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1 MANATT, PHELPS & PHILLIPS, LLP •

CHAD S. HUMMEL (Bar No. CA 139055)2 SHARI MULROONEY WOLLMAN (Bar No. CA 137142)

ERIN C.WITKOW (Bar No. CA 216994) FILED11355 West Olympic Boulevard los angeles SUPERIOR COURT3

Los Angeles, CA 90064-1614 .

4 Telephone: (310)312-4000 • AUG 12 2013Facsimile: (310)312-4224 nWW 1

5 JOBflj A. CLARKE, CLERK I

6Attorneysfor Plaintiff / 1 6\ttf\s~ *IMAX CORPORATION BY U^Kfe, DEPUTY

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(M Wo HomM !8 SUPERIOR COURT OF THE STATE OF CALIFORNIA I9 FOR THE COUNTY OF LOS ANGELES

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MAX CORPORATION, aCanadian Case No. BC51 8 132\

Corporation, 112

Plaintiff,COMPLAINT FOR:

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13 TRADE SECRET MISAPPROPRIATION ; :

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vs. PURSUANT TO CAL. CIV. CODE § 3426, \

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GDC TECHNOLOGY (USA) LLC, aETSEQ.;

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15 California Limited Liability Company;GDC TECHNOLOGYOF AMERICA,

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16 LLC, a Delaware Limited Liability UNFAIR COMPETITION UNDER CAL. 1

17Company, GDC TECHNOLOGYLIMITED, a British Virgin Islandscompany; GDC TECHNOLOGY

BUS. & PROF. CODE § 17200ET SEQ.

\18 LIMITED, a Cayman Islands company, I

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Plaintiff MAX Corporation ("MAX"), by and through its undersigned attorneys, states

the following for its Complaint against Defendants GDC Technology (USA), LLC, GDC

Technology of America, LLC, GDC Technology Limited (BVI), and GDC Technology Limited(Cayman) (collectively, "GDC" or"Defendants").

NATURE OF THE CASE

1. MAX has filed this action permanently to stop GDC's illegal commercial

exploitation of MAX's trade secret large format digital theatre projection system and film

conversion technologies. Former MAX employee, Gary Tsui, stole this proprietary technology

from MAX, then surreptitiously provided it to film companies in China, including a company

now called China Giant Screen orChina Film Giant Screen ("CFGS"), for which he has acted as

the "Chief Engineer." MAX is informed and believes, and on that basis alleges that CFGS

currently uses MAX's trade secrets under the same name,.and previously used those trade secrets

under the name "DMAX" until it was forced to change that name as a result of a trademark action

initiated by MAX. MAX is further informed and believes, and on that basis alleges that

Defendant GDC has acquired and is now knowingly and actively using MAX's trade secrets

through, among other things, its relationship with CFGS, in its efforts unfairly to compete

globally with MAX.

2. Prior to filing this action, MAX delivered an unambiguous cease and desist letter

to GDC which was ignored. Thereafter, MAX filed a lawsuit in the United States District Court

for the Central District of California which alleged the same set ofoperative facts and causes of

action that are alleged herein. In response to the District Court's inquiry about federal diversity

jurisdiction, in light of the complex and apparently interwoven corporate relationships with and

among the defendants here, MAX voluntarily dismissed that case in order to pursue relief in this

Court, and has now added an additional GDC defendant. GDC had not responded to that

Complaint.

3. Before either action was filed, and, on information and belief, continuing

thereafter, GDC has been actively touting its CFGS-based large format film projection systems

and conversion technology that, as described herein, MAX is informed and believes were2

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derived from and incorporate the trade secrets stolen by Tsui. Significantly, as a part of an Initial

Public Offering ("IPO") it recently postponed, GDC stated that its large format film technologies

are dependent on CFGS and that EPO proceeds will be used for "geographical expansion to

existing and new markets, research and development including on our new business initiatives

such as private digital cinema and China Film Giant Screen." Unabated, Defendants will be the

knowing participants in this high tech piracy, to theirfinancial benefit and MAX's detriment.

4. The illegal activities at issue here began several years ago. In 2009, MAX

discovered thai Tsui had stolen its proprietary and trade secret information relating to MAX's

core projection and conversion technologies, including software source code. While employed by

MAX, but unbeknownst to it, Tsui formed his own company in competition with MAX, and

used MAX's trade secrets to compete against - and beat out - MAX on a bid for a significant

project in China.

5. Following Tsui's trail from Ontario, Canada to Beijing, China (and now to Los

Angeles), MAX conducted its own investigations into Tsui's activities and, after finding

incriminating information, MAX initiated lawsuits against Tsui in both Canada and China.

