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Gould v. Facebook (N.D. Cal.)

Gould v. Facebook (N.D. Cal.)

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One of two class action lawsuits filed against Facebook over Facebook's alleged leakage of user information when end users access content and ads.
One of two class action lawsuits filed against Facebook over Facebook's alleged leakage of user information when end users access content and ads.

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Published by: Venkat Balasubramani on Jun 04, 2010
Copyright:Attribution Non-commercial

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07/31/2010

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COMPLAINT
12345678910111213141516171819202122232425262728SEAN REIS (SBN: 184044)(sreis@edelson.com)EDELSON MCGUIRE LLP30021 Tomas Street, Suite 300Rancho Santa Margarita, California 92688Telephone: (949) 459-2124Facsimile: (949) 459-2123JAY EDELSON (jedelson@edelson.com)MICHAEL J. ASCHENBRENER (maschenbrener@edelson.com)BENJAMIN H. RICHMAN (brichman@edelson.com)EDELSON MCGUIRE,
 
LLC350 North LaSalle Street, Suite 1300Chicago, Illinois 60654Telephone: (312) 589-6370Fax: (312) 589-6378ATTORNEYS FOR PLAINTIFF AND THE PUTATIVE CLASS
UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF CALIFORNIASAN JOSE DIVISION
DAVID GOULD, an individual, onbehalf of himself and all others similarlysituated,Plaintiff,v.FACEBOOK, INC., a Delawarecorporation,Defendant.))))))))))))))))))))Case No.
COMPLAINT FOR:(1)
 
Violations of Cal. Bus. & Prof.Code § 17200;(2)
 
Violations of Cal. Penal Code § 502;(3)
 
Violations of Cal. Civ. Code § 1750;(4)
 
Breach of Contract;(5)
 
Breach of Implied Contracts;(6)
 
Breach of the Implied Covenant of Good Faith and Fair Dealing;(7)
 
Violations of Cal. Civ. Code §§ 1572, 1573;(8)
 
Unjust Enrichment;(9)
 
Negligence;(10) Negligence Per Se.DEMAND FOR JURY TRIALCLASS ACTION
 
 
COMPLAINT
212345678910111213141516171819202122232425262728Plaintiff, by and through his attorneys, upon personal knowledge as to himself and hisown acts, and upon information and belief as to all other matters, alleges as follows:
NATURE OF THE ACTION
1.
 
Plaintiff, David Gould (“Plaintiff” or “Mr. Gould”), brings this class actioncomplaint against Facebook, Inc. (“Facebook”) for sharing its users’ sensitive personallyidentifiable information (“PII”), including users’ real names, place of birth, current city,schools attended, friend lists, pictures, genders, and more with Facebook’s advertisingpartners, in violation of its own Privacy Policy and accepted industry standards.
PARTIES
 2.
 
Plaintiff David Gould is a resident of South Lake Tahoe, California. He is aregistered user of Facebook, Inc.’s services and has been since at least 2008.3.
 
Defendant Facebook, Inc. is a Delaware corporation headquartered in SanClara County, California, at 1601 South California Avenue, Palo Alto, California 94304.Facebook does business throughout the State of California and the nation.
JURISDICTION AND VENUE
 4.
 
This Court has original jurisdiction over this action pursuant to 28 U.S.C.§ 1332(d), because (a) at least one member of the putative class is a citizen of a statedifferent from Defendant, (b) the amount in controversy exceeds $5,000,000, exclusive of interest and costs, and (c) none of the exceptions under the subsection apply to this action.5.
 
Personal jurisdiction and Venue are proper because Facebook is a corporationheadquartered in Santa Clara County and/or because the improper conduct alleged in theComplaint occurred in, was directed from, and/or emanated or exported from California.
INTRADISTRICT ASSIGNMENT
6.
 
Pursuant to Local Civil Local Rule 3-2(e), this case shall be assigned to theSan Jose Division.
 
 
COMPLAINT
312345678910111213141516171819202122232425262728
FACTSAbout Facebook
7.
 
Facebook is the world’s largest social networking website, with over 400million registered users worldwide.8.
 
According to Facebook, its “mission is to give people the power to share andmake the world more open and connected.” (www.facebook.com/facebook?v=info%ref=pf)To accomplish that mission, Facebook allows anyone with access to a computer and Internetconnection to register for its services free of charge.9.
 
One of the only requirements Facebook places on its registrants is that theyuse their actual names, rather than create a “screen name” or “user name,” as iscommonplace with other website registrations.10.
 
Once registered, a Facebook user may post a multitude of information to theirown personal “Facebook profile” page, including their birth date, place of birth, current andpast addresses, present and past employment, relationship status, personal pictures, videos,and more. Facebook, in fact, presents users with pre-made forms in which users may enterthis type of personal information.11.
 
As of May 21, 2010, Facebook’s default privacy settings allow everyone onthe internet, including advertisers, to see a user’s real name, gender, picture, friends,networks, wall posts, photos, and likes, among other data.12.
 
In many ways, Facebook is accomplishing its official mission. Facebook users share unprecedented personal information through the service. And while users may doso in order to connect with other Facebook users, they are also sharing this information withFacebook. And all this personal information is valuable to Facebook because it is valuable toadvertisers.

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