Complaint Harlan Ellison in Time

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DRINKER BIDDLE & REATl-I LLP
Cl11;'istopher F. Wong (SBN 142507)
chns. worm@dbr.com
Adam J. Thurston (SBN 162636)
adam. com
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Ryan R. Salsig,1SBN 250830)
4 ryan.salsig@dbr.com
1800 Century Park East, Suite 1400
Los Angeles, California 90067-1517
Telephone: (310) 203-4000
Facslmile: (310) 229-1285
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Attorneys for Plaintiff
The Kil1manjaro Corporation
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UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
13 THE KILIMANJARO
CORPORA 110N. a California
14 Corporation.
07 5 i f;3C<)
C01v1PLAINT FOR COPYRIGHT
INFRINGEMENT AND
DECLARATORY RELIEF 15 Plai ntiff,
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v.
NEW REGENCY PRODUCTIONS,
INC., a California corporationi
ANDREW NICCOL, an indiVIdual;
and DOES 1 through 10. inclusive,
Defendants.
JURy TRIAL DEMAND
Plaintiff The Kilimaltjaro Corporation ("TKC' or "Plaintiff') hereby alleges
the following claims for relief against defend'ants New Regency Productions, Inc.
("Regency"), Andrew Niccol and Does 1 through \ 0, inclusive
(collectively,
JURISDICTION AND VENUE
1. This Court has original subject matter jurisdiction over this Ilction and
the claims asserted herein, pursuant to 28 U.S.C. 1331 ("federal question
DRINK6R &: l.AOIII04:i'905.1
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A.TTIJKI'IIII'I'P. ",T tAW
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COMPLAINT FOR COPYRIGHT lNFRINOEMENT AND.TURV TRIAL DEMAND
Case 2:11-cv-07575-JFW -JC Document 1 Filed 09/14/11 Page 1 of 16 Page ID #:5
jurisdiction") and 1338(a) (actions arising under any Act of Congress relating to
2 copyright), in that this action arises under the laws of the United States and, more
3 specifically, Acts of Congress relating to copyrights.
4 2. Defendants are subject to personal jurisdiction of the Court because
5 they reside, have agents, do or transact business, or are othelwise found, and have
6 purposefully availed themselves of the privilege of doing business, in California
7 and this District.
8 3. Venue is proper in this District pursuant to 28 U.S.C. 1400(a)
9 because Defendants have a regular and established place of business in this District
10 and may be found in this District. Venue is also proper in this District pursuant to
11 28 U.S.C. 1391(b)(2) because a substantial part of the events or omissions giving
12 rise to the claims occurred in this District and a substantial part of the property that
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is the subject of this action is situated in this District. Alternatively, venue is also
proper in this District pursuant to 28 U.S.C. 1391(b)(3) because Defendants have
a regular and established place of business in this District and may be found in this
District.
THE PARTIES
4. At all times material hereto, Plaintiff TKC was a California
corporation with its principal place of business in Sherman Oaks, California, duly
authorized to do and doing business in this District. At all times material hereto,
TKC has been engaged in the business of, among other things, holding, distributing,
copying, licensing and otherwise exploiting the copyrighted works of Harlan
Ellison, including without limitation, for adaptation into television programs,
feature films and other formats. Harlan Ellison is the President of TKC.
5. TKC is informed and believes and thereon alleges that defendant
Niccol is an individual residing and doing business in this District. TKC is
informed and believes and thereon alleges that defendant Niccol wrote the
screenplay for a feature length motion picture entitled I'm.Mortal, and sold,
DRINKER BIDDLE & LAOII 1045905. 1 - 2 -
REATH LLP
ATTORNEYS AT LAW
Los ANGELES
COMPLAINT FOR COPYRIGHT INFRINGEMENT AND JURY TRIAL DEMAND
1 licensed, or otherwise authorized defendant Regency to use it to make the motion
2 picture entitled In Time, as more fully alleged below.
3 6. TKC is informed and believes and thereon alleges that defendant
4 Regency is a California corporation with its principal place of business in Los
5 Angeles, California, doing business in this District. At all times material hereto,
6 Regency has been engaged in the business of, among other things, developing,
7 producing and distributing feature films.
8 7. The true names and capacities, whether individual, corporate, partner,
9 associate, agent, employee, or otherwise, of the defendants named in this complaint
10 as Does 1 through 10, inclusive, are unknown to TKC, which therefore sues such
11 defendants by such fictitious names. TKC will amend this complaint to show the
12 true names and capacities of the Doe defendants when it has ascertained the same.