Through those suits, MAX uncovered voluminous, conclusive proof of Tsui's retention and theft

of MAX's confidential and proprietary trade secrets, including CDs containing the source code

for MAX's 2D/3D conversion process and re-mastering technology, as well as the repeated use

of MAX's trade secrets to form companies in Canada and China in direct competition with

MAX. Based on that evidence, MAX has obtained extraordinary relief from two foreign

tribunals, including a rarely granted, multi-site search and seizure order, a contempt order, and

ultimately an arrest warrant issued by the Canadian court, and a broad search and seizure order

issued by the Beijing court and executed by several Chinese judges. Tsui remains an

international fugitive, and his plan to profit unlawfully from the technology stolen from MAX

has now touched U.S. soil with Defendant GDC's efforts to market CFGS with the benefit of

public funding.

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6. Plaintiff MAX Corporation ("Plaintiff) is a Canadian corporation having aprincipal place of business located at 2525 Speakman Drive, Sheridan Science and TechnologyPark, Mississauga, Ontario, Canada L5k 1B1, and is and was at all times mentioned hereinqualified to do business in California.

7. Upon information and belief, Defendant GDC Technology (USA), LLC is a

California limited liability company having a principal place of business located at 1016 W.

Magnolia Blvd., Burbank, California 91506. Upon information and belief, GDC Technology(USA), LLC is awholly-owned subsidiary of GDC Technology Limited, acompany incorporatedin theBritish Virgin Islands.

8. Upon information and belief, Defendant GDC Technology of America, LLC is a

Delaware limited liability company having a principal place of business located at 21155

Whitfield Place, Suite 207, Sterling, Virginia 20165.

9. Upon information and belief, Defendant GDC Technology Limited is acompanyincorporated in the British Virgin Islands, with its principal place of business located at Unit 1-7,

20th Floor, Kodak House II, 39 Healthy Street East, North Point, Hong Kong.

10. Upon information and belief, Defendant GDC Technology Limited is acompany

incorporated in the Cayman Islands, with its principal place of business located at Unit 1-7, 20th

Floor, Kodak House II, 39 Healthy Street East, North Point, Hong Kong.

JURISDICTION AND VENUE

11. This Court has jurisdiction over this action pursuant to Article VI, section 4 ofthe

California Constitution.

12. This Court has personal jurisdiction over Defendants, and each of them, because,

upon information and belief, each does business within the State of California. Further, MAX is

informed and believes, and on that basis alleges, that Defendant GDC Technology (USA) LLC is

domiciled in the State of California with its principal place of business in California, and the

remaining Defendants have purposefully availed themselves of the privileged of conductingactivities within the State of California by, inter alia, entering into business agreements governing

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activities in this State. Further, this Court has jurisdiction over Defendants as they have engaged

and continue to engage in the conduct that gives rise;to the claims stated herein within California

and Los Angeles County.

1.3. Venue is proper in this judicial district pursuant to Code of Civil Procedure

Section 395 because, upon information and belief, at least one of the Defendants resides in Los

Angeles County and the acts giving rise to the Complaint occurred within this judicial district.

FACTUAL BACKGROUND

Background Regarding IMAX and Its Technologies

14. MAX is one of the world's leading entertainment technology companies, with a

particular emphasis on film and digital imaging technologies, including 3D, post production and

digital projection. For almost 40 years, MAX has been a pioneer and provider of immersive

motion picture technologies, including large format projection systems, as well as the technology

of converting 2D images and motion pictures to 3D images and motion pictures ("2D to 3D

Conversion"), and the Digital Media Re-Mastering ("DMR") technology of converting standard

35 mm or digital format films into films for exhibition on MAX's large format projectionsystems.

15. MAX maintains a multi-million dollar Research and Development program to

develop and improve its state of the art projection and film conversion technologies, and it

employs dozens of engineers and other technical experts to work on these projects. Among the

core technologies that play a key role in MAX's market competition, and to which MAX

expends significant funds to market and develop, are:

• The MAX Image Enhancer Technology: MAX developed an Image Enhancer

which is a combination of proprietary hardware and software that allows images from two

projectors used in its large format projection system to be superimposed to asub-pixel resolution,

reducing the pixilation artifacts and increasing light levels by up to 100 percent and contrast

levels up to 30 percent. This is a critical feature to enable the projector to project images at

optimal light levels which result in high resolution images.

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• The MAX 2D to 3D Conversion Technology: This is a software-based post-

production process that converts images shot on a regular motion picture camera to 3D using a

combination of MAX proprietarysoftware.

* The MAX DMR Film Conversion Technology: This proprietary software is a

secure re-mastering process for transforming standard Hollywood films (35 mm ordigital format)

into films for exclusive exhibition in MAX large format theaters.

