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Plaintiffs CASEY LOEWEN and JONATHAN WRIGHT, on behalf of themselves, and all others similarly situated, and the general public, file this Complaint against Defendant LYFT, INC., a Delaware corporation, and DOES 1 through 100 inclusive. Plaintiffs’ allegations are based upon information and belief and upon investigation of Plaintiffs’ counsel, except for allegations specifically pertaining to Plaintiffs, which are based upon Plaintiffs’ personal knowledge.
JURISDICTION & VENUE
1.
This Court has subject matter jurisdiction under the Class Action Fairness Act of 2005, 28 U.S.C. § 1332(d)(2)–(6), because there is (1) at least 100 class members, (2) minimal diversity, and (3) an amount in controversy that exceeds $5 million, exclusive of interest and costs. 2.
This Court has personal jurisdiction over Defendant LYFT, INC. because it is domiciled in the Northern District of California.
See Milliken v. Meyer
, 331 U.S. 457, 462–63 (1940). 3.
Venue is proper in the Northern District of California pursuant to 28 U.S.C. § 1391(b) and (c).
PARTIES
4.
Plaintiff CASEY LOEWEN (“LOEWEN”) is an individual who, at all times relevant herein, was a resident of San Diego, California. Plaintiff brings this action on behalf of himself, and the general public. 5.
Plaintiff JONATHAN WRIGHT (“WRIGHT”) is an individual who, at all times relevant herein, was a resident of Los Angeles, California. Plaintiff brings this action on behalf of himself, and the general public. 6.
Plaintiff LOEWEN and Plaintiff WRIGHT will collectively be referred to hereafter as “Plaintiffs.” 7.
Defendant LYFT, INC. is a corporation formed under the laws of Delaware, having its principal place of business at 2300 Harrison Street, San Francisco, California 94110.
Case3:15-cv-01159 Document1 Filed03/11/15 Page2 of 22