ANDRE I3IROTTEi JR. i -Unitedc States Attorney Central'DistiicfofCalifornia 

8 LEE WEIDMAN AUSA 

Chief Civil Division -

9 WENOYWEISS,AUSA 

Chief, Ch:il J:rauds Se9tion. 

10 Central District of CalIfornia 

California State Bar No: 181073 

11 Room 7516, Federal Building 300 North Los Angeles Street 

12 Los Angeles, CA 90012 Telephone: 894-0444 13 FacSImile: 13) 894-2380 E-mail: wen y.weiss@usdoj.gov 

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Attorneys for Plaintiff 

15 THE UNITED STATES OF AMERICA 

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UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

COMPLAINT FOR CIVIL 

PENALTIES, INJUNCTION 

22 AND OTHER RELIEF 23 SPOKEO, INC., 24 Defendant. 

25 26 Plaintiff, the United States of America, acting upon notification and 27 authorization to the Attorney General by the Federal Trade Commission 

28 ("FTC" or"Commission"), for its Complaint alleges that: 

Complaint Page 1 of 12 

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ANDRE I3IROTTEi JR. i -Unitedc States Attorney Central'DistiicfofCalifornia 

8 LEE WEIDMAN AUSA 

Chief Civil Division -

9 WENOYWEISS,AUSA 

Chief, Ch:il J:rauds Se9tion. 

10 Central District of CalIfornia 

California State Bar No: 181073 

11 Room 7516, Federal Building 300 North Los Angeles Street 

12 Los Angeles, CA 90012 

Telephone: 894-0444 13 FacSImile: 13) 894-2380 E-mail: wen y.weiss@usdoj.gov 

14 

Attorneys for Plaintiff 

15 THE UNITED STATES OF AMERICA 

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IN THE UNITED STATES DISTRICT COURT 

FOR THE CENTRAL DISTRICT OF CALIFORNIA 

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UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

COMPLAINT FOR CIVIL 

PENALTIES, INJUNCTION 

22 AND OTHER RELIEF 23 SPOKEO, INC., 24 Defendant. 

25 26 Plaintiff, the United States of America, acting upon notification and 27 authorization to the Attorney General by the Federal Trade Commission 

28 ("FTC" or"Commission"), for its Complaint alleges that: 

Complaint Page 1 of 12 

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§ 45(a), and the FCRA, 15 U.S.C. §§ 1681 

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1681x. 

JURISDICTION AND VENUE 

2. This Court has subject matter jurisdiction over this matter under 

28 U.S.C. §§ 1331, 1337(a), 1345, and 1355, and under 15 U.S.C. §§ 45(a), 

53(b), 56(a), and 1681s. 

3. Venue in the United States District Court for the Central District 

of Cali fomi a is proper under 15 U.S.C. § 53(b) and under 28 U.S.C. 

§§ 1391(b)-(c) and 1395(a). 

PLAINTIFF 

4. This action is brought by the United States of America on behalf 

of the Federal Trade Commission. The Commission is an independent agency 

of the United States government given statutory authority and responsibility by, 

inter alia, the FTC Act, as amended, 15 U.S.C. §§ 41-58, and the FCRA, 15 

U.S.C. §§ 1681-1681x. The Commission is charged, inter alia, with enforcing 

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), which prohibits unfair and 

deceptive acts or practices in or affecting commerce; and the FCRA, which 

imposes duties upon consumer reporting agencies. 

DEFENDANT 

5. Defendant Spokeo, Inc. ("Spokeo") is a privately-held Delaware 

C-type corporation doing business in California. Spokeo has its principal place 

of business at 199 South Los Robles Avenue, Suite 711, Pasadena, CA 9110l. 

Spokeo transacts or has transacted in this district and throughout the 

United States. 

Complaint Page 2 of 12 

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§ 45(a), and the FCRA, 15 U.S.C. §§ 1681 

,

1681x. 

JURISDICTION AND VENUE 

2. This Court has subject matter jurisdiction over this matter under 

28 U.S.C. §§ 1331, 1337(a), 1345, and 1355, and under 15 U.S.C. §§ 45(a), 

53(b), 56(a), and 1681s. 

3. Venue in the United States District Court for the Central District 

of Cali fomi a is proper under 15 U.S.C. § 53(b) and under 28 U.S.C. 

§§ 1391(b)-(c) and 1395(a). 

PLAINTIFF 

4. This action is brought by the United States of America on behalf 

of the Federal Trade Commission. The Commission is an independent agency 

of the United States government given statutory authority and responsibility by, 

inter alia, the FTC Act, as amended, 15 U.S.C. §§ 41-58, and the FCRA, 15 

U.S.C. §§ 1681-1681x. The Commission is charged, inter alia, with enforcing 

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), which prohibits unfair and 

deceptive acts or practices in or affecting commerce; and the FCRA, which 

imposes duties upon consumer reporting agencies. 

DEFENDANT 

5. Defendant Spokeo, Inc. ("Spokeo") is a privately-held Delaware 

C-type corporation doing business in California. Spokeo has its principal place 

of business at 199 South Los Robles Avenue, Suite 711, Pasadena, CA 9110l. 

Spokeo transacts or has transacted in this district and throughout the 

United States. 

Complaint Page 2 of 12 
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7. The FCRA was enacted in 1970, became effective on April 25, 

1971, and has: been in force since that date. 

8. Section 621 of the FCRA, 15 U.S.C. § 1681s, authorizes the 

Commission to use all of its functions and powers under the FTC Act to 

enforce compliance with the FCRA by all persons subject thereto except to the 

extent that enforcement specifically is committed to some other governmental 

agency, irrespective of whether the person is engaged in commerce or meets 

any other jurisdictional tests set forth by the FTC Act. 

VIOLATIONS OF THE FAIR CREDIT REPORTING ACT 

9. Spokeo assembles consumer information from "hundreds of online 

and offline sources," such as social networking sites, data brokers, and other 

sources to create consumer profiles, which Defendant promotes as "coherent 

people profiles" and "powerful intelligence." These consumer profiles identify 

specific individuals and display such information as the individual's physical 

address, phone number, marital status, age range, or email address, Spokeo 

profiles are further organized by descriptive headers denoting, among other 

22 things, a person's hobbies, ethnicity, religion, or participation on social 

23 networking sites, and may contain photos or other information, such as 

24 economic health graphics, that Spokeo attributes to a particular individual. 25 Among other things, Spokeo sells the profiles through paid subscriptions, 

26 which provide a set number of searches based on subscription level, as well as 27 through Application Program Interfaces ("API") that provide customized 

28 and/or higher volume access. 