13 TKC is informed and believes and on that basis alleges that, at all relevant times,
14 Does 1 through 10, inclusive, are responsible in some manner for the conduct
15 herein alleged and proximately caused TKC's damages. TKC is informed and
16 believes and on that basis alleges that, at all relevant times, Does 1 through 10,
17 inclusive, and each of them, were the agents of, and/or were acting in concert with,
18 each of the remaining defendants and, in doing the things alleged, were acting
19 within the scope of such agency. Any reference to any of the named defendants
20 herein shall also constitute a reference to the Doe defendants.
21 FACTUAL BACKGROUND
22 8. Harlan Ellison is one of the most celebrated science fiction writers of
23 our time, and has won more awards for his science fiction writing than any other
24 living author, including the Hugo award (eight and a halftimes), Nebula (four
25 times), Bram Stoker (six times), Edgar (two times), the Writers Guild of America
26 A ward (four times), and many others.
27 9. Harlan Ellison is the author of "Repent, Harlequin!" Said the
28 Ticktockman (hereafter, "Repent, Harlequin!"), one of the most famous and widely
DRINKER BIDDLE &
REATH LLP
LA01 / 1045905.l - 3 -
ATTORNEYS AT LAW
Los ANGEl. E5
1 published science fiction short stories ever written. Repent, Harlequin! won the
2 1966 Hugo Award for best short story, as well as the 1965 Nebula Award. It has
3 been translated into rmmerous foreign languages and published throughout the
4 world. It is also among the most reprinted short stories in the English language.
5 Repent, Harlequin! was first published in 1965 and is registered with the United
6 States Copyright Office under registration number B217120, which was duly
7 renewed in December 1993 under renewal number RE648724.
8 10. By a fully executed written agreement dated July 19,2001, and
9 recorded with the United States Copyright Office, Harlan Ellison transferred all
10 right, title and interest in Repent, Harlequin! to TKC. As a result of this transfer,
11 TKC owns the copyrights in and to Repent, Harlequin!.
12 11. Over the years, Mr. Ellison has been approached on numerous
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occasions with requests for permission to adapt Repent, Harlequin! into a feature
film but, until recently, Mr. Ellison has declined. In or around November 2010,
TKC entered into an agreement with a third party to create a screenplay based upon
Repent, Harlequin!, suitable for sale or license to a studio for the creation of a
feature length motion picture. The screenplay has been written and is ready to
present to studios.
12. However, the value and marketability of the screenplay authorized by
TKC has been and will be seriously and irreparably degraded by the creation,
marketing and release of an unauthorized feature film by Regency entitled In Time,
which infringes TKC's copyright in Repent, Harlequin! In Time is scheduled to be
released in theaters on October 28, 2011.
13. Repent, Harlequin! is one ofMr. Ellison's most famous works and his
most precious assets. It is truly outrageous that Andrew Niccol and Regency have
gone behind his back to create a movie based on this iconic and valuable work
without any attempt to obtain his authorization or to accord him credit.
14. The similarity between In Time and Repent, Harlequin! is obvious and,
DRINKER BIDDLE & LA01/1045905.1 - 4-
REATH LLP
ATTORNEYS AT LAW
Los ANGELES
1 indeed, widely noted by critics who have seen advanced screenings. For example,
2 Richard Roeper states in his Fall Movie Preview that "In Time is based on a
3 brilliant story by the great Harlan Ellison .... " Similarly, the E-Street preview
4 states that In Time is "[b]ased on the Harlan Ellison story 'Repent, Harlequin, said
5 the Ticktockman .... '"
6 15. In Time copies key plot elements, themes, characters, events,
7 sequences and settings of Repent, Harlequin!, including without limitation, the
8 following:
9 a. Repent, Harlequin! takes place in a dystopian corporate future in
10 which everyone is allotted a specific amount of time to live. The
11 precise amount of time each person has left to live is known,
12 tracked on a time card, and subject to monitoring by a government
13 authority known as the "Master Timekeeper." In Time also takes
14 place in a dystopian corporate future in which everyone is allotted a
15 specific amount of time to live. The precise amount of time each
16 person has left to live is known, tracked on a luminescent clock
17 displayed on the ann, and subject to monitoring by a govermnent
18 authority known as the "Senior Timekeeper."
