20SMCV00748

Assigned for all purposes to: Santa Monica Courthouse, Judicial Officer: Elaine Mandel

Electronically FILED by Superior Court of California, County of Los Angeles on 05/29/2020 04:55 PM Sherri R. Carter, Executive Officer/Clerk of Court, by B. McClendon,Deputy Clerk

BRUCE H. SlNGMAN Pro Se (State Bar No: 58317)

Post Office Box 1350
2 Pacific Palisades, California 90272
Phone: (310) 486-0995
3 Email: brucesingman@eartWink.net

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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 COUNTY OF LOS ANGELES

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l1 BRUCE H. SINGMAN )CASE NO:

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Plaintiff )COMPLAINT FOR DECLARATORY
13 )RELIEF
)
14 V. )
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lMDB.COM, INC. and DOES I through 10, )
16 inclusive. )
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17 Defendants. )JUDGE:
) DEPT.:
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COMES NOW, PLAINTIFF BRUCE H. SINGMAN and alleges and complains as follows:
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INTRODUCTION
This Complaint consists of a cause of action brought by Plaintiff BRUCE H. SINGMAN
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. ("Plaintiff') against Defendant IMDB.COM, INC. ("Defendant") resulting from Defendant's
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failure to make the changes and deletions to correct the listing of Plaintifl's action adventure
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science fiction foature film "Warrior" on Defendant IMDB.COM's Internet Web Site !MOB.com
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providing for the listing of the title of the movie as is without the attachment of a date to the title
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27 in the heading of the listing unless the title of a movie is similar to titles of other movies listed and
then the date of the release of the movie to the public shall be listed along side of the title of the
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COMPLAINT FOR DECLARATORY RcLlff

 1 movie in the heading of the listing. ln the instant case, Plaintiff has not yet released his movie

2 "Warrior" to th.e public and Defendant IMDB.COM, INC. has wrongfully attached to the listing of
3 the title "Warrior" in the heading of the listing of the movie the year 2002 in parentheses. Such
4 wrongful listing of (2002) alongside of the title "Warrior'' misleads film distributors and buyers
5 and licensees to believe that the rights to exhibit and sell the movie have been sold and licensed
6 since the year 2002. Plaintiff brings this action to cause Defendant to change the date of 2002

7 attached to the title "Warrior" to the date 2020 in anticipation of the release of the movie to the
8 public during the year 2020 if and when Defendant makes such date change and other correlative
9 changes to correct mistakes made in the listing of the movie as included within the Prayer of this
10 Complaint and/or to recover the damages Plaintiff is suffering as a result of Defendant's failure

11 and refusal to make such date change and correlative changes and deletions as set forth in the
12 Prayer of this Complaint
13 THE PAR.TIES
14 I. Plaintiff BRUCE H. SINGMAN (hereinafter "Plaintiff BRUCE H. SINGMAN") is
15 and, at all times mentioned herein, was an individual who resides in the County of Los Angeles,
16 Cities of Pacific Palisades and Torrance and El Monte in the State of California.

17 2. Plaintiff is informed and believes and on that basis alleges that Defendant IMDB.COM,
18 INC. (hereinafter "Defendant !MOB.COM, INC.") is, and at all times mentioned herein was, a

19 Corporation organized under the laws of the State of Washington and doing business in the
20 County of Los Angeles and City of Los Angeles in the State of California as an Internet Movie

21 Data Base.
22 3. The true names and capacities, whether individual, corporate, associate or
23 otherwise of Defendants named herein as Does I through I0, inclusive, are unknown to Plaintiff
24 who therefore sues these Defendants by such fictitious names. Plaintiff will amend this Complaint
25 to show the tme names and capacities of these Defendants when the same have been ascertained.
26 Plaintiff is informed and believes that each fictitiously named Defendant is responsible ,in law and
27 in fact for the obligations alleged herein.
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COMPLAINT FOR DECLARATORY R.1::LIEF
 l 4. Plaintiff is informed and believes and thereon alleges that, at all relevant times,
2 each of the Defendants was acting within the course and scope of his or her or its age11cy and/or

3 employment Upon such information and belief, Plaintiff alleges that each of the Defendants,
4 including the factiously name Defendants, are liable to Plaintiff based on the facts alleged herein.

s VENUE AND JURISDICTION

6 5. This Court bas jurisdiction over this action and venue is proper in this Court
7 pursuant to California Code of Civil Procedure sections 395(a) and 395.5 because (a) the events,

8 acts and/or omissions which are the subject of this lawsuit were made and/or were to be performed
9 within this County; and/or (b) Plaintiff resides in Los Angeles County and a significant portion of