(Collectively, "MAX Image Enhancer Technology", "MAX 2D to 3D Conversion Technology"

and "MAX DMR Film Conversion Technology" referred to as "MAX Trade Secrets").

16. The MAX Trade Secrets are not accessible to the public or any third party

through any public channels, and MAX has never publicly disclosed such proprietary

information to the public. These technologies are core, critical components of MAX's offerings,

and the culmination of over four decades of research and development, which clearly have

practical applicability and have brought significant economic benefit to MAX. In addition, in

the competitive marketplace for providing large format and/or 3D imaging technology to the

cinema industry, there is great economic benefit to MAX in this proprietary technical and

business information.

17. MAX has taken extensive measures to protect the MAX Trade Secrets, including

not only contractual measures, but also technological and procedural measures. MAX requires

employees to sign Employee Confidentiality and Non-Competition Agreements in order to

protect and keep confidential the MAX Trade Secrets. In addition, as per the MAX Code of

Ethics, confidential, trade secret information, such as the MAX Trade Secrets, is made available

by limiting access to such information to those employees who have a need to know in order to

do their job, and the access of that information is supervised and monitored by MAX to ensure

that confidentiality is maintained.

18. Based on the foregoing, MAX alleges that the MAX Trade Secrets areentitled to

protection under the California Uniform Trade Secrets Act. Nevertheless, in the event that it is

ultimately determined that some or all of the MAX Trade Secrets do not qualify for protection

under the California Uniform Trade Secrets Act, MAX further and separately alleges, and6

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therefore pleads in the alternative, that some or all of the MAX Trade Secrets nonetheless

represent confidential and proprietary information that belongs to MAX for which GDC owed

contractual, statutory and/or common law duties and legal obligations not to acquire, use and/or

disclose.

Theft of IMAX's Trade Secrets By Former Employee Gary Tsui

19. MAX employed an individual named Xiaoyu Cui aka Gary Tsui ("Tsui") as a

Software Engineer in its Ontario, Canada headquarters from July 22, 1999, until he was

terminated on or about November 26, 2009.

20. Tsui's responsibilities at MAX included, without limitation:

(a) developing proprietary high-performing image processing software and

algorithms for large format motion picture production applications and digital cinematic products;

(b) designing and implementing new image processing software products for

the advancement of MAX image processing technology, including re-mastering technology;

(c) developing software that allows for 3D cloning functions and ensures the

delivery ofexcellent 3D quality through MAX's Live Action 3D conversion process;

(d) developing and improving MAX's DMR software, which allows

conventional films to be converted into large format;

(e) developing and managing version control for all of MAX's image

technology software; and

(f) developing an encryption scheme for the MAX Image Enhancer, by virtue

of which Tsui became extremely knowledgeable as to how the proprietary Image Enhancer

technology works.

21. By virtue of his responsibilities and access to other employees, Tsui also gained

knowledge of highly confidential and proprietary business information regarding products,

pricing and market plans.

22. At the outset of his employment with MAX, Tsui executed a Confidentiality and

Non-Competition Agreement, in which he acknowledged that he would: (a) not disclose MAX

trade secrets and other intellectual property during or after his employment with MAX; and (b)7

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not compete with MAX or any of its subsidiaries while employed with MAX and for aspecifiedperiod from the conclusion ofhis employment with MAX.

23. In August 2008, a delegation from Hangzhou, China visited MAX's offices in

Ontario, Canada for the purpose of conducting due diligence on MAX's technology inanticipation of MAX's response to aRequest for Proposal to build alarge format 3D theater at ascience and technology museum in Hangzhou. During that tour, Tsui acted as atranslator for the

Hangzhou delegation, which included an individual named Allan Qiang ("Qiang").24. Months later, Tsui gave notice of his resignation from MAX on November 2,

2009, but was to continue to work at MAX to transition his responsibilities through the end ofNovember. On November 24, 2009, MAX learned that the Hangzhou Project was awarded toJiangsu Sunway Digital, Inc. ("Sunway"), an entity unknown in the industry at that time, whichhad submitted a bid 13 percent lower than MAX's bid.

25. MAX subsequently learned that Sunway was established on July 2, 2009, by Tsuiand Qiang, while Tsui was still employed by MAX. MAX is informed and believes that it was

impossible for Sunway to have independently developed the necessary technology (technologythat took MAX over four decades to create) to complete the Hangzhou Project in the four short

months between when the company was formed and when it won the Hangzhou bid. Given the

timing and the extensive access to MAX's trade secrets by Tsui during his employment and

during his formation of Sunway, the technology used by Sunway to win the Hangzhou projectwas, upon information and belief, derived from MAX's proprietary technology and trade secrets.

