Case 4:16-cv-02013-KAW Document 1 Filed 04/18/16 Page 1 of 26 1 Todd M. Logan (SBN 305912)
[email protected] 2 EDELSON PC 3 329 Bryant Street, Suite 2C San Francisco, California 94107 4 Tel: 415.212.9300 Fax: 415.373.9435 5 Jay Edelson* 6
[email protected] EDELSON PC 7 350 North LaSalle Street, 13th Floor Chicago, Illinois 60654 8 Tel: 312.589.6370 9 Fax: 312.589.6378 10 *Motion for admission pro hac vice to be filed 11 Counsel for Plaintiff and the Putative Class 12 IN THE UNITED STATES DISTRICT COURT 13 FOR THE NORTHERN DISTRICT OF CALIFORNIA 14 SAN FRANCISCO DIVISION 15 JUSTIN BAKER-RHETT, individually and Case No.: 16 on behalf of all others similarly situated, CLASS ACTION COMPLAINT 17 Plaintiff, FOR: 18 v. (1) Violations of Cal. Bus. & Prof. Code § 17500; 19 S. CARTER ENTERPRISES, LLC, a (2) Violations of Cal. Bus. & Prof. Delaware limited liability company, and Code §§ 17200, et seq.; 20 KANYE WEST, an individual, together (3) Fraudulent Inducement; and 21 d/b/a TIDAL, (4) Unjust Enrichment. 22 Defendants. DEMAND FOR JURY TRIAL 23 Plaintiff Justin Baker-Rhett brings this Class Action Complaint and Demand for Jury 24 Trial against Defendants S. Carter Enterprises, LLC (“SCE”) and Kanye West (collectively 25 “Defendants”), based upon their conduct of fraudulently inducing consumers to subscribe to 26 Tidal—a subscription-based music streaming service owned by Defendants. Plaintiff Baker- 27 28 CLASS ACTION COMPLAINT CASE NO. Case 4:16-cv-02013-KAW Document 1 Filed 04/18/16 Page 2 of 26 1 Rhett alleges as follows upon personal knowledge as to himself and his own acts and experiences 2 and, as to all other matters, upon information and belief, including investigation conducted by his 3 attorneys: 4 NATURE OF THE ACTION 5 1.