19 b. In Repent, Harlequin!, the amount of time an individual has left to
20 live may be manipulated, and breaking the rules of society results
21 in the deduction of time from the perpetrator's life. For example,
22 tardiness to work results in revocation of a commensurate amount
23 of time from one's life. Similarly, in In Time, the amount of time
24 one has left to live may be manipulated, and violations are punished
25 by deducting time from the perpetrator's life, such as for tardiness
26 to work or failure to meet one's quota.
27 c. In Repent, Harlequin!, when one's allotted time to live has expired,
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DRINKER BIDDLE & LA01/1045905.1
instant death occurs by stoppage of the heart. This is precisely
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REATH LLP ----------------------------------1
ATTOKNEYS AT L AW
COMPLAINT FOR COPYRIGHT INFRINGEMENT AND JURY TRlAL DEMAND
Los ANCf.I. ES
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AT LAW
Los ANGELES
LAOl! 1045905. 1
what happens to In Time characters, as well.
d. In Repent, IIarlequin!, the constant threat of advancing the time of
one's death by time revocation is the system used to force
conformity with a highly regimented and oppressive society in
which the masses are forced to adhere to a strict time schedule in
their daily lives as they serve their corporate masters. Similarly, in
In Time, the constant threat of imminent death by running out of
one's allotted time is the system used to force conformity with a
highly regimented and oppressive society in which the masses live
short, brutish lives of poveliy in service to the wealthy corporate
elite.
e. The protagonist in Repent, Harlequin! rebels against the system in
the hopes of destroying it and restoring freedom to the masses. He
becomes an outlaw and a hero of the people by sabotaging the
system in ways that disrupt the strict schedule and encourages
people to enjoy their time. The protagonist in In Time also rebels
against the system in the hopes of destroying it. He becomes an
outlaw and a hero of the people by sabotaging the strict time
distribution system by giving others more time to live.
f. In Repent, Harlequin!, the protagonist's acts of defiance present a
threat to the system of strict schedule control enforced by the
Master Timekeeper and his staff, who monitor infractions from a
central command post. The Master Timekeeper and his staff
proceed to hunt down the protagonist, at first using wanted posters
and eventually by resorting to informants and torture. Similarly, in
In Time, the protagonist's acts of defiance present a threat to the
system of strict time distribution control enforced by the Senior
Timekeeper and his staff, who also monitor infractions from a
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central command post. The Senior Timekeeper and his staff
proceed to hunt down the protagonist, at first using electronic
wanted posters and eventually employing a street gang that uses
intimidation, torture and murder.
6 FIRST CLAIM FOR RELIEF FOR COPYRIGHT INFRINGEMENT
7 (Against All Defendants)
8 16. TKC incorporates by reference paragraphs 1 through 15, inclusive, and
9 realleges them here as though fully set forth herein.
10 17. Repent, Harlequin! is an original work of authorship fixed in a
11 tangible means of expression that constitutes a literary work pursuant to 17 U.S.C.
12 102(a), and is subject to copyright protection under the Copyright Act, 17 U.S.C.
13 101 et seq.
14 18. TKC's exclusive rights extend to each protectable component of
15 Repent, Harlequin!, including the right to create derivative works such as an
16 adaptation of Repent, Harlequin! to a motion picture screenplay.
17 19. IKC has the right and standing to enforce its exclusive rights to
18 Repent, Harlequin! and its copyrightable component parts.
19 20. At all times material hereto, TKC has duly complied with all of the
20 provisions of the copyright laws of the United States applicable to Repent,
21 Harlequin!.
22 21. Defendants had access to Repent, Harlequin! because Repent,
23 Harlequin! was and is a successful, well known science fiction short story that was
24 and is widely distributed and continues to be sold and available throughout the
25 United States.
26 22. By producing and distributing In Time, Defendants have reproduced,
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LOS ANCELES-
copied, prepared derivative works based upon, and distributed copies of substantial
portions of Repent, Harlequin!, including key plot elements, characters, events and
LAOIlL045905.1 - 7 -
1 sequences for their own use, without TKC's permission or authorization.
2 Defendants continue to do so.
3 23. Defendants' conduct constituted, and continues to constitute,
4 infringement upon TKC's exclusive rights to reproduce, copy, prepare derivative
5 works based upon, and distribute Repent, Harlequin!, all in violation of 17 U.S.C.
6 106 and 501.
