SUMMONS(CITACION JUDICIAL)

NOTICE TO DEFENDANT: EVAN SPIEGEL, an individual; ROBERT C.(AVISO AL DEMANDADO): MURPHY, an individual; SNAPCHAT, INC., aDelaware corporation; and DOES 1 through 50 inclusive,

YOU ARE BEING SUED BY PLAINTIFF: ELIZABETH TURNER, an(LOESTA DEMANDANDO EL DEMANDANTE): individual; and SARAHTURNER, an individual,

SUM-100

FOR COURT USE ONLY

(SOLO PARA USO DE LA CORTE)

f onforwie^ copyf^lGtNAL FILED .

SEP 23 201'tSherti R. Carter, Executive OHicer/Clerl^

By Wlyrna Beltran, Deputy

NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the informationbelow.

You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copyserved on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form ifyou want the court to hear yourcase. There may be a court form that you can use foryour response. You can find these court forms and more information at the California CourtsOnline Self-Help Center {www.courtinfo.ca.gov/selfhelp), your county law library, or the courthouse nearest you. Ifyou cannot pay the filing fee, askthe court clerk for a fee waiver form. Ifyou do not file your response on time, you may lose the case by default, and your wages, money, and propertymay be taken without further warning from the court.

There are other legal requirements. You may want to call an attorney right away. Ifyou do not know an attorney, you may want to call an attorneyreferral service. Ifyou cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locatethese nonprofit groups at the California LegalServices Web site iwww.lawhelpcalifomia.org), the California Courts OnlineSelf-Help Center{www.courtinfo.ca.gov/selfhelp), or by contacting your local court or county bar association. NOTE: The court has a statutory lienforwaivedfees andcosts on any settlement or arbitration award of $10,000 or more in a civil case. The court's lienmust be paid before the court will dismiss the case.(AVISO! Lohan demandado. Si no responde dentro de 30 dfas, la cortepuede decidiren su contra sin escucharsu version. Lea la informacion acontinuacidn

Tiene 30 DlAS DE CALENDARIO despu6s de que le entreguen esta citacidn y papeies iegaies para presentar una respuesta por escrito en estacode y hacerque se entregue una copia al demandante. Una carta o una llamada teiefdnica no io protegen. Su respuesta por escrito tiene que estaren fonvato legal correcto si desea que procesen su caso en la corte. Es posible que haya un formulan'o que usted pueda usarpara su respuesta.Puede encontrar estos formularios de la corte y mas Informacidn en el Centra de Ayuda de las Cortes de Califomia fwww.sucorte.ca.gov). en labibliotecade leyes de su condado o en la corte que le quede m^s cerca. SI no puede pagar la cuota de presentacidn, pida al secretario de la corteque le d6 un formulan'o de exencion de pago de cuotas. SI no presenta su respuesta a tiempo, puede perder el caso por incumplimiento y la corte lepodr^ quitar su sueldo, dinero y bienes sin m^s advertencia.

Hay otros requisites legates. Es recomendable que llame a un abogado inmedlatamente. Si no conoce a un abogado, puede llamara un servlcio deremision a abogados. Si no puede pagar a un abogado, es posible que cumpla con los requisites para obtener servicios legates gratuitos de unprograma de servicios legates sin fines de lucro. Puede encontrar estos grupos sin fines de lucro en el sitio web de Califomia Legal Services,fwww.lawhelpcalifomia.orgj, en el Centro de Ayuda de las Cortes de Califomia, fwww.sucorte.ca.gov) o poni6ndose en contacto con la corte o elcoleglo de abogados locales. AVISO: Por ley, la corte tiene derecho a reclamar las cuotas y los cosfos exentos por imponer un gravamen sobrecualquier recuperacidn de $10,000 6 mSs de valorreclbida mediante un acuerdoo una concesidn de arbitraje en un caso de derecho civil. Tienequepagar el gravamen de la corte antes de que la corte pueda desechar el caso.

