1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

Home , Dollar Rent A Car, Turo (company)

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prts website a operates I cars. of fleet a rent or own not does it because company car platform to share their personal cars. As California law makes 1 TURO INC. Attorneys forPlaintiff (415)693-2222 Facsimile: Telephone: (415 San Francisco,CA94111-5800 101 CaliforniaStreet,5thFloor ([email protected]) MAX A.BERNSTEIN(305722) ([email protected]) BETHANY C.LOBO(248109) ([email protected]) BENJAMIN H.KLEINE(257225) ([email protected]) MATTHEW D.BROWN(196972) ([email protected]) MICHAEL G.RHODES(116127) COOLEY LLP CITY OFLOSANGELES, INC., TURO

Turo’swebsitecanbe f

Case 2:18-cv-06055Document1Filed07/12/18Pageof28ID#:1 1. Plaintiff TuroInc.(“Tur v.

uo s sfwr cmay ht rvds t cmuiy f users of community its provides that company software a is Turo Defendant. Plaintiff, ) 693-2000 1 n mbl-eie p pafr truh hc ues nae in engage users which through platform app mobile-device and ound athttps://turo.com/. CENTRAL DISTRICT OFCALIFORNIA CENTRAL DISTRICT UNITED STATESDISTRICTCOURT P o”) allegesasfollows: RELIMINARY RELIMINARY WESTERN DIVISION WESTERN DIVISION 1.

DEMAND O D C Case No.2:18-cv-6055 S TATEMENT ECLARATORY OF OMPLAINT THER C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT R ELIEF

FOR

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clear, Turo is not a rental rental a not is Turo clear, JURY O AND UDGMENT URO URO URO THER n stark contrast, Turo contrast, stark n I NC I R NC

. ELIEF TRIAL TRIAL FOR FOR

. FOR FOR D ;

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Users, and more than 10,000 Calif Code §§48.175.00 clarify to sharing. car such with connection and sharing car peer-to-peer promote to laws similar M and Washington, Oregon, alone: not is California 11580.24. § and websiteoperator,not an LAX rental car company permit. This makes no sense as Turo assert City the exchanges, User these of Because “City”). (the Los Angeles International Airpor on Turo. sharing lineofbusiness ist Howeve year. coming the in verticals additional offer to plans availability, price, and options f options and price, availability, 2 of Turo’s personal vehicle sharing program rent from distinct entity, of kind new “per a as program[s]” sharing recognize to Code Insurance the amending by model economy” privately-owned carswithas acces them gives it because Turo love turn, in Guests, source. tur retirees, to students from owners, helps car Turo use. car mutually-agreed time andplace. search listings, select and book a car, and arrange with the ca th list Owners follows: as works personal

Turohasotherofferings beyond

Case 2:18-cv-06055Document1Filed07/12/18Page2of28ID#:2 4. 5. 3. 2.

vehicle sharing. Thatis, Turo allows users to connect with e Californians love Turo. Hundreds Turo. love Californians Some Users coordinate through Turo h Clfri lgsaue a ebae ti invtv “sharin innovative this embraced has legislature California The benefitted has technology Turo’s 5-48.175.900; S.B.743,2018Reg.Sess.(Md.2 a rental car company. arentalcarcompany. he subjectofthislawsuit. uperior userexperience. uperior or pickup. Users seeking a c a seeking Users pickup. or t (“LAX”), which is owned by th ornia car owners have listed t providing apersonalvehicles See i piaeyond as n Tur on cars privately-owned eir Or. Rev. Stat. §§ 742.585-742.600; Wash. Rev. Wash. 742.585-742.600; §§ Stat. Rev. Or. 2. 2 are called “Users” he the public by revolutionizing by public the of thousands of Californians of thousands of C ’s platform to exchange cars J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT r’s owner to pick it up at a n idle cars into an income an into cars idle n T ar (“guests”) use Turo to Turo use (“guests”) ar O URO heir vehicles for sharing THER al car companies (users (users companies car al s that Turo must obtain must Turo that s s to a wide selection of selection wide a to s haring platform, andit is a software company r, its personal vehicle personal its r, e City of Los Angeles aryland have enacted have aryland I rein). Cal. Code Ins. NC 018). epniiiis in responsibilities R . ELIEF FOR FOR ach other.Turo D ; oa vehicle sonal o, indicating indicating o,

ECLARATORY ECLARATORY 2:18- short-term at or near CV are Turo Turo are -6055 g A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

LAX. Specifically, on informati car rental for designed charges exorbitant pay to Users its and This wouldbeapurerevenuegra meeting at or near the LAX ten percent of each booking (the “Gr any benefit provided to, or serv rental. If applied to a five-da a to applied If rental. th for day per $7.50 as calculated is Charge Facilities LAX the f O to Charge”). Facilities “LAX (the airport the at infrastructure meant Charge” Facilities “Customer per-transaction a seeks those Userscausebyexcha private groundtransportationfro tr many price the than LAX—more to payment $37.50 costly a make LAX terminals. Limousines and amere LyftuserspayLAX By contrast,Uberand others whousesimilar orgreaterLAXresources. twe even or ten Users its and Turo charge to seeks irrationally staging area, yet pay only $4 (limousines) or $5 (taxis) per tr Charge)— Facilities LAX the for charge additional in $87.50 popping way requires that owners offer, immunity provided by the Communications Decency Act, 47 U.S.C. federal of afoul run would action an such But LAX. near or at decis the for Turo sue to threatened has LAX matter, initial an are arranged by the Users themselves. The Communications Decen

Case 2:18-cv-06055Document1Filed07/12/18Page3of28ID#:3 6. 7. 8. 9.

Pursuant to the rental car com car rental the to Pursuant Remarkably, this is not the only fee that the City seeks to imp to seeks City the that fee only the not is this Remarkably, For aweek-longcarsharethat These exorbitant chargesarenot These nging cars at or near LAX. nging carsatornearLAX. y Turo car share, it would requ would it share, car Turo y or guests select for, LAX deliv ice used by, Turo and its Users on and belief, the City would c mLAX totheirfinaldestinati taxis likewise meetpassengers c b from local car owners that is that owners b fromlocalcar all for simply exchanging keys at the LAX curb LAX the at keys exchanging simply for all s ($50 for the Gross Receipt Gross the for ($50 s 3. costs aguest pany permit, the City would requi would City the permit, pany only arbitrary C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT $4 to meet carscurbside atthesame tomeet $500, this amounts ip. In other words, the City and unjust, but T ery—any such exchanges O n information and belief, and information n ireTuro and its Users to , or any supposed burden URO on. harge Turo and its Users companies operating at operating companies e first five days of a car car a of days five first e THER ion of its Users to meet to Users its of ion totallyunconnectedto oss Receipts Charge”). nty times as much as much as times nty I urbside and require a $37.50 and Charge s law, specifically the the specifically law, NC cy Act thus provides R . ELIEF § 230. Turo in no FOR FOR inance rental car car rental inance avelers pay for pay avelers D ;

ECLARATORY ECLARATORY 2:18- illegal. As As illegal. ose. It also also It ose. to an eye- CV re Turo re -6055 . A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

cannot beliableforsuchpublica and selections the publishes that platform online an Turo, that construction of a behemoth “Cons behemoth a of construction Turo and its Users. In fact, the LAX Facilities Charge is coll cha be only can Charge Facilities 180+ refueling stations, and 17, and stations, refueling 180+ information and belief, it will feature 30+ car washing bays, 6 th and companies car rental to services expensive of range wide Turo anditsUsersisthusunfai LA the Imposing purpose. any for facility sprawling this visit require none of the Consolidated Rent-a-Car Facility’s amenitie one another using nothing more than an online app or website. Users to bypass this manner precise of expensive overhead and s lobbies. customer and s companies, back-office booths, counters, service customer of feet square the California Constitution to r amen which Initiative”), Taxes Hidden “Stop (the 26 Proposition unconstitutional because they are unapproved taxes. In 2010, C not rationally relatedtothepurposeforwhichfeeis bein a reasonable relation to the cos the to relation reasonable a Article I, Section 8 of the United States Constitution and the Thus, itisunconstitu have voters and Users, its and Turo to applied as test relation charges proposed LAX’s of Both reject. or approve to entitled t tax a but fee, a legally not is test relation reasonable this

Case 2:18-cv-06055Document1Filed07/12/18Page4of28ID#:4 10. 11. 12.