IO the events, acts and/or omissions referred to herein occurred in this County or had the proximate
11 effect of causing damage to Plaintiff in this County. Each Defendant is doing busirwss in and
12 transacts business in the County of Los Angeles and is within the jurisdiction of this Court for
13 purposes of service of process. The transaction or occurrence occurred in the County of Los
14 Angeles in California.
15 STATEMENT OF FACTS COMMON TO ALL CLAIMS FOR RELIEF

16 6. Plaintiff BRUCE H. SINGMAN is a graduate of the University of Illinois in

17 Champai1,rn-Urbana, Illinois and has a B.S. Degree in Political Science and is a graduate of the
18 University of California School of Law in Berkeley, California and has a J.D. Degree and is an
19 attorney licensed to practice law in the State of California and pi:actices law in the County of Los
20 Angeles, State of California As a result of having represented National Football Leagµe players,
21 Plaintiff BRUCE H. SfNGMAN became an owner of a video production company on about

22 September of 1994 then based in the City of Burbank, State of California and created, wrote and

23 produced audio/video programs for home entertainment and television broadcast in which

24 National Football League and National Basketball Association players and coaches and

25 automobile racing champions demonstrate their skills and techniques and share their Iife stories.
26 7. As a result of bis production of such audio/video programs, Plaintiff BRUCE H.
27 SINGMAN produced an action adventure science fiction feature film entitled "Warrior" and

28 completed the production of the film in 2002. In the course of completing production of

COMPLAINT FOR DECLARATORY RELTF.F

 1 "Warrior", Plaintiff BRUCE H. SINGMAN sought and received loan funds from an individual,
2 who was desirous of distributing foatur.e fihns, for the production of the last four days of the

3 thirty-five days of production of "Warrior". Without Plaintiff BRUCE H. SINGMAN's

4 knowledge or authority, such lend~r delivered a file of the completed film "Warrior" to Tanya

5 York of York Entertainment of Los Angeles County, who was acting under the guise of a film

6 distributor. and Tanya York stole the file of the film "Warrior" and in the course of her

7 wrongdoing used the name Mexican Blow in place of the name "Warrior" in a feeble attempt to

8 conceal such theft as she posted a v ideo of Plaintiff BRUCE H. SINGMAN's feature film

9 "Warrior" under the title of Mexican Blow for sale on AMAZON.COM, INC.'s Web Site.

10 AMAZON.COM, INC. is the owner of Defendant IMDB.COM, INC.

11 8. Plaintiff BRUCE H. SINGMAN listed his feature film "Warrior" under the title

12 "Warrior" on the IMDB.com Web Site and, without Plaintiff's knowledge or authority, Defendant

13 !MOB.COM, INC. added (2002) to the title of Warrior in the heading of the listing of Warrior on

14 Defendant IMDB.COM, INC.'s Web Site, apparently for the purpose of distinguishij g Plaintiff

15 BRUCE H. SINGMAN's movie "Warrior" from other feature films !fated on Defendant
16 IMDB.COM, INC.' s Web Site with the name Warrior in the title of such other films.

17 9. As Plaintiff BRUCE H. SINGMAN discovered, in accord with a policy of

18 Defendant IMOB.COM, INC. 's Web Site, the year listed alongside of the title of a movie in the
19 heading of the listing of movies on Defendant IMDB.COM, INC.'s Web Site is deemed by

20 Defendant IMDB.COM, INC. to be the date of the "release to the public" of a movie listed on
21 Defendant IMDB.COM, lNC.'s Web Site even though such movie may not yet have been released

22 to the public though could have been screened for the filmmaker' s family and friends, cast and

23 crew and fellow members of the film industry, as Plaintiff's movie "Warrior" was screened for

24 his family and friends, cast and crew and fellow members of the fihn industry.

25 Plaintiff BRUCE II. SINGMAN, in the midst of his continuing law p acticc and

26 efforts to sell the videos of the skill demonstration/life story programs of his All Pro Sports

27 Football Series (h!m://www.allprosportsfoothallseries.com), All Pro Sports Basketball Series and

28 All Pro Sports Driving Series (hereinafter "All Pro Sports Series") and products imp~nted with

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COMPLAINT FOR DECLARATORY RF.T .TEF
 1 the autographs and his artist's illustrations of the iconic National Football League and National

2 Basketball Association players and coaches and automobile racing champions featured in the

3 aforementioned All Pro Sports Series (hereinafter "All Pro Sports Designs"), sought a distributor

4 for his feature film " Warrior" amongst the dozens of those who profess to be skilled and

5 experienced in the art of feature film distribution.