26. Given Tsui's misappropriation of MAX's trade secrets and unlawful competition

with MAX, MAX terminated Tsui's employment on or about November 26, 2009.

27. After his termination, forensic searches of Tsui's MAX computer revealed

abundant evidence of his creation of Sunway and his rampant use of MAX's trade secrets for his

personal gain. MAX learned that, immediately after his termination from MAX, Tsui concealed

two computer hard drives in Ontario, then fled to China. Those hard drives, which MAX later

learned were retrieved by Qiang, were assumed to contain highly confidential and proprietaryinformation relating the MAX Trade Secrets.

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IMAX Sues Tsui inCanada andChina and Uncovers OverwhelmingEvidence ot Tsui's Theftand Use of IMAX's Trade Secrets.

28. On December 8, 2009, after Tsui fled to China, IMAX initiated alawsuit againstTsui, Qiang and their related companies in Ontario, Canada, through which MAX sought, amongother remedies, an injunction to: (a) prohibit Tsui from disclosing or using MAX's confidential

and proprietary information; (b) prohibit Tsui from competing with MAX; and (c) requiring Tsuito preserve all information, documents and other property of MAX. The Ontario Superior Court

of Justice awarded the injunctive relief sought by MAX in its entirety on December 22, 2009("the Order").

29. Tsui ignored the entry of the Order, fled to China, and continued to use the MAX

Trade Secrets in violation of the Order.

30. In fact, in 2012, evidence was uncovered in the Ontario litigation confirming thatTsui was continuing to use the MAX Trade Secrets under avariety of different business names.

31. This evidence indicates that, in early January 2012, Tsui's Sunway business had

morphed into a joint venture called "DMAX." Upon information and belief, "DMAX" was

renamed CFGS, after MAX asserted a trademark action against it. IMAX is informed and

believes, and on that basis alleges, that CFGS, however named, utilizes the stolen MAX Trade

Secrets and intends to serve as a competitive alternative to MAX's large format screentechnologies.

32. In addition to DMAX and CFGS, MAX is informed and believes, and on that

basis alleges that Tsui also founded Beijing Cubic Pictures Technology, Inc., which provides 2D

to 3D film conversion using, upon information and belief, the MAXTrade Secrets.

33. In January 2012, the Ontario Court of Justice found Tsui in contempt of its prior

injunction, and again ordered Tsui to stop competing with MAX, and to return the company'sproperty, including proprietary and confidential information. Once again, Tsui disregarded thisorder.

34. Further, based on the overwhelming evidence uncovered in that lawsuit, the

Ontario court granted IMAX an "Anton Pillar" Order, a rarely granted remedy that is the

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equivalent ofa criminal search and seizure order. Under this order, Tsui's residences and offices

in Ontario were searched in July 2012, and additional evidence was uncovered demonstrating

Tsui's theft of the MAX Trade Secrets, use of those Trade Secrets to compete directly with

MAX while he was still employed with MAX, and disclosure of those Trade Secrets to third

parties for the purpose of unfairly competing with MAX.'

35. On April 30, 2013, a warrant was issued for Tsui's arrest based on his refusal to

comply with the court's prior orders, and his continued unlawful use of the MAX Trade Secrets.

If Tsui returns to Canada, he will be immediately apprehended and incarcerated. The Ontario

action is to proceed to trial in 2013; although, as part ofthe Ontario court's contempt order, all of

Tsui's defenses have been summarily stricken by the court.

36. Given Tsui's disregard of the Ontario court's orders, and his continued use of the

MAX Trade Secrets in China, MAX filed a lawsuit against Tsui in Beijing, China on February

16, 2013. Based on evidence provided to the Beijing court, an Evidence Preservation Order was

granted by the court, a rare form of relief that provides for broad search and seizure of evidence

by court officials.

37. The execution of this order revealed overwhelming evidence of Tsui's theft and

continued possession and use of MAX's Trade Secrets, including numerous CDs that contained

highly confidential and proprietary source code used in connection with the MAX 2D to 3D

Conversion Technology and the MAX DMR Film Conversion Technology.

38. MAX is informed and believes that CFGS has participated in the defense ofTsui

in China, who has conceded to the Chinese court that he is the "Chief Engineer" of that company.

GDC Partners With CFGS to Use IMAX's Trade Secrets in the UnitedStates and DeceivesConsumers Regarding Its Ability to Offer Large Format Technologies

39. On its website, www.gdc-tech.com, GDC represents that it "is currently the largest

supplier of digital cinema servers throughout Asia and the second largest provider of digital

cinema servers worldwide, serving its customers through offices in the US, Mexico, Spain, Hong

' Other materials found on the premises were destroyed intentionally in violation of the court'sorder by Tsui's relatives in the presence of law enforcement personnel.

