Voom - Complaint

7/28/2019 Voom - Complaint

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Case 2:13-cv-02321-DMG-MRW Document 1 Filed 04/01/13 Page 1 of 18 Page ID #:16

1 HeeDong Chae Bar No. 263237Chong Roh Bar No. 2424372 EastWest Law Group .3600 Wilshire Blvd. Suite 22283 Los Angeles, CA 90010Telephone: (213)387-36004 Facsllnile: (213) 387-36365 Attorneys for PlaintiffVOOM GROUP, INC.6789

UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

1011 VOOM GROUP, INC. a Californiacorporation,1213 vs. Plaintiff,

.14 Incremento, Inc. dba Peaches and Cream,a California corporation; Textile One, Inc.,15 a California corporation; Your Runway, aCalifornia business form Unknown; Patzzi,16 Inc. dba Codigo, a California corporation;BIEN p p a r e i ~ a California business form17 unlmown; Gilli, Inc., a Californiacorporation; Hebron Textile Com., a .18 California corporation and DOES 1through 10, inclusive,19 Defendants.

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~ " ' Y 1 3 - 0 2 3 2 1 - (YlC)-casYNo. [ n t ~ vJ ICOMPLAINT FOR COPYRIGHT JINFRINGEMENTCONTRIBUTORY ANDVICARIOUS COPYRIGHTINFRINGEMENT, AND UNFAIRcoMPETITION

DEMAN;D FOR JURY TRIAL

21 Plaintiff, Voom Group, Inc., ("Voom") alleges follows:22 JURISDICTION AND VENUE23 1. This is a civil action seeldng damages and injunctive relief for copyright24 infringement under the copyright laws of the United States (17 U.S.C. 101, et25 seq.).26 2. This Court has jurisdiction over the subject matter of this action27 pursuant to 28 U.S.C. 1331 and 1338(a).28 3. This Court has personal jurisdiction over all the Defendants by virtUe of


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1 their transacting, doing, and soliciting business in this District, and because a2 substantial part of the relevant events occurred in this District and because a3 substa:n,tial part of the property that is the subject of this action is situated here.4 PARTIES5 4. Plaintiff, Voom Group, Inc. ("Voom"), is a corporation organized and6 existing under the laws ofState ofCalifornia, with its principal place ofbusiness at7 in the County ofLos Angeles.8 5. Plaintiff is informed and believes, and thereon alleges, that defendant,9 Incremento, Inc. dba Peaches and Cream ("PNC") is a California corporation, with

10 principal place of business at 1015 S. Crocker St., Unit R3, Los Angeles, California11 90021.12 6. Plaintiff is informed and believes, and thereon alleges, that defendant13 Textile One, Inc. ("Textile One") is a California corporation, with principal place of14 business at 1383 E. 15th St., Los Angeles, California 90021.15 7. Plaintiff is i n f o r m ~ d and believes, and thereon alleges, that defendant16 Your Runway is a California business, legal form unknown, with place ofbusiness at17 17351 Railroad St. #D, City of Industry, California 91748.18 8. Plaintiff is informed and believes, and thereon alleges, that defendant19 Patzzi, Inc. dba Codigo, is a California corporation, with principal place ofbusiness20 at 1100 S. San Pedro St. Unit C-8, Los Angeles, California 90015.21 9. Plaintiff is informed and believes, and thereon alleges, that defendant22 EIEN Apparel ("EIEN") is a California business, legal form unknown, with place of23 business at 735 E. 12th St., Suite 113, Los Angeles, California 90021.24 10. Plaintiff is informed and believes, and thereon alleges, that defendant25 Gilli, Inc. ("Gilli") is a California corporation, with place ofbusiness at 381 0 S.26 Main St., Los Angeles, California 90037.27 11. Plaintiff is informed and believes, and thereon alleges, that defendant28 Hebron Textile Corp. ("Hebron") is a California corporation, with place ofbusiness

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1 at 1139 E. Pico Blvd., Los Angeles, California 90021. 2 12. Plaintiff is unaware of the true names and capacities, whether3 individual, corporate, or otherwise, of he Defendants named herein as Does 14 through 10, inclusive, but is informed and believes, and thereon alleges, that each of