oevr udr aiona Gove California under Moreover, oh h Gos eeps hre n LX aiiis hre r al are Charge Facilities LAX and Charge Receipts Gross the Both hs rirr hre lovoaete drat omre cla commerce “dormant” the violate also charges arbitrary These tional fortheCityto impose thesecharg equire that any “fee” charged b t of the service covered by the by covered service the of t r andunlawfulunderGovernment tion orforUserconductstemm 000+ stalls for rental cars—as rental for stalls 000+ rged to rental car companies, car rental to rged olidated Rent-a-Car Facility,” Rent-a-Car olidated u Tr i dmcaiig car democratizing is Turo But 4. net oe 5443 te LAX the 50474.3, § Code rnment C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT ected specifically to finance equal protection clauses of g collected. T es on TuroanditsUsers. es y a local government bear fee. Any “fee” that fails 0+ car maintenance bays, a Clfri vtr are voters California hat O Accordingly, Turo Users URO THER never approved either. approved never s and will never need to alifornia voters enacted offerings of its Users, its of offerings X Facilities Charge on on Charge Facilities X ing from thesame. ing from hare cars directly with well as over 100,000 over as well Code§50474.3,and ded Article XIII C of C XIII Article ded which excludes both excludes which which will provide a a provide will which I NC ae o rna car rental for pace eir customers. On On customers. eir R al h reasonable the fail hrn, allowing sharing, . ELIEF FOR FOR D ;

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decisions to meet at or near LAX. Any such attempt would run a run would attempt such Any LAX. near or at meet to decisions that: declaration C the asks Turo provides. platform Turo’s opportunity economic looking to offset the high cost of car ownership in California entrep of detriment the to companies, rental car national large sharing is not stymied by heavy-handed regulations meant to pro appro new its that ensure to seeks Turo Specifically, lawsuit. enforcement unconstitutional and arbitrary, unfair, unreasonable, and unlawful charges and LAX’s at theairport,sometimes even U Turo cited aggressively has LAX Indeed, one. as permitted be instead arbitrarily (and incorrectly) insisting that Turo is a developing an appropriate permit for Turo and other personal ve airport propertyinasimilar manner. on imposed those than higher dramatically are that charges via agai discriminating (b) and Users; its and Turo by used service an to related actually not are that charges exorbitant imposing int on burden undue an imposing (a) from it prohibit provisions tha fact the ignored has City The Constitution. California the the Fourteenth Amendment to the United States Constitution and hre t TC o txs Bt L But taxis. or TNCs to charged personal vehicle sharing program; and (b) pay reasonable fees t fo appropriate regime permitting a to submit (a) to prepared is towards an amicable resolution, but LAX has refused to meet wit CEO, Andre Haddad, has repeatedly asked tomeet with LAX execut

Case 2:18-cv-06055Document1Filed07/12/18Page5of28ID#:5 14. 13.

(a) itse and Users of community its protecting to committed is Turo coope preferred have would Turo

The City cannot hold Turo, an online platform, liable for its U its for liable platform, online an Turo, hold cannot City The impounding their carswithout ca X a rfsd vn o nae w engage to even refused has AX fot. ie n ohr choice other no Given efforts. 5. ration with LAX over litigation. over LAX with ration C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT rental car company and must by taking advantage of the T O URO r its business model as a a as model business its r reneurial local residents residents local reneurial y benefit provided to or or to provided benefit y THER o LAX, similar to those hicle sharing programs, ach to peer-to-peer car peer-to-peer to ach use. aggressive, misplaced, h him even once. Turo nst Turo and its Users its and Turo nst tect the interests of the Article I, Section 7 of tee constitutional these t erstate commerce by commerce erstate I sers exchanging cars exchanging sers NC uiess ht use that businesses R Tr big this brings Turo , ut o a judicial a for ourt . ELIEF FOR FOR foul of immunity immunity of foul ith the idea of of idea the ith D ; vs o work to ives

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airports nationwide. as an existential threat and has gone on the offensive to exclu html (lastvisited July 11,2018). and_alamo_brands_earn_top_three_spots_in_jd_power_rental_car_sa https://www.enterpriseholdings. n .. oe 21 Rna Cr Sa Car Rental 2016 Power J.D. in 3 be compelled bytheC afforded onlineentitiesbythe violation ofCaliforniaC Facilities Charge on each booking made via Turo are unlawful as and its Users pose an undue burde States Constitution because the charges that the City is attemp t Ues y moig hre ta fr xed h aon LX as LAX amount the similarly-situated companies a exceed far that charges imposing by Users its discrimin unlawfully it because Constitutions States United and use ofLAX’sfacilities;and the benefits conferred, and are not based on any fair approxima Rental andcontrols37percentof Car a Rent Alamo owns also that player powerful a is Enterprise (toge Holdings Enterprise parent, its and Rent-a-Car Enterprise

Case 2:18-cv-06055Document1Filed07/12/18Page6of28ID#:6 NTERPRISE 15.

LAX Takes Direction from Nat Direction LAX Takes (c) (b) (d) (e) h cmag t mslsiy uo s rna cr opn began company car rental a as Turo misclassify to campaign The H OLDINGS

The City’s attemptsThe toimpose th Because Turo is not a rental car company, Turo and its Users ca The City has violated the “dorma The City has violated the equal protection clauses of the Calif the of clauses protection equal the violated has City The ity topayLAXchargesthatonlyapply , Enterprise, National, and Alamo Brands Earn Top Three Spots onstitution, ArticleXIIIC; nd theirusers withoutanyration Communications DecencyAct,47 Communications com/en/press-archive/2016/11/ent theairportcarrentalmarket n on interstate commerce, are ifcin td (o. 0 2016 10, (Nov. Study tisfaction 6. ional Car RentalCompanies C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT e Gross Receipts Charge and LAX Charge and Receipts e Gross nt” commerce clause of the Unit de Turo and its Users from T O . ting to extract from Turo URO tion of Turo or its Users’ 3 al basis. THER Enterprise viewsTuro excessive in relation to rental car companies; rental carcompanies; unauthorized taxes in ates against Turo and Turo against ates U.S.C. §230; I erprise_national_ NC hr “Enterprise”). ther, R n Ntoa Car National and . ELIEF FOR FOR tisfaction_study. ), sesses against against sesses D ;

ECLARATORY ECLARATORY 2:18- available at CV -6055 ornia nnot with with ed

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damaging legislation in state leg state in legislation damaging Enterprise explained at this mee this at explained Enterprise with the specific purpose of “discuss[ing] Turo and the collect firm advocacy airport an with met Enterprise” from “contingent thereafter, Shortly airports. at Turo via sharing car limiting rep Enterprise an th 2017, September just doing Enterprise show Documents possible. however Turo 2018, an Enterprise representativ Enterprise an 2018, co car rental govern to meant regulations to Turo subject would competition through competition regulation a gen more and, model innovative Turo’s stifle to clear: is wants with EnterprisethanTuroregarding ha to appear representatives its and LAX Tellingly, Turo. with inst takes toprotectfromcompetition. actively attempts LAX patron a as instead but purview regulatory their a as not Enterprise treat officials LAX that show emails These to Enterprise that “the Los Angeles City Attorney is pursuing l entities with and without LAX rental car permits. LAX obliged through armies of paid lobbyi paid of armies through America in company car rental largest the as influence enormous poi vantage consumers’ from outmoded increasingly is Enterprise

Case 2:18-cv-06055Document1Filed07/12/18Page7of28ID#:7 16. 17. 18.

nepie a luce a multi- a launched has Enterprise This is particularly disconcerting, given that LAX refuses even refuses LAX that given disconcerting, particularly is This A i udl atnie o nepies ead fr rao. reason. a for demands Enterprise’s to attentive unduly is LAX sts, expansive political donations political expansive sts, nd litigation,tothedetriment islatures and aggressively pre aggressively and islatures ting that it was planning to lo to planning was it that ting e emailed LAX, seeking updates seeking LAX, emailed e resentative emailed LAX to dis to LAX emailed resentative 7. how to regulateTuro rne atc o Tr, lobbyin Turo, on attack pronged C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT T O itigation against Turo[.]” oftaxpayers. ion of at fees airports[.]” URO ssuring airports to stifle to airports ssuring THER in November 2017, a a 2017, November in bby for legislation that legislation for bby ve held more meetings more held ve mpanies. By February February By mpanies. and diligently reported . AndwhatEnterprise , and its own political own its and , permitted entity under entity permitted that represents LAX, represents that erally, pro-consumer pro-consumer erally, I on Turo and lists of of lists and Turo on . It exerts its power its exerts It . NC R cuss approaches to to approaches cuss utos rm and from ructions . ELIEF FOR FOR t i sil wields still it nt, at atLAX. In D ;