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Kong, Japan, Singapore, China and India." It claims to deliver and install "digital cinema servers,projection and 3D systems worldwide."

40. In June 2013, MAX first became aware that GDC had partnered with China Film

Group to develop and sell CFGS systems in the United States and internationally. Specifically,GDC has represented the following in recent publicly distributed and/or filed materials:

(a) "We [GDC] have been selected by the China Film Group, the largest filmdistributor in China, to provide film mastering and exhibition technologies for the China FilmGiant Screen format."

(b) "We [GDC] have also leveraged our relationship with China Film Giant

Screen to exhibit content in the China Film Giant Screen large-screen format. The China Film

Giant Screen format is one of a few large-screen formats used by Hollywood studios. As of

March 31, 2013, China Film Giant Screen had deployed 24 units of our digital cinema servers ontheirlarge-screen format systems in China."

(c) "Our [GDC's] close interaction with leaders of the digital cinema industryhas allowed us to develop a number of proprietary technologies that have improved theaudiovisual experience, enhanced the security of content delivery, reduced content delivery costsand simplified exhibition, including . . . film mastering and exhibition technologies for China

Film Giant Screen, one of afew large-screen formats used by Hollywood blockbusters, in 2012

(d) "We [GDC] also recently entered into contracts for licensing and resellingChina Film Giant Screen systems in Asia (excluding China) on an exclusive basis and in the rest

of the world on a non-exclusive basis. We expect to be able to derive revenue both from initial

equipment sales and sharing of box office revenue for movies in the China Film Giant Screen

large-screen format beginning in the second half of 2013 or in 2014

41. In separate materials, GDC markets its ability to provide - specifically inconnection with the giant screen format - "unique image and projector alignment technologies"and "unique content mastering technologies." Upon information and belief, these "unique image"and "unique content mastering" technologies refer to MAX's highly confidential and proprietary

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DMR Film Conversion Technology. As alleged above, Chinese court officials recovered source

code for MAX's 2D to 3D Conversion Technology and DMR Film Conversion Technology from

Tsui in 2013 in connection with the execution of a search and seizure order. In these same

materials, GDC also markets its ability to provide "projector alignment technologies" in

connection with "giant screen format," which, upon information and belief, refers to MAX's

proprietary and highly confidential Image Enhancer Technology, which serves as acritical feature

of MAX's projection system technology. Further, in these materials, GDC announces its

intention to "Become a Leader in the Large Screen Format Market Segment" through, upon

information and belief, its relationship with CFGS, using MAX's Trade Secrets.

42. Given the conclusive evidence ofTsui's theft of MAX's Trade Secrets, the nature

of CFGS's "large screen format" technologies, Tsui's admission that he is CFGS's "Chief

Engineer," and the impossibly short time to market for CFGS which could not have been

achieved but for the theft, MAX is informed and believes that GDC has acquired and is now

using the MAX Trade Secrets in the CFGS or large format film technologies that it is now

marketing.

43. On June 18, 2013, MAX sent GDC a letter informing GDC ofTsui's theft of the

MAX Trade Secrets, improper use of the MAX Trade Secrets, and intentional interference with

MAX's economic relations. MAX also informed GDC of the lawsuits it filed against Tsui in

Canada and China, including the injunction and warrant for Tsui's arrest issued by the Canadian

court and the search and seizure order issued by the Chinese court (and the abundance of

evidence obtained therefrom), and provided GDC pleadings from both actions. This letter also

informed GDC that:

"It is material and critical that GDC know that its partner, CFGS, has built

technology on the basis of confidential and proprietary information and trade

secrets wrongfully taken from MAX by [Tsui,] one ofMAX's former employees,

who is now the Chief Engineer at CFGS."

44. To date, GDC has provided no response to this letter. After receiving this letter,

GDC continued to aggressively market its relationship with CFGS through publicly distributed12

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and filed documents which tout its ability to exhibit CFGS' large-format and related technologies,despite the fact that GDC has been put on notice that those technologies are derived from theMAX Trade Secrets, and GDC does not have the right to offer these technologies to the public.Given that the materials distributed by GDC to the public and potential investors repeatedlyemphasize GDC's ability to offer CFGS' large-format and related technologies, thisrepresentation is likely to deceive consumers.

FIRST CAUSE OF ACTION(For Violation of California Uniform Trade Secrets Act

Cal. Civ. Code §§ 3426, et seq.)

45. MAX hereby incorporates Paragraphs 1through 44, inclusive, by reference asthough fully set forth herein.

46. MAX has developed, and is the owner of, the MAX Trade Secrets. MAX has atall times owned and possessed the MAX Trade Secrets.

47. The MAX Trade Secrets are proprietary to MAX, are not generally known to thepublic or others who can obtain economic value from their disclosure or use, and MAX derives

independent economic value from the fact that the MAX Trade Secrets are not generally known.48. At all relevant times, MAX has used and is using regular and reasonable efforts to

protect the confidentiality of the MAX Trade Secrets and is maintaining them as trade secrets.

The information in question was atrade secret at the time of the misappropriation.

49. At all relevant times, MAX has derived an economic benefit and leadershipposition in its industry by vigilantly protecting the MAX Trade Secrets and not permitting orallowing such information to be accessed or used by anyone without an express or implied dutyand obligation to MAX to maintain the secrecy thereof. These efforts by MAX include the

confidentiality and non-compete agreements that MAX requires individuals, including Tsui, toexecute upon their employment, as well as the lawsuits MAX has filed against Tsui in Canada

and China in order to protect the MAX Trade Secrets and maintain their secrecy.

50. MAX is informed and believes, and thereon alleges, that prior to June 2013, and

continuing today, GDC wrongfully acquired, disclosed and/or used the MAX Trade Secrets, by

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COMPLAINT

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MANATiyiHELFS &PHiLLlVs, LLP

ATTOKNtvS AT Law

LOS ANCtttS

virtue of its relationship with CFGS and its "Chief Engineer," Tsui, against whom there is

overwhelming evidence of theft and continued use of the MAX Trade Secrets.

51. MAX is informed and believes, and thereon alleges, that at the time the MAX

Trade Secrets were misappropriated and/or used, GDC knew that the MAX Trade Secrets were,

in fact, trade secrets, and were owned and protected by MAX, and/or that GDC acquired the

MAX Trade Secrets improperly by or through people who had a duty to maintain the

confidentiality of the MAX Trade Secrets.

52. The conduct of GDC as alleged herein, constitutes a violation of the California

Uniform Trade Secrets Act, California Civil Code section 3426 etseq.

53. As a direct and proximate result of GDC's above-described conduct, acts, and

omissions, MAX has suffered and/or will suffer numerous harms, including but not limited to,

lost revenues and profits, damaged relations with current and prospective customers, and material

and continuing loss of value of its trade secrets.

54. As a direct and proximate result of GDC's above-described conduct, acts, and

omissions, Defendants have been unjustly enriched by misappropriating the MAX Trade Secrets

and by using the MAXTrade Secrets to unfairly compete with MAX in the large format motion

picture industry. Defendants have been able to avoid or significantly minimize the normal costs

and expenses associated with launching a new business enterprise in this industry.

55. As a direct and proximate result of GDC's above-described conduct, MAX has

been damaged in an amount to be proven at trial. The misappropriation, acquisition, use and/or

disclosure of the MAX Trade Secrets was a substantial factor in causing MAX's injury and

harm.

56. GDC, by engaging in the conduct alleged herein, has acted intentionally, willfully,

and maliciously, and in conscious disregard ofMAX's rights and interests, and with the purpose

of injuring MAX and depriving it of its rights. As a result, MAX is entitled to an award of

exemplary or punitive damages, in an amount to be determined at trial.

57. Pursuant to California Civil Code sections 3426.3 and 3426.4, MAX also seeks

enhanced damages and to recover its attorneys' fees and costs incurred as a result of GDC's14

COMPLAINT

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MANATT,ip,l>IELPS&Phillips, LLP

ATTOKNirs A! Law

Los ANCtl.ES

misappropriation of its trade secrets and/or reasonable royalties pursuant to California Civil CodeSection 3426.2.

58. Pursuant to California Civil Code section 3426.2, MAX seeks preliminary andpermanent injunctive relief to enjoin and restrain GDC's unlawful conduct. GDC's wrongful

misappropriation and use of the MAX Trade Secrets will, unless and until enjoined andrestrained by order of this Court, cause great and irreparable injury to MAX's business bydestroying the confidential and proprietary nature of the MAX Trade Secrets and making thatinformation available to MAX's competitors. Injunctive relief is also appropriate to restrainGDC from further unlawful conduct for which MAX has no adequate remedy at law.

SECOND CAUSE OF ACTION(Unjust Enrichment)

59. MAX hereby incorporates Paragraphs 1 through 58, inclusive, by reference asthough fully set forth herein.

60. GDC was the recipient of proprietary information and confidential property owned byMAX.

61. GDC acquired that property in a way that caused it to receive a valuable benefit

through its actions that GDC would not have otherwise received and which GDC continues to

retain. In this way, GDC profited and unjustly benefitted from the receipt and improper use of

MAX's proprietary information and confidential property.