7 24. Defendants' infringement was, and continues to be, intentional,
8 deliberate, willful, malicious and in blatant disregard ofTKC's exclusive rights.
9 25. Defendants' acts as alleged above have caused, and ifnot enjoined,
10 will continue to cause, irreparable damage to TKC's exclusive rights in a manner
11 that cannot be calculated or compensated solely by money damages. Accordingly,
TKC is entitled to a preliminary and permanent injunction against Defendants and
their officers, directors, employees, agents, representatives, affiliates, subsidiaries,
distributors and all persons acting in concert with them, to stop their infringing
conduct, pursuant to 17 U.S.C. 502.
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26. TKC is further entitled to temporary and permanent orders impounding
and disposing of all infringing materials, including but not limited to all originals,
copies, reproductions and derivatives of In Time, in Defendants' possession,
custody or control pursuant to 17 U.S.C. 503.
27. Defendants' infringing conduct has caused TKC to suffer damages and
harm, including, but not limited to, lost derivative market exploitation opportunity,
lost revenues and profits, lost market share, loss of goodwill and reputation, and
other damages, including costs and attorneys' fees, the exact nature and extent of
which will be proven at trial.
28. Accordingly, TKC is entitled to an award against Defendants for the
recovery of Defendants , profits, ifany, TKC's actual damages or statutory
damages, punitive damages, and attorneys' fees and costs, pursuant to 17 U.S.C.
504 and 505.
DRINKER BIDDLE & LAO 1/ 1045905.1
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REATH LLP
ATTORNEYS AT LAW
Los ANGELES
SECOND CLAIM FOR RELIEF FOR A DECLARATORY JUDGMENT
2 (Against All Defendants)
3 29. TKC incorporates by reference paragraphs 1 through 28, inclusive, and
4 realleges them here as though fully set forth herein.
5 30. An actual controversy has arisen and now exists relating to the rights
6 and duties ofTKC and Defendants under the U.S. copyright laws in that TKC
7 contends that Defendants' use, reproduction, marketing, sale, and distribution of In
8 Time infringe upon TKC's exclusive copyrights. Upon information and belief,
9 Defendants contend that their use, reproduction, marketing, sale, and distribution of
10 In Time are lawful.
11 31. Pursuant to the Declaratory Judgment Act, 28 U.S.C. 2201 & 2202,
12 and Rule 57 of the Federal Rules of Civil Procedure, TKC desires ajudicial
13 determination of its rights, and a declaration of whether Defendants' use,
14 reproduction, marketing, sale, and distribution of In Time infringe upon TKC's
exclusive rights in violation of the U.S. copyright laws. 15
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32. A judicial declaration is necessary and appropriate at this time under
the circumstances in order that TKC may ascertain the parties' rights.
PRA YER FOR RELIEF
WHEREFORE, TKC prays for judgment against Defendants as follows:
1. That Defendants, and each of them, be adjudged to have infringed
TKC's copyrights, in violation of 17 U.S.C. 106 and 501;
2. That Defendants, and each of them, and their respective officers,
directors, employees, agents, representatives, affiliates, subsidiaries, distributors
and all persons acting in concert with them, be forthwith preliminarily and
thereafter permanently enjoined from infringing TKC's copyrights, pursuant to 17
U.s.C. 502;
3. That Defendants, and each of them, and their respective officers,
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directors, employees, agents, representatives, affiliates, subsidiaries, distributors
and all persons acting in concert with them, be forthwith preliminarily and
thereafter permanently ordered to impound and dispose of all infringing materials,
pursuant to 17 U.S.C. 502;
5. That Defendants, and each of them, be directed to file with this Court
and serve on TKC, by and through its counsel of record herein, within thirty (30)
days after service of any such injunctions, a report in writing, under oath, setting
forth in detail the manner and form in which Defendants have complied with the
injunctions and orders described above;
6. That Defendants, and each of them, be required to account to TKC for
any and all profits derived by their respective exploitation of In Time;
7. That Defendants, and each of them, be ordered to pay over to TKC all
damages, including future damages, that TKC has sustained, or will sustain, as a
consequence of the acts complained of herein, subject to proof at trial, and that
TKC be awarded any profits derived by Defendants as a result of said acts, or as
determined by said accounting, or in the alternative, statutory damages, pursuant to
17 U.S.C. 504;
8. For a judicial declaration that Defendants' use, reproduction,
marketing, sale, and distribution of In Time infringe TKC's exclusive rights under
the copyright laws;
9. That TKC be awarded its costs, attorneys' fees and expenses in this
action pursuant to 17 U.S.C. 505;
10. That TKC be awarded pre-judgment interest; and
LAO II 1045905.1 -10-
11. hat TKC have such other and further relief as the COlirt may deem
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Dated: September 14, 2011
Attorneys for Plaintiff
The Kiltmanjaro Corporation
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COMPLAINT FORCOPYRIGH INFRINGEMENT AND JURY TRJAL DEMAND
1 JURy TRIAL DEMAND
2 Plaintiff IKC hereby demands a trial by jury.
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Dated: September 14,2011
PlaiIltiff .
