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
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
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.
Pursuant to Local Civil Local Rule 3-2(e), this case shall be assigned to theSan Jose Division.