62. In addition, MAX is informed and believes, and on that basis alleges, that GDC has

misled and deceived members of the public and potential investors and has sought to obtain

public funding by concealing facts that are material pertaining to the actual source of its

technologies licensed from CFGS.

63. As a result of its improper actions, GDC has been and/or will be unjustly enriched at

the expense of IMAX and as a benefit to GDC.

64. Under principles of equity and good conscience, GDC should not be permitted to

retain the benefits it has received, in an amount to be proven at trial.

15

COMPLAINT

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MANATTljgHELPSS:Phillips, LLP

ATTORNEYS AT LAW

. LOSANCELES

THIRD CAUSE OF ACTION

(Violation of Statutory Unfair Competition LawBus. & Prof. Code §§ 17200 etseq.)

65. MAX hereby incorporates Paragraphs 1 through 64, inclusive, by reference asthough fully set forth herein.

66. By virtue of the misconduct described herein, GDC has engaged in unlawful,unfair and/or fraudulent business acts and practices and unfair, deceptive, untrue or misleadingadvertising in violation of California Business and Professions Code sections 17200 et seq.

67. MAX is informed and believes, and on that basis alleges that GDC has distributed

materials to the public, including potential investors, in which GDC has falsely and misleadinglyrepresented and/or omitted material facts related to its ability to offer and exhibit CFGS' large-format and related technologies. GDC knew or, by the exercise of reasonable care, should have

known that its representations and/or omissions regarding its ability to offer CFGS' large-formatand related technologies were untrue or misleading. Given that the materials distributed by GDCto the public and potential investors repeatedly emphasize GDC's ability to offer CFGS' large-format and related technologies, these representations were material, and were likely to deceivethe public.

68. Furthermore, MAX is informed and believes, and on that basis alleges that GDC

has not disclosed to the public or potential investors that MAX had threatened and has now

initiated a lawsuit against GDC. MAX is informed and believes, and on that basis alleges thatthis information is material, as potential investors and the general public continue to erroneouslybelieve that GDC will generate revenue from the GFGS large-screen format when, in actuality,that technology is the subject of the instant litigation, as well as the litigation in Canada andChina described above.

69. As a proximate result of GDC's fraudulent business acts and practices and false

advertising, MAX has lost money and property, and GDC has enjoyed unlawful profits, in asum

not yet fully ascertained. MAX seeks the remedy of disgorgement and restitution for illicit

profits obtained by GDC, from their fraudulent business practices and false advertising, as allegedherein.

16

COMPLAINT

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Attokwevs Ar Law

LOS AMCttt?

70. MAX seeks preliminary and permanent injunctive relief to enjoin and restrain

GDC's conduct. GDC's wrongful conduct will, unless and until enjoined and restrained by order

of this Court, cause irreparable injury to MAX's business. Injunctive relief is also appropriate to

restrain GDC from further unlawful conduct for which MAX has no adequate remedy at law.

PRAYER FOR RELIEF

WHEREFORE, as a result of the foregoing, MAX respectfully prays for relief againstGDC as follows:

(a) actual damages in the amount caused by GDC to be proven at trial;

(b) monetary damages in an amount by which GDC was unjustly enriched and

will be unjustly enriched;

(c) reasonable royalties for the use of trade secrets pursuant to Civil Code

3426.3(b);

(d) exemplary damages pursuant to Civil Code 3426.3(c);

(e) awarding compensatory and punitive damages in an amount to be

determined at trial, with interest, at the maximum amount permitted by law;

(f) attorneys' fees, costs and disbursements in prosecuting this action, as well

as interest, to the extent permitted by law;

(g) preliminary and permanent injunctive relief as the Court may deem

necessary and proper;

(h) such other and further relief as this Court deems just and proper.

Dated: August 12, 2013

310432166.4

MANATT, PHELPS & PHILLIPS, LLPCHAD S. HUMMELSHARI MULROONEY WOLLMANERIN C. WITKOW

9^Q_Attorneysfor PlaintiffMAX CORPORATION

17

COMPLAINT

.ATTORNEY 0R PARTy WITHOUT ATTORniTi^mTd^fnumt^, aadaMass)Chad S. Hummel (Bar No. 139055j!shari Mulrooney Wollman (Bar No 137142MANATT, PHELPS &PHILLIPS, LLP °- "'***11355 W.Olympic Blvd.Los Angeles, CA 90064

telephone no.: (310) 312-4000 fax no, (310) 312-4224attorney for (Name): Plaintiff IMAX Corporation

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELESstreet aooress: 111 N. Hill Street

MAILINGAOORESS:

cityand zip cone: Los Angeles, CA 90012branch name: Central

!WFOR COURT USE ONLY

- FILEDjtys ANGELES SUPERIOR COURT

AUG 12 2013A. CLARKE, CLERK

, <tfafy~—tim&WVS. DEPUTY

CM-010

casename: IMAX Corporation v. GDC Technology (USA) LLC, et al.