Complaint Page 3 of 12 

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7. The FCRA was enacted in 1970, became effective on April 25, 

1971, and has: been in force since that date. 

8. Section 621 of the FCRA, 15 U.S.C. § 1681s, authorizes the 

Commission to use all of its functions and powers under the FTC Act to 

enforce compliance with the FCRA by all persons subject thereto except to the 

extent that enforcement specifically is committed to some other governmental 

agency, irrespective of whether the person is engaged in commerce or meets 

any other jurisdictional tests set forth by the FTC Act. 

VIOLATIONS OF THE FAIR CREDIT REPORTING ACT 

9. Spokeo assembles consumer information from "hundreds of online 

and offline sources," such as social networking sites, data brokers, and other 

sources to create consumer profiles, which Defendant promotes as "coherent 

people profiles" and "powerful intelligence." These consumer profiles identify 

specific individuals and display such information as the individual's physical 

address, phone number, marital status, age range, or email address, Spokeo 

profiles are further organized by descriptive headers denoting, among other 

22 things, a person's hobbies, ethnicity, religion, or participation on social 

23 networking sites, and may contain photos or other information, such as 

24 economic health graphics, that Spokeo attributes to a particular individual. 25 Among other things, Spokeo sells the profiles through paid subscriptions, 

26 which provide a set number of searches based on subscription level, as well as 27 through Application Program Interfaces ("API") that provide customized 

28 and/or higher volume access. 

Complaint Page 3 of 12 
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Complaint 

a. Spokeo entered into API user agreements with, and 

provided high access to, paying business customers, 

including entities operating in the human resources, 

background screening, and recruiting industries. 

q. In its marketing and advertising, the company has promoted 

. the use of its profiles as a factor in deciding whether to 

interview ajob candidate or whether to hire a candidate 

after ajob interview. Spokeo purchased thousands of online 

advertising keywords including terms targeting employment 

background checks, applicant.screening, and recruiting. 

Spokeo ran online advertisements with taglines to attract 

recruiters and encourage HR professionals to use Spokeo to 

obtain information about job candidates' online activities. 

c. Spokeo has affirmatively targeted companies operating in 

the human resources, background screening, and recruiting 

industries. It created a portion of its website intended 

specifically for recruiters, which was available through a 

dedicated click tab labeled "recruiters" that was prominently 

displayed at the top of the Spokeo home page. Recruiters 

were encouraged to "Explore Beyond the Resume." In 

addition, Defendant promoted the Spokeo.comlHR URL to 

recruiters in the media and in marketing to third parties, and 

offered special subscription plans for its HR customers. 

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Complaint 

a. Spokeo entered into API user agreements with, and 

provided high access to, paying business customers, 

including entities operating in the human resources, 

background screening, and recruiting industries. 

q. In its marketing and advertising, the company has promoted 

. the use of its profiles as a factor in deciding whether to 

interview ajob candidate or whether to hire a candidate 

after ajob interview. Spokeo purchased thousands of online 

advertising keywords including terms targeting employment 

background checks, applicant.screening, and recruiting. 

Spokeo ran online advertisements with taglines to attract 

recruiters and encourage HR professionals to use Spokeo to 

obtain information about job candidates' online activities. 

c. Spokeo has affirmatively targeted companies operating in 

the human resources, background screening, and recruiting 

industries. It created a portion of its website intended 

specifically for recruiters, which was available through a 

dedicated click tab labeled "recruiters" that was prominently 

displayed at the top of the Spokeo home page. Recruiters 

were encouraged to "Explore Beyond the Resume." In 

addition, Defendant promoted the Spokeo.comlHR URL to 

recruiters in the media and in marketing to third parties, and 

offered special subscription plans for its HR customers. 

Page 4 of 12 
6 Spokeo.comlHR page, or those who had previously purchased access to 

7 profiles thrQugh API user agreements., did notuse the CQmpJlny's website or 

-8 . information for FCRA-covered purposes. 

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12. The consumer profiles Spokeo provides to third parties are 

"consumer reports" as defined in section 603(d) of the FCRA, 15 U.S.C. 

§ 1681a(d): 

any written, oral, or other communication of any information by a consvmer rep' orting agel).cy 

on a consumer's credIt wortlimess, credIt standmg credit cap'acity, character, general reputation, personai characteristics, or mode of living which is used or expected to be used or collected in whole or in part for the purpose of serving as a factor in establishmg the consumer's eligibility for (A) credit or insurance to be used primarily for persona1, family, or household 

purposes; (B) e.mployment pU1]Joses; or (C) any other 

purpose authorIzed under sectIOn 604. 

Spokeo profiles are consumer reports because they bear on a consumer's 

character, general reputation, personal characteristics, or mode of living and/or 

other attributes listed in section 603( d), and are "used or expected to be used. 

.. in whole or in part" as a factor in determining the consumer's eligibility for 

employment or other purposes specified in section 604. 

13. In providing "consumer reports" Spokeo is now and has been a 

"consumer reporting agency" ("CRA") as that term is defined in section 603(t) 

of the FCRA, 15 U.S.C. § 1681a(t). That section defines a "consumer 

reporting agency" as 

Complaint 

any person which, for monetary fees, dues, or on coop,erativ!3 nonpr:ofit basis, regularly engap;es in whole· or m part III the practice of assemollng or 

Page 5 of 12 

6 Spokeo.comlHR page, or those who had previously purchased access to 

7 profiles thrQugh API user agreements., did notuse the CQmpJlny's website or 

-8 . information for FCRA-covered purposes. 

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12. The consumer profiles Spokeo provides to third parties are 

"consumer reports" as defined in section 603(d) of the FCRA, 15 U.S.C. 

§ 1681a(d): 

any written, oral, or other communication of any information by a consvmer rep' orting agel).cy 

on a consumer's credIt wortlimess, credIt standmg credit cap'acity, character, general reputation, personai characteristics, or mode of living which is used or expected to be used or collected in whole or in part for the purpose of serving as a factor in establishmg the consumer's eligibility for (A) credit or insurance to be used primarily for persona1, family, or household 

purposes; (B) e.mployment pU1]Joses; or (C) any other 

purpose authorIzed under sectIOn 604. 