ECLARATORY ECLARATORY 2:18- CV tomeet -6055 While for g A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

C00219642/ (lastvisited July 11,2018). Committee Financial Summary, Summary, Financial Committee Enterprise and Hertz have secure legislatio control lik to Hertz, lobbyists market. car rental airport the of share significant col which “Hertz”), (collectively, Car a Rent Dollar and Rental which Inc., Holding Global Hertz of subsidiary a is Corporation to the rental car industry and fa and industry car rental the to litigate Turooutoftheairportmarket. influe its use to seeks and threat existential an as Turo views Hertz, the City cannotlegallyhol Hertz, the wis the to contrary But others. all above Hertz and Enterprise Utah, to pass laws that would de Hawa Massachusetts, Maryland, California, in including country, charges onTuroanditsc conduct—let alone regulate Turo as if it were a rental car comp mone taxpayer spend to threatened car company undercurrentlaws. as car rental companies under state law—thus tacitly admitting California. 4 government. i its advance to dollars of millions spending committee, action

Case 2:18-cv-06055Document1Filed07/12/18Page8of28ID#:8 See 19. 20. 21. 22. F EDERAL

4 The Hertz Corporation has simila has Corporation Hertz The oh nepie n Hrz have Hertz and Enterprise Both ne pesr fo tee ainl etl a cmais te Ci the companies, car rental national these from pressure Under Turo Inc. is a Delaware corporation with its headquarters in Sa Enterprisespentover$850,000 E LECTION LECTION ommunity ofUsers. ommunity C OMMISSION vorable regulatory environment ad euaoy oiis Thro policies. regulatory and n fine Turo and other peer-to-pee d lavish tax loopholes worth bi d Turo,anonlin available at o a asi aant uo th Turo against lawsuit a on y P ARTIES , Enterprise Holdings, Inc. Political Action Action Political Inc. Holdings, Enterprise , 8. eety obe saeoss acr statehouses lobbied recently on federallobbyists alonein rly sought to destroy Turo. Th Turo. destroy to sought rly

C https://www.fec.gov/data/committee/ J e platform, r UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT T O esponsible forsuchUser s. Like Enterprise, Hertz URO llions of dollars per year nterests at each level of of level each at nterests THER any or impose unlawful r car sharing companies nce to regulate, tax, or or tax, regulate, to nce that Turo is not a rental Etrrs, employs Enterprise, e lectively account for a a for account lectively hes of Enterprise and Enterprise of hes I g tee methods, these ugh NC R ws hit Car Thrifty owns i Msor, and Missouri, ii, . ELIEF FOR FOR t ol benefit would at D ;

ECLARATORY ECLARATORY 2:18- n Francisco, 2017. CV e Hertz Hertz e s the oss -6055 ty has has ty A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Business SchoolstudentnamedShelbyClark:

within theCourt’sjurisdiction. presents action the because 2201 § U.S.C. 28 to pursuant action California lawpursuant Turo alleges violations of its rights under the Constitution an southern California. The City o resides inCaliforniaandhasits Airports, which isgovernedbyth resides in this judicial distric judicial this in resides part of the events giving rise to Turo’s claims for relief occu 5

Turodidnotoperate inCalif

Case 2:18-cv-06055Document1Filed07/12/18Page9of28ID#:9 Turo Brings Short-TermPersonalC Turo Brings 27. 26. 25. 24. 23. 28. 29.

cars!’” went on. I thought: ‘Wait a mi h that road the clearly not on been driven for cars weeks, and that of was when the hundreds light passed “I car. a to get to 2 bike to had I and snowing, was It was Thanksgiving Day in 2008, and I needed to rent a Zipcar. This Court has personal jurisdic personal has Court This The Court may declare the legal rights and obligations of the p aris claims those over jurisdiction supplemental has Court This This Court has jurisdiction of this action under 28 U.S.C. § 13 § U.S.C. 28 under action this of jurisdiction has Court This l city a is “Defendant”) or “City” (the Angeles Los of City The Venue is proper under 28 U.S.C. § uo frel Rlyie) a fudd n pi 2009 April in founded was RelayRides) (formerly Turo to 28U.S.C.§1367. A DDITIONAL DDITIONAL t and in the State of Californi of State the in and t J ornia beforeDecember 2010. URISDICTION AND URISDICTION principal place of business i principalplaceofbusiness wns and operates LAX through th e BoardofAirportCommissione S nute! I should be taking one of TATEMENT OF TATEMENT 9. ar SharingtotheEcon 1/2 miles through Boston snow Boston through miles 1/2 tion over Defendant, because De because Defendant, over tion 1391 because Defendant is loc C J V UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT ENUE F ACTS ACTS

a, and because a substantial substantial a because and a, rred in this judicial district. d laws of the United States. n California. T O

URO THER an actual controversy actual an e Los Angeles World I NC rs. R . ELIEF FOR FOR those 5 bulb by a Harvard Harvard a by D ; It It ad

ECLARATORY ECLARATORY 2:18- arties in this 31 because because 31 ing under ing omy ocated in in ocated CV ated and fendant -6055 A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

road. impacts environmental reducing Case 2:18-cv-06055Document1Filed07/12/18Page10of28ID#:10 founded RelayRides,thefirstp T cars. their sharing in interested were others whether see to “shared mobility” platforms like platforms mobility” “shared Turo, as an innovator in the sha of cars sit unused in America; American cars remain parked over with those willing to pay reasonable fees to use them. Every d like Zipcar, RelayRides allowed allowed RelayRides like Zipcar, researchers have found that members of car sharing programs are programs sharing car of members that found have researchers Departmen States United u Likewise, sharing. instead car by supplemented and ownership car forgo to individuals encouraging by and driving, reducing by lifestyles healthy support resources, ed o ddctd etl as wih eur epnie overhea expensive require diminish which is waste, environmental cars, rental dedicated for need ow car for sense makes modelIts source ofincome benefitsCalifor p insurance and loan car their offset to many helps which year, peer carsharingplatform providerintheUnitedStates. their earningstomake carpayme owners car of majority the Indeed, loans. student with people fixe on seniors including cars, more or one own that households

33. In fact, researchers at the University of California, Berkeley Berkeley California, of University the at researchers fact, In 30. 31. 32.

Turo lets these households realize income on an otherwise idle Clark researched insurance and technologies and surveyed the ma Clark envisioned a platform that would pair people who have spa have who people pair would that platform a envisioned Clark On average, California car owners who use Turo earn about $3,50 about earn Turo use who owners car California average, On ring economy, provides an elega eer-to-peer sharingservice.Un individual carownerstoshare Turo can create new revenue so revenue new create can Turo nts, reducedebt,orsavefort ing. Turo is the largest and m and largest the is Turo ing. ners and drivers. Asthe shari nians who belongtotheover9 by eventually decreasing the num the decreasing eventually by 10. C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT T ay, hundreds of thousands O URO heir future. benefit the environment the benefit like fleet-based services fleet-basedservices like nt solution to this waste. using Turo report using report Turo using THER ng economy grows,the their vehicles. hen, in April 2009, he he 2009, April in hen, 95 percent of the time. ost successful peer-to- successful ost 0 percentofAmerican urces from underused from urces d incomes and young and incomes d ayments. This extra This ayments. I NC more likely to sell to likely more R t of Transportation of t ber of cars on the on cars of ber . ELIEF FOR FOR se public transit transit public se ae on that found have ad massive and d D ;

ECLARATORY ECLARATORY 2:18-

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companies, which own vast fleets of vehicles, run private netwo private run vehicles, of fleets vast own which companies, (including direct subsidies, ba and federal the from breaks tax generous to due profits immense their conduct to estate real significant utilize buses, shuttle guidelines foruse,includingpri i also may Owners availability. t of features special and location, model, make, the describing year. in fees) licensing and registration of pass-through and sales, m business This car. a of need These Usersthengai Turo’s main homepage; and (b) inputting a desired timeframe usi location desired a typing (a) by: app or website Turo’s search photographs oftheir cars. compa car renting fromarental Case 2:18-cv-06055Document1Filed07/12/18Page11of28ID#:11 July 11,2018). https://ops.fhwa.dot.gov/publica Practices andGuiding Principles U content/qt8w77044h/qt8w77044h.pdf B 6 with increasedpublictransitus owners car in Reductions cars. new buying avoid and cars their

See,e.g.