Tfie name and address of the court Is: case number:(El nombre y direccion de la corte es): (NOmem uei caso):Los Angeles Superior Court111 N. Hill Street

Los Angeles, CA 90012The name, address, and telephone number of plaintiffs attorney, or plaintiffwithout an attorney, is:(El nombre, la dlreccidn y el numero de telefono del abogado del demandante, o del demandante que no tiene abogado, es):Eric S. Engel (SNB 105656) / H. Kim Sim(SB# 252321) 310-998-9100 310-998-9109Conkle, Kremer & Engel, PLC3130Wilshire Blvd., Ste. 500Santa Monica, CA 90403DATE: SHERRI R. CARTER

(Fecha)

BC5S8442

Clerk, by(Secretario)

myrn.a beltran Deputy(Adjunto)

(For proof of service of this summons, use Proof of Service of Summons (form POS-OfO).)(Para prueba de enirega de esta citation use el formulario Proof of Service of Summons, (POS-010)).

NOTICE TO THE PERSON SERVED; You are servedSEAL 1.

2.

3.

as an individual defendant.

as the person sued under the fictitious name of (specify):

on behalf of (specify):

under: | i COP 416.10 (corporation)I I COP 416.20 (defunct corporation)I I COP 416.40 (association or partnership)I I other (specify):

4. I " I by personal delivery on (date):

I I COP 416.60 (minor)I I COP 416.70 (conservatee)I I COP 416.90 (authorized person)

Form Adopted for Mandatory UseJudicial Council of Califomia

SUM-100 [Rev. July 1.2009)

SUMMONSSolut^ns'

Page 1 of 1

Code of Civil Procedure §§ 412.20, 465

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Eric S. E^el (SB# 105656)e.en^el(mconklelaw.com

H. KimSm(SB# 252321)k.sim@.conklelaw. com

CONI^, KREMER &ENGELProfessional Law Corporation3130 Wilshire Boulevard, Suite 500Santa Monica, California 90403-2351Phone: (310) 998-9100 • Fax: (310) 998-9109

Attorneys for Plaintiffs Elizabeth Turnerand Sarah Turner

CONFORMED COPYORIGINAL FILED

Superior Court of CaliforniaCounty of Los Angeles

SEP 23 2mSherri R. Carter, Executive Officer/Clerk

By Myma Beltran, Deputy

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES, CENTRAL DISTRICT

ELIZABETH TURNER, an individual;and SARAH TURNER, an individual.

Plaintiffs,

V.

EVAN SPIEGEL, an individual;ROBERT C. MURPHY, an individual;SNAPCHAT, INC., a Delawarecorporation; and DOES 1 through 50inclusive.

Defendants.

3884.002\9994

Case No.

COMPLAINT FOR:

1. VIOLATION OF STATUTORYRIGHTS OF PUBLICITY

2. VIOLATION OF COMMONLAW RIGHTS OF PUBLICITY

Complaint Filed: September 23,2014Trial Date: None Set

COMPLAINT

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3884.002\9994 -1- COMPLAINT

SUMMARY OF CLAIMS

1. This action begins with Evan Spiegel and Robert C. Murphy, the founders

and principals of Snapchat, Inc., misleading two young sisters, Elizabeth and Sarah

Turner, into allowing their photographs to be taken as a “class project.” Spiegel and

Murphy then used the sisters’ photographs for promotion of the Picaboo application

for iPhone, under Model Releases “exclusively for the purpose of promoting the

Picaboo application for iPhone.” The Picaboo App for iPhone was later renamed the

Snapchat App for iPhone.

2. The principals of Snapchat, Inc. misused the sisters’ photographs for profit

and to enhance the Defendants’ goodwill and enterprise value. The Defendants’

misuse of the sisters’ photographs included extensive promotion of the different and

much more frequently used Snapchat App for Android, without even asking for

Elizabeth and Sarah’s consent. The principals of Snapchat, Inc. used Elizabeth and

Sarah’s photographs so prominently and extensively that they have effectively

become the “faces” of the Snapchat applications. As a result of the prominent and

extensive promotion of their personae by Snapchat, Inc. and its principals, Elizabeth

and Sarah have suffered having their images tainted by the somewhat tawdry

reputation of Snapchat applications, widely reputed to be used as “sexting” apps. For

example, Google Images searches of the offensive slur “snapchat sluts” results in the

sisters’ photographs, promulgated by Snapchat, Inc. and its founders, appearing first

at the top of the search results.