Spokeo profiles are consumer reports because they bear on a consumer's 

character, general reputation, personal characteristics, or mode of living and/or 

other attributes listed in section 603( d), and are "used or expected to be used. 

.. in whole or in part" as a factor in determining the consumer's eligibility for 

employment or other purposes specified in section 604. 

13. In providing "consumer reports" Spokeo is now and has been a 

"consumer reporting agency" ("CRA") as that term is defined in section 603(t) 

of the FCRA, 15 U.S.C. § 1681a(t). That section defines a "consumer 

reporting agency" as 

Complaint 

any person which, for monetary fees, dues, or on coop,erativ!3 nonpr:ofit basis, regularly engap;es in whole· or m part III the practice of assemollng or 

Page 5 of 12 
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are "used or expected to be used" for "employment purposes." 

14. Se.ction 607(a) Qfthe FCRA, 15 U.S.C. § 1681e(a), requires CRAs 

to maintain reasonable procedures to limit the furnishing of consumer reports 

to the purposes specified in section 604, 15 U.S.C. § 1681b. These procedures 

require that the CRA, prior to furnishing a user with a consumer report, require 

the prospective usets of the information to identify themselves to the CRA, 

certify the purpose for which the information is sought, and certify that the 

information will be used for no other purpose. The CRA must make a 

reasonable effort to verify the identity of each new prospective user and the 

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uses certified prior to furnishing such user a consumer report. In addition, 

section 607(a) prohibits any CRA from furnishing a consumer report to any 

person it has reasonable grounds to believe will not use the consumer report for 20 

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a permissible purpose. Spokeo has failed to maintain any procedures required 

by section 607(a). 

15. .Section 607(b) of the FCRA, 15 U.S.C. § 1681e(b), requires all 

consumer reporting agencies.to follow reasonable procedures to assure 

maximum possible accuracy of consumer report information. Spokeo has 

failed to follow any reasonable procedures to maximum possible 

accuracy of the information in reports that it prepared as required by section 

607(b). 

Complaint Page 6 of 12 

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are "used or expected to be used" for "employment purposes." 

14. Se.ction 607(a) Qfthe FCRA, 15 U.S.C. § 1681e(a), requires CRAs 

to maintain reasonable procedures to limit the furnishing of consumer reports 

to the purposes specified in section 604, 15 U.S.C. § 1681b. These procedures 

require that the CRA, prior to furnishing a user with a consumer report, require 

the prospective usets of the information to identify themselves to the CRA, 

certify the purpose for which the information is sought, and certify that the 

information will be used for no other purpose. The CRA must make a 

reasonable effort to verify the identity of each new prospective user and the 

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uses certified prior to furnishing such user a consumer report. In addition, 

section 607(a) prohibits any CRA from furnishing a consumer report to any 

person it has reasonable grounds to believe will not use the consumer report for 20 

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a permissible purpose. Spokeo has failed to maintain any procedures required 

by section 607(a). 

15. .Section 607(b) of the FCRA, 15 U.S.C. § 1681e(b), requires all 

consumer reporting agencies.to follow reasonable procedures to assure 

maximum possible accuracy of consumer report information. Spokeo has 

failed to follow any reasonable procedures to maximum possible 

accuracy of the information in reports that it prepared as required by section 

607(b). 

Complaint Page 6 of 12 
6 forth in 16 CFR 698, Appendix H. The User Notice provides users of 

7 consumer reports with important information regarding their obligations under 

8 the FCRA, including the obligation of the user to provide a notice to consumers 

9 who are the subject of an adverse action (e.g., denial of employment) based in ) 

10 whole or in part on information contained in the consumer report. Spokeo has 

11 failed to provide the section 607 ( d) User Notice to those who purchase 

12 consumer reports. 

13 17. Section 604 of the FCRA, 15 U.S.C. § 1681b, prohibits CRAs 

14 from furnishing consumer reports to persons who the reporting 15 agency does not have reason to believe have a "permissible purpose." Section 

16 604(b), 15 U.S.C. § 1681b(b), includes employment purposes as a permissible 

17 purpose but prescribes certain conditions for furnishing and using consumer 18 reports for employment purposes. Spokeo regularly furnishes consumer reports 

19 to third parties without procedures to inquire into the purpose for which the 

20 user is buying the report. Spokeo has violated Section 604, 15 U.S.C. § 1681b, 

21 in furnishing consumer reports to persons that it did not have a reason to 

22 believe had a permissible purpose to obtain a consumer report. 23 COUNT 1 - VIOLATIONS OF SECTION 607(a) of the FCRA 

24 18. Section 607(a) of the FCRA, 15 U.S.C. § 1681e(a), requires that 

25 every consumer reporting agency maintain reasonable procedures to limit the 

26 furnishing of consumer reports for enumerated "permissible purposes." These 27 reasonable procedures include making reasonable efforts to verify the identity 

28 of each prospective user of consumer report information and the uses certified 

Complaint Page 7 of 12 

6 forth in 16 CFR 698, Appendix H. The User Notice provides users of 

7 consumer reports with important information regarding their obligations under 

8 the FCRA, including the obligation of the user to provide a notice to consumers 

9 who are the subject of an adverse action (e.g., denial of employment) based in ) 

10 whole or in part on information contained in the consumer report. Spokeo has 

11 failed to provide the section 607 ( d) User Notice to those who purchase 

12 consumer reports. 

13 17. Section 604 of the FCRA, 15 U.S.C. § 1681b, prohibits CRAs 

14 from furnishing consumer reports to persons who the reporting 15 agency does not have reason to believe have a "permissible purpose." Section 

16 604(b), 15 U.S.C. § 1681b(b), includes employment purposes as a permissible 

17 purpose but prescribes certain conditions for furnishing and using consumer 18 reports for employment purposes. Spokeo regularly furnishes consumer reports 

19 to third parties without procedures to inquire into the purpose for which the 

20 user is buying the report. Spokeo has violated Section 604, 15 U.S.C. § 1681b, 

21 in furnishing consumer reports to persons that it did not have a reason to 

22 believe had a permissible purpose to obtain a consumer report. 23 COUNT 1 - VIOLATIONS OF SECTION 607(a) of the FCRA 

24 18. Section 607(a) of the FCRA, 15 U.S.C. § 1681e(a), requires that 

25 every consumer reporting agency maintain reasonable procedures to limit the 

26 furnishing of consumer reports for enumerated "permissible purposes." These 27 reasonable procedures include making reasonable efforts to verify the identity 

28 of each prospective user of consumer report information and the uses certified 

Complaint Page 7 of 12 
6 for no other purpose. 

