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Case 3:17-cv-01738-JSC Document 1 Filed 03/29/17 Page 1 of 32 1 Jack Stone Diamond Heights 1-101 Saiwai-chou 21-18 % 2 Kanagawa-ken, Chigasaki-shi 3 253-0052, Japan Phone: (81) 070-6951-2337 4 Email: email0stackjones.com 5 UNITED STATES DISTRICT COURT 6 NORTHERN DISTRICT OF CALIFORNIA 7 8 9 Jack Stone, c Cale'J^o. : e 10 11 COMPLAINT Plaintiff, 13 vs 14 15 Facebook Inc. And Subsidiaries (a Consolidated Group), et al. 16 17 18 Defendant 19 20 21 22 1. Par-ties In this Complain-k 23 24 a. Plaintiff. 25 Name: Jack Stone Address: Diamond Heights 1-101 Saiwai-chou 21-18 Kanagawa- 26 ken, Chigasaki-shi 253-0052, Japan 27 Telephone: (81) 070-6951-2337 28 Jack Stone vs. Facebook Inc. r et al. Complaint Page 1 Of 32 Case 3:17-cv-01738-JSC Document 1 Filed 03/29/17 Page 2 of 32 1 b. Defendants♦ 2 Name: Facebook Inc. and Subsidiaries (a Consolidated Group) 3 Address: 1 Hacker Way, Menlo Park, California 94025 Telephone: (1) 650-543-4800 4 Name: Mark Zuckerberg 5 Address: 1456 Edgewood Drive Palo Alto, California 94301 6 Telephone: (1) 650-543-4800 7 Name: Sheryl Sandberg Address: 1 Hacker Way, Menlo Park, California 94025 8 Telephone: (1) 650-543-4800 9 10 2. Jurisdiction 11 a. The plaintiff's case belongs in federal court under 12 13 Federal Question Jurisdiction because the action involves 14 federal laws and federal rights. The federal laws involved in 15 this matter include, 1.) Title 18, U.S. Code Part I, Chapter 33, 16 Section 701, 2.) First Amendment rights to free speech, and 17 access to a public forum under, Rosenherger v. Rector ana 18 19 Visitors of the University of Virginia, 515 U.S. 819 (1995) 20 where the Court held that a public forum does not have to be a 21 physical location, 3.) Fourteenth Amendment broad interpretation 22 of privacy rights. 4. Tort laws including fraud. 23 b. This case also belongs in federal court under Diversity 24 25 Jurisdiction all parties related to this matter do not reside in 26 the same state. The plaintiff resides in Chigasaki, Japan. The 27 defendant's principle place of business, and primary residences 28 Jack Stone vs. Facebook Inc., et al. Complaint Page 2 Of 32 Case 3:17-cv-01738-JSC Document 1 Filed 03/29/17 Page 3 of 32 1 are located in Menlo Park, in the county of San Mateo, 2 California. The amount in controversy is also more than $75,000. 3 4 3. Venue 5 The Northern District of California may hear this cause of 6 7 action because plaintiff's harm arose from conduct committed by 8 the defendants within the city of Menlo Park, located in the 9 county of San Mateo. Further, Facebook Inc. founder, chairman of 10 the board and chief executive officer, Mark Zuckerberg and chief 11 operating officer, director and member of Facebook Inc. equity 12 13 subcommittee, Sheryl Sandberg both have their primary residences 14 located in Menlo Park, which is a city located within the county 15 of San Mateo, in the state of California. 16 17 4 . In-tradistrict Assignment 18 This lawsuit should be assigned to San Francisco/Oakland 19 20 because the defendant's actionable conduct occurred in Menlo 21 Park, a city located inside the county of San Mateo, which is 22 where Facebook's principal place of business, and the primary 23 residences of the defendants named herein are located. 24 25 5. Statement of Facts and Claims 26 27 A. Coercion of private data, privacy violations and national 28 security. Facebook tracks users, reads private messages, cranes Jack Stone vs. Facebook Inc. ^ et al. Complaint Page 3 Of 32 Case 3:17-cv-01738-JSC Document 1 Filed 03/29/17 Page 4 of 32 1 informa-bion from those messages, and thereaf-ber provides that 2 information to marketers, and engages in surveillance for 3 government agencies in violation of Fourth Amendment warrant requirements. 4 5 Sal. On May 5^^, 2015, Facebook Inc. (Facebook) blocked 6 access to a Facebook page, http://facebook.com/stack.jones, 7 which the plaintiff had operated since January of 2009. Blocking 8 access to the page resulted in irreparable harm to the 9 10 plaintiff, including the loss of business contacts. This was not 11 the first time Facebook blocked access to the page in question. 12 Each blocking was committed for the sole purpose of coercing the 13 extraction of private information, including names, addresses, 14 and various forms of identification, including plaintiff's 15 16 photographic images that the company used for facial recognition 17 technology purposes. Thereafter, Facebook provided that private 18 information to third parties, including governmental agencies, 19 without informing the plaintiff, or obtaining informed consent. 