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ALLEGATIONS COMMON TO ALL CLAIMS J
4. This action arises, in part, under the United States Copyright Act, 17U.S.C. Sections 101 et seq., based on acts of copyright infringement committed in the United States, as well as under the common law right of privacy, statutory andcommon law right of publicity and unfair competition and unfair business practiceslaws of the State of California. This Court has federal question jurisdiction over thismatter pursuant to 28 U.S.C. §§ 1131 and 1338, and supplemental jurisdiction overPlaintiff’sclaimsarisingunderCalifornialawpursuantto28U.S.C.§1367,becausethey flow from a common nucleus of operative facts.5. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391 (b), (c)and 1400(a) because Defendants, and each of them, are subject to personal jurisdiction in this District, a substantial part of the events, acts and/or omissionsgiving rise to the claims herein occurred in this District and/or this is a District where at least seven of ten Defendant(s) reside or may be found.
6. Plaintiff DUSTIN LANCE BLACK (“Plaintiff” or “Black”) is,and at all times relevant hereto has been, an individual residing and doing businessin the County of Los Angeles, State of California. Black is an Academy Award-winning motion picture screenwriter and accomplished television screenwriter and producer. His motion picture credits include “
,” for which he won the covetedAcademy Award in 2009, and his television writing and production credits includethe highly acclaimed HBO television series entitled “
.” Black is an avid proponent for, and prominently involved in, the advocacy of the advancement of Lesbian, Gay, Bisexual and Transgender (“LGBT”) issues and rights./ / /
Case 2:09-cv-05380-RGK-RC Document 1 Filed 07/23/2009 Page 3 of 57