·7 20. By and through the a.cts and practices described in Paragraph 19 

8 above, Defendant has violated section 607(a) of the FCRA, 15 U.S.C. 

9 § 1681e(a). 

10 21. Pursuant to section 621(a)(1) of the FCRA, 15 U.S.C. 

11 § 1681 s( a)( 1), the acts and practices alleged in Paragraph 19 also constitute 

12 unfair or deceptive acts or practices in violation of section 5(a) of the FTC Act, 

13 15 U.S.C. § 45(a). 

14 COUNT 2 - VIOLATIONS OF SECTION 607(b) OF THE FCRA 

15 22. Section 607(b) of the FCRA, 15 U.S.C. § 16ale(b), requires 

16 consumer reporting agencies to follow reasonable procedures to assure 

17 maximum possible accuracy of the information concerning the individual about 18 whom the report relates. 

19 23. As described in Paragraph 15, Defendant has failed to use 

20 reasonable procedures to assure IDaximum possible accuracy of consumer 

21 report information. 

22 24. By and through the acts and practices described in Paragraph 23, 23 Defendant has violated section 607(b) of the FCRA, 15 U.S.C. § 1681e(b). 

24 25. Pursuant to section 621(a)(1) of the FCRA, 15 U.S.C. 

25 § 1681s(a)(1), the acts and practices alleged in Paragraph 23 also constitute 

26 unfair or deceptive acts. or practices in violation of section 5(a) of the FTC Act, 

27 15 U.S.C. § 45(a). 28 

Complaint Page 8 of 12 

6 for no other purpose. 

·7 20. By and through the a.cts and practices described in Paragraph 19 

8 above, Defendant has violated section 607(a) of the FCRA, 15 U.S.C. 

9 § 1681e(a). 

10 21. Pursuant to section 621(a)(1) of the FCRA, 15 U.S.C. 

11 § 1681 s( a)( 1), the acts and practices alleged in Paragraph 19 also constitute 

12 unfair or deceptive acts or practices in violation of section 5(a) of the FTC Act, 

13 15 U.S.C. § 45(a). 

14 COUNT 2 - VIOLATIONS OF SECTION 607(b) OF THE FCRA 

15 22. Section 607(b) of the FCRA, 15 U.S.C. § 16ale(b), requires 

16 consumer reporting agencies to follow reasonable procedures to assure 

17 maximum possible accuracy of the information concerning the individual about 18 whom the report relates. 

19 23. As described in Paragraph 15, Defendant has failed to use 

20 reasonable procedures to assure IDaximum possible accuracy of consumer 

21 report information. 

22 24. By and through the acts and practices described in Paragraph 23, 23 Defendant has violated section 607(b) of the FCRA, 15 U.S.C. § 1681e(b). 

24 25. Pursuant to section 621(a)(1) of the FCRA, 15 U.S.C. 

25 § 1681s(a)(1), the acts and practices alleged in Paragraph 23 also constitute 

26 unfair or deceptive acts. or practices in violation of section 5(a) of the FTC Act, 

27 15 U.S.C. § 45(a). 28 

Complaint Page 8 of 12 
6 User Notices to users and thereby has violated section 607(d) of the FCRA, 15 

7 U.S.C. § 1681e(d). 

8 28. By and through the acts and practices described in Paragraph 27 

9 above, Defendant has violated section 607(d) of the FCRA, 15 U.S.C. 

10 § 1681e(d). 

11 29. Pursuant to section 621(a)(l) of the FCRA, 15 U.S.C. 

12 § 1681s(a)(1), the acts and practices alleged in Paragraph 27 also constitute 

13 unfair or deceptive acts or practices in violation of section 5(a) of the FTC Act, 

14 15 U.S.C. § 45(a). 

15 COUNT 4 - VIOLATIONS OF SECTION 604 OF THE FCRA 

16 30. Section 604 of the FCRA, 15 U.S.C. § 1681b prohibits CRAs from 

17 furnishing consumer reports to persons that it did not have reason to believe 

18 had a permissible purpose to obtain a consumer report. 

19 31. As described in Paragraph 17, in multiple instances, Spokeo has 

20 furnished consumer reports to persons that it did not have reason to believe had 

21 a permissible purpose to obtain a consumer report. 

22 32. By and through the acts and practices described in Paragraph 31 23 above, Defendant has violated section 604 of the FCRA, 15 U.S.C. § 1681b. 

24 33. Pursuant to section 621(a)(1) of the FCRA, 15 U.S.C. 

25 § 1681 s( a)( 1 ), the acts and practices alleged in Paragraph 31 also constitute 

26 unfair or deceptive acts or practices in violation of section 5(a) of the FTC Act, 

27 15 U.S.C. § 45(a). 

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Complaint Page 9 of 12 

6 User Notices to users and thereby has violated section 607(d) of the FCRA, 15 

7 U.S.C. § 1681e(d). 

8 28. By and through the acts and practices described in Paragraph 27 

9 above, Defendant has violated section 607(d) of the FCRA, 15 U.S.C. 

10 § 1681e(d). 

11 29. Pursuant to section 621(a)(l) of the FCRA, 15 U.S.C. 

12 § 1681s(a)(1), the acts and practices alleged in Paragraph 27 also constitute 

13 unfair or deceptive acts or practices in violation of section 5(a) of the FTC Act, 

14 15 U.S.C. § 45(a). 

15 COUNT 4 - VIOLATIONS OF SECTION 604 OF THE FCRA 

16 30. Section 604 of the FCRA, 15 U.S.C. § 1681b prohibits CRAs from 

17 furnishing consumer reports to persons that it did not have reason to believe 

18 had a permissible purpose to obtain a consumer report. 

19 31. As described in Paragraph 17, in multiple instances, Spokeo has 

20 furnished consumer reports to persons that it did not have reason to believe had 

21 a permissible purpose to obtain a consumer report. 

22 32. By and through the acts and practices described in Paragraph 31 23 above, Defendant has violated section 604 of the FCRA, 15 U.S.C. § 1681b. 

24 33. Pursuant to section 621(a)(1) of the FCRA, 15 U.S.C. 

25 § 1681 s( a)( 1 ), the acts and practices alleged in Paragraph 31 also constitute 

26 unfair or deceptive acts or practices in violation of section 5(a) of the FTC Act, 

27 15 U.S.C. § 45(a). 

