Jeffrey M. Kurzon (#JM3388)
[email protected] Jesse Strauss (#JS0212)
[email protected] Attorneys for Plaintiffs and the Classes Kurzon Strauss LLP 305 Broadway, 9 FL New York, NY 10007 212-822-1496 www.KurzonStrauss.com IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Jonathan Tasini, Molly Secours, Tara ECF CASE Dublin, Richard Laermer and Billy Altman, individually and on behalf of all CIVIL ACTION: 11 CV 2472 (JGK) others similarly situated, Plaintiffs, FIRST AMENDED CLASS ACTION COMPLAINT v. AOL Inc., TheHuffintonPost.Com, Inc., JURY TRIAL DEMANDED Arianna Huffington and Kenneth Lerer Defendants. CLASS ACTION COMPLAINT Plaintiffs and putative Class Representatives Jonathan Tasini (“Tasini”), Molly Secours (“Secours”), Tara Dublin (“Dublin”), Richard Laermer (“Laermer”) and Billy Altman (“Altman”) (Tasini, Secours, Dublin, Laermer and Altman, together, the “Plaintiffs”), bring this action both individually and on behalf of damages and injunctive relief classes (collectively, “the Classes,” as further defined herein), alleging as for their Class Action Complaint against Defendants AOL Inc. (“AOL”), TheHuffingtonPost.com, Inc. (“TheHuffingtonPost.com”), Arianna Huffington (“Huffington”) and Kenneth Lerer (“Lerer”) (AOL, TheHuffingtonPost.com, Huffington and Lerer, together, and as the context so merits, the “Defendants”), upon personal knowledge as to themselves and as to all other matters upon information and belief, based on, inter alia, the investigation made by their attorneys signed below, as follows: