Barlow and Harken V Match

Case 3:11-cv-01354-N Document 1
Filed 06/21/11
Page 1 of 17 PageID 1
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION GUY BARLOW, JR. and MARK H. HARKEN, on behalf of themselves and all similarly situated persons, PLAINTIFFS vs. MATCH.COM, LLC, DEFENDANT
CASE NO. ____________________
JUDGE ______________________
PLAINTIFFS ORIGINAL CLASS ACTION COMPLAINT AND JURY DEMAND Plaintiffs Guy Barlow, Jr. (Barlow) and Mark H. Harken (Harken) (together, Plaintiffs), on behalf of themselves and all similarly situated persons, complain of the acts of Defendant Match.com, LLC, and respectfully show the following: NATURE OF THE CASE 1. This is a national class action against Match.com for engaging in unfair,
unconscionable and deceptive trade practices. Plaintiffs bring this action on behalf of themselves and all similarly situated persons throughout the United States (the Class Members) who subscribed and/or continue to subscribe to the Match.com online dating service and did not receive the products and services for which they paid. 2. Plaintiffs, on behalf of themselves and the Class Members, seek actual damages,
statutory treble damages, equitable relief, injunctive relief, pre- and post-judgment interest, attorneys fees, litigation expenses and court costs.
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JURISDICTION AND VENUE 3. This Court has subject matter jurisdiction over Plaintiffs claims pursuant to 28
U.S.C. 1332(d)(2) (CAFA) because (i) there are 100 or more Class Members, (ii) at least one Class Member is a citizen of a state that that is diverse from Match.coms citizenship, and (iii) the matter in controversy exceeds $5,000,000 USD exclusive of interest and costs. This Court also has subject matter jurisdiction over Plaintiffs state law claims pursuant to 28 U.S.C. 1367. This Court has personal jurisdiction over Match.com because at all relevant times, it owned (and continues to own) a business located in the Northern District of Texas, and conducted (and continues to conduct) substantial business in the Northern District of Texas. 4. Venue is proper in the Northern District of Texas pursuant to 28 U.S.C. 1391(a)
because a substantial part of the events and omissions giving rise to this action occurred in the Northern District of Texas and Match.com resides, is located, can be found and/or maintains its corporate headquarters in the Northern District of Texas. PARTIES 5. Plaintiff Barlow is a citizen and resident of Texas. Barlow was a Match.com
Subscriber from September 12, 2010 through March 21, 2011. 6. Plaintiff Harken is a citizen and resident of Texas. Harken was a frequent
Match.com Subscriber from approximately April 2009 through September 2009. 7. Defendant Match.com is a corporation organized under the laws of the State of
Delaware. According to its website, www.match.com, Match.coms headquarters and principal place of business is in Dallas, Texas. According to its website, Match.com was launched in April 1995, and helped pioneer the online dating industry. Also according to its website, Match.com serves millions of singles in 24 countries and territories, hosting websites in 15 different
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languages. Also according to its website, 20,000 singles join the Match.com community every day and hundreds of thousands of people find love on Match.com every year. Match.com may be served with Summons and a copy of this Original Class Action Complaint and Jury Demand by serving its registered agent for service of process, National Registered Agents, Inc., 16055 Space Center Blvd., Suite 235, Houston, Texas 77062. FACTUAL BACKGROUND 8. Match.com is an online dating service that advertises in print, via the internet and
on televisionnationally and worldwide. 9. The purpose of Match.coms heavy advertising is to drive traffic to its website,
www.match.com, its principal money making asset, that displays online personal profiles and transmits communications between certain Members who desire to make a love connection. 10. 11. There are two types of Match.com MembersSubscribers and Non-subscribers. In order to view the Match.com website, a person must agree to the Match.com
Terms of Use Agreement and incorporated terms and conditions and register by (i) creating a User name and Password, (ii) providing their gender, age, education level, email address, body type, eye color, income, pets, diet, hobbies, political and religious beliefs, favorite books, movies, places and other personal and confidential information, and (iii) specifying the geographic area, gender and age range of people they are interested in meetingthereby creating an online profile. Match.com encourages Members to include photographs in their online profiles. Creating an online profile is free. 12. Non-subscribers may access Match.com on a limited basis for free. Subscribers