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Complaint Page 9 of 12 
6 endorsing Spokeo to be posted on news and technology websites. These 

7 comments were reviewed' and edited by Spokeo managers and then posted 

8" using account names, provided by Spokeo; that would give the readers of these 

9 . comments the impression they had been submitted by independent, ordinary 

10 consumers or business users of Spokeo. 

11 COUNT 5 - ENDORSEMENTS 

12 36. As described in Paragraph 35, Defendant has represented, 

13 expressly or by implication, that its comments about Spokeo were independent 

14 comments reflecting the views of ordinary consumers or business users of 

15 Spokeo. 

16 37. In truth and in fact, the comments about Spokeo were not 

17 independent comments reflecting the views of ordinary consumers or business 

18 users ofSpokeo. The comments were created by employees and managers of 

19 Spokeo in response to news articles or reviews of Spokeo. Therefore, the 

20 representations set forth in Paragraph 36 were, and are, false and misleading. 

21 38. The acts and practices alleged in Paragraphs 35-37 constitute 22 unfair or deceptive acts or practices in or affecting commerce in violation of 

23 Section 5(a) of the Federal Trade Commission Act, 15 U.S.C. § 45(a). 

24 THIS COURT'S POWER TO GRANT RELIEF 

25 39. Section 621(a)(2)(A) of the FCRA; 15 U.S.C. § 1681s(a)(2)(A), 

26 authorizes the Court to award monetary civil penalties in the event of a 

27 knowing violation of the FCRA, which constitutes a pattern or practice. 

28 Spokeo' s violations of the FCRA, as alleged in this Complaint, have been 

Complaint Page 10 of 12 

6 endorsing Spokeo to be posted on news and technology websites. These 

7 comments were reviewed' and edited by Spokeo managers and then posted 

8" using account names, provided by Spokeo; that would give the readers of these 

9 . comments the impression they had been submitted by independent, ordinary 

10 consumers or business users of Spokeo. 

11 COUNT 5 - ENDORSEMENTS 

12 36. As described in Paragraph 35, Defendant has represented, 

13 expressly or by implication, that its comments about Spokeo were independent 

14 comments reflecting the views of ordinary consumers or business users of 

15 Spokeo. 

16 37. In truth and in fact, the comments about Spokeo were not 

17 independent comments reflecting the views of ordinary consumers or business 

18 users ofSpokeo. The comments were created by employees and managers of 

19 Spokeo in response to news articles or reviews of Spokeo. Therefore, the 

20 representations set forth in Paragraph 36 were, and are, false and misleading. 

21 38. The acts and practices alleged in Paragraphs 35-37 constitute 22 unfair or deceptive acts or practices in or affecting commerce in violation of 

23 Section 5(a) of the Federal Trade Commission Act, 15 U.S.C. § 45(a). 

24 THIS COURT'S POWER TO GRANT RELIEF 

25 39. Section 621(a)(2)(A) of the FCRA; 15 U.S.C. § 1681s(a)(2)(A), 

26 authorizes the Court to award monetary civil penalties in the event of a 

27 knowing violation of the FCRA, which constitutes a pattern or practice. 

28 Spokeo' s violations of the FCRA, as alleged in this Complaint, have been 

Complaint Page 10 of 12 
6 February 10,2009, and $3,500 per violation for violations occurring on or after 

1 . that date. 

8 40. Each instance in which Spokeo has failed to comply with the 

9 FCRA constitutes a separate violation of the FCRA for the purpose of 

10 assessing monetary civil penalties under section 621 of the FCRA, 15 U.S.C. 

11 § 1681 s. Plaintiff seeks monetary civil penalties for every separate violation of 

12 the FCRA. 

13 41. Under section 621(a) of the FCRA, 15 U.S.C. § 1681s(a), and 

14 section 13(b) of the' FTC Act, 15 U.S.C. § 53(b), this Court is authorized to 

15 issue a permanent injunction prohibiting Defendant from violating the FTC Act 

16 and the FCRA. 

17 PRAYER FOR RELIEF 

18 WHEREFORE, Plaintiff requests that this Court, pursuant to 15 U.S.C. 

19 §§ 45(a)(1), 45(m)(1)(A), 53(b), 1681s, and 1691c, and pursuant to the Court's 

20 own equitable powers: 

21 (1) Enter judgment against Defendant and in favor of Plaintiff for each 

22 violation alleged in this Complaint; 

23 (2) Enter a permanent injunction to prevent future violations of the 

24 FCRA and the FTC Act by Defendant; 

25 (3) Award Plaintiff monetary civil penalties from Defendant for each 

26 violation of the FCRA alleged in this Complaint; and 

27 (4) Award Plaintiff the costs of bringing this action, as well as such other 

28 and additional relief as the Court may determine to be just and proper.The parties, 

Complaint Page 11 of 12 

6 February 10,2009, and $3,500 per violation for violations occurring on or after 

1 . that date. 

8 40. Each instance in which Spokeo has failed to comply with the 

9 FCRA constitutes a separate violation of the FCRA for the purpose of 

10 assessing monetary civil penalties under section 621 of the FCRA, 15 U.S.C. 

11 § 1681 s. Plaintiff seeks monetary civil penalties for every separate violation of 

12 the FCRA. 

13 41. Under section 621(a) of the FCRA, 15 U.S.C. § 1681s(a), and 

14 section 13(b) of the' FTC Act, 15 U.S.C. § 53(b), this Court is authorized to 

15 issue a permanent injunction prohibiting Defendant from violating the FTC Act 

16 and the FCRA. 

