1
23
4
5
HARMEET
1<.
DHILLON,
ESQ. (SBN:
207873)NITOJ
P.
SINGH,
ESQ. (SBN:
265005)DHILLON
&
SMITH LLP177 Post Street, Suite 700
San
Francisco, California 94108Telephone:
(415)
433-1700Facsimile: (415) 520-6593
!FEB
0 8
20
2
6 Attorneys for Hive Mind, Inc.78
9
10
11
12131415SUPERIOR
COURT
OF THE STATE OF CALIFORNIACOUNTY OF
ALAMEDA
-UNLIMITED
JURISDICTIONHive
Mind, Inc., a Delaware corporation,Case Number:Plaintiff,COMPLAINT
v.
1. Breach of Fiduciary
Duty
-
Wright
2.
Breach
of
Fiduciary
Duty
-
Parekh
William
R.
Wright,
an
individual;
Stupid
16
Fun
Club, LLC; a Delaware limited3.
Fraud
4.
IntentionalInterference
with
Prospective Economic
Advantage
7 liability company;
and
Raj Parekh,
an
5.
Misappropriation
of
Trade
Secrets
1819
20
21
222324
2526
individual,
6.
Declaratory
Relief
Defendants.
Jury
Trial
Demanded
Hive
Mind, Inc.,
by
and
through
its attorneys, Dhillon
&
Smith LLP, files this
Complaint
against
StupidFun
Club, LLC; Raj Parekh;
and
William Wright.
Uponpersonal knowledge
(unless otherwise indicated) Hive Mind, Inc. alleges as follows:
THE
PARTIES
1.
Plaintiff Hive Mind, Inc. ("Hive Mind") is a Delaware limited liability
Complaint
DHILLON
&
SMITH
LLP
-1-
>-
,~t·)~
,;","1lCS',
Complaint
D
HILLON
&
S
MITH
LLP
-2-
1234567891011121314151617181920212223242526company with its principal place of business in Berkeley, California, in AlamedaCounty.2.
Defendant William Wright (“Wright”), upon information and belief, is anindividual residing in Alameda County, California. Wright is a former director of HiveMind.3.
Defendant Stupid Fun Club, LLC (“SFC”) is a Delaware limited liabilitycompany with its principal place of business in Berkeley, California, in AlamedaCounty. Upon information and belief, Wright is a member of SFC and sits on SFC’sBoard of Directors.4.
Defendant Raj Parekh (“Parekh”), upon information and belief, is anindividual residing in Los Altos, California, in Santa Clara County.
JURISDICTION AND VENUE
5.
This Court has personal jurisdiction over defendants as they all reside inCalifornia, and venue is proper in this Court, because one or more defendants reside inthis county.
FACTUAL ALLEGATIONSInitial Formation of Hive Mind
6.
In or around June 2011, Jawad Ansari (“Ansari”) partnered with Wright toexplore whether the two could implement and monetize a new cross-platform, cross-media, social gaming experience (the “Concept”) that Wright had envisioned.7.
Wright is the creator of the successful “Sims” series of videogames and the“Spore” videogame. He is also the creator of other video games. Wright’s attachment tothe Concept instantly provided a high level of credibility to the project.8.
In 2008, Wright left Electronic Arts and created the SFC, a think tank togenerate IP and find partners for each of media and entertainment platforms. ElectronicArts invested $10,000,000 in 2009 for approximately 40% -50% ownership of SFC and a
Complaint
D
HILLON
&
S
MITH
LLP
-3-
1234567891011121314151617181920212223242526seat on SFC’s Board of Directors. Joel Linzner, Executive VP of Electronic Arts has since been the Board member of SFC representing Electronic Arts.9.
Ansari and Wright envisioned that the Concept would turn a video gameor social game player’s everyday life into part of the interactive experience by buildingupon alternate reality games and tapping streams of personal information on phones,tablets, social networks, and computers.10.
The Concept would not only include games across platforms, but wouldinclude,
inter alia
, broadcast television shows featuring the Concept.11.
Ansari and Wright ultimately formed what became known as Hive Mindto develop, produce, and license the Concept.12.
Prior to the formation of Hive Mind, Wright was not able to attractsignificant interest in the Concept, nor was he able to find strategic partners to helpdevelop the Concept. In addition, since obtaining funding from Electronic Arts for$10,000,000 in 2009, Wright was unable to successfully close any deal to generaterevenues and establish SFC as a going concern.13.
While Wright was a skilled and proven game designer, Ansari held thecomplementary skills that could bring the Concept into reality. Ansari had significantexperience investing in and building and representing emerging private companies,including video and social game and media companies. Ansari’s experience andpersonal connections in the global investment, telecom, technology, video game andmedia industries would lead to opportunities and partnerships that had not previously been available to Hive Mind.14.
The business model for Hive Mind was to develop and publish games based on the Concept’s intellectual property and then market strategic partnershipsglobally in each of the mediums contemplated by the Concept, including,
inter alia
,games, television, movies, internet and merchandise.
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