ERKELEY ERKELEY NITED 34. 35. 36. S

TATES Ssn hhe & dm Cohen, Adam & Shaheen Susan , P Turo maintains a software platfo software a maintains Turo Private car owners who use Turo set up a profile and list their list and profile a up set Turo use who owners car Private Users who wish to book a car share also set up profiles on Turo OLICY D B PRMN OF EPARTMENT Turo Is an OnlineMatchmakingPlatform Turo Isan n access to over 800 ma n accesstoover800 RIEFS Not LiablefortheConductofItsUsers , available at il-outs, waiver of capital gains e, walking,biking,andreduced ny—they can pick a car with the car a ny—they canpick ce andterms ofdelivery.Mos tions/fhwahop16022/fhwahop16022 pt oe eald descriptions detailed more nput hratr “hrd oiiy) t ix, at Mobility”) “Shared (hereafter, odel is fundamentally different different fundamentally is odel tpq4&=g ls vstd J visited (last ?t=p2q24m&v=lg T RANSPORTATION 11. https://cloudfront.escholarship.org/dist/prd/ kes and models, and— kes and rm that matches car owners with owners car matches that rm C J Overview ofSharedMobility UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT , Shared Mobility:Current taxes for car purchases and T operations, and rake in in rake and operations, O URO t car owners also upload alsoupload t carowners excess of $3 billion per billion $3 of excess into the search menu on menu search the into parking demand. THER he cars, and indicating and cars, he rks ofairpor ng a drop-down menu. specific make, model, model, make, specific hip, in turn, correlate turn, in hip, I of the cars and set set and cars the of NC R unlike iftheywere tt government state .pdf (last visited visited (last .pdf . ELIEF FOR FOR rm a rental car from l 1, 2018); 11, uly D ;

ECLARATORY ECLARATORY 2:18- available at . They can t vans and CV thosein cr by cars 6 -6055

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Case 2:18-cv-06055Document1Filed07/12/18Page12of28ID#:12 and colortheywant. ugt n codnt drcl wt is we fr eiey r p or determined location. delivery for owner its with directly coordinate and budget location where the owner keeps location wheretheowner pick will guest the that agree can guest and owner the Instead, deliver the car at any location th th is, That option. delivery customized completely a create to with the guest to meet there. E there. meet to guest the with email) priortotheexchange. tool messaging Turo’s via (either other each with coordinate to companies, which are governed by d are programs such that recognized thus legislature California enacted in 2010, created a legal framework for personal vehicle Turo isnotarentalcarcompany. is not a ticket seller, Skype is “rent.” Just as Kayak and Expedi liability stemming from U such including inaparkinglot,at a anywhere meet to agree can They car. the exchange will guest mandate LAX exchanges, the Comm

37. 38. 39. 42. 41. 40. The CaliforniaLegislatureHasR Model IsLegallyDistinctFromt

Turo does not require that owne that require not does Turo If the owner chooses to deliver the car, she can use the Turo p An ownermayalsooptionally offe California law is in accord. California Insurance Code § 11580 § Code Insurance California accord. in is law California As noted above, Turo is a car sharing platform, without any fle Because Turo is an online platform, and because Turo does not r not does Turo because and platform, online an is Turo Because That is, they can pic can they is, That the curb,oratanyothercustom not a telecom company, and Doo ven then, Turo does not dictate ser-organized exchanges. at she agrees with the guest, it (oratanyotherowner-specif a are not airlines,eBayisno a arenot a separate legal framework. S unications Decency Act, 47 U.S.C 12. k the exact carthat k theexact ecognized That Turo’s Car Shari ThatTuro’sCar ecognized he RentalCarCompanyModel rs offer, or guests receive, car receive, guests or offer, rs r deliveryto“LAX,”onlyifs C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT or the two can simply agree fits the occasion andtheir fitstheoccasion ized location. T where the owner and her O t an auctioneer, StubHub rDash is not a restaurant, URO THER sharing programs. The ied location). s, or via phone, text, or text, phone, via or s, istinct from rental car rental from istinct onr a ofr to offer can owner e pecifically, pecifically, Insurance up the car from the the from car the up I t or near the airport, the near or t NC R cu fo a pre- a from ickup . ELIEF FOR FOR . § 230 precludes D ;

ECLARATORY ECLARATORY 2:18- latform tools et of cars to delivery. delivery. he agrees ng equire or or equire CV -6055 .24, A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

proa vhce hrn porm s oehn distinct—i.e., something is program sharing vehicle personal a “any person in the business of renting vehicles to the public.” § 1939.01(a). the to vehicles passenger renting of business the in entity or Cal. Veh.Code§11752(e). person or entity in the business of renting passenger vehicles Case 2:18-cv-06055Document1Filed07/12/18Page13of28ID#:13 idle assetwithoutoperati empowered by California Insuranc 7 busin do to qualified entity legal “per a defines (a) 11580.24 § Code the environmentalorconsumer-c supporte California of Attorneys comme not are programs ca private that explains (b) and state”; the within individuals n for vehicles passenger private of sharing the facilitating of share theirpersonalvehiclesw al platform online an Turo, that plain make also law California aiona hpe, omnt Ac Community Chapter, California Pla American the Sacramento, of City the Club, Sierra the Fund, are beingshared,relievingow cover that insurance auto provide to Turo like programs sharing

uos sr ae lo o rna cr opne. hy r inst are They companies. car rental not also are Users Turo’s

45. 44. 43.

These statutes show that a rental car company rents cars to cus to cars rents company car rental a that show statutes These (c) (b) (a) Consistent with this provision of California insurance law, oth h Ntoa Rsucs ees C Defense Resources National The

The California Insurance Code defines a “rental car company” as company” car “rental a defines Code Insurance California The pers “a as company” “rental a defines Code Civil California The “ as company” car “rental a defines Code Vehicle California The ng ascommercialentities. rcial vehicles. Mor vehicles. rcial ners ofthisresponsibility. ith guests,isnotarentalcar ess in the State of Californi of State the in ess d the passage of this law—many this of passage the d hoice benefitsofcarsharingpr e Code 11580.24 § to earn incom sonal vehicle sharing program sharing vehicle sonal in o rvn Atm, n the and Asthma, Prevent to tion 13. eover, this law requi law this eover, C J ucl te niomna Defen Environmental the ouncil, UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT Id. company: to the public in California.” §11580.24(c)(1). Cal. Ins. Code § 1758.89. a engaged in the business the in engaged a T O public.” Cal. Civ. Code Civ. Cal. public.” URO THER rs shared through such through shared rs ograms likeTuro. ograms nomril s by use oncommercial lowing car owners to owners car lowing s vehicles while they they while vehicles s I ” such as Turo as “a as Turo as such ” NC res personal vehicle personal res e from an otherwise of them because them of R nning Association, nning . ELIEF FOR FOR 7

a platform that that platform a a individuals ead D ;

ECLARATORY ECLARATORY 2:18- er aspects of Consumer tomers and CV -6055

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Case 2:18-cv-06055Document1Filed07/12/18Page14of28ID#:14 Turo, awebsiteandapp,toapply car share where Turo’s Users decide to meet at or near LAX. Bu that Turo obtain a rental car company permit and pay the LAX Fa Facility. Consol the of development the fund to Charge Facilities LAX the statements asserting that California Government Code § 50474.3 day five to up used, is car the that day per ($7.50 transaction of entities. charge on rental car companies, but does not permit forcing the category from “CarRental”). 8 pri of sharing the “facilitat[es] insurance providers that offer pr offer that providers insurance Washington passedsimi business model providesconsumers c rental a of definition statutory the meet not does Turo such, programs aredistinctfrom rental carcompanies. “pee that stated has Transportation of Department States United c rental a not is Turo because Users Turo to coverage such deny li companies. platforms car rental clear considered makes which statute sharing car peer-to-peer

The CityCannotChargeTurothe

See Shared Mobility, Shared 47. 49. 48.

46.