17 PRAYER FOR RELIEF 

18 WHEREFORE, Plaintiff requests that this Court, pursuant to 15 U.S.C. 

19 §§ 45(a)(1), 45(m)(1)(A), 53(b), 1681s, and 1691c, and pursuant to the Court's 

20 own equitable powers: 

21 (1) Enter judgment against Defendant and in favor of Plaintiff for each 

22 violation alleged in this Complaint; 

23 (2) Enter a permanent injunction to prevent future violations of the 

24 FCRA and the FTC Act by Defendant; 

25 (3) Award Plaintiff monetary civil penalties from Defendant for each 

26 violation of the FCRA alleged in this Complaint; and 

27 (4) Award Plaintiff the costs of bringing this action, as well as such other 

28 and additional relief as the Court may determine to be just and proper.The parties, 

Complaint Page 11 of 12 
7 

8 

9 

10 

11 

12 

13 

14 

15 

16 17 

18 

19 

20 21 

22 

23 24 25 26 27 

28' 

:w D.C. 2.0580 

3 .. 6-2 _75,fvOlce) 202.326-3062 fax) 

, 

JAMIEHINE 

Attorney Federal Trade Commission 

600 Pennsylvania Avenue, NW Washinijton,. D.C. 20580 

3 6-2188 fvoice) 202 326-3062 fax) 

KATHERINE ARMSTRONG 

Attorney Federal Trade Commission 

600 Pennsylvania Avenue, NW D.C. 20580 

36-3 50 fvoice) 202 326-3062 fax) 

DEPARTMENT OF JUSTICE 

ANDRE BIROTTE, JR. Un1ted States Attorney' ' Central District of California 

ChIef, Clvll DIvisIOn 

Trial Attorney Consumer Protection Branch 

U.S. DeRartment of Justice 

POBox386 ' 

Washington, DC 20044-0386 Telephone: 202-307-6154 alan. phelps@usdoj .gov 

Complaint Page 12 of 12 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 17 

18 

19 

20 21 

22 

23 24 25 26 27 

28' 

:w D.C. 2.0580 

3 .. 6-2 _75,fvOlce) 202.326-3062 fax) 

, 

JAMIEHINE 

Attorney Federal Trade Commission 

600 Pennsylvania Avenue, NW Washinijton,. D.C. 20580 

3 6-2188 fvoice) 202 326-3062 fax) 

KATHERINE ARMSTRONG 

Attorney Federal Trade Commission 

600 Pennsylvania Avenue, NW D.C. 20580 

36-3 50 fvoice) 202 326-3062 fax) 

DEPARTMENT OF JUSTICE 

ANDRE BIROTTE, JR. Un1ted States Attorney' ' Central District of California 

ChIef, Clvll DIvisIOn 

Chief, Civil Frauds Section 

Central District of California 

California State Bar No. 181073 

Room 7516, Federal Building 300 North Los Angeles Streel Los Angeles, CA 90012 TelepJ:lOne: (213) .894-0444. E-mall: wendy.welss@usdoJ.gov 

MAAME EWUSI-MENSAHFRIMPON 

Acting Deputy Assistant Attorney Gener I 

MICHAEL S. BLUME 

Director 

Consumer Protection Branch 

Trial Attorney Consumer Protection Branch 

U.S. DeRartment of Justice 

POBox386 ' 

Washington, DC 20044-0386 Telephone: 202-307-6154 alan. phelps@usdoj .gov 

Complaint Page 12 of 12 
discovery Magistrate Judge is Stephen J. Hillman. 

The case number on all documents filed with the Court should read as follows: 

CV12- 5001 MMM (SHx) 

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 related 

motions. 

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

NOTICE TO COUNSEL 

A copy of this notice must be served with the summons and complaint on all defendants (if a removal action is 

filed, a copy of this notice must be served on all plaintiffs). 

Subsequent documents must be filed at the following location: 

[X] Western Division 

312 N. Spring St., Rm. G-8 

Los Angeles, CA 90012 

U Southern Division U 

411 West Fourth St., Rm. 1-053 

Santa Ana, CA 92701-4516 

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

Eastern Division 

3470 Twelfth St., Rm. 134 

Riverside, CA 92501 

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

discovery Magistrate Judge is Stephen J. Hillman. 

The case number on all documents filed with the Court should read as follows: 

CV12- 5001 MMM (SHx) 

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 related 

motions. 

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

NOTICE TO COUNSEL 

A copy of this notice must be served with the summons and complaint on all defendants (if a removal action is 

filed, a copy of this notice must be served on all plaintiffs). 

Subsequent documents must be filed at the following location: 

[X] Western Division 

312 N. Spring St., Rm. G-8 

Los Angeles, CA 90012 

U Southern Division U 

411 West Fourth St., Rm. 1-053 

Santa Ana, CA 92701-4516 

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

Eastern Division 

3470 Twelfth St., Rm. 134 

Riverside, CA 92501 

CV-18 (03/06) NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY 
PLAINTIFF(S) 5001 

v. 

SPOKEO, INC., 

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 attached li complaint 0 amended complaint 

o counterclaim D cross-claim or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer 

or motion must be served on the plaintiffs attorney, ANDRE BIROTTE JR., US Attorney , whose address is 

300 North Los Angeles St., Room 7516, Los Angeles, CA 90012 . If you fail to do so, 

judgment by default will be entered against you for the relief demanded in the complaint. You also must file 

your answer or motion with the court. 

JUN - 7 2012 

Clerk, U.S. District Court 

Dated: ___________ _ JULIE PRAD By: ______________ 

Deputy Clerk 

(Seal of the Court) nS4 

[Use 60 days if the defendant is the United States or a United States agency, or is an officer or employee of the United States. Allowed 

60 days by Rule 12(a)(3)]. . 

CV-OIA (10/11 SUMMONS 

PLAINTIFF(S) 5001 

v. 

SPOKEO, INC., 

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 attached li complaint 0 amended complaint 

o counterclaim D cross-claim or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer 

or motion must be served on the plaintiffs attorney, ANDRE BIROTTE JR., US Attorney , whose address is 

300 North Los Angeles St., Room 7516, Los Angeles, CA 90012 . If you fail to do so, 

judgment by default will be entered against you for the relief demanded in the complaint. You also must file 

your answer or motion with the court. 

JUN - 7 2012 

Clerk, U.S. District Court 

Dated: ___________ _ JULIE PRAD By: ______________ 

Deputy Clerk 

(Seal of the Court) nS4 

[Use 60 days if the defendant is the United States or a United States agency, or is an officer or employee of the United States. Allowed 

60 days by Rule 12(a)(3)]. . 

CV-OIA (10/11 SUMMONS 
II. BASIS OF JUR,ISDICTION (Place an X in one box only.) 

III. CITIZENSHIP OF PRINCIPAL PARTIES - For Diversity Cases Only 

(Place an X in one box for plllintiffanq ons for defendant.) .. 