5 the fictitiously named defendants engaged in, or is in some manner responsible for,6 the wrongful conduct alleged herein. Plaintiff therefore sues these defendants by7 such fictitious names and will amend this complaint to state their true names and8 capacities when such names have been discovered.9

10 FACTS COMMON TO ALL CLAIMS11 13. This is an action fot copyright infringement, as well as contributory and12 vicarious copyright infringement, and related state law claims arising from the13 conduct ofDefendants.14 14. Voom is a leading designer ofwomen's fashions. Voom's designs are15 created in.:.house and its designs are produced on its original clothing.16 15. Voom launched its first line in 2002. Since that time, Voom designs17 have been featured in national magazines being worn by celebrity talents such as18 Jessica Alba, Eva Longoria, Paris Hilton, Nicky Hilton, Miley Cyrus, Eve, Emmy19 Rossum, Shannon Elizabeth and Jennifer Love Hewitt.20 16. Voom is the owner ofnumerous copyright registrations filed with the21 U.S. Copyright Office for its unique and original print and fabric designs (the "Voom22 designs"). V oom Products bearing the V oom Designs have become widely23 recognized for their distinctive and original style, and for their high quality of24 manufacture.25 17. As a result of the quality and reputation of the Voom Products and the26 desirability and recognition of the Voom Designs, Voom has achieved an27 outstanding reputation in the marketplace and among_consumers. The Voom28 Products and the Voom Designs have come to symbolize the reputation and goodwill

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1 ofVoom.2 18. In2011, Voom createdthe Voom design, "DA;RLA0112," a sample of3 which is attached hereto as Exhibit "A." Voom applied for and received a United4 States copyright registration VA 1-809-710 for "DARLAO 112" A true and correct5 copy of the registration certificate is attached hereto as Exhibit "B" and incorporated6 herein by refere4ce.7 19. On information and belief, defendants, and each of them, purchased,8 sold, manufactured, caused to be manufactured, imported, and! or distributed fabric9 and/or garments comprised of fabric featuring a design that is at the very least,

10 substantially similar to Voom s "DARLAO 112" copyright.11 20. The substantial similarity between the Voom's "DARLA0112"12 copyright and those of he fabric and/or garments ofDefendant, and each of hem, is13 too striking to be the result of anything other than lawful copying.14 21. Without authorization or license from Voom, Defendants, and each of15 them, have coped and reproduced for sale or offer for sale, and are marketing,16 promoting, displaying and distributing fabric and/or garments.17 22. On information and belief, the conduct ofdefendants, and each of hem,18 has been willful, with knowledge ofVoom's rights and/or in reckless disregard of19 them, and Defendants, and each of them are unlawfully profiting from the20 unauthorized reproduction of the copyrighted Voom designs.21 .FIRSTCLAIMFORRELIEF22 (Copyright Infringement, 17 U.S.C. 501, et seq.)23 23. V oom incorporates herein by e f ~ r e n c e all the allegations of paragraphs24 1 through 22, inclusive.

. .25 24. Voom is the owner of the Voom Designs and the copyrights embodied26 therein.27 25. Defendants, and each of them, are not authorized by Voom to28 reproduce, display, offer for sale or sell copies ofthe VoomDesigns.

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I 26. Voom has developed a reputation and a l u a b ~ e goodwill in the unique2 and original appearance of the Voom Designs and the Voom Products.3 27. As a result ofDefendants', and each of their willful and infringing4 conduct, Voom has suffered damages in an amount not yet lmown but to be proven at5 a trial of this action.6 28. Voom will continue to be damaged by Defendants', and each of their7 unauthorized conduct unless they are enjoined by this Court from any further8 manufacture, display, promotion, distribution, offer for sale.or sale of the Infringing9 Products.