20 21 5bl. The blocking of the page that took place on May 5^^, 22 2015 occurred mere minutes after the plaintiff had filed a 23 complaint with the company that photographic images of 24 25 plaintiff's fifteen-month-old infant child, which were placed in 26 a private folder, with restricted access, and not available to 27 the public, were displayed publicly on Facebook. 28 Jack Stone vs. Facebook Inc., et al. Complaint Page 4 Of 32 Case 3:17-cv-01738-JSC Document 1 Filed 03/29/17 Page 5 of 32 1 5cl. Facebook was reckless in allowing the images of the 2 plaintiff's child to be displayed publicly. Regardless, after 3 obtaining notice to remove said images from public viewing, 4 Facebook did not take any action whatsoever to have the 5 6 photographic images of the plaintiff s fifteen-month-old infant 7 child removed from public viewing, but instead responded by 8 blocking plaintiff's access to http://facebook.com/stack.jones. 9 10 5dl. The blocking of the page was retaliatory in nature, 11 and resulted in preventing the plaintiff from obtaining access 12 to more than 1200 contacts, including phone numbers, email 13 addresses, and physical addresses. The blocking also prevented 14 the plaintiff from being able to communicate with business 15 16 entities, family members and friends. 17 5el. The blocking of the page in question also prevented 18 19 the plaintiff from taking the necessary steps to ensure the 20 photographic images of plaintiff's infant child were removed 21 from public viewing, as access to Facebook is blocked from those 22 that do not have a Facebook account. 23 24 5fl. Facebook permitting photographic images of the 25 plaintiff's infant child to be viewed publicly, resulted in an 26 invasion of privacy. Facebook's has a history of disregard for 27 28 end user rights, and the company unceasingly invades the right Jack Stone vs. Facebook Inc. ^ et al. Complaint Page 5 Of 32 Case 3:17-cv-01738-JSC Document 1 Filed 03/29/17 Page 6 of 32 1 Of privacy, and is the subject of numerous class action suits. 2 5gl. The plaintiff contacted Facebook's Appeals Department, 3 4 and was subjected to endless harassment, that included Facebook 5 demanding the plaintiff ^'identify'' himself by providing two 6 copies of United States government issued forms on 7 identification, including passport and other forms of 8 identification in violation of Title 18, U.S. Code Part I, 9 10 Chapter 33, Section 701. 11 5hl. Other forms of identification Facebook demanded 12 13 include copies of military identification, social security 14 cards, green cards, voter identification, driver licenses, 15 credit cards, bank statements, medical records, marriage 16 certificates, insurance cards, paycheck stubs, utility bills, 17 yearbook photos, etc. Facebook demanded photographic images be 18 19 attached to these forms of identification. These demands were 20 legally impossible as nearly none of these forms of 21 identification, including social security cards, or marriage 22 certificates have photographic images imbedded in them. 23 24 5il. Title 18, U.S. Code Part I, Chapter 33, Section 701, 25 makes it a crime punishable by fine and imprisonment of up to 26 six months for each offense for photocopying much of the 27 28 Jack stone vs. Facebook Inc., et al. Complaint Page 6 Of 32 Case 3:17-cv-01738-JSC Document 1 Filed 03/29/17 Page 7 of 32 1 documentation Facebook had demanded the plaintiff turn over to 2 the company. Title 18, U.S. Code Part I, Chapter 33, Section 701 3 does not permit government issued identification photocopied, 4 and turned over to any third party for any purpose whatsoever. 5 6 This would especially apply to Facebook where the company is 7 notoriously known for failing to recognize the right of privacy, 8 and where the company has been providing that private data to 9 marketers, and other entities, including governmental agencies 10 without prior prior knowledge, or consent. 11 12 5jl. The plaintiff refused to be coerced by Facebook into 13 submitting the demanded private data citing. Title 18, U.S. Code 14 Part I, Chapter 33, Section 701, stating that doing so could 15 16 result in the plaintiff being convicted of crimes, and that said 17 convictions could result in both fines and imprisonment of up to 18 six months for each offense. Regardless, Facebook, continued to 19 demand the plaintiff to turn over copies of federally issued 20 forms of identification in violation of Title 18, U.S. Code Part 21 22 I, Chapter 33, Section 701. Facebook continued to refuse to 23 reinstate plaintiff's access to http://facebook.com/stack.jones, 24 and continues to coerce other end users to violate federal law 25 related to Title 18, U.S.
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