'I U.S. Government Plaintiff 03 Federal Question (U.S. ;' PTt DEF ". ........ . PTF DEF 

Government Not a Party) Citizen of This State \'r 0 OJ 0 I mcorporated or Principal Place 0 4 0 4 

.. ' "of.Business in this State 

o 2 U.S. Government Defendant 0 4 Diversity (Indicate Citizenship Citizen of Another State 

of Parties in Item III) 

o .r}, 0 2 . Incqrporated and Principal Place 0 5 0 5 

of Business in Another State 

Citizen or Subject ofa Foreign Country 0) 03 ForeigiiNation 

IV. ORIGIN (Place an X in one box only.) 

ti'l Original 

Proceeding 

o 2 Removed from 0 3 Remanded from 0 4 Reinstated or 

State Court Appellate Court Reopened 

1- , 

o 5 Transferred from another d;str.i,c} 0 6 Multi-

.. v: ,,", .- .... ',c', . , " .oi.strict 

. '. Litigation" 

V. REQUESTED IN COMPLAINT: JURY DEMAND: 0 Yes IiNo (Check 'Yes' only if demanded in complaint.) 

CLASS ACTION under F.R.C.P. 23: 0 Yes liNo o MONEY DEMANDED IN COMPLAINT: $ 

06 06 

o 7 A:ppeal to District 

Judge from 

Judge 

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.) 

Action for civil penalties and injunctive relief under the Fair Credit Reporting Act, 15 USC 1681 et seq.; and the Federal Trade Commission Act, 15 U,S.c. 45 

VII. NATURE OF SUIT (Place an X in one box only.) 

o 400 State Reapportionment Insurance Labor Standards o 410 Antitrust Marine Airplane Act 

0430 Banks and Banking Miller Act Airplane Product Vacate Sentence LaborfMgrnt. 

o 450 Commerce/ICC Negotiable Instrument Liability Habeas Corpus Relations 

Rates/etc. Recovery of Assault, Libel & General LaborfMgmt. 

0460 Deportation Overpayment & Slander Death Penalty Reporting & 

0470 Racketeer Influenced Enforcement of Fed. Employers' Mandamus/ Disclosure Act 

and Corrupt Judgment Liability Other Railway Labor Act. 

Organizations Medicare Act Marine Civil Rights Other Labor Marine Product 0480 Consumer Credit Recovery of Defaulted Liability Prison Condition Litigation 0490 Cable/Sat TV Student Loan (Excl. Motor Vehicle Empl. Ret. Inc. 

0810 Selective Service Veterans) Motor Vehicle 0850 Securities/Commodities/ Recovery of Product Liability Agriculture Exchange Overpayment of Other Personal Other Food & 

0875 Customer Challenge 12 Veteran's Benefits Injury Voting Drug 

M890 

USC 3410 Stockholders' Suits Personal Injury- Employment Drug Related 

Other Statutory Actions Other Contract Med Malpractice Housing/Acco- Seizure of , 'I': 

0891 Agricultural Act Personal Injury- mmodations Property 21 USC 

0892 Economic Stabilization Product Liability Welfare 881 

Act Asbestos Personal American with Liquor Laws 

0893 Environmental Matters Injury Product Disabil ities - R.R. & Truck 0894 Energy Allocation Act Liabil Employment Airline Regs 0895 Freedom oflnfo. Act Foreclosure American with Occupational 0900 Appeal of Fee Determi- Rent Lease & Ejectment Disabil ities - Safety !Health ',> 

nation Under Equal Torts to Land Application Other Other Taxes (U.S. Plaintiff Access to Justice Tort Product Liability 0463 Habeas Corpus- Other Civil or Defendant) 

0950 Constitutionality of All Other Real Property Alien Detainee Rights 0871 IRS-Third Party 26 . 

State Statutes 0465 Other Immigration USC 7609 

Actions 

FOR OFFICE USE ONLY: Case Number: ___________________________ _ 

AFTER COMPLETING THE FRONT SIDE OF FORM CV-71, COMPLETE THE INFORMATION REQUESTED BELOW. 

CV-71 (05/08) CIVIL COVER SHEET Page I 0{2 

II. BASIS OF JUR,ISDICTION (Place an X in one box only.) 

'I U.S. Government Plaintiff 03 Federal Question (U.S. 

Government Not a Party) 

III. CITIZENSHIP OF PRINCIPAL PARTIES - For Diversity Cases Only 

(Place an X in one box for plllintiffanq ons for defendant.) .. 

Citizen of This State 

;' PTt DEF ". ........ . PTF DEF 

\'r 0 OJ 0 I mcorporated or Principal Place 0 4 0 4 

.. ' "of.Business in this State 

o 2 U.S. Government Defendant 0 4 Diversity (Indicate Citizenship Citizen of Another State o .r}, 0 2 . Incqrporated and Principal Place 0 5 0 5 

of Parties in Item III) of Business in Another State 

Citizen or Subject ofa Foreign Country 0) 03 ForeigiiNation 

IV. ORIGIN (Place an X in one box only.) 

o 2 Removed from 0 3 Remanded from 0 4 Reinstated or 

1- , 

o 5 Transferred from another d;str.i,c} 0 6 Multi-

.. v: ,,", .- .... ',c', . , " .oi.strict 

06 06 

ti'l Original 

Proceeding State Court Appellate Court Reopened 

. '. Litigation" 

o 7 A:ppeal to District 

Judge from 

Judge 

V. REQUESTED IN COMPLAINT: JURY DEMAND: 0 Yes IiNo (Check 'Yes' only if demanded in complaint.) 

CLASS ACTION under F.R.C.P. 23: 0 Yes liNo o MONEY DEMANDED IN COMPLAINT: $ 

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.) 

Action for civil penalties and injunctive relief under the Fair Credit Reporting Act, 15 USC 1681 et seq.; and the Federal Trade Commission Act, 15 U,S.c. 45 

VII. NATURE OF SUIT (Place an X in one box only.) 

o 400 State Reapportionment 110 Insurance Labor Standards o 410 Antitrust 0120 Marine Airplane Act 

0430 Banks and Banking 0130 Miller Act Airplane Product Vacate Sentence LaborfMgrnt. 

o 450 Commerce/ICC 0140 Negotiable Instrument Liability Habeas Corpus Relations 

Rates/etc. 0150 Recovery of Assault, Libel & General LaborfMgmt. 