10 29. V oom is informed and believes, and on that basis alleges, that11 Defendants, and each of them, have realized profit by virtue of their infringement of12 Voom's copyrights.13 30. Voom has sustained economic damage as a result ofDefenclants', and14 each oftheir, infringement ofVoom's copyrights in an amount to be proven at trial.15 31. V oom is entitled to recover the actual damages it has suffered and/or16 any profits gained by Defendants, and each of hem, that are attributable to their acts17 of copyright infringement pursuant to 17 U.S.C. 504(b). Alternatively, Voom is18 entitled to the maximum statutory damages allowed under 17 U.S.C. 504(c) based19 on Defendants', and each of heir, willful acts of copyright ip.fringement. Voom will20 make its election at the appropriate time before final judgment is rendered.21 32. Voom is also entitled to recover its full costs and reasonable attorneys'22 fees pursuant to 17 U.S.C. 505.23 33. Voom is also entitled to an injunction pursuant to 17 U.S.C. 50224 against co1_1tinuing reproduction, distribution, and/or display ofVoom's copyrighted25 works by Defendants, and each ~ f t h e n : i .26 SECOND CLAIM: FOR RELIEF27 (Contributory Copyright Infringement)28 34. Voom incorporates herein by reference all the allegations ofparagraphs

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1 1 through 33, inclusive.2 35. At all times relevant herein, Defendants, and each of them, induced,3 encouraged, assisted, facilitated and profited from the illegal reproduction and/or4 subsequent sales ofproduct featuring V oom' s designs as alleged herein. -5 36. Through their conduct as set forth herein, Defendants have engaged and6 continued to engage in the business oflmowingly inducing, causing, and materially7 contributing to the a b o v e ~ d e s c r i b e d unauthorized reproductions and/or distributions8 of the Voom's copyrighted material, thus contributing to the infringement ofVoom's9 copyrights and exclusive rights under the Copyright Act.

10 37. The forgoing acts by Defendants have been willful, intentional, and11 purposeful, in disregard of and indifference to the rights ofVoom.12 38. Defendants' conduct, as set forth herein, constitutes contributory13 infringement ofVoom's copyrights and exclusive rights under. the Copyright Act in14 violationof 17 U.S.C. 106, 115, and 501.15 39. As a direct and proximate result of the contributory infringements by16 Defendants ofVoom's copyrights and exclusive rights under the Copyright Act,17 Voom is entitled to damages and Defendants' profits pursuant to 17 U.S.C. 504(b)18 for each infringement. Alternatively, Voom is entitled to the maximum statutory19 damages pursuant to 17 U.S.C. 504(c) based on Defendants willful acts of20 copyright infringement. Voom will make its election at the appropriate time before21 final judgment is rendered.22 40. Voom is also entitled to recover its full costs and reasonable attorneys'23 fees pursuant to 17 U.S.C. 5os.24 41. Voom is also entitled to an injunction pursuant to 17 U.S.C. 50225 against continuing reproduction, distribution, and/or display ofVoom's copyrighted

26 works by Defendants.27 THIRD CLAIM: FORRELIEF28 (Vicarious Copyright Infringement)

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1 42. Voom incorporates herein by reference all the allegations ofparagraphs 2 1 through 41, inclusive.3 43. At all times relevant herein, Defendants exercised control over the4 fabric and/or garments which directly infringed upon Voom's copyrighted works, and5 Defendants derived fmancial benefit from such fabric and/or garments.6 44. The foregoing acts of infringement by Defendants have been willful,7 intentional, and purposeful, in disregard of and indifference to the rights ofV oom.8 45. Defendants' conduct, as set forth herein, constitutes v i ~ a r i o u s9 infringement of Voom's copyrights and exclusive rights under the Copyright Act in

10 violation of 17 U.S.C. 106, 115, and 501.11 46. As a direct and proximate result of the vicarious infringements by12 Defendants ofVoom's copyrights ~ d exclusive rights under the Copyright Act,13 Voom is entitled to damages and Defendants' profits pursuant to 17 U.S.C. 504(b)14 for each infringement. Alternatively,. Voom is entitled to the maximum statutory15 damages pursuant to 17 U.S.C. 504( c) based on Defendants' willful acts of16 copyright infringement. V oom will make its election at the appropriate time before17 final judgment is rendered.18 47. Voom is also entitled to recover its full costs and reasonable attorneys'19 fees. pursuant.to 17 U.S.C. 505.20 48. Voom is also entitled to an injunction pursuant to 17 U.S.C. 502 21 against continuing reproduction, distribution, and/or display ofVoom's copyrighted22 works by Defendants.23 FOURTH CLAIM FOR RELIEF24 (State Unfair Competition)25 49. Voom incorporates herein by reference all the allegations ofparagraphs26 1 through 48, inclusive.27 50. Defendants business practices as alleged herein constitute unfair28 competition and unfair business practices and acts in violation ofCalifornia Business