See, e.g. Consistent with the will of the rental car companies, the City The City would charge Turo and its Users between $7.50 and $37. and $7.50 between Users its and Turo charge would City The The California Government Code allows airports to impose this t this impose to airports allows Code Government California The Other governmental and private actors agree. For example, Oreg example, For agree. actors private and governmental Other , Cal.Gov’tCode lar carsharinglaws supra note 8 at 10, 13-16 (defining carsharing as a separate separate a as carsharing (defining 13-16 10, at 8 note ae asne vhce fr no for vehicles passenger vate otections to rental car compan car rental to otections for such a permit or paysuch or for suchapermit iial, rdt ad compan card credit Similarly, with a far more appealingalt afarmore with LAX Facilities ChargeUnderCal LAX Facilities §§ 50474.1,50474.3. 14. toCalifornia’sand 8 C

J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT s). LAX has made public public made has LAX s). T O se charges on other types URO ar company. Indeed, its Indeed, company. ar ies’ customers regularly regularly customers ies’ charges. cmeca ue” As use.” ncommercial t the City cannot require THER Maryland justpasseda authorizes it to charge ar company. And the And company. ar cility Charge for each ernative tothem. r-to-peer carsharing” r-to-peer I NC R . idated Rent-a-Car Rent-a-Car idated ELIEF FOR FOR e uo r not are Turo ke e ad personal and ies has demanded D ; ifornia Law

ECLARATORY ECLARATORY 2:18- CV on and on -6055 ype of of ype 50 per 50

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Case 2:18-cv-06055Document1Filed07/12/18Page15of28ID#:15 the transit infrastructure needed counters, car rental for need the abolished has Turo As from. infrastruct finance to Users require unjustly would it rea instead, a Charge Facilities LAX Rent-A-Car the approximation of any benefit, service, or good that LAX is provide Consolidated Nor expensive an thereto. require transportation not do Users since rationally related to any cost LAX incurs as a result of Turo U this fee. charge to City the authorize not does 50474.3 § Code Government peer-to-pee facilitates that website a is Turo public.” the to § 1939.01(a) defines as “a person or entity in the business of state legislature.Cal provid periodically to airport an facility—requiring car rental limit this fee to the amount necessary to recoup the costs of c s The .” conditions. . following the under 50474.21, Section require rental companies to collect an alternative customer fac Code §50474.3,astocertaine its Userstopaykeepoutdate entities, whichoperateonlyonlin Tur like program sharing vehicle personal a of users on charges of thetotalamount of each res Turo and its Users pay a Gross Receipts Charge of, on informati

The City’sDemandsViolateSectio 50. 52. 51. 53. 54.

The LAX Facilities Charge could b oevr te A Fclte Char Facilities LAX the Moreover, Code Civil California which company,” “rental a not is Turo But o te Clfri saue uhrzs n ipr t rglt o regulate to airport an authorizes statute California other No The City demands that Turo apply for a rental car company permi company car rental a for apply Turo that demands City The . Gov’tCode§50474.3(b). ervation plusanLAX Facilities ntities. That provisionreads, ntities. That d rentalcarcompanies inbusin to connect the two, it makes e (notattheairport)topay 15. n XIIICoftheCaliforniaCon e authorized by California Gov C J e s o raoal connected reasonably not is ge UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT r car sharing, so California so sharing, car r chargestotheairport. no sense to force Turo and renting passenger vehicles onstructing onstructing a consolidated sers meeting at the airport, in part:“Anyairport may T e audits to this end to the to end this to audits e O ility charge, as defined in URO tatute goes on to strictly to on goes tatute Charge of$7.50–$37.50 ess. on and belief, 10 percent THER expensive car lots, and lots, car expensive ure they never benefit benefit never they ure s to Turo and its Users; I NC , r eurs such requires or o, Turo and its Users its and Turo R . ELIEF FOR FOR oal o fair or sonable D ;

stitution ECLARATORY ECLARATORY 2:18- Center or impose r t and that CV ernment ernment -6055 or

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Case 2:18-cv-06055Document1Filed07/12/18Page16of28ID#:16 a taxunlessitfallswithinoneo fall withinanyofthe sevenexc approve, byvote,anymeansofra exception an prove to authority taxing the of burden the is it has significantly expanded voters’ Constitution, enactedbyPropos Facilities ChargetoTuroanditsU either ofthesecharges. at meet they anytime abuse andstrengthene Californ approval. voter require not did that “assessments” or decades, local governments bypasse approval voter get to governments of California,”providesasfollows: of Purpose of Declarations and “Findings labeled section, That

58. 59. 55. 56. or expanded taxes as “fees.” or expandedtaxesas def simply by taxes increasing on restrictions these circumvent govern local nor Legislature the neither that so purposes local effectiveness the f ‘tax’ a ensure defines also to measure this order limitations, constitutional In [] taxes. of imposition applica program limitations the permitting to subject or be should licensing and taxes any actually of part not are and program a or regulation actual co reasonable the exceed which but “regulatory” as couched Fees 57.

Under thisnewconstitutionallangua The Gross Receipts Charge as it is applied to Turo and its User its and Turo to applied is it as Charge Receipts Gross The oevr te plcto o te rs Rcit Cag ad LAX and Charge Receipts Gross the of application the Moreover, In 1996, California voters passe voters California 1996, In California voters stated their purpose in the first section of LAX. As above, Turo and its Users cannot Users its and Turo above, As LAX. d taxpayerprotections e ipy moe t rie eeu fr a for revenue raise to imposed simply re eptions enumerated in ArticleX eptions enumeratedin f sevennarrowlydefinedexce ition 218andam ising revenuethatisatax. ability to veto arbitrary ta sers isaviolationofArtic d this requirement by reframi before enacting any new taxes new any enacting before 16. bypassing Proposit d Proposition 218, which requir which 218, Proposition d ended byProposi C J ge, any “levy, charge, or e ge, any“levy,charge,or UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT xes. Under Proposition 26, le XIIICoftheCalifornia T applies. The people must people The applies.

O ptions. Thisnewregime URO ia’s voters rebuffed this rebuffed voters ia’s THER III C, Section 1(e). III C,Section the People of the State State the of People the ion 26in2010. ng new taxes as “fees” I tion 26. NC legally be subject to subject be legally . For the next two R or state and state or . ELIEF FOR FOR ments can can ments ining new ining ble to the the to ble f these of Proposition 26. D ;

ECLARATORY ECLARATORY 2:18- sts of sts new new are xaction” is s does not does s CV ed local local ed -6055 A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page17of28ID#:17 for a “benefit,” “privilege,” “se eainhp o h pyrs bur payor’s the to relationship “that the manner in which those costs are allocated to a payor more than necessary to cover the reasonable costs of the govern without voterapprovalclearlyr Charg Receipts Gross the levy to attempt City’s The activity.” revenue for the City that comes that City the for revenue that LAXprovides toTuroanditsUsers. be any of approximation fair or reasonable a not also is Charge reasons, same these For Users. its and Turo support to airport any to related rationally or connected reasonably not is Charge LAX incurs as a result of Turo Users meeting at the airport. and a ticketing booth that tracks coordi to personnel LAX areas, staging lanes, dedicated require par discrepancy, this for reason no is There trip.) per $5 pay pe $4 pay taxis $4, pay riders Lyft and (Uber lower. magnitude compa limousine and taxi and Lyft, and Uber like TNCs including charges merelyfortherightt Remarkably, the Gross Receipts Charge would demand of Turo and predates November 2,2010. predates November Users its and Turo like platform online an charging of practice ordinance, no is There 26. Proposition postdates that tax new other consumers orproviderso

60. 62. 61. 63. 64.

As relevant here, a local governme local a here, relevant As ahr te rs Rcit Cag wud ipy e nw stream new a be simply would Charge Receipts Gross the Rather, t exceed far would Charge Receipts Gross the because so is This Meanwhile, the payments that the City demands of other similar other of demands City the that payments the Meanwhile, Applying the Gross Receipts Charge to Turo and its Users would Users its and Turo to Charge Receipts Gross the Applying o meet at or near the airport. o meetatorneartheairport. rvice,” or “product” unless it f groundtransportation atLAX. es n o bnft rcie fr received benefits or on, dens uns afoul theserequirementsof rides. Turo Users spend no m without additional cost or burd or cost additional without 17. nt needs voter approval to ch to approval voter needs nt C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT can prove the fee is (1) “no “no (1) is fee the prove can bear[s] a fair or reasonable In fact, the Gross Receipts T O ticularly given that taxis that given ticularly URO ore ore time at curb the than . THER mental activity” and (2) e on Turo and its Users its and Turo on e nate passenger pickup, passenger nate a tax of this kind that en to the LAX airport. LAX the to en m te governmental the om, nefit, service, or good or service, nefit, r trip, and limousines and trip, r cost incurred by the by incurred cost I the Gross Receipts NC euain o LAX or regulation, R its Users exorbitant nies, are orders of of orders are nies, . ELIEF FOR FOR D ;

ECLARATORY ECLARATORY 2:18- arge a fee CV he costs he entities, create a create -6055 of A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page18of28ID#:18 include peer-to-peer car sharing companies: include peer-to-peercarsharingcompanies: the was 2016 in Only 2010. 2, November after long Company” Car subject totherentalcarpermitt the Rules and Regulations, LAX itself did not consider Turo to platforms. online other and Turo including regime, regulatory out well fall that entities upon) taxes unconstitutional impose purportedly to company car rental a of definition statutory and co to intended was industry, sharing car peer-to-peer the from, t of application justifying analysis any conducted, not has LAX 2010, theyaresubjecttoArticle place took acts these Because tax. a of charging the to regard a constitutes chang a constitute also may and Charge, tax a of increase or extension, Receipts Gross accompanying the including its owndesign(“LAXRules”). LAXGTRulesRegs (last v 9

h cret A Rls n Regul and Rules LAX current The

rental vehicles as part of its of part as vehicles rental a procures provides, indirectly, or directly that, business Any 67. manages vehicle rental activities activities rental vehicle manages s o lmtd o taiinl etl a bsnse, rkr f businesses, brokers rental car businesses, delivery car rental traditional to, limited not is 68. and carsharingbusinesses. 69. 65. 66.