0460 Deportation Overpayment & Slander Death Penalty Reporting & 

0470 Racketeer Influenced Enforcement of 0330 Fed. Employers' Mandamus/ Disclosure Act 

and Corrupt Judgment Liability Other Railway Labor Act. Organizations Medicare Act 0340 Marine Civil Rights Other Labor 

0480 Consumer Credit Recovery of Defaulted 0345 Marine Product Prison Litigation 

0490 Cable/Sat TV Student Loan (Excl. Liability Empl. Ret. Inc. 0350 Motor Vehicle 0810 Selective Service Veterans) 355 Motor Vehicle Act 0850 Securities/Commodities/ Recovery of Product Liability Agriculture Exchange Overpayment of 360 Other Personal Other Food & 

0875 Customer Challenge 12 Veteran's Benefits Injury Voting Drug 

M890 

USC 3410 Stockholders' Suits 362 Personal Injury- Employment Drug Related 

Other Statutory Actions Other Contract Med Malpractice Housing/Acco- Seizure of > •• ' " 

0891 Agricultural Act Contract Product 365 Personal Injury- mmodations Property 21 USC 861 HIA (I 395ff) 

0892 Economic Stabilization Liability Product Liability Welfare 881 862 Black Lung (923) 

Act Franchise 0368 Asbestos Personal American with Liquor Laws 863 DI'NCIDIWW 

0893 Environmental Matters Injury Product Disabil ities - R.R. & Truck (405(g» 0894 Energy Allocation Act Land Condemnation Employment Airline Regs SS ID Title XVI 0895 Freedom oflnfo. Act Foreclosure American with Occupational 0900 Appeal of Fee Determi- Rent Lease & Ejectment Disabil ities - Safety !Health 

nation Under Equal Torts to Land Other Other Taxes (U.S. Plaintiff 

Access to Justice Tort Product Liability 0463 Other Civil or Defendant) 

0950 Constitutionality of All Other Real Property Rights IRS-Third Party 26 . 

State Statutes 465 USC 7609 

FOR OFFICE USE ONLY: Case Number: ___________________________ _ 

AFTER COMPLETING THE FRONT SIDE OF FORM CV-71, COMPLETE THE INFORMATION REQUESTED BELOW. 

CV-71 (05/08) CIVIL COVER SHEET Page I 0{2 
IX. VENUE: (When completing the following information, use an additional sheet if necessary.) 

(a} List the County in this District; California County outside ofthis District; State if other than California; or Foreign Country, in which EACH named plaintiff resides. 

Check here if the government, its agencies or employees is a named plaintiff. If this box is checked, go to item (b). 

County in this District: * California County outside of this District; State, if other than California; or Foreign Country 

(b) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named defendant resides. 

0 Check here if the government, its agencies or employees is a named defendant. If this box is checked, go to item (c). 

County in this District: * California County outside of this District; State, if other than California; or Foreign Country 

Los Angeles County 

(c) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which 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 this District; State, if other than California; or Foreign Country 

Los Angeles County 

* Los Angeles, Orange, San Bernardino, Riverside, Ventura, Santa Barbara, or San Luis Obis·po Counties 

Note: In land condemnation cases, use the location of the tract of land involved 

X. SIGNATURE OF ATTORNEY (OR PRO PER): Date ---1-"/ ....... 1-+-/''--2..-- _______ _ 

Notice to CounseVPariies: The CV -71 (JS-44) Civil Cover Sheet and the information contained herein neither replace nor supplement the filing and service of pleadings 

or other papers as required by law. This form, approved by the Judicial Conference of the United States in September 1974, is required pursuant to Local Rule 3-1 is not filed 

but is used by the Clerk ofthe Court for the purpose of statistics, venue and initiating the civil docket sheet. (For more detailed instructions, see separate instructions sheet.) 

Key to Statistical codes relating to Social Security Cases: 

Nature of Suit Code Abbreviation 

861 HIA 

862 BL 863 DIWC 

863 DIWW 864 SSID 865 RSI 

CV-71 (05/08) 

Substantive Statement of Cause of Action 

All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended. 

Also, includ.e claims by hospitals, nursing facilitieS, etc., for certification as providers of services under the 

program. (42 U.S.C. 1935FF(b» 

All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969. 

(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; plus all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405(g» 

All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security 

Act, as amended. (42 U.S.c. 405(g» 

, ... -t 

All claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security 

Act, as amended. 

All claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended. (42 

U.S.C. (g» 

CIVIL COVER SHEET Page 2 of2 

IX. VENUE: (When completing the following information, use an additional sheet if necessary.) 

(a} List the County in this District; California County outside ofthis District; State if other than California; or Foreign Country, in which EACH named plaintiff resides. 

Check here if the government, its agencies or employees is a named plaintiff. If this box is checked, go to item (b). 

County in this District: * California County outside of this District; State, if other than California; or Foreign Country 

(b) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named defendant resides. 

0 Check here if the government, its agencies or employees is a named defendant. If this box is checked, go to item (c). 

County in this District: * California County outside of this District; State, if other than California; or Foreign Country 

Los Angeles County 

(c) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which 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 this District; State, if other than California; or Foreign Country 

Los Angeles County 

* Los Angeles, Orange, San Bernardino, Riverside, Ventura, Santa Barbara, or San Luis Obis·po Counties 

Note: In land condemnation cases, use the location of the tract of land involved 

X. SIGNATURE OF ATTORNEY (OR PRO PER): Date ---1-"/ ....... 1-+-/''--2..-- _______ _ 

Notice to CounseVPariies: The CV -71 (JS-44) Civil Cover Sheet and the information contained herein neither replace nor supplement the filing and service of pleadings 

or other papers as required by law. This form, approved by the Judicial Conference of the United States in September 1974, is required pursuant to Local Rule 3-1 is not filed 

but is used by the Clerk ofthe Court for the purpose of statistics, venue and initiating the civil docket sheet. (For more detailed instructions, see separate instructions sheet.) 

Key to Statistical codes relating to Social Security Cases: 

Nature of Suit Code Abbreviation 

861 HIA 

862 BL 863 DIWC 

863 DIWW 864 SSID 865 RSI 

CV-71 (05/08) 

Substantive Statement of Cause of Action 

All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended. 

Also, includ.e claims by hospitals, nursing facilitieS, etc., for certification as providers of services under the 

program. (42 U.S.C. 1935FF(b» 

All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969. 

(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; plus all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405(g» 

All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security 

Act, as amended. (42 U.S.c. 405(g» 

, ... -t 

All claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security 

Act, as amended. 

All claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended. (42 

U.S.C. (g» 

CIVIL COVER SHEET Page 2 of2