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R. Rex Parris, Esq. (SBN 96567) rrparris@rrexparris.com Alexander R. Wheeler, Esq. (SBN 239541) awheeler@rrexparris.com Kitty Szeto, Esq. (SBN 258136) kszeto@rrexparris.com John M. Bickford, Esq. (SBN 280929)  jbickford@rrexparris.com 
R. REX PARRIS LAW FIRM
43364 10th Street West Lancaster, California 93534 Telephone: (661) 949-2595 Facsimile: (661) 949-7524 Daniel A. Carpio, Esq. (SBN 280818) carpio@dunnpi.com Michael B. Turner, Esq. (SBN 281229) turner@dunnpi.com 
DUNN & ASSOCIATES
854 Pico Boulevard Santa Monica, California 90405 Telephone: (310) 393-2769 Facsimile: (310) 396-7575 Attorneys for Plaintiffs and the Putative Class
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
CASEY LOEWEN and JONATHAN WRIGHT, individually, and on behalf of other members of the general public similarly situated, Plaintiffs, v. LYFT, INC., a Delaware corporation, and DOES 1 through 100, inclusive, Defendants. )) ) ) ) ) ) ) ) ) ) ) ) ) Case No.:
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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.
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8.
 
Plaintiffs are ignorant of the true names and capacities of defendants sued herein as DOES 1 through 100, inclusive, and therefore sue said defendants by such fictitious names. Plaintiffs will amend this complaint to allege the true names and capacities of DOES 1 through 100 when ascertained. Each of these fictitiously named defendants participated or acted in concert with Defendant LYFT, INC. and is therefore responsible in some manner for the acts, occurrences, and/or omissions alleged herein, and has thereby proximately caused damages to Plaintiffs and the class, and is liable to Plaintiffs and the class by reason of the facts alleged herein. 9.
 
Plaintiffs are informed and believe, and based thereon allege, that at all times herein mentioned, each of the defendants was the agent, partner, successor, or employee of Defendant LYFT, INC. and, in doing the things complained of herein, was acting within the course and scope of such agency, partnership, succession, or employment. All acts and omissions alleged to have been done by defendants, and each of them, were done with the consent, knowledge and ratification of all other defendants. 10.
 
Defendant LYFT, INC. and DOES 1 through 100 will collectively be referred to hereafter as “LYFT”.
FACTUAL ALLEGATIONS A. BACKGROUND FACTS
11.
 
LYFT is a San Francisco-based transportation network company that facilitates peer-to-peer ridesharing through its mobile-phone application by connecting  passengers who need a ride to drivers who have a car. Passengers use the app by entering their pickup address and where they would like a ride to. Once a LYFT driver accepts a passenger’s ride request, the app displays a photo of the driver and the car’s license plate number and model. The car arrives bearing LYFT’s signature pink mustache for easy identification. 12.
 
In order to become a LYFT driver, applicants need to fill out an application, take a “welcome ride,” and pass a background check, in that order. The
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