LifeLock 2015 Annual Report Download - page 269

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 111 of 289
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11. Plaintiff Napoleon Ebarle is a resident of California and subscriber, during all relevant times hereto, to LifeLock.
12. Plaintiff Jeanne Stamm is a resident of California and subscriber, during all relevant times hereto, to LifeLock.
13. Plaintiff Brian Litton is a resident of California and subscriber, during all relevant times hereto, to LifeLock.
14. Plaintiff Reiner Jerome Ebarle is a resident of California and subscriber, during all relevant times hereto, to LifeLock.
15. Defendant LifeLock is a Delaware corporation with its principal executive offices at 60 East Rio Salado Parkway, Suite 400, Tempe, Arizona
85281. LifeLock conducts business throughout California and the United States. It is currently estimated that LifeLock provides identity theft services to
over 3 million subscribers.
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16. This Court has subject matter jurisdiction over this action under the Class Action Fairness Act of 2005, which, inter alia, amends 28 U.S.C. §
1332 to add subsection (d), which confers jurisdiction over class actions where, as here, “any member of a class is a citizen of a State different from any other
Defendant,” and the aggregated amount in controversy exceeds five million dollars. See 28 U.S.C. § 1332(d)(2) and (6).
17. This Court has jurisdiction over Defendant because it does business in California and upon information and belief Defendant’s conduct that
gives rise to this complaint, as further described below, occurred within and/or was implemented, authorized, or ratified in California.
18. In accordance with 28 U.S.C. § 1391, venue is proper in this district because a substantial part of the conduct complained of herein occurred in
this District.
1279432.1 - 5 - AMENDED CLASS ACTION COMPLAINT
CASE NO. 3:15-CV-258