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1 & Professions Code 17200, et seq.2 51. Pursuant to California Business & Professions Code 17203, Voom is3 entitled to enjoin these practices. Without injunctive relief, Voom has no means by4 which to control Defendants' unlawful copying and distribution ofVoom's5 copyrighted works. V oom is therefore entitled to injunctive relief prohibiting6 Defendants from continuing such acts ofunfair competition.7 52. Defendants' practices as alleged herein also constitute unfair8 c.ompetition and unfair business practices under state common law. As a direct and9 prpximate result ofDefendants' infringing conduct, Voom has suffered and will

10 continue to suffer lost sales and profits in an a1,11ount not yet fully ascertained in an11 amount to be proven at trial.12 PRAYERFORRELIEF13 WHEREFORE, in consideration of he foregoing, Voom prays for judgment as14 follows:15 1. A declaration that Defendants' unauthorized conduct violates Voom's16 rights under common law and the Copyright Act;17 2. Immediately and permanently enjoining Defendants, tlwir officers,18 directors, agents, servants, employees, representatives, attorneys, related companies,19 successors, assigns, and all others in active concert or participation with them from20 copying a:nd reproducing or republishing any ofVoom's copyrighted works without21 consent, and from otherwise infringing Voom's copyrights or other rights in any22 manner;23 3. An order for Defendants to account to Voom for all gains, profits, and24 advantages derived by Defendants by their infringements ofVoom's copyrights or25 such damages as are proper, and since Defendants intentionally infringed plaintiffs'26 copyrights, and for award of the maximum allowable statutory damages in the27 amount of$150,000.00 for each violation;28 4. Award to Voom of actual and/or statutory damages for Defendants'

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1 copyright infringement in an amount to be determined at trial;2 5. Award to Voom its costs, reasonable attorneys' fees, and disbursements3 in this action, pursuant to 17 U.S.C. 505; and456789

10111213141516171819202122232425262728

6. Awarding Voom such other and further relief as is just and proper.

JURY DEMANDPlaintiff hereby demands a trial by jury on all issues so triable.

Dated: March 27, 2013 East West Law Group

B y : ~HeeDong ChaeChongR:ohAttorneys for Plaint iffVOOM, INC.

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EXHIBIT A


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Certificate of RegistrationThis Certificate issued ltl!der the seal of fhe CopyrightOffice hi accordaqce Wi.th title q, Unitccf States Cotfe,attests tbat.registratlqn i1as been m a d ~ for the workidentified be1ow. Tlw lrtforll)atiort on ~ h l s ceitiJicate hasbeen made a part ohhe Copyright Office records.

Register of Copyrights, lJiiited States vfAtnet\ta

R ~ g i ~ t r a ~ l > i i N11rnberVA 1 ~ 8 0 9 . - 7 1 0E f f e ~ W ll f

r e g 1 s t . r a t i o ~ uJanuary 19,2012

Title --........ . - ~ ~ - - ~ - - - - - - - - - - - - - - - - - - - -Title ofWork: DARLAOI12Completion/Publication -------------.........----Y ~ a r of 9ompJetion: 201 t". Date of 1stPublicati9n: August 22, 20 II Nation of ls t Publication: Unitec! S t a t e ~ >Author

Author: VOOM GROUP, INC.Author Created: 2-D artwork

Work made for hire: YesC i t i z ~ n of: Uri.ited S t a t ~ iJoilrldled in: Unjted State$

Copyright l ~ i m ~ n tCopyright Claimant: VOOM GROUP, INc.ll dE. 9thSt.; Ste, Bi 413, !.tO$ ANQEi,ES, 9A 9oQ79, !Jnited w t e ~

Rights and Permis$iQn$OrganiZation Name: VOOM GROUP, INC.

Certification

Nap:te: lANE Y1MEmail: [email protected] d d r . ~ s : i10E. 9TB STREET, STE. B. i.iJ 3

kQS N G ~ ~ E $ , CA 90079 U ~ i i t e d ~ t a t e . s

Name.: SEO'NO ROK KIMDate: S e p k m J , J ~ l ' ~ B , 2QJI

te.le.phPne: 213-627-8$33


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EXHIBITB


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UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA

NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY

This case has been assigned to District Judge Dolly Gee and the assigned discoveryMagistrate Judge is Michael Wilner.The case number on all documents filed with the Court should read as follows:

CV13- 2321 DMG (MRWx)Pursuant to General Order 05-07 of the United States District Court for the Central

District of California, the Magistrate Judge has been designated to hear discovery relatedmotions.

