Jeffrey L. Fazio (SBN 146043)
Dina E. Micheltti (SBN 184141)
Hancock Rothert & Bunshoft
4 Embarcadero Center
San Francisco, CA 94111
Telephone: (415) 981-5550
Facsimile: (415) 955-2599
Andrew N. Friedman
Cohen, Milstein, Hausfeld & Toll, P.L.L.C.
West Tower, Suite 500
1100 New York Ave. NW
Washington, DC 20005
Telephone: (202) 408-4600
Facsimile: (202) 408-4699
[Additional counsel appear on the signature page”
Attorneys for Plaintiff
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
LEGAL STAFFING PARTNERS, INC. d/b/a JURIS RESOURCES., a North Carolina Corporation, Individually and as a Representative of all Parties or entities similarly situated,
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CLASS ACTION COMPLAINT FOR:
(1) BREACH OF CONTRACT;
(2) BUSINESS & PROFESSIONS CODE '17200; AND
(3) BUSINESS & PROFESSIONS CODE '17500.
JURY TRIAL DEMANDED
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1. Plaintiff, Legal Staffing Partners, Inc. ("plaintiff" or "LSP"), brings this action on behalf of itself and all others similarly situated throughout the United States, for breach of contract and violations of the Business & Professions Code '' 17200 et seq. and 17500 et seq. Plaintiff alleges the following on information and belief:
SUMMARY OF ACTION
2. This is a breach of contract and consumer protection class action on behalf of all persons and entities who made a "one-time payment" to LookSmart, Ltd. ("defendant" or "LookSmart") for listing services between May 13, 1998 to the present (the "Class Period"), and whose account was unilaterally changed by LookSmart to another type of service which requires additional payments. LookSmart is in the business of providing online marketing products for persons and businesses desiring targeted advertising. LookSmart offers online businesses the ability to list descriptive keywords of their products and services in LookSmart's searchable directory. LookSmart distributes the directory to leading Internet portals, Internet Service Providers (ISPs) and media companies where Internet users are able to make targeted searches yielding persons and businesses in LookSmart's directory.
3. This action arises out of defendant's dissemination of false and misleading statements about the cost of its services. During the Class Period, defendant represented that a "one-time payment" would satisfy all costs associated with its services. LookSmart breached that agreement when in 2002 it required additional payments for their services in the form of a new "pay-per-click" program.
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