receive full access to Match.coms products and services for approximately $39.99 per month.
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13.
Match.com advertises that it has 15 million Members. Match.com, however,
carefully wordsmiths its advertising to avoid disclosing the fact that only 1.4 million of its Members are actually Subscribers. Thus, less than ten percent (10%) of Match.coms 15 million Members can actually be reached by another Member. 14. Both Subscribers and Non-subscribers may browse the Match.com online
profiles utilizing search parameters. Match.com displays the online profiles of Subscribers and Non-subscribers without differentiating between them. 15. If a Subscriber identifies an interesting online profile and desires to make contact,
Match.com encourages the Subscriber to send the person an email or a wink by giving the Subscriber an online cue that the targeted person will receive the Subscribers communication. Match.com also may give the Subscriber an online cue that the targeted person is online at that very moment so that an instant connection can be madewhich may or may not be true. 16. If the targeted person also is a Subscriber, he or she may receive the sending
Subscribers email or wink. On the other hand, if the intended recipient is a Non-subscriber, Match.com does not inform the sending Subscriber that the intended recipient cannot open, read and/or respond to their emails or winks and/or the intended recipient cannot view the Subscribers profile, username or photographsalthough Match.com has the capability to do so. 17. In fact, when a Match.com Subscriber emails a Non-subscriber, Match.com
uniformly misleads the Subscriber to believe that any Member may access and read an e-mail and see who sent it by proclaiming in the Terms of Use that Receiving email is free; you can receive responses even if you have never subscribed to Match.comeven though such e-mails cannot be opened, viewed, read and/or replied to.
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18.
In short, only Match.com Subscribers can connect with other Match.com
Subscribers and/or view online profiles of other people who attempt to contact themwhich Match.com does not disclose to its Subscribers. 19. As a result, Match.com Subscribers have been (and continue to be) cheated out of
millions of dollars of Subscriber fees and time because the vast majority of Match.com Members are not reachable, which Match.com intentionally and uniformly conceals from Subscribers when they attempt to e-mail or wink a Non-subscriber. 20. Adding insult to injury, by playing on the emotions of Subscribers who obviously
are anxious to know whether their e-mails and winks are being read or ignored by the intended recipients, Match.com offers Subscribers an add-on serviceat an additional cost of $3.99 per monththat confirms if and when their e-mails are read. 21. Match.com deceptively uses the word receiving in the Terms of Use, by
claiming that Receiving e-mail is freealthough e-mails cannot be viewed, read or replied to. 22. Match.com further deceives and exploits Subscribers by sending enticements to
Non-subscribers such as, Someone Has Emailed You! And She Just Might Be the One, rather than sending Subscribers emails to Non-subscribers. 23. Match.com further deceives and exploits Subscribers by sending notifications that
state You have unread e-mails, or She responded. Subscribe now to see what she wrote, to former Subscribers, as a means of inducing them to re-subscribe when, in fact, there are no unread or new e-mails in their inboxes. 24. Match.com further deceives and exploits Subscribers into believing that more
Members are interested in connecting with them than actually are interested by sending e-mails to Subscribers recommending matchescompatible candidates who are likely to be interested
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in them based on their match criteriawhich include online profiles of terminated Subscribers, which Match.com does not disclose to active Subscribers. 25. Match.com further deceives and exploits Subscribers by occasionally allowing
Non-subscribers to read e-mails, receive winks and/or see the profiles of sending Subscribers on a random basis as a further teaser inducement for Non-subscribers to become Subscribers. 26. Match.com further deceives and exploits Subscribers by updating the online
profiles of Non-subscribers to say Online Nowthereby furthering its purpose to mislead Subscribers as to how many Members are accessible at a given time. 27. Match.com further deceives and exploits Subscribers in an effort to create the
appearance that Non-subscribers are accessible by updating Member profiles with a flashing label that reads "Online Now," or "Active Within one hour, or Active Within three hours, or Active Within 24 hours, or Active Within two days, or Active Within three days. Match.com updates the activity meters whenever a Member logs in to the Match.com website for any reason, including cancelling their subscription, or at random without the Member logging in. 28. Match.com further deceives and exploits Subscribers by allowing online profiles