6 11. On or about September 20, 2018, Plaintiff BRUCE H. SINGMAN entered into a
7 Film Distribution Agreement with the successful and experienced film distribytor Acort

8 International, a subsidiary of Maxim Media Marketing, Inc. based in Tempe, Arizona, for the

9 distribution of his feature film "Warrior" and shipped to Acort International the "deliverables"

10 required to be delivered by Plaintiff to Acort International including a very expeT ive High

11 Definition file of" Warrior". Shortly after the execution of the aforementioned Agreement, Darrin

12 Ramage, the President of Acort International discovered the (2002) set alongside of the title of his

13 feature film "Warrior'' in the heading of the listing of "Warrior" on Defendant If1DB.COM,

14 INC.'s !MOB.com Web Site, which, as stated herein, connotes the date of the "relJase to the

15 public" of a film listed on Defendant !MOB.COM, JNC.'s !MOB.com Web Site. ~- Ramage

16 transmitted correspondence through email to Plaintiff BRUCE H. SINGMAN in 2018 advising

17 Plaintiff that he would not proceed with the distribution of Plaintiff's feature film "Warrior''

18 unless and until the (2002) set forth alongside of the title of "Warrior'' in the heading of the listing

19 of"Warrior'' on the IMDB.com Web Site is deleted or replaced by a year such as 2018 or 2019

20 along with other correlative changes and deletions to the listing of Plaintiff's feature film
21 "Warrior'', which would conform to the fact that "Warrior" has nothing to do with the fictitious

22 name Mexican Blow and that Plaintiffs feature film " Warrior" has not yet been "rele115ed to the

23 public".

24 12. Plaintiff BRUCE H. SINGMAN immediately commenced to send extensive and

25 comprehensive correspondence to the owners and Chief Executive Officers of AMAZON.COM,

26 INC. and Defendant IMDB.COM, INC. through email, regular and priority US Mail, facsimiles

27 and FedEx and the Edit Page function of Defendant IMDB.COM, INC.'s JMDB.col Web Site
28 providing the legal and logical reasoning as to why the year 2002 alongside of the title "Warrior"

COMPLAINT FOR DECLARATORY RELIEF

 1 in the heading of the listing on Defendant lMDB.COM, INC's IMOB.com Web Site should be

2 deleted and replaced by the year 2019 as Plaintiff's feature film "Warrior'' bas not yet been
3 "released to the public" along with all of the other changes and deletions which are correlative to

4 the change from 2002 to 2019 for the (to be) date of the release to tbe public of Plaintiff's feature
5 film "Warrior".

6 13. After several weeks of failure and refusal of the owne.rs and Chief Executive

7 Officers of AMAZON.COM, INC. and Defendant IMDB.COM, INC. to respond to Plaintiffs

8 aforementioned correspondence, Plaintiff BRUCE H. SINGMAN received by email
9 correspondence from Noah Eisner, House Counsel for Defendant AMAZON.COM, INC.,
10 correspondence, which failed to refute the legal and logical reasoning of Plaintift"s position that

11 his movie "Warrior" has never been released to the public and that the year 2002 along'side of the
12 title "Warrior" in the heading of the listing on Defendant IMDB.COM's IMDB.coJ Web Site

13 should be deleted and replaced by the year 2019, as Plaintiffs feature film "Warrior" fas not yet
14 been "1:eleased to the public" along wid1 all of the other changes and deletioos b.ich are
15 correlattve to the change from 2002 to 2019 for the (to be) date of the release to th public of

16 Plaintiffs feature film "Warrior'', which should be made by AMAZON.COM, INC. and
17 Defendant IMDB.COM, INC. Plaintiff BRUCE H. SINGMAN immediately respon1ed to Mr.

18 Eisner's email correspondence by sending correspondence by email and US Regular ~ail to Mr.
19 Eisner demonstrating why his email correspondence failed to refute the legal and logical reasoning

20 as to why the changes and deletions Plaintiff was requesting should be made by AMAZON.COM,
21 INC. and Defendant !MOB.COM, INC. and advised Mr. Eisner that Plaintiff would be
22 commencing legal action against AMAZON.COM, INC. and Defendant lMDB.COM, INC. for

23 the damages Plaintiff is suffering as a result of AMAZON.COM, INC. 's and pefondant
24 !MOB.COM, INC.'s failure and refusal to make the correlative changes and deletions to the listing
25 of Plaintiff's movie "Warrior" on Defendant IMDB.COM, INC.'s IMDB.com Web Site.
26 IllIIfIllIf//f/f /////f/IllI/III!!!ffIIIIf/ff/f/ff/ff

27 ////If!fl/flIllf II/IfI If//fl/flII/flIllI/IfIIf!fl/I/I//I/

28 IIIIIIIIIIIII!/flIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIfIIIIIIIIIIIIIIIIIIIIIIIIIIIf

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COMPLAINT FOR DECLARATORY RF.LIEF
 1 FIRST CAUSE OF ACTION
2 Declaratory Relief
3 14. Plaintiff re-alleges and incorporates by reference each and every allegation

4 contained in Paragraphs 1. through 18. set forth herein-above.

