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MARY DOE v. MATCH.COM, INC. et al - Document No. 1

MARY DOE v. MATCH.COM, INC. et al - Document No. 1

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Published by Justia.com
COMPLAINT against MATCH.COM, INC., MATCH.COM, L.P. ( Filing fee $ 150 receipt number 902692.), filed by MARY DOE.(ss, ) Additional attachment(s) added on 3/11/2004 (ss, ). 2:2004cv00938 Pennsylvania Eastern District Court
COMPLAINT against MATCH.COM, INC., MATCH.COM, L.P. ( Filing fee $ 150 receipt number 902692.), filed by MARY DOE.(ss, ) Additional attachment(s) added on 3/11/2004 (ss, ). 2:2004cv00938 Pennsylvania Eastern District Court

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Published by: Justia.com on Apr 29, 2008
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IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF PENNSYLVANIA
MURPHY & GOLDSTEIN, P.C.
BY: WILLIAM P. MURPHY, ESQUIRE
ATTORNEYS FOR PLAINTIFF
I.D. #: 23339

BY: HOWARD K. GOLDSTEIN, ESQUIRE
I.D. #: 31285
1616 Walnut Street, Suite 2000
Philadelphia, PA 19103
(215) 731-1230

:
MARY DOE, an individual known to defendant, :
JURY TRIAL DEMANDED
:
Plaintiff
:
v.
::
CIVIL ACTION NO.
MATCH.COM, INC.
:
3001 George Bush Highway, Ste. 100
:
Richardson, TX 75082
::
and
::
MATCH.COM, L.P.
:
3001 George Bush Highway, Ste. 100
:
Richardson, TX 75082
::
Defendants
::
CIVIL ACTION COMPLAINT
1. The plaintiff is an adult individual who resides in the Commonwealth of
Pennsylvania and the Eastern District of Pennsylvania.
2. She is named in the caption of this Complaint by a pseudonym for the protection
of her privacy and is known to defendants.
3. Defendant, Match.com, Inc., is a corporation that is incorporated in Texas, has its
principal place of business elsewhere than in Pennsylvania, and is engaged in operating
Case 2:04-cv-00938-JG Document 1
Filed 03/03/2004 Page 1 of 14
MARY DOE v. MATCH.COM, INC. et al
Doc. 1
Dockets.Justia.com
3
and conducting for profit an international and local Internet online dating service referred to
herein as \u201cMatch.com\u201d and/or as the \u201conline dating service.\u201d
4. Defendant Match.com, L.P., is a Texas company related to Match.com, Inc. and
headquartered in Richardson, Texas, at the address of Match.com, Inc.

5. Upon information and belief, Match.com, L.P. was at all times pertinent to this
Complaint engaged in the operation of the Match.com online dating service, and, in all
respects alleged by plaintiff herein, acted or omitted to act directly, jointly with Match.com
Inc., as the alter ego of Match.com Inc., as the agent and servant of Match.com, Inc.
conducting itself within the scope and authority of its agency, and/or as the principal or
mutual co-agent of Match.com, Inc.

6. Upon information and belief, Match.com, Inc., in all respects alleged by plaintiff
herein, acted or omitted to act directly, jointly with Match.com, L.P., as the alter ego of
Match.com, L.P., as the agent and servant of Match.com, L.P. conducting itself within the
scope and authority of its agency, and/or as the principal or mutual co-agent of Match.com,
L.P.

7. Plaintiff became a paying subscriber of the Match.com online dating service in
March 2003 in order to be anonymously profiled on defendant\u2019s Internet web site as a
woman from Philadelphia in search of prospective dating partners who may be interested in
a prospective dating connection to Philadelphia.

8. Jurisdiction is based on diversity jurisdiction 42 U.S.C. \u00a7 1332, the amount in
controversy being in excess of $75,000.00, exclusive of interest and costs.
9. The present action sounds in both tort and contract and arises out of transactions
and occurrences, including publication to and receipt by plaintiff of the below-mentioned e-
Case 2:04-cv-00938-JG Document 1
Filed 03/03/2004 Page 2 of 14
4
mails at her home, within the Eastern District of Pennsylvania.
The Match.com, Online Dating Service Subscribed to by Plaintiff

10. Notwithstanding the alleged involvement and/or interaction of Match.com, Inc.
and Match.com, L.P., plaintiff reasonably believed at the time she subscribed to the
Match.com online dating service and at the time of the injuries alleged below occurred, that
she was dealing with one cohesive Match.com enterprise.

11. As part of the national online dating service, defendants at all times pertinent to
this Complaint obtained personal information from their paying subscribers which they
understood and declared would be keep private and secure.

12. As part of the service operation, defendants caused the personal profiles of
paying subscribers, including plaintiff, to be organized and arranged according to the
geographic location which the subscriber selected.

13. Defendants made that information available by publishing it on the Internet at a
web site \u201cwww.match.com\u201d as an advertisement to, and/or notice designed to attract, other
subscribers and the general public to consider dating opportunities with an individual
subscriber.

14. Defendants also offered as part of its service to subscribers, including plaintiff,
an electronic method by which interested responders anywhere on the globe may
communicate with a subscriber even though the anonymity of the subscriber is preserved.

15. This system preserves the control of the subscriber over that subscriber\u2019s
anonymity.
16. Of course, the geographical identification of the profiled subscriber targets the
subscriber\u2019s published profile principally to persons who reside or expect to be present in
Case 2:04-cv-00938-JG Document 1
Filed 03/03/2004 Page 3 of 14

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