3. Owing in part to promotion through photographs of Elizabeth and Sarah,

the Defendants’ Snapchat applications have become extraordinarily successful. The

founders of Snapchat, Inc. famously refused a cash acquisition offer from Facebook

for $3 billion, and the company is currently valued at about $10 billion. The sisters

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3884.002\9994 -2- COMPLAINT

were never paid anything by Snapchat, Inc. or its founders and principals. Elizabeth

and Sarah Turner have suffered substantial injuries and damages as a result of the

violations of their rights of publicity under California law.

PARTIES

4. Plaintiff Elizabeth Turner (“Elizabeth”) is an individual residing in

Georgia.

5. Plaintiff Sarah Turner (“Sarah”) is an individual residing in Georgia.

6. Elizabeth and Sarah are sisters. In July 2011, Elizabeth was 18 and Sarah

was 19 years old, and both were living in Los Angeles County, California.

7. Defendant Evan Spiegel (“Spiegel”) is an individual residing in Los

Angeles County, California.

8. Defendant Robert C. Murphy (“Murphy”) is an individual residing in Los

Angeles County, California.

9. Defendant Snapchat, Inc. is a Delaware corporation with its principal place

of business located at 64 Market Street, Venice, California, in Los Angeles County.

On information and belief, Defendant Snapchat, Inc. is the successor entity to Toyopa

Group, LLC and Future Freshman, LLC, both California Limited Liability

Companies.

10. On information and belief, Spiegel and Murphy were both owners and

managers of Future Freshman, LLC and Toyopa Group, LLC, and since the formation

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3884.002\9994 -3- COMPLAINT

of Snapchat, Inc. have been its principal officers. On information and belief, Spiegel

and Murphy direct and control Snapchat, Inc.’s activities from within Los Angeles

County, California.

11. Plaintiffs are unaware of the true names and capacities, whether individual,

corporate, associate or otherwise, of defendants Does 1 through 50, inclusive, or any

of them, and therefore sue these defendants by such fictitious names. The Doe

defendants include persons and entities assisting or acting in concert with the named

defendants in connection with the actions complained of herein, and include persons

and entities that are responsible in some manner for the acts, occurrences and liability

alleged herein. All defendants herein are referred to collectively as “Defendants.”

12. Defendants are jointly and severally liable for the wrongful conduct set

forth herein because they have aided and abetted, or conspired to commit, such

wrongful conduct, and have served as the agents for one another in such wrongful

conduct.

JURISDICTION AND VENUE

13. The Court has subject matter jurisdiction over this action pursuant to

Article VI, section 10 of the California Constitution and California Code of Civil

Procedure § 410.50.

14. Venue is proper in Los Angeles County pursuant to California Code of

Civil Procedure §§ 393 & 395(a) because it is where the cause of action arose and

injury occurred, and where one or more of the Defendants either reside or maintain

their principal place of business, where Defendants received substantial benefits as a

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3884.002\9994 -4- COMPLAINT

result of the conduct alleged, and where the conduct and activities giving rise to the

claims in this action occurred.

DEFENDANTS MISLED ELIZABETH AND SARAH INTO MODELING TO

PROMOTE THEIR SNAPCHAT APP FOR IPHONE

15. In June 2011, Elizabeth was a student at Duke University who engaged in

some professional modeling. Spiegel was a student at Stanford University, and

Murphy was a recent graduate of Stanford University. Spiegel and Murphy were

working together on a disappearing photograph software application (“App”) for

iPhone called “Picaboo,” as a follow-up to a prior venture in which they had engaged

under a business entity called Future Freshman, LLC.

16. On or about July 15, 2011, Spiegel contacted Elizabeth through a mutual

acquaintance, and asked her to model for photographs for free “for a class project.”

Spiegel suggested Elizabeth come to his house in Pacific Palisades to model.

Elizabeth responded that she would only come to his house if her sister Sarah

accompanied her.