5 15. An actual controversy has arisen and now exists between Plaintiff and Defendant

6 concerning their respective rights and duties in that Plaintiff contends that: he has not yet released
7 his feature film "Warrior" to the public and the date (2002) should not have been set alongside of
8 the title of the feature film "Warrior" in the heading of the first page of the listing of the movie
9 "Warrior" on IMDB.com and that, if any date needs to accompany the title "Warrior" in the
10 beading of the listing of the movie at IMDB.com that date should be (2020); he has never changed

11 the title or authorized anyone else to change the title of the movie to Mexican Blow qr any title
12 other than ''Warrior"; and that he engaged Acort International in 2018 to distribute his ftture film
13 "Warrior", but that Darrin Ramage, the President of Acort International, refused to proceed with

14 the distribution of" Warrior" upon discovery of the date (2002) alongside of the title "Warrior" in
15 the beading of the listing of the movie on !MOB.com as he claimed that he would not be able to

16 and would not make an effort to distribute "Warrior" because of the date (2002) set ~ongside of
17 the title "Warrior" in the heading of the listing of "Warrior" on IMDB.com. Defendant
18 IMDB.COM, INC., without knowing the facts of the theft of a file of the feature film " 'Y'arrior" by
19 Tanya York of York Entertainment and without the knowledge of Plaintiff and Tanya York's

20 attempt to conceal such theft by wrongfully and without the knowledge and/or authorization of

21 Plaintiff changing the name of the movie "Warrior" to Mexican Blow, set the dkte (2002)
22 alongside of the title of the movie "Warrior" in the heading of the listing of the movie "Warrior"

23 011 IMDB.com. Consequently, Defendant IMDB.COM, INC. wrongfully insists that the date of
24 the release of "Warrior" to the public is (2002) and refuses to delete the date of (2002) alongside
25 of the title of"Warrior" i.n the heading of the listing of" Warrior" on IMDB.com or to f hange the

26 date of (2002) to the date of 2020 so that Plaintiff is able to cause the distribution of his feature
27 film " Warrior".
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COMPLA INT FOR DECLARATORY RELIEF
 1 16. A judicial determination of these issues and the duty of Defendant t make the

2 changes and deletions Plaintiff has requested is necessary and appropriate at this time under the

3 circumstances so that Plaintiff may cause the distribution of his feature film "Warriorr by Acort

4 International or another feature film distribution company if Acort International is unwilling at this

5 time to distribute Plaintiff's feature film "Warrior".

6 17. As a result of Defendant's refusal to make the changes and deletions sought by

7 Plaintiff as herein alleged, Plaintiff is entitled to the payment to him in the amount of Five

8 Hundred Million Dollars ($500,000,000) with interest thereon.

9 23. As a direct and proximate cause of Defendant's refusal to make the changes and

10 deletions sought by Plaintiff as herein alleged, Plaintiff has been damaged in an amount to be

JI proven at trial of no less than Five Hundred Million Dollars ($500,000,000).

12 PRAYER

13 WHEREFORE, Plaintiff prays for judgment against Defendant as follows:

14 1. The change to the date of the release of"Warrior" to the public from 2002 to 2020;

15 2. the correlative change of the heading in the listing of "Warrior"

16 on !MOB.com from "Warrior" (2002) to "Warrior" (2020);

17 3. the deletion of"aka Mexican Blow" in the Details Section of the listing

18 of "Warrior" on IMDB.com;
19 4. the deletion of all of those listed under Distributors along with the information

20 following the names i.e. Palisades Productions, XVIII Entertainment and York Entertairent;

21 5. the deletion of the Reviews of the movie "Warrior" under User Reviews;

22 6. For damages in favor of Plaintiff in an amount to be determined at trial;

23 7. For pre-judgment interest on any recovery by Plaintiff;

24 8. For expenses of suit incurred herewith;

25 9. For reasonable attorney's fees; and

26 I0. For such other relief as the Court may deem just and proper.

21 I/Ill/II/I

28 Ill/II/II

COMPLAINT FOR DEC LARATORY RELIEF

 I DATED: May 29,_2020
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6 VERIFICATION
l, BRUCE H. SINGMAN, am the Plaintiff in the above entitled action. l have read the oregoing
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complaint and know the contents thereof. The same is true of my own knowledge, except as to
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those matters which are the(ein alleged on information and belief and, as to those matte7 , I
9 believe them to be true.
10 I declare under penalty of perjury under the laws of the State of California that the
11 foregoing is true and correct.
Executed this 29th day of May, 2020 in Los Angeles, California.
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tR~CE H. SINGMAN
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COMPLAINT FOR DECLARATORY RELIEF