of former Subscribers to continue to appear on the Match.com website as the profile of an active Subscriber without informing active Subscribers that the former Subscribers online profiles are no longer active and/or without informing the former Subscribers that Match.com has not removed his or her online profile. 29. Rather, by stating in the Terms of Use: When you resign your membership, we
immediately hide your profile and photos from other members, Match.com deceives and exploits Subscribers into thinking that only active Members online profiles remain visible, and that their own online profiles will be removed if and when they terminate their subscriptions.
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30.
Match.com further deceives and exploits Subscribers who attempt to remove their
online profiles by failing to disclose to such Subscribers that their online profiles, in fact, were not removed in a further effort to artificially inflate the apparent number of active Members. 31. Match.com further deceives and exploits Subscribers by updating activity meters
and creating the appearance that Non-subscribers are actively utilizing the site by sending messages to cell phones and other handheld devices that Someone has winked back at you even when a Subscriber has not sent any winks. 32. Match.com further deceives and exploits Subscribers by manufacturing bogus
online profiles as evidenced by the number of profiles of allegedly different Members containing identical photographs and identical phrases. For example, the phrase, [M]y favorite chocolate is TWIX and I once ate twenty packs in one night, was stated verbatim in the following profiles that were live on Match.com at the same time: BabeeGrlShelli, PowerfulDaisya, GoodGrlKelliy, IWunUSoBad, ArtistikJannaovq, BeautifulAbigat, DiscoverMargef and KreepNLydian. 33. Similarly, the same photograph appeared in the profile of FindKassandrawos, a
resident of Virginia who describes herself as shy, and SweetAirYaritzal, a people person from Pennsylvania, at the same time. 34. In addition, the phrase used by FindKassandrawos, people usually get the wrong
impression of me, because I dont like to talk to (sic) much, but its only because Im shy, appeared verbatim in the profiles of CrazySexyAmy1 and MidnightViviana at the same time. 35. Likewise, the phrase used by SweetAirYaritzal, When my friends introduce me,
they always start off with, shes MS. PEOPLE PERSON, also appeared verbatim in the profiles of Hot1Debra1, MaritzaBoutUso and GrumpyColleen at the same time.
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36.
On information and belief, and in a further effort to retain Subscribers,
Match.com further deceives and exploits Subscribers by calling them and impersonating other Members, although obviously never agreeing to meet the Subscribers for dates. 37. On information and belief, Match.com further deceives and exploits Subscribers
by updating activity meters sua sponteeven though Members have not logged in for weeks, months or yearsin order to create the appearance that Non-subscribers are active on the Match.com website. At any given time, a significant percentage of Match.com Members whose profiles appear with the label Online Now is not logged in to the Match.com website, nor are they online and/or can be reached. 38. The above-described deception perpetrated (and continuing to be perpetrated) by
Match.com has harmed (and continues to harm) Match.com Subscribers, including Plaintiffs and Class members. Plaintiffs and Class members paid subscription fees to reach out to Match.com Members that Match.com knew were unreachable, but did not disclose to Subscribers. 39. Additional misleading and deceptive practices are achieved through Match.coms Chemistry.com charges
premium Chemistry service, which began in January 2006.
substantially higher subscription fees and similarly and deceptively purveys online profiles of Non-subscribers who are unable to respond to communications from Subscribers. CLASS ACTION ALLEGATIONS 40. reference. 41. Plaintiffs bring this action as a national class action pursuant to Rule 23 of the The preceding factual statements and allegations are incorporated herein by
Federal Rules of Civil Procedure. Plaintiffs seek to represent a Class consisting of all current or former Match.com Subscribers, from April 21, 1995 to the present. Excluded from the Class are
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Match.com officers, directors, agents, representatives and/or employees, the Court and Court personnel. 42. This action is properly brought as a class action because Class Members are so