17. On July 18, 2011, Elizabeth and Sarah met Spiegel and Murphy. Spiegel

took photographs of Elizabeth and Sarah at the Santa Monica Pier, Santa Monica

beach, and at the Toyopa Drive, Pacific Palisades home that served as the principal

place of business for the predecessors to Snapchat, Inc., Future Freshman, LLC and

Toyopa Group, LLC. Murphy assisted Spiegel in taking the photographs.

18. Elizabeth and Sarah were paid nothing for their modeling for Spiegel and

Murphy’s “class project.” Elizabeth and Sarah provided their own wardrobe, and did

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3884.002\9994 -5- COMPLAINT

their own makeup and hairstyling. Spiegel and Murphy did not request Elizabeth and

Sarah to sign any Model Release on July 18, 2011.

19. Three days later, on July 21, 2011, Spiegel emailed Elizabeth and attached

a Model Release, and requested that Elizabeth sign a Model Release and have Sarah

sign one as well. Elizabeth and Sarah were then living in Los Angeles County,

California. Elizabeth and Sarah signed the Model Releases in Los Angeles County on

July 25, 2011, and emailed the Model Releases back to Spiegel as requested. At the

time, Spiegel was living in Los Angeles County, California. A true copy of

Elizabeth’s signed Model Release is attached as Exhibit 1, and a true copy of Sarah’s

signed Model Release is attached as Exhibit 2. Elizabeth and Sarah were paid nothing

for signing the Model Releases.

20. The Model Releases provide in pertinent part as follows:

I, the undersigned, do hereby consent and agree that Future

Freshman LLC, its employees, and agents have the right to

take photographs, videotape, or digital recordings of me on

July 18, 2011 and to use these in any and all media, now or

hereafter known, and exclusively for the purpose of

promoting the Picaboo application for iPhone.

21. The Model Releases were thus expressly limited to use of the photographs

taken of Elizabeth and Sarah on July 18, 2011 “exclusively for the purpose of

promoting the Picaboo application for iPhone.”

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3884.002\9994 -6- COMPLAINT

22. After signing and returning the Model Releases to Spiegel, Elizabeth and

Sarah had no further contact with Spiegel or Murphy about use of the photographs

taken on July 18, 2011.

DEFENDANTS EXTENSIVELY PROMOTED THE SNAPCHAT APP FOR

IPHONE BY USING THE PHOTOGRAPHS OF ELIZABETH AND SARAH

23. In about July 2011, Spiegel and Murphy began promoting the Picaboo

application for iPhone (“Picaboo App for iPhone”), using the photographs taken of

Elizabeth and Sarah. Spiegel particularly used the attractiveness of Elizabeth to

generate early interest in the Picaboo App for iPhone. For example, on information

and belief, Spiegel wrote an online post directed to college fraternity members to

promote the Picaboo App for iPhone. Under the heading “Ridiculous iPhone App,”

Spiegel specifically pointed these young male potential users of the Picaboo App for

iPhone to the iTunes download site that featured in “iTunes screenshots” photographs

of Elizabeth, the “very good-looking” girl “from Duke”:

I thought you might want to check out the iPhone app I built

this summer.

It’s called Picaboo and it’s the fastest way to share photos

that disappear. You take a picture, set the timer up to ten

seconds, and send to a friend. When they receive your

Picaboo they have until the timer is up to view it – then it

disappears forever. Fun shit.

The girl who modeled in our iTunes screenshots is from

Duke and very good looking: itunes/apps/picaboo

If you want any more info – hit me up. We’re trying to get

the word out.

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3884.002\9994 -7- COMPLAINT

Also, proof [a photograph of Elizabeth] attached.

24. In or about September 2011, Defendants changed the name of the

“Picaboo App for iPhone” to the “Snapchat App for iPhone.” On information and

belief, this name change involved no substantive change in the software application

other than its name, and it remained exclusively an application for iPhone.