All discovery related motions should be noticed on the calendar of the Magistrate Judge

NOTICE TO COUNSELA copy of this notice must be served with the summons and complaint on all defendants (i f a removal action isfiled, a copy of this notice must be served on all plaintiffs).Su sequent documents must be filed at the following location:

Western Division312 N. Spring St., Rm. G-8Los Angeles, CA 90012U Southern Division

411 West Fourth St., Rm. 1-053Santa Ana, CA 92701-4516

Failure to file at the proper location will result in your documents being returned to you.

U Eastern Division3470 Twelfth St., Rm. 134Riverside, CA 92501

CV-18 (03/06) NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY


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HeeDong Chae Bar No. 263237Chong Roh Bar No . 242437EastWest Law Group3600 Wilshire Blvd. Suite 2228Los Angeles, CA 90010Telephone: (213) 387-3600

UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA

VOOM GROUP, INC., a California corporation CASE NUMBER

v. PLArNTIFF(S) 1 - - - = - C _ _ : : . V - - - - - - . f ! ! l ! - - ~ . . . . . . . , _ ............. l . . . . . . : . . . . ! b - - 4 - 1 - - ' f _ (;Jy_\Incremento, Inc. dba Peaches and Cream, a California -}corporation;[SEE ATTACHED] SUMMONS

DEFENDANT(S).

TO: DEFENDANT(S):A lawsuit has been filed against you.Within 21 days after service of this summons on you (not counting the day you received it), you

must serve on the plaintiff an answer to the attachedM omplaint D amended complaintD counterclaim D cross-claim or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answeror motion must be served on theplaintiffs attorney, HeeDong Chae, Esq. , whose address isEastWest Law Group, 3600 Wilshire Blvd. Suite 2228, Los Angeles, CA90010 . Ifyou fail to do so,judgment by default will be entered against you for the relief demanded in the complaint. You also must fileyour answer or motion with the court.

Clerk, U.S. District Cou

Dated: APR ... 1

[Use 60 days if he defondant is the United States or a United States agency, or is an officer or employee of he United States. Allowed60 days by Rule 12(a)(3)].

CV-OlA (10/11 SUMMONS


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ATIACHMENT

Textile One, Inc., a California co!J)oration; Your Runway, a California businessform unknown; Patzzi, Inc. dba Cod!go, a California corporation; BIEN AQparel, aCalifornia business form unknown; Gilli, Inc., a Califorma corporation; HeoronTextile Corp., a California corporation and DOES 1 through fD, inclusive,


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UNITED STATJ:S DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIACIVIL COVER SHEET .

I. (a} PLAINTIFFS (Check box If you are representing yourself D } DEFENDANTS (Check box if you are representing yourself 0 )Voom Group, Inc.

(b) Attorneys (Firm Name, Address and Telephone Number. Ifyouare representing yourself, provide same.)Chong RohEast West law Group3600 Wilshire Blvd., Suite 2228, los Angeles,CA 90010213.387.3600

II .BASIS OF JURISDICTION (Place an X n one box only.)

Incremento, Inc. db a Peaches and Cream; Textile One, Inc.; Patzzl,lnc. dba Codlgo;Gllli, Inc.; Hebron Textile,lnc.; EIEN Apparel;Your Runway

(b) Attorneys (Firm Name, Address and Telephone Number. If youare representing o u r s e l ~ provide same.)

III. CITIZENSHIP OF PRINCIPAL PARTIES-For i v e r s ! ~ Cases Only(Place an X n one box for plaintiff and one for defendant)0 1. u.s, GovernmentPlaintiff 18] 3. Federal Question (U.s. PTF PEF Incorporated or Principal Place PTFCitizen ofThls State 0 1 D 1 of Business In this State ffil 4 DEF181 4D 2. U.S. GovernmentDefendant

Government Not a Party)0 4. Diversity (Indicate Citizenshipof Parties In Item Ill)

IV. ORIGIN (Place an X n one box only.)[gl 1. original D 2. Removed from O 3, Remanded fromProceeding State Court Appellate.Court