numerous that joinder of all of them is impracticable. Class members are widely dispersed throughout the United States. While the exact number of Class Members is unknown to Plaintiffs at this time, the Class Members may easily be identified from Match.coms records. On information and belief, there are hundreds of thousands of putative Class Members. 43. This action also is properly brought as a class action because certain common
questions of law and/or fact exist as to all Class Members that predominate over any questions solely affecting individual Class Members including, inter alia: (i) Whether Match.coms unconscionable and deceptive acts and practices violated (and continue to violate) the Texas Deceptive Trade Practices-Consumer Protection Act? Whether Match.coms unconscionable and deceptive acts and practices constituted (and continue to constitute) breach of contract at Texas common law? Whether Match.coms unconscionable and deceptive acts and practices constituted (and continue to constitute) breach of the duty of good faith and fair dealing at Texas common law? Whether Plaintiffs and Class Members are entitled to compensation under the equitable doctrine of money had and received? Whether Plaintiffs and Class Members are entitled to compensation under the equitable doctrine of unjust enrichment? Whether Plaintiffs and Class Members are entitled to actual damages and, if so, the appropriate type and amount? Whether Plaintiffs and Class Members are entitled to injunctive relief and, if so, the appropriate form? The only question affecting individual Class Members is the precise amount to
(ii)
(iii)
(iv)
(v)
(vi)
(vii)
44.
which each Plaintiff and each Class Member is entitled as compensation for Match.coms unlawful
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unconscionable and deceptive acts and practices, which will be a simple and uniform mathematical computation. 45. Plaintiffs claims are typical of Class Members claims since their experiences at
issue in this case are identical (or virtually identical) to each other. 46. Class Members interests will be fairly and adequately protected by Plaintiffs.
Plaintiffs interests are consistent with those of Class Members. Plaintiffs and Class Members are represented by experienced and able counsel knowledgeable about class action litigation, complex commercial litigation and financial and accounting matters. 47. Plaintiffs interests are not antagonistic to, or in conflict with, the interests they seek
to represent. Plaintiffs know of no difficulty that would be encountered in the management of this action as a class action. 48. Class certification, therefore, is appropriate pursuant to FED. R. CIV. P. 23(b)(2)
because Match.com has acted (or refused to act) on grounds generally applicable to the Class, thereby making appropriate final injunctive relief or corresponding declaratory relief with respect to the Class as a whole. 49. Class certification also is appropriate pursuant to FED. R. CIV. P. 23(b)(3) because
the above common questions of law or fact predominate over any questions affecting individual Class members, and a class action is superior to other available methods for the fair and efficient adjudication of this controversy. 50. The expense and burden of litigation would substantially impair the ability of Class
Members to pursue individual lawsuits in order to vindicate their rights. In the absence of a class action, Match.com will retain the benefits of its wrongdoing despite its serious breaches of the terms of its Terms of Use Agreement and the law.
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CLAIMS FOR RELIEF/CAUSES OF ACTION COUNT I BREACH OF CONTRACT 51. reference. 52. The Match.com Terms of Use Agreement, including its incorporated terms and The preceding factual statements and allegations are incorporated herein by
conditions, which was electronically accepted and executed by Plaintiffs and Class Members, constitutes a contract between Plaintiffs and Class Members, on the one hand, and Match.com, on the other hand, under Texas law. 53. Match.com breached the clear language of the Terms of Use Agreement by, inter
alia, engaging in the above-described wrongful acts and failing to deliver the contracted for products and services. 54. Match.coms wrongful conductwhich caused (and continues to cause) Plaintiffs
and Class Members to suffer damagesconstitutes breach of contract at Texas common law. COUNT II BREACH OF THE DUTY AND/OR IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING 55. reference. 56. The Match.com Terms of Use Agreement electronically executed and accepted by The preceding factual statements and allegations are incorporated herein by
Plaintiffs and Class Members, as well as the above-described confidential, special and/or fiduciary relationships, created a duty of good faith and fair dealing owed by Match.com to Plaintiffs and Class Members under Texas law.