25. Defendants launched the Snapchat App for iPhone with a website at the

domain name “snapchat.me,” which featured prominently a carousel of photographs

of Elizabeth and Sarah and links to the iTunes download site for the Snapchat App for

iPhone, which also prominently featured photographs of Elizabeth and Sarah. The

photographs used by Defendants on the snapchat.me website included one photograph

cropped and edited by Defendants to falsely suggest to the casual observer that

Elizabeth was pulling off Sarah’s bathing suit top and that they were nude on the

beach. The following are examples of the snapchat.me website as it existed in

September 2011:

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3884.002\9994 -8- COMPLAINT

26. Substantially the same website design and photographs were used by

Defendants on a subsequent snapchat.com website for promotion of the Snapchat App

for iPhone.

27. The same series of photographs of Elizabeth and Sarah have been

prominently used by Defendants for advertising and promotion of the Snapchat App

for iPhone consistently from approximately August 2011 through the present.

Through the date of this Complaint, the photographs of Elizabeth and Sarah have

continuously appeared on the iTunes Store page for downloads of the Snapchat App

for iPhone, which is the standard default location for authorized downloads of

applications for iPhones.

28. As the Snapchat App for iPhone grew in popularity, it acquired a

somewhat tawdry reputation as a “sexting app,” used by individuals to send sexually

graphic photographs, text and images that were intended to disappear shortly after

receipt. The photographs and personae of Elizabeth and Sarah used by Defendants to

promote the Snapchat App for iPhone were tainted with application’s tawdry

reputation, and photographs of Elizabeth and Sarah began appearing prominently in

Google searches for offensive phrases such as “snapchat sluts.”

WITHOUT EVEN ASKING FOR CONSENT, DEFENDANTS USED

PHOTOGRAPHS OF ELIZABETH AND SARAH EXTENSIVELY TO

PROMOTE THE MUCH MORE POPULAR SNAPCHAT APP FOR

ANDROID

29. On October 29, 2012, Defendants launched the Snapchat App for Android,

a completely different technological platform than the iPhone. Defendants promoted

the Snapchat App for Android by touting it as different from the Snapchat App for

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3884.002\9994 -9- COMPLAINT

iPhone, such as by announcing: “This isn’t just a copy of our iPhone app. We

wanted to create a true Android app….”

30. Immediately following the October 29, 2012 launch of the Snapchat App

for Android, Defendants began promoting the Snapchat App for Android through use

of the same series of photographs of Elizabeth and Sarah that had been taken on July

18, 2011. The same series of photographs of Elizabeth and Sarah have been

prominently used by Defendants for advertising and promotion of the Snapchat App

for Android consistently from approximately November 2012 through the present.

Through the date of this Complaint, the photographs of Elizabeth and Sarah have

continuously appeared on the Google Play Store page for downloads of the Snapchat

App for Android, which is the default standard location for authorized downloads of

applications for Android devices.

31. The photographs of Elizabeth and Sarah have so extensively and

consistently been used by Defendants that they have effectively been used first as “the

faces” of the Snapchat App for iTunes, and subsequently as “the faces” of the

Snapchat App for Android.

32. Defendants’ launch of the Snapchat App for Android was a very large step

into a new operating system platform that promised enormous profit growth

opportunities for Defendants. On information and belief, Defendants also permitted

other Snapchat applications to be distributed and promoted on different technology

platforms, sometimes also promoted with photographs of Elizabeth and Sarah. On

information and belief, the number of Android smartphones in use far surpasses the

number of iPhones in use, such that approximately 80% of the smartphone market

today is held by Android smartphones. Accordingly, on information and belief, the

number of downloads and uses of the Snapchat App for Android far surpasses the

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3884.002\9994 -10- COMPLAINT

number of downloads and uses of the Snapchat App for iPhone. Therefore, the

Defendants’ uses of the photographs of Elizabeth and Sarah for the promotion of the

Snapchat App for Android are far more numerous and extensive than their uses of

photographs of Elizabeth and Sarah for the Snapchat App for iPhone.

33. With the huge increase in uses of the Snapchat App for Android, the

tawdry reputation of the Snapchat applications has not abated, and the association of

Elizabeth and Sarah’s personae with that tawdry reputation has grown stronger with

the Defendants’ use of their photographs to promote the Snapchat App for Android.