Citizen of Another StateCitizen or Subject of aForeign Country

DcJ 4, Reinstated orReopened

02 02 Incorporated and Principal PlaceofBusiness In Another State03 03 Foreign Nation

5. 1ransrerreo nom Anotner !>,MUltiDistrict (Specify) O DistrictlitigationV. REQUESTED IN COMPLAINT: JURY DEMAND: 18] Yes 0 No (Check 11Yes" only if demanded in complaint.)CLASS ACTION under F.R.Cv.P. 23: 0 Yes 18) No 0 MONEY DEMANDED IN COMPLAINT:$

D 5 DD 6 D

VI. CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filing and write a brief statement of cause. Do not cite jurisdictional statutes unless diversity.)17 USC Section 101. Defendants have Infringed Plaintiff's United States copyright

VII. NATURE OF SUIT (Place an X n one box only).OTHER STATUTES CONTRACT REAL PROPERTY CONT IMMIGRATION PRISONER PETITIONS PROPERTY RIGHTS

0 375 False Claims Act 0 11 o nsurance 0. 240Tortsto Land D 462 Naturalization Habeas Corpus: 181 820 Copyrightsp 245 Tort Product Application 0 463 Allen DetaineeD 400 State 0 120Marlne Liability 465 Other 0 510 Motions to Vacate 0 830PatentReapportionment D Immigration Actions0 130 Miller Act 290 All Other Real Sentence D 840 Trademark0 410 Antitrust 0 0 530 GeneralO 140 Negotiable SOCIAL SECURITYD 430 Banks and Banking Instrument 0 535 Death Penalty 0 861 HIA (1395fi}0 450 Commerce/ICC 150 Recovery of Other: D 862 Black Lung (923}ates/Etc. 0 540 Mandamus/OtherOverpayment &0 460 Deportation Enforcementof 315 Airplane D 371 Truth In Lending 0 550 Civil Rights D 863 DIWC/DIWW (405 (g))Judgment 00 470 Racketeer lnflu- Product Liability D 380 Other Personal 0 555 Prison Condition 0 864SSIDTitleXVIenced & Corrupt Org. 0 151 Medicare Act 0 320 Assault, Libel & Property DamageSlander i:J 385 Property Damage 560 Civil Detainee 0 865 RSI (405 (9)}0 480 Consumer Credit 152 Recovery of 330 Fed. Employers' 0 Conditions of0 490 Cable/SatTV 0 Defaulted Student 0 Liability Product Liability Confinement FEDERAL TAXSUITSLoan (Exd. Vet) BANKRUPTCY FORFEI U E ENALTY D 870 Taxes (U.s. Plaintiff or0 850 Securities/Com D 340Marlne D 422Appeal28 625 Drug Related Defendant)153 Recovery ofmodltles/Exchange . 0 Overpayment of 0 345 Marine Product usc 158 0 Seizure of Property 21 D 871IRSThlrd Party26 USCD 890 Other Statutory Vet. Benefits Liability 0 423 Wlthdrawai2B USC881 7609Actions D 350 Motor Vehicle USC1?7D 160 Stockholders'0 891 Agricultural Acts Suits 355 Motor Vehicle CIVIL RIGHTS 0 6900therD Product Liability 0 440 Other Civil Rights0 893 Environmental 0 190Dther 360 Other Personal LABORMatters C o n ~ c t D Injury 0 441 Voting 0 710 Fair Labor Standards0 895 Freedomoflnfo. O 195 Contract 362 Personal Injury- D 442 Employment ActAct Product Liability 0 Med Malpratlce D 720 Labor/Mgmt.0 896 Arbitration 365 Personal Injury- O 443 Housing/ Relations196 Franchise D ProductLiability Accomodations D 740 Railway laborActREAL PROPERTY

899 Admin. Procedures 210 Land 367 Health Care/ 445 American with [ j 751 Family and Medical0 Act/Review ofAppeal of 0 Condemnation O Pharmaceutical 0 Disabilities- leave ActAgency Decision Personal Injury Employment0 220 Foreclosure Product Liability O 446 American with O 790 Other Labor 0 950 Constitutionalityof 368 Asbestos Disabilities-Other LitigationState Statutes D 230Re 1\ rs Injury O 791 Employee Ret Inc, Security Act