On information and belief, the LAX Rules first defined the term the defined first Rules LAX the belief, and information On hs mnmn, ae ihu ay oslain ih o involvem or with, consultation any without made amendment, This LAX has not provided to Turo, a h apiain f h rna cr emt eie o uo n its and Turo to regime permit car rental the of application The LAX publishes a set of “Ground Transportation Rules and Regulat isited July11,2018). 9 ing regime andassociatedchar

XIIIC,Section2oftheCali business and/or conducts, facili conducts, and/or business companies, companies, peer-to-peer car ren as part of its business. Thi business. its of part as 18. tos r pse a https://ww at posted are ations nd on information and belief, Tu C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT T fornia Constitution. O ges. URO only after November 2, November after only ntort the plain language plain the ntort be a rental car company THER e in methodology with methodology in e Before this revision to revision this Before reach (and thereby to thereby (and reach ie f h rna car rental the of side I NC s includes, but includes, s R tal businesses nd/or brokers e rs Receipts Gross he or car rental rental car or . tates, and/or tates, ELIEF FOR FOR term defined to defined term imposition, n D ;

ECLARATORY ECLARATORY 2:18- w.lawa.org/ w.lawa.org/ ro alleges CV “Rental ions” of Users, -6055 ent A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page19of28ID#:19 Facilities Charge also violates A to Turo and its Users also does also Users its and Turo to Proposition 218andame Constitution. Se C, XIII Article of limitations the to subject are they 2010, place took acts these Because tax. a of charging the to regard a constitutes chang a constitute also may Charge, and tax a of increase or extension, Facilities LAX accompanying the including promulgated byLAXin2017. Users topay$7.50–$37.50pertransaction. L that privilege or service any in Article XIII C, Section 1(e) of the California Constitution. t of application justifying analysis any conducted, not has LAX California lawbecause itisnot XIII C, Section 2, LAX’s applica these taxes. 10 allegedly incurredinconnection as or Programs Sharing Vehicle Personal other or Turo to Charge is unlawful.

If the Gross Receipts Charge could be termed a fee, it would s would it fee, a termed be could Charge Receipts Gross the If 72. 73. 76. 75. 74. 71. 70.

10 n diin o iltn te aiona oenet oe te LA the Code, Government California the violating to addition In Like the Gross Receipts Charge, the LAX Facilities Charge as it LAX has not provided to Turo, a its and Turo to regime permit car rental the of application The the belief, and information On Because LAX has failed to abide by the procedures required by A by required procedures the by abide to failed has LAX Because The City of Los Angeles has not has Angeles Los of City The

nded byProposition 26. reasonable,fair,orproportio AX provides to Turo, and would r would and Turo, to provides AX not fall within any of the seve the of any within fall not rticle XIII C of the Californi tion of the Gross Receipts Char with TuroUsersexchangingcar 19. nd on information and belief, Tu sought or received voter approv voter received or sought LAX Facilities Charge was only only was Charge Facilities LAX C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT The charge does not cover nal. a Constitution, enacted by T O n exceptions enumerated exceptions n URO ction 2 of the California the of 2 ction only after November 2, November after only THER ge to Turo and its Users e in methodology with methodology in e s at or near LAX. s atornearLAX. till be unlawful under unlawful be till I NC equire Turo and its and Turo equire R he LAX Facilities Facilities LAX he . ELIEF FOR FOR esn te costs the sessing imposition, n D ;

ECLARATORY ECLARATORY 2:18- is applied ro alleges CV Users, -6055 al for for al rticle X A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page20of28ID#:20 allegedly incurredinconnection as or Programs Sharing Vehicle Personal other or Turo to Charge XIII C, Section 2, the City’s a City’s the 2, Section C, XIII tax. Users isunlawful. owner at LAX arrive from out-of-s (including the these charges), a as treatment Turo’s authorize to purport Rules LAX the extent omre Tu, hs cags ilt Atce , eto 8 of 8 U.S.C 42 to Section pursuant Constitution I, Article violate charges these Thus, a discriminate they commerce. and LAX, by Users its and Turo on conferred excessive are they facilities, or services LAX’s of use Users’ are they commerce; interstate anr s uo frhr demonstr further Turo, as manner compani limousine and companies, Rent-a-Car Facility. LAX’ like services and facilities airport other on rely or from Turo Users. its and Turo by used service or good, benefit, any Charges aredispropor

78. 77. 79. 81. 80. 82.

Because theCityhasfailedtoabi The City of Los Angeles has not sought or received voter approv The Gross Receipts and LAX F Gross ReceiptsandLAX The Moreover, the City demands only a fractional amount from TNCs, from amount fractional a only demands City the Moreover, As discussed in detail above, these charges are not a fair appr Moreover, the majority of Turo’s of majority the Moreover, The GrossReceiptsandLAXFa tionate andexcessive. the “Dormant”CommerceClause y areunconstitutionalasapplied pplication of the LAX Facilities LAX the of pplication not based on any fair approximati fair any on based not with TuroUsersexchangingcar tate and have pre-arranged the . § 1983, as applied to Turo a Turo to applied as 1983, § . ating that the Gross Receipts a s ht s arot rpry in property airport use that es 20. acilities Charges poseanunduebur acilities de bythe proceduresrequired Users who arrange to meet a Tu a meet to arrange who Users cilities ChargesViolate C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT T

O in relation tothe benefits toTuro. s proposed Consolidated proposed s URO THER Charge to Turo and its and Turo to Charge ir Turo booking before s at or near LAX. s atornearLAX. Users do not benefit not do Users nd its Users. To the To Users. its nd I on of Turo’s and its and Turo’s of on rental car company company car rental NC virtually the same R nd LAX Facilities Facilities LAX nd . h Uie States United the ELIEF FOR FOR esn te costs the sessing gainst interstate interstate gainst D ;

ECLARATORY ECLARATORY oximation of 2:18- byArticle al for this this for al CV -6055 den on ro car ro taxi A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page21of28ID#:21 variety ofbusinesses, including participant. The City imposes the Gross Receipts and LAX Facil interstate commerce. arriving, further illustrating that the Gross Receipts and LAX other similarly situatedcompani it and Turo treating intentionally by provisions constitutional the of 7 Section I, Article and Fourteenth Amendment to the United States Constitution (pursuan equa the under treatment equal and fair to rights their violate clausescrutiny. commerce is conduct City’s The LAX. at business conduct to permitted is City even has any business partners in this context). The City do (Turo City the of partners” “business are that businesses on company (includingthesecharg treatme Turo’s authorize to purport Rules LAX the extent the To airport premises via mobile and w matchmaking platforms that allow ai other on rely or from benefit users—like Turo’s—only use LAX property for user pick-ups and Ube d like TNCs from demands it that charges the of excess in far protection under the law by intentionally levying charges on Tu City only charges $4 per trip to Uber and Lyft and their users— their and Lyft and Uber to trip per $4 charges only City Facility Rent-a-Car Consolidated

83. 84. 85.