The Kil1manJaro CorporatlOn
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RE/\TrI LLP
,\ TT01U';EY5 AT LAW
La" ASCF.LB
COMPLAlNT FOR COPYRIGHT INFRINGEMENT AN D JURY nUAL DEMAND
CENTRAL DISTRICT OF CALIFORNIA
NOTJCE OF ASSlGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY
This case has been assigned to District Judge John F. Walter flnd the assigned discovery
Magistrate Judge is Jacqueline Chooljian.
The case number on all documents filed with the Court should read as follows:
CVll- 75?5 JFW (JCX)
Pursuant to General Order 0507 of the United States District Court fOf the Centml
District of California, the Magistrate Judge has been designated to bear discovery relatc:d
motions.

IIIOTICE TO COUNSEL
A copy of this notics must be served with thfil $ummons and complaint on all defendants (If a removal t/ctlon Is
flied. it copy of this MOoe must be served on all plaintiffs).
Subsequent documents must be at the follOwing location:
[Xl Western Division
312 N. Spring St .. Rm. G-8
Los Angeles, CA 90012
U Souther... Dlv1slon
411 WIst FOLlrth St., Rm.1D53
Santa Ana, CA 92701-4516
Failure It;> file OIt the ptoper loeal)on wlll result In your oocumente being rell1l'n91t 10 you,
[J eastern Division
3470 Twelfth St., Am. 134
Riverside, CA 92501

cv,a (OSI06) NOTIC"; OF TO UNITEO STATfOS MAGISTRATE JUDGi: CISCQvgRY
DIUNKER BIDDLE & REATH LLP
Christopher F. Wong (142507) chris.wong@dbr.coll1
Adam J. ThLlrstOn (162636) adam.thurston@dbr,com
Ryan Salsig (250830) ryan,salsig@dbr.com
1800 Century Park East, Suite 1400
Los Angeles, Calitornia 90067-1517
Telephone:(31 0) 203-4000
Facsimile:(310 229-1285
CENTRAL DISTRICT OF CALIFORNIA
THE KILlMANJARO CORPORATION
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a California CAsr:NUMBp.R
Corporation,
V. I'LMNTlFF(S) eVil 0 7 5 7 51ff1 (JlxJ
NEW REGENCY PRODUCTIONS,INC., a California -------- - ---------
corporatiOll; ANDREW NICCOL, all individual; and
DOES 1 10, inclusive, SUMMONS

TO:DEFENDANT(S): NEW REGENCY PRODUCTIONS, INC., a California corporation; ANDREW
NICCOL, an individual; and DOeS 1 through 10, inclusive.
A laws\.\h has been filed againsl
Within n days after service ofthi:> summons on you (not counting tlle day you received it), you
nmst serve 011 lhe plaintiff an answer to the attached I8l complaint D __ amended complaint
o COllnterclaim 0 cross"claim or a motion under R1.!1e 12 of the Federal Rules ofClvil Procedure. The answer
or motion must be served on the plaintiff's attorney, DRINKER BIDDLE & REATH Christopher Wong /
Adam Th\,u'ston, whose address is ] 800 Cenmrv Park East, Stute 1400, Los Angeles, California 90Q9..7 1517.
If you fail to do S0, by default will be entered ag.unst you for the relief demanded in the cDmplaint.
You also must file your answer or motion with the court.
SEP 1 4 2011
. By: __
""
Deputy Clerk
Dated:
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(Seal oflhe. COllrt)
[USB 60 d(l)ls if the defendant is fhft Uniled Slates Dr a United Slales agency, or ill an ojflcer or employee of the United States. If /lDwed
60 days b)l Rule 11(a)(3)).