AFTER COMPLETING PAGE 1OFFPRM CV-71, COMPLETE THE INFORMATION REQUESTED ON PAGE2.CV-71 (02/13) CNIL COVER SHEET Page 1of2

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UNITED STATES DISTRICT COURT, ~ E N T R A L DISTRICT OF CALIFORNIACIVIL COVER SHEET

VIJI(a). IDENTICAL CASES: Has this action been previously filed In this court and dismissed, remanded or dosed7 Jg] NOlfyes,listcase number(s):

VIII (b). RELATED CASES: Have any cases been previously filed ln this court that are related to the present case7 Jgj NOIf yes, Jist case number(s):

Civil cases are deemed related ifa previously filed case and the present case:(Check all boxes that apply) O A. Arise from the same or closelyrelated transactions, happenings, or events; or

0 B. Call for determination of the same or substantially related or similar questions of law and fact; or0 C. For other reasons would entail substantial duplication of labor If heard by different judges; or0 D. Involve the same patent, trademarkor copyright and one of he factors Identified above In a, b or c also is present

D .YES0 YES

IX. VENUE: (When completing the following Information, use an additional sheet If necessary.)(a) List the County In this District; California County outside of his District; State If other than California; or Foreign Country, In which EACH namedplaintiff resides,0 Check here If the government, Its agencies or employees Is a named plaintiff. Ifthis box Is checked, go to Item (b).County In this District:* California County outside of this District;State, Ifother than California; or ForeignCountrv .Los Angeles

(b) List the County In this District; California County outside of this District; State If other than California; or Foreign Country, In which EACH narneddefendant resides.0 Check here If the government, its agencies or employees is a named defendant. Ifthis box is checked,.go to item (c),County in this District:*los Angeles

California County outside ofthls District; State, Ifother than California; or ForeignCountrv

(c) List the County in this District; California County outside ofthls District; State If other than California; or Foreign Country, In whlch EACH claim arose,NOTE: In land condemnation cases, use the location of the tract of land involved.County in this District:* California County outside of his District; State, Ifother than California; or ForeignCountrvLos Angeles

" os Angeles, Orange, San Bernardino, Riverside, Ventura, Santa Barbara, or San Lu1s Obispo Count1esNote: In land condemnation cases use the location of the tract of land involvedX. SIGNATURE OF ATTORNEY (OR SELFREPRESENTED LITIGANT): DATE: ' " " M " " a ~ " " c h u . . 2 . . . , 7 " ' , 2..,0,_,_1,_3-----Notice to Counsel/Parties: The CV71 (JS-44) Civil Cover Sheet and the Information con a ned herein neither replace nor supplement the filing andservice of pleadings orother papers as required by law, This form, approved by the Judicial Conference of the United States In September 1!174, is required pursuant to Local Rule 31 Js not filedbut Is used by the Clerk of the Court for the purpose of statistics, venue and Initiating the civil docket sheet. (For more detailed lnstructlons,see separate instructions sheet).Key to Statistical codes relating to Social Security Cases:Nature of Suit Code Abbreviation Substantive Statement of Cause ofAction

861 HIA

B62 BL

863 DIWC863 DIWW

864 SSID865 RSI

CV-71 (02/13)

All claims for health insurance benefits (Medicare) underTitle 18, Part A, of the Social Security Act, as amended. Also,Include claims by hospitals,skilled nursing facilities, etc., for certification as providers ofservices under the program,(42 U.S.C. 1!135FF(b))All claims for "Black lung benefits underTitle 4, Part B, of the Federal Coal Mine Health and Safety Act of 196!1. (30 U.s.c,923)All claims filed by Insured workers for disability Insurance benefits under Title 2 of the Social Security Act, as amended; plusall claims filed for child's Insurance benefits based on disability. (42 U.S.C. 405 (g))All claims filed for widows or widowers lnsu ranee benefits based on disability underTitle 2 of theSocial Security Act, asamended. (42 U.S. C. 405 (g))All claims for supplemental security Income payments based upon disability flied underTitle 16 of the Social Security Act, asamended. - All claims for retirement (olq age) and survivors benefits underTitle 2 of he Social Security Act, as amended,(42 u.s.c, 405 (g)) .

CIVIL COVER SHEET Page 2 of2

Voom - Complaint

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