The City is acting in its regulatory capacity, not in a capacit a in not capacity, regulatory its in acting is City The TheCity’s demands that Turo and its Users pay exorbitant charg pcfcly te iy ilts uos n is sr’ ih to right Users’ its and Turo’s violates City the Specifically, The GrossReceiptsandLAXFa the EqualProtectionClause allpeer-to-peercarsharingc es), theyareunconstitutional as es andtheiruserswithoutara aiona osiuin Te C The Constitution. California eb-based eb-based applications. Despit users to coordinate pick-ups a pr fclte ad evcs l services and facilities rport Lk Tr, hs cmais a companies these Turo, Like . 21. cilities ChargesViolate C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT has a monopoly over who ompanies, andnotmerely l protection clauses of the the of clauses protection l T Facilities Facilities Charges burden O tional basisfordoing so. URO s Users differently than differently Users s THER ro and its Users that are es not concede that the the that concede not es appliedtoTuro. e these similarities, the ities Charges on a wide nd drop-offs on or near a mere fraction of the the of fraction mere a k LXs proposed LAX’s ike t to 42 U.S.C. § 1983) I NC subject to dormant to subject R rop-offs and do not r and Lyft, whose Lyft, and r . t voae these violates ity ELIEF nt as a rental car car rental a as nt FOR FOR e lo online also re D ; y as a market a as y

ECLARATORY ECLARATORY 2:18- CV es also also es -6055 equal A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page22of28ID#:22 LAX Facilities Charge and 10 per its Users. pickups—provisions for space curbside designated them provides stagin of use make also Lyft and Uber Users. its and Turo from coordinate passengerpickup,and area staging lanes, dedicated with taxis provides LAX as Users, infrastructu LAX on burden greater substantially a impose users Turo and its Users (limousines pay $5 per trip and taxis pay $4 what to compared dollar the on pennies pay yet area, staging a companies and their users. In fact, taxis and limousines meet protection by levying charges far in excess of those it collect that havezealouslycampaigned re a as Turo misclassify to desire strong a have that companies Turo and local taxpayers. On information and belief, LAX has c protecting the interests of large multi-national rental car com contrary, the City has acted with animus towards Turo and with and itsUsersviolatestheirc requirements and related charge new innovative business model. Turo brings this lawsuit now on now lawsuit this brings Turo model. business innovative new always sought to work with airports cooperatively to devise a s model unique the for appropriate been willing to cooperate with LAX to arrive at a new constitut

86. 88. 87. 89.

ieie te iy lo ilts uos n is sr’ ih to right Users’ its and Turo’s violates also City the Likewise, Accordingly, the City’s attempt The City can offer no rational basis for this disparate treatme disparate this for basis rational no offer can City The h Ct cno lwul ips rna cr opn permitting company car rental impose lawfully cannot City The Turo’s WillingnesstoCooperatewith LAX onstitutional right s on Turo and its Users. Despit to tryachievethisend. cent Gross Receipts Charge that a ticketingbooththat tracks f esnl eil saig pr sharing vehicle personal of 22. to impose these disparate charg s toequalpro C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT tection under thelaw. s from taxis and limousine panies, to the detriment of users curbside and require T O ). Indeed, taxis and their URO rides. olution that works for its e this fact, Turo has long THER ional permitting regime the improper motive of g areas and LAX even LAX and areas g the City would charge would City the olluded with rental car ntal car company and company car ntal LAX seeks to recover I s, LAX personnel to personnel LAX s, re than Turo and its and Turo than re ly because LAX has has LAX because ly NC not given to Turo or or Turo to not given gas Tr has Turo ograms. R . ELIEF FOR FOR D ;

ECLARATORY ECLARATORY 2:18- nt. On the On nt. es on Turo CV -6055 equal A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page23of28ID#:23 at or near LAX. at ornearLAX. allegedly committed by Turo and its Users—namely the conduct of saidallegations herein, asif so inviolation ofthe LAX Rules information content providers. way, this In LAX. at meet to decide Users Turo’s which through based platform. and Rules responsib LAX held the be of can violations Turo whether concerning City the and Turo posting on Turo their agreement their Turo on posting refused to negotiate in good fait good in negotiate to refused permitting regime. negotiate an appropriate car sha car appropriate an negotiate any activity at LAX or apply for apply or LAX at activity any outreach fromitsCEO,AndreHaddad sharing industry. ( industry. sharing Administrative Code § 171.02(b § Code Administrative if Turorefusestosubmit tothe

92. 94. 93. 96. 95. 97. 90. 91.

Turo repeats and realleges each realleges and repeats Turo Turo is an interactive computer interactive an is Turo As alleged herein, an actual and The City asserts that Turo Users meeting at LAX to exchange veh exchange to LAX at meeting Users that Turo asserts City The Turo’s Users provide user content on the Turo platform, includi The City would hold Turo liable for the actions of its Users, s Users, its of actions the for liable Turo hold would City The Turo would greatly prefer coope prefer greatly would Turo LAX has instead sent Turo cease-and-desist letters, ordering Tu See Exs. 1 and 2 (alleging, 2 and 1 Exs. weresetforthinfull. F unlawfulfeesassociatedwith IRST h, demanding instead that Turo that instead demanding h, ring permit with LAX—including LAX—including with permit ring )).) The City has threatened leg threatened has City The )).) (Declaratory Relief) andLosAngelesAdministrative a permit that makes no sense f sense no makes that permit a to exchange vehicles at LAX and LAX at vehicles exchange to o Agls diitaie Code Administrative Angeles Los C , but itseffortshavebeen , but AUSE OF 23. justiciable controversy now ex and every foregoing allegation foregoing every and service that provides a website a provides that service ration over litigation. Turo ha Turo litigation. over ration A inter alia C J CTION UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT

, violations of Los Angeles Los of violations , T O this permit. URO THER submit to an unlawful an to submit or the peer-to-peer car car peer-to-peer the or rebuffed ateveryturn. al action against Turo against action al I Code. NC Turo Users meeting R through good faith good through . Turo’s Users are Users Turo’s ELIEF FOR FOR their subsequent their le for alleged D ; 171.02(b) §

ECLARATORY ECLARATORY 2:18- ists between s sought to sought s pecifically pecifically ro to cease ng content contained and app- and CV icles do icles -6055 A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page24of28ID#:24 herein, as if saidallegations herein, asif rental carcompanies. and to as rentalcarcompanies tr and regulate to authority LAX’s concerning City the and Turo threatened totakelegal threatened in results that content the publishes Turo because liable Turo meeting on or near LAX premises to consummate those transaction Rules and the Los Ange and theLos Rules federal CommunicationsDecen content thatleadstothe pu from stemming claim law common or statutory federal or state Turo UsersatLAX. Business and Professions Code, § 17200 of TuroUsersatLAX. to 28U.S.C.§2201.

104. 105. 106. 98. 99. 101. 100. 102. 103.

Turo repeats and realleges each realleges and repeats Turo As alleged herein, an actual and Turo anditsUsersare notrenta Turo isimmune fromthisassert Turo cannot be held liable by the City for alleged violations o violations alleged for City the by liable held be cannot Turo Turo cannot be held liable by the City for alleged violations o violations alleged for City the by liable held be cannot Turo o violations alleged for City the by liable held be cannot Turo This issueisproperlyresolved Turo seeks a declaratory judgment adjudicating this controversy this adjudicating judgment declaratory a seeks Turo actionagainstTuro. les Administrative C Administrative les exchange of cars at LAX. ofcarsatLAX. exchange weresetforthinfull. S impose chargesonTuroanditsU ECOND ECOND cy Act,47U.S.C.§230. (Declaratory Relief) C AUSE OF 24. et seq. byadeclarationfrom this Cour l carcompanies underCaliforni justiciable controversy now ex and every foregoing allegation foregoing every and ode thatallegedlyre ed liabilitybyvi allegedly resulting from the meeting of A C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT CTION

T rtue ofSectio O URO THER these meetings and has and meetings these sers thatapplyonly to eat Turo and its Users its and Turo eat sult from the meeting the from sult I NC s. LAX would hold R . ELIEF FOR FOR lcto o User of blication D ;

ECLARATORY ECLARATORY 2:18- ists between n 230 of the f California f t. f any other any f a law. f the LAX the f contained pursuant CV -6055 A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page25of28ID#:25 herein, as if saidallegations herein, asif herein, as if saidallegations herein, asif approval. taxes notapprovedbyvoters. all, is unlawful in that the Gross Receipts Charge and LAX Faci and LAX Facilities Charge, to the extent the latter is applicab Turo and the City concerning whether LAX’s attempt to levy the to 28U.S.C.§2201. Facilities ChargeorGrossReceip its and Turo compelling for Constitutions California and States § 50474.3and50474.21. companies, including but not limited to those identified in Cal to 28U.S.C.§2201.

111. 116. 112. 114. 113. 115. 107. 108. 109. 110.

Turo repeats and realleges each realleges and repeats Turo Turo repeats and realleges each realleges and repeats Turo As alleged herein, an actual and This issueisproperlyresolved v without taxes these Users its and Turo charge cannot City The Turo seeks a declaratory judgment adjudicating this controversy this adjudicating judgment declaratory a seeks Turo The City has no statutory or regulatory basis that is valid und r to pertinent charges pay to made be cannot Users its and Turo This issueisproperlyresolved Turo seeks a declaratory judgment adjudicating this controversy this adjudicating judgment declaratory a seeks Turo weresetforthinfull. weresetforthinfull.