CVOIA (12/07)
LAO!I !04593rJ,l
SllMMONS
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UNITED STATES DlSTRICT COURT, CENTRAL DlSTR1CT Of CALlFORNIA
CIVIL COVEll
I (II) PlAINTIFFS ("'lwk bo); ifyuu ate '\.'f1T1!scl1ting ),lluIselfD)
1)Ii:FENPANTS
THE KILIMANJARO CORPORATION. a Califomia
NEW REGENCY PRODUCTIONS, INC., a corporation;
Corpol'ation
NICCOL, an individual; and POES 1 thrc,ugh I D,
incll.lsivc
(11) Ano,.ncys (Pirlll Address find NUIl'1bcr. II' you lire A[lCIllley.' (I f Known 1

DruNKER BIDDLE & REA TH LLP
Christopher F. (142507) Adam Thurston (162636)
1800 Ct:nrury Suite 1400
Los Angeles, Califomia 90067- J 517
Telephone:(31 0) 2034000 I Facsimile:(310) 229- J 285
.
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b 5 i 0 lO' Acl
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370 Olher S I-Illbeas o no J...abDrfMsml.
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o 4 70 h,fluIlCCu of
p 330 Fed, cmployol1\' o 3!1;i Propeny 540 M\lIIdall1Usl ACl
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... o 550 Civil Rights 79U OLher Labor
o 480 COrnillll1tr Crollil o 152 of Detimll(tl
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.. ..
- -
--
OFFICii: USE ON I. V: CAse Number: I -p 11 1 1 .. -'1 I r;;. [ iIii
AFTER COMPLETING TIIE cy-YCf>MI'f"E1\ T1Ti? tNFORMATION ROUESTtD uELOW.
CV-71 (OS/OK) CIVIL COVER SHE!:."!'
\I\m
an
can LO[!aillal, II1C I I
PAQO I Df2
www.l"ormIWQr<t!ow.aom
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
VII 1(11). IDENTICAL CASES: Has this action been previously filed in this court and dismissed, remanded or closed? (gJ No 0 Yes
If yes, list case number(s): I
""Itb). RELATED CASES: Have any cases been previously filed in this court that are related to the present case? (gJ No 0 Yes
If yes, list case number(s): I
Civil cases are deemed related if a previously filed case and the present case:
Check all boxes that apply) D A. Arise from the same or closely related transactions, happenings, or events; or
D B. Call for detennination of the same or substantially related or similar questions of law and fact; or
Dc. For other reasons would entail substantial duplication oflabor if heard by different judges; or
D D. Involve the same patent, trademark or copyright, and one of the factors identified above in a, b or c also is present.
LX. VENUE: (When completing the following infonnation, use an additional sheet ifnecessary.)
a) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named plaintiff resides.
D
Check here if the government, its agencies or employees is a named plaintiff. If this box is checked, go to item (b).
County in this District" Cal ifornia County outside of this District; State. if other than California; or Foreign Country
The Kilimanjaro Corporation: Los Angeles County, California
b) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named defendant resides.
(gJ Check here jfthe govemment, its agencies or employees is a named defendant. If this box is checked, go to item (c).
County in this District:" California County outside of this District; State, if other than California; or Foreign Country
Andrew Niccol: Los Angeles County, California
New Regency Productions, Inc.: Los Angeles County, California
c) List the County in this District; California County outside of this District; State if other than Califomia; or Foreign Country, in which EACH claim arose.
Note: In land condemnation cases, use the location of the tract of land involved.
County in this District:" Califomia COllnty outside ofthis District; State, if other than California; or Foreign Country
Los Angeles County, California
Los Angeles, Orange, San Bernardino, River ide. Vcnlnm. Santa Barba.,:,a, or San Luis Obispo Counties
Note: In land condemnation cases, use the locatloll of 'the Iraclbi'lnncl
X. SIGNATURE OF ATTORNEY (OR PRO PER): I X-.\.....

IOate ISeptember 14,2011
Adam J. -

Notice to Counsel/Parties: The CV-71 (JS-44) Civil Cover Sheet and the infornlation contained herein neither replace nor supplement the filing and service of pleadings
or other papers as required by law. This fonn, approved by the Judicial Conference of tile United States in September 1974, is required pursuant to Local Rule 3 -I is not filed
but is used by tile Clerk of tile Court for the purpose of statistics, venue and initiating the civil docket sheet. (For more detailed instructions, see separate instructions sheet.)
CV -71 (05/08) CIVIL COVER SHEET Page 2 of2
American LegalNet, Inc
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