For example, as of the date of this Complaint, a search of Google Images for the

offensive slurs “snapchat sluts” or “snapchat whores” places the photographs of

Elizabeth and Sarah, as used in Snapchat applications, in the number one search result

position at the top left of the search results, as shown here:

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3884.002\9994 -11- COMPLAINT

FIRST CAUSE OF ACTION

FOR VIOLATION OF STATUTORY RIGHTS OF PUBLICITY

BY PLAINTIFFS AGAINST ALL DEFENDANTS

34. Plaintiffs reallege paragraphs 1 through 33 of this Complaint as if set forth

in full herein.

35. Defendants intentionally and deliberately used, without authorization or

consent, the photographs, images and likenesses of Elizabeth and Sarah for economic

gain in the promotion and distribution of the Snapchat App for Android and, on

information and belief, other technology platforms apart from the Snapchat App for

iPhone. Elizabeth and Sarah are readily identifiable in the photographs, images and

likenesses used by Defendants.

36. Defendants’ extensive use without consent of the photographs, images and

likenesses of Elizabeth and Sarah caused them substantial injury and damage,

including emotional distress, embarrassment, and loss of pecuniary value of the use of

their photographs, images and likenesses. As a result of Defendants’ extensive use

without consent of the photographs, images and likenesses of Elizabeth and Sarah,

Defendants gained profits, enhanced goodwill and enhanced economic value, a

portion of which is attributable to Defendants’ use of the photographs, images and

likenesses of Elizabeth and Sarah.

37. Defendants’ wrongful conduct toward Elizabeth and Sarah as alleged

herein was malicious and oppressive. Defendant Snapchat, Inc.’s wrongful conduct

was through the intentional acts and conduct of its controlling principal officers,

Spiegel and Murphy. As a result, Plaintiffs are also entitled to an award of punitive

damages.

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3884.002\9994 -12- COMPLAINT

SECOND CAUSE OF ACTION

FOR VIOLATION OF COMMON LAW RIGHTS OF PUBLICITY

BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS

38. Plaintiffs reallege paragraphs 1 through 33 of this Complaint as if set forth

in full herein.

39. Defendants used, without authorization or consent, the photographs,

images and likenesses of Elizabeth and Sarah for economic gain in the promotion and

distribution of the Snapchat App for Android and, on information and belief, other

technology platforms apart from the Snapchat App for iPhone. Elizabeth and Sarah

are readily identifiable in the photographs, images and likenesses used by Defendants.

40. Defendants’ extensive use without consent of the photographs, images and

likenesses of Elizabeth and Sarah caused them substantial injury and damage,

including emotional distress, embarrassment, and loss of pecuniary value of the use of

their photographs, images and likenesses. As a result of Defendants’ extensive use

without consent of the photographs, images and likenesses of Elizabeth and Sarah,

Defendants gained profits, enhanced goodwill and enhanced economic value, a

portion of which is attributable to Defendants’ use of the photographs, images and

likenesses of Elizabeth and Sarah.

41. Defendants’ wrongful conduct toward Elizabeth and Sarah as alleged

herein was malicious and oppressive. Defendant Snapchat, Inc.’s wrongful conduct

was through the intentional acts and conduct of its controlling principal officers,

Spiegel and Murphy. As a result, Plaintiffs are also entitled to an award of punitive

damages.

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PRAYER

WHEREFORE, Plaintiffs Elizabeth Turner and Sarah Turner pray for judgment

against Defendants, and each of them, as follows;

1. For damages in an amount to be proved at trial, including at least:

a. Loss ofpecuniary value ofthe use oftheir photographs, images and

likenesses;

b. Compensation for emotional distress and embarrassment;

c. Portions ofDefendants' profits, enhanced goodwill and enhanced

economic value attributable to Defendants' use of the photographs, images and

likenesses of Elizabeth and Sarah;

2. Punitive damages;

3. Attorney fees for violation of the statutory right ofpublicity;

4. Costs of suit; and

5. Such other and further relief as the Court may deem just and proper.

Dated: September 22, 2014

3884.002\9994

Eric S. EngelH. Kim Sim, members ofCONKLE, KREMER & ENGELProfessional Law Corporatim

Attorneys forSarah Turner

COMPLAINT

tiffs Elizabeth Turner and

Exhibit 1

Exhibit 2