F T OURTH OURTH HIRD (Declaratory Relief) (Declaratory Relief) ts Charge,orobtainarental C C AUSE OF AUSE OF AUSE 25. byadeclarationfrom this Cour byadeclarationfrom this Cour justiciable controversy now ex and every foregoing allegation foregoing every and and every foregoing allegation foregoing every and A C A J CTION UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT CTION

T le to Turo and its Users at at Users its and Turo to le ifornia Government Code O car company permit. URO THER lities Charge constitute Users to pay the LAX the pay to Users Gross Receipts Charge I NC R . ELIEF FOR FOR D ;

er the United United the er ECLARATORY ECLARATORY 2:18- ists between t. t. contained contained pursuant pursuant CV ental car ental -6055 oter A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page26of28ID#:26 herein, as if saidallegations herein, asif sr, ihu ay ainl ai fr on s. h Ct’ act City’s The improper collusionwithlarge multi-national motive rental and so. doing for basis rational any without users, similarly-situated di companies, including TNCs, taxi and limousin Users its and Turo treating purposefully or intentionally by the of 7 Section I, Article and 1983) § U.S.C. 42 to (pursuant S United the to Amendment Fourteenth the under protection equal Turo and the City concerning whether LAX has violated Turo’s an and its Users constitute an undue the Gross Receipts and LAX Facilities Charges that the City see Section 8 of the United States Constitution (pursuant to 42 U.S the concerning City the and Turo car companies. car companies. its Users need to pay the Gross Receipts and LAX Facilities Cha reas this For Users. its and Turo on clause commerce “dormant” i and Turo excessive inrelationtotheb by used facilities and services the of approximation to 28U.S.C.§2201.

121. 122. 117. 118. 119. 120.

Turo repeats and realleges each realleges and repeats Turo As alleged herein, an actual and As alleged herein, an actual and This issueisproperlyresolved th violate that charges unconstitutional impose cannot City The Turo seeks a declaratory judgment adjudicating this controversy this adjudicating judgment declaratory a seeks Turo weresetforthinfull. enefits conferreduponthem byLA F IFTH IFTH (Declaratory Relief) burden on interstate commerce “dormant” commerce clause embo clause commerce “dormant” C AUSE OF 26. byadeclarationfrom this Cour justiciable controversy now ex justiciable controversy now ex and every foregoing allegation foregoing every and A C J CTION UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT

T O URO .C. § 1983), and whether THER car companies. ks to recover from Turo California Constitution California X. , are not based on a fair rges pertinent to rental e companies, and their I frnl fo other from fferently on, neither Turo nor Turo neither on, NC d its Users’ rights to os ute exhibit further ions R s sr, n are and Users, ts . ELIEF tates Constitution tates FOR FOR died in Article I, I, Article in died D ;

ECLARATORY ECLARATORY 2:18- ists between ists between t. contained pursuant CV -6055 e A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page27of28ID#:27 to pay the Gross Receipts and L neither Thus, so. doing for basis rational a without treatment for allegedviolations for alleged violations of Califo of violations alleged for allegedly resultfromthe mee to 28U.S.C.§2201. approval; unl is that tax a constitute would Users its and Turo on Charge rental carcompanies orbeperm Faci LAX and Receipts Gross the including charges, pay to Users in CaliforniaGovernment li not but including companies, car rental to pertinent charges companies underCalifornialaw; stemming from publication ofUser statutory federal or state other any of violations alleged for allegedly resultingfr

123. WHEREFORE 124. 1. 125. 2. 7. 6. 5. 4. 3.

h Ct cno itninly r upsfly ujc Tr t d to Turo subject purposefully or intentionally cannot City The This issueisproperlyresolved Issue a declaratory judgment that Turo cannot be held liable by liable held be cannot Turo that judgment declaratory a Issue Issue a declaratory judgment that Turo cannot be held liable by liable held be cannot Turo that judgment declaratory a Issue controversy this adjudicating judgment declaratory a seeks Turo su a elrtr jdmn ta te moiin f h Gos R Gross the of imposition the that judgment declaratory a Issue Turo compel cannot City that that judgment declaratory a Issue Issue a declaratory judgment that Turo and its Users cannot be re not are Users its and Turo that judgment declaratory a Issue by liable held be cannot Turo that judgment declaratory a Issue om themeetingofTuroUsersatLAX; oftheLAXRulesand , Turorespectfullyrequ Code§50474.3and50474.21; ting ofTuroUsersatLAX; AX Facilities Charges pertinent itted asrentalcarcompanies; rnia Business and Professions C Professions and Business rnia P RAYER FOR FOR RAYER content thatleadstotheexc 27. byadeclarationfrom this Cour the LosAngelesAdm R ests thatthiscourt: ELIEF C J UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT

T O Turo nor its Users need need Users its nor Turo mited to those identified those to mited URO THER to rental car companies. r omn a claim law common or hange ofcarsatLAX. ode, § 17200 § ode, I wu wtot voter without awful NC inistrative Codethat R . ELIEF FOR FOR iis hre, as Charges, lities D ;

ECLARATORY ECLARATORY 2:18- made to pay t. pursuant the City the City the City CV tl car ntal isparate eceipts and its and -6055 et seq. A TTORNEYS TTORNEYS S C AN AN OOLEY F RANCISCO A LLP LLP 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 T 9 8 7 6 5 4 3 2 1 L AW

Case 2:18-cv-06055Document1Filed07/12/18Page28ofID#:28

h Gos eeps n LX aiiis hre priet o rent to because these charges violate t pertinent Charges Facilities LAX and Receipts Gross the cha th of clause “dormant” commerce these because Charges Facilities LAX and Receipts Gross the approval; unl is that tax a constitute would Users its and Turo on Charge of theFederalRulesCivilProcedure. Constitutions, asapplied; or interfering withsuchexchange vehicles exchanging from Users its and Turo prohibiting (b) and precluding the City from (a) compelling Turo to apply for a ren 176760538 Date

d : Ju 8. ajurytrial Turo herebydemands 10. 9. 11. 13. 12.

l y 12,2018 su a elrtr jdmn ta te moiin f h LX Fac LAX the of imposition the that judgment declaratory a Issue Issue a declaratory judgment that neither Turo nor its Users ne Users its nor Turo neither that judgment declaratory a Issue ne Users its nor Turo neither that judgment declaratory a Issue Grant any and all appropriate i Grant such other and further relief as this Court should find j Turoitsfeesandco Award D he equal protection clauses of t EMAND FOR FOR EMAND s, intheabsenceofsuchape e UnitedStatesConstitution,as onalltheissuessotriablep TURO INC. Attorneys forPlaintiff Matthew D.Brown COOLEY LLP /s/ MatthewD.Brown sts incurredherein;and 28. njunctive relief, including but J URY URY C J T UDGMENT AND UDGMENT AND OMPLAINT OF OF OMPLAINT RIAL

T he Federal and California O URO rmit; tal car company permit; THER at or near the airport, applied; I wu wtot voter without awful NC R ursuant to Rule 38 . ELIEF al car companies companies car al FOR FOR rges violate the the violate rges ust and proper. D ; not limited to

ECLARATORY ECLARATORY 2:18- ed to pay to ed pay to ed CV -6055 ilities Case 2:18-cv-06055 Document 1-1 Filed 07/12/18 Page 1 of 3 Page ID #:29

Exhibit 1

EXHIBIT 1 Page 29 Case 2:18-cv-06055 Document 1-1 Filed 07/12/18 Page 2 of 3 Page ID #:30

EXHIBIT 1 Page 30 Case 2:18-cv-06055 Document 1-1 Filed 07/12/18 Page 3 of 3 Page ID #:31

EXHIBIT 1 Page 31 Case 2:18-cv-06055 Document 1-2 Filed 07/12/18 Page 1 of 4 Page ID #:32

Exhibit 2

EXHIBIT 2 Page 32 Case 2:18-cv-06055 Document 1-2 Filed 07/12/18 Page 2 of 4 Page ID #:33

EXHIBIT 2 Page 33 Case 2:18-cv-06055 Document 1-2 Filed 07/12/18 Page 3 of 4 Page ID #:34

EXHIBIT 2 Page 34 Case 2:18-cv-06055 Document 1-2 Filed 07/12/18 Page 4 of 4 Page ID #:35

EXHIBIT 2 Page 35