Imber-Gluck v. Google Inc.

Filing 1

COMPLAINT against All Defendants ( Filing fee $ 400, receipt number 0971-8433433.). Filed byIlana Imber-Gluck. (Attachments: # 1 Exhibit A to Complaint, # 2 Exhibit B to Complaint, # 3 Civil Case Cover Sheet, # 4 Attachment to Civil Case Cover Sheet)(Patterson, James) (Filed on 3/7/2014)

EXHIBIT "B"

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PATTERSON LAW GROUP
James R. Patterson (CA 211102)
402 West Broadway, 29th Floor
San Diego, California 92101
Telephone: [phone]
Facsimile: 619.756.6991
[e-mail]

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CARPENTER LAW GROUP
Todd D. Carpenter (CA 234464)
8 402 West Broadway, 29th Floor
San Diego, California 92101
9 Telephone: [phone]
10 Facsimile: 619.756.6991
[e-mail]
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Attorneys for Plaintiffs

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[Additional Counsel]

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHEN DISTRICT OF CALIFORNIA

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ILANA IMBER-GLUCK, On Behalf of
Herself and All Others Similarly Situated,

DECLARATION OF TODD D.
CARPENTER IN SUPPORT OF
JURISDICTION

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Plaintiff,

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Case No.

vs.
GOOGLE, INC., a Delaware Corporation.

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Defendants.

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Case No.
DECLARATION OF TODD D. CARPENTER

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I, TODD D. CARPENTER, declare as follows:
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I am an attorney duly licensed to practice before all of the courts of the State

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of California. I am the principle and owner of the Carpenter Law Group and the counsel

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of record for Plaintiff in the above-entitled action

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2.

Defendant Google, Inc. (“Google”) has done and is doing business in the

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Northern District of California. Such business includes the marketing, distributing, and

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sale of its applications and in-application-related purchases.

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3.

Google also owns property in California, and its principal place of business is

located at 1600 Amphitheatre Parkway, Mountain View, California 94043, which is in the
Northern District of California.
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Furthermore, Google’s Terms and Conditions state that “[a]ll claims arising

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out of or relating to these terms or the Services will be litigated exclusively in the federal

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or state courts of Santa Clara County, California, USA, and you and Google consent to

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personal jurisdiction in those courts.”

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5.

Finally, California, and the Northern District of California in particular, is the

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location from which Google’s alleged misconduct emanated. This conduct similarly

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injured and affected Plaintiff and all other Class members.

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I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.

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Executed this 6th Day of March, 2014, in San Diego, California.

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/s/ Todd D. Carpenter
Todd D. Carpenter

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Case No.

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DECLARATION OF TODD D. CARPENTER