurisdiction over copyright actions).2.
Personal jurisdiction over the Defendants is proper. On informationand belief, each of the Defendants resides, may be found, has a principal place of business, and/or does business in California. Further, on information and belief,each Defendant conducts business with other Defendants and/or unnamed entities inorder to operate their website as part of a business venture that is centered inCalifornia. Additionally, Defendants have chosen to direct their infringing activitiestowards California in particular. Defendants enable users, including Californiaresidents, to access torrent files on their website, and the users’ computers interactwith the website to download infringing copies of Plaintiffs’ works. In fact, thevoluminous acts of direct infringement for which Defendants are liable require ahigh level of interaction between users’ computers and Defendants’ website. Oninformation and belief, many of these acts of direct infringement for whichDefendants are liable occur in California, where California residents accessDefendants’ website in order to download infringing copies of Plaintiffs’ works. Inthese and other ways, Defendants have had continuous contact with the State of California and its residents.