Class Action Complaint - 2
1221 Second Avenue, Suite 500Seattle, Washington 98101-2925Telephone: (206) 623-1745Facsimile: (206) 623-7789
Facebook maintains personal information pertaining to each individual as wellas monitors the individual online habits of their users keeping track of websites they visit.4.
Upon obtaining personal information and wire and electronic communicationsof the Plaintiff, Facebook conspired to use the information for target marketing whichpertained to the Plaintiff and the individual Class members, over the Internet.5.
Such conduct was committed in violation of Title III of the Omnibus CrimeControl and Safe Streets Act of 1968 as amended by the Electronic Communication PrivacyAct of 1986, 18 U.S.C. § 2511,
(the “Wiretap Act”).
Plaintiff Matthew J. Vickery is an individual who resides in King County,Washington. Upon information and belief, Defendant intercepted, collected, and storedpersonal information from Plaintiff.
Defendant is a company organized and existing under the laws of the State of Delaware, with its principal place of business at 1601 S. California Ave. Palo Alto, California.94304. Facebook, Inc. owns and operates websites including www.facebook.com, whichoffers online social interaction and picture storage.8.
Defendants Doe 1 through 10 are the remaining directors, employees, agents,or contractors of Facebook that are yet to be named and whose identity will become knownthrough discovery and/or by requests made by Plaintiff or the members of the plaintiff class,after which such remaining defendants will be added as individual defendants.
Case 2:11-cv-01901-JLR Document 1 Filed 11/14/11 Page 2 of 15