ComplexCase Designation

D Counter • JoinderFiled with first appearance bydefendant

(Cal. Rules of Court, rule 3.402)

CASE NUMBER:

8C518132CIVIL CASE COVER SHEET

S Unlimited Q Limited(Amount (Amountdemanded demanded isexceeds $25,000) $25,000 or less)

Items 1-6below must becompleted (see instructions on page 2).Check onebox below for the case type that best describes this caseAuto Tort

D Auto (22)LJ Uninsured motorist (46)Other Pl/PDAVD (Personal Injury/PropertyDamageAVrongful Death)Tort• Asbestos (04)• Product liability (24)D Medical malpractice (45)• Other PI/PO/WO (23)Non-PI/PD/WO (Other) TortD••••

Contract

LJ Breach of contract/warranty (06)Q Rule 3.740 collections (09)D Other collections (09)Lj Insurance coverage (18)• Other contract (37)Real Property

LJ Eminent domain/Inversecondemnation (14)

D Wrongful eviction (33)

Provisionally Complex Civil Litigation(Cal. Rules ofCourt, rules3.400-3.403)Q Antitrust/Trade regulation (03)

Construction defect (10)Mass tort (40)Securities litigation (28)Environmental/Toxic tort(30)Insurance coverage claims arising from theabove listed provisionally complexcasetypes (41)

Enforcement of JudgmentD Enforcement of judgment (20)Miscellaneous Civil Complaint• RICO (27)Lj Other complaint (not specified above) (42)Miscellaneous Civil Petition

LJ Partnership and corporate governance (21)U Other petition (not specified above) (43)

D••n•

Business tort/unfair business practice (07) Q Other real property (26)Civil rights (08)Defamation (13)Fraud (16)

Intellectual property (19)Professional negligence(25)

[X, Other non-PI/PD/WO tort (35}Employment

LJ Wrongful termination (36)S3 Other employment (15)

Unlawful Detainer

[__ Commercial (31)• Residential (32)• Drugs (38)Judicial Review

D Asset forfeiture (05)D Petition re: arbitration award (11)• Writ of mandate (02)LJ Other judicial review (39)

a. Q Large number of separately represented parties d.b. • Extensive motion practice raising difficult or novel e.

issues thatwill be time-consuming to resolvec Q Substantial amount of documentary evidence f.

3. Remedies sought (check all that apply): a. _*_ monetary b. _j4. Number ofcauses ofaction (specify): 35. (This case • is (3 is not a class action suit.6. c|ft there areany known related cases, file and serve a notice of related caseDate: August 12,2013Chad S. Hummel •

(TYPE OflPRINT NAME)

2. This case D is __ is not complex under rule 3.400 of the California Rules of Court. If the case is complex mark thefactors requiring exceptional judicial management: M '

O Large number of witnessesD Coordination with related actions pending in one or more courts

in other counties, states, or countries, or in a federal court• Substantial postjudgment judicial supervisionnonmonetary; declaratory or injunctive relief c. [__ punitive

f ? NOTICE

'^lTp^Tr^%Shf' w"h the «?' PaPer fifed in (he acti0fl °'Proceeding (except small claims cases or cases filedri Mr^i.ns V '°r ^ lns,i,utions Code> <CaL Rutes °' Court, rule 3.220.) Failure to file may result

•rFjle this cover sheet in addition to any cover sheet required by local court rule

^^^e^gZlSf S6q- °f ^ Ca,if0mia Ru'eS °'C0Urt' *» ™st ""*a«W °< «* -ver sheet on allUnless this is acollections case under rule 3.740 or acomplex case, this cover sheet will be used for statistical purposes only.

"""""••"-—•——-— ~~ —___——. _____________ _____ _. pan

IRNEY FOR PARTY)

FormAdoptedlorMandatory UseJudicial Council of CaliforniaCM-0lO(Rev. July I. 2O07|

CIVIL CASE COVER SHEET

Page 1 of 2

Cat Rules0*Court, rules2.30,3.250.3.400-3.403, 3.740:Cal. Standardsof JudicialAdministration, std. 3.id

www.covrtinto.ca.gov

_.-,.._ INSTRWTIONS ON HOW TO COMPLETE THE ckvER SHEET

_gl_IiifSII§ESAuto Tort

Auto (22)-Personal Injury/PropertyDamage/Wrongