IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF MICHIGAN
TONY PRATT, individually and on behalf )of a class of similarly situated individuals, )) Case No.
, ))v. ) Hon.)ALLTEL COMMUNICATIONS, LLC, a Delaware )limited liability company, and PREDICTO ) Magistrate JudgeMOBILE, LLC, a Delaware limited liability )company. ))
CLASS ACTION COMPLAINT
Plaintiff Tony Pratt, by his attorneys, alleges upon personal knowledge as to himself and hisown acts and experiences and upon information and belief including investigation of counsel asto all other matters, as follows:
NATURE OF THE ACTION
Plaintiff Pratt brings this case as a class action against Alltel Communications,LLC (“Alltel”) and Predicto Mobile, LLC (“Predicto”) seeking to stop Defendants’ practice of causing cellular telephone customers to be billed for mobile content services ordered not bythem, but rather by the customer previously assigned their telephone number, and to obtainredress for all persons injured by Defendants’ conduct in this regard.2.
The increased use of cell phones has given rise to a new industry that provides so-called “mobile content” services such as ringtones, text alerts, jokes, news, games, and dailyhoroscopes to cell phone users’ mobile devices. Predicto and other providers of mobile contentcharge for their services and cause such charges to be placed directly on customers’ cell phoneaccounts through their wireless carriers, including Alltel. The carriers simply bill and collect1
Case 2:09-cv-13691-DPH-MAR Document 1 Filed 09/17/2009 Page 1 of 13
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