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57.
Under the Terms of Use Agreement (that, in fact, Match.com drafted and imposed
on Plaintiffs and Class Members by virtue of its superior bargaining position), as well as the above-described confidential, special and/or fiduciary relationships, it is reasonably clearif not crystal clearthat Match.com was required to deliver the products and services to Subscriber Members as advertised and disclose the above information it did not disclose in the process. 58. Match.coms exploitation of Plaintiffs and Class Members confidential and
personal information and their emotional vulnerability, failure to deliver the promised products and services and repeated, ongoing, deceptive and unconscionable manipulation of Plaintiffs and Class Members emotions for financial gainwhich caused (and continues to cause) Plaintiffs and Class members to suffer damagesconstitutes breach of the duty and/or implied covenant of good faith and fair dealing at Texas common law. COUNT III VIOLATION OF THE TEXAS DECEPTIVE TRADE PRACTICES-CONSUMER PROTECTION ACT 59. reference. 60. Match.com utilized Plaintiffs and Class Members confidential and personal The preceding factual statements and allegations are incorporated herein by
information, exploited their emotional vulnerability and personal confidences, failed to deliver the promised products and services and, in the process, deceptively manipulated their emotions to a grossly unfair degreeall to Plaintiffs and Class Members detriment and Match.coms financial gain. Match.coms wrongful actions and course of actionwhich caused (and
continues to cause) Plaintiffs and Class members to suffer damagesconstituted (and continues to constitute) unconscionable conduct in violation of the Texas Deceptive Trade Practices-
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Consumer Protection Actto wit, ongoing and continuous violations of Section 17.50(a)(3) of the Texas Business and Commerce Code. 61. Concurrent with filing and serving this Original Class Action Complaint and Jury
Demand, Plaintiff Barlow served Match.com with notice, pursuant to Section 17.505(a) of the Texas Business and Commerce Code, informing Match.com that he intends to amend the Original Class Action Complaint and Jury Demand sixty-one (61) days after its filing to assert claims for Match.coms above-described unconscionable conduct in violation of Section 17.50(a)(3) of the Texas Business and Commerce Code. Plaintiff Harken delivered his Section 17.505(a) notice to Match.com more than sixty days ago. COUNT IV MONEY HAD AND RECEIVED 62. reference. 63. By its above-described wrongful acts, Match.com holds moneyi.e., the wrongfully The preceding factual statements and allegations are incorporated herein by
charged and collected subscription fees for products and services not deliveredthat, in equity and good conscience, belong to Plaintiffs and Class Members. Match.com should be compelled to refund such wrongfully charged subscription fees paid by Plaintiffs and Class Members under the equitable doctrine of money had and received. COUNT V UNJUST ENRICHMENT 64. reference. The preceding factual statements and allegations are incorporated herein by
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65.
By its above-described wrongful acts, Match.com has been (and continues to be)
unjustly enriched by, inter alia, (i) the wrongfully charged subscription fees paid by Plaintiffs and Class Members, and (ii) Match.coms corresponding return on investment on the amounts wrongfully taken. Accordingly, Plaintiffs, on behalf of themselves and the Class Members, seek to impose a constructive trust over (and recover) all amounts by which Match.com has been unjustly enriched. TOLLING OF THE STATUTES OF LIMITATION 66. reference. 67. EQUITABLE ESTOPPEL. Match.com took active steps to conceal its above The preceding factual statements and allegations are incorporated herein by
wrongful actions and/or inaction. The details of Match.coms efforts to conceal its unlawful conduct are in its possession, custody and control, and await further discovery. At such time as this material information was first revealed to Plaintiffs, they exercised due diligence by retaining counsel and pursuing their claims. As such, and if such be necessary, all applicable statutes of limitation (if any) are tolled under the doctrine of equitable estoppel. 68. EQUITABLE TOLLING. Match.com took active steps to conceal its above
wrongful actions and/or inaction. The details of Match.coms efforts to conceal its unlawful conduct are in its possession, custody and control, and await further discovery. Even by
exercising reasonable diligence, Plaintiffs could not have discovered this information if for no other reason than Plaintiffs had no reason to make such inquiries. At such time as this material information was first revealed to Plaintiffs, they exercised due diligence by retaining counsel and pursuing their claims. As such, and if such be necessary, all applicable statutes of limitation (if any) are tolled under the doctrine of equitable tolling.
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RELIEF REQUESTED 69. reference. 70. ACTUAL DAMAGES. As a direct and/or proximate result of Match.coms wrongful The preceding factual statements and allegations are incorporated herein by
conduct, Plaintiffs and Class Members have been (and continue to be) damaged in the amount of, inter alia, the subscription fees paid to Match.com for products and services Match.com failed to deliver. All of the damages sustained by Plaintiffs and Class Members were reasonably foreseeable by Match.com, and exceed the minimum jurisdictional limits of this Court. All conditions
precedent to Plaintiffs and Class Members claims have been performed and/or occurred. 71. TREBLE DAMAGES. Plaintiffs and Class Members also are entitled to treble
damages for Match.coms knowing, intentional, unconscionable and deceptive acts and practices, pursuant to Section 17.50(b)(1) of the Texas Business and Commerce Code. All conditions precedent to Plaintiffs and Class Members claims for relief have been performed and/or occurred. 72. INJUNCTIVE RELIEF. Plaintiffs and Class Members also are entitled to injunctive
relief on a going forward basis requiring Match.com to cease and desist its above-described wrongful acts and practices, provide full disclosure and transparency to all of its Members, and provide its Subscribers with the products and services for which they paid. All conditions precedent to Plaintiffs and Class Members claims for relief have been performed and/or occurred. 73. ATTORNEYS FEES, LITIGATION EXPENSES
AND
COSTS. Plaintiffs and Class
Members also are entitled to recover their attorneys' fees, litigation expenses and court costs in prosecuting this action pursuant to, inter alia, Section 38 of the Texas Civil Practice and Remedies Code and/or Section 17.50(d) of the Texas Business and Commerce Code.
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WHEREFORE, Plaintiffs, on behalf of themselves and the Class Members, respectfully request that (i) Match.com be cited to appear and answer this lawsuit, (ii) this action be certified as a class action, (iii) Plaintiffs be designated the Class Representatives, and (iv) Plaintiffs counsel be appointed as Class counsel. Plaintiffs, on behalf of themselves and the Class Members, further request that upon final trial or hearing, judgment be awarded against Match.com, in favor of Plaintiffs and the Class Members, for: (i) (ii) (iii) (iv) (iii) (v) (v) (vi) actual damages in an amount to be determined by the trier of fact; treble damages; equitable relief as set forth above; injunctive relief as set forth above; pre- and post-judgment interest at the highest applicable legal rates; attorneys fees and litigation expenses incurred through the trial and any appeals; costs of suit; and such other and further relief that this Court deems just and proper. JURY DEMAND Plaintiffs respectfully demand a trial by jury on all of their claims and causes of action so triable.
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Respectfully submitted,
By: /s/ Mitchell A. Toups Mitchell A. Toups WELLER, GREEN, TOUPS & TERRELL, LLP P.O. Box 350 Beaumont, TX 77704 (409) 838-0101 (409) 832-8577 FAX matoups@wgttlaw.com Richard L. Coffman THE COFFMAN LAW FIRM The First City Building 505 Orleans St., Ste. 505 Beaumont, TX 77701 (409) 833-7700 (866) 835-8250 FAX rc@cofflaw.com Peter G. Malouf THE LAW OFFICE OF PETER G. MALOUF P.O. Box 12745 Dallas, TX 75225 (972) 971-5509 pmalouf@pmalouf.com ATTORNEYS FOR PLAINTIFFS AND THE PUTATIVE CLASS
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Case 3:11-cv-01354-N Document 1

CASE NO. ____________________

Case 3:11-cv-01354-N Document 1

Case 3:11-cv-01354-N Document 1

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Match.com advertises that it has 15 million Members. Match.com, however,

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In short, only Match.com Subscribers can connect with other Match.com

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Case 3:11-cv-01354-N Document 1

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On information and belief, and in a further effort to retain Subscribers,

premium Chemistry service, which began in January 2006.

Case 3:11-cv-01354-N Document 1

Case 3:11-cv-01354-N Document 1

Case 3:11-cv-01354-N Document 1

Case 3:11-cv-01354-N Document 1

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Case 3:11-cv-01354-N Document 1

Case 3:11-cv-01354-N Document 1

COSTS. Plaintiffs and Class

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Case 3:11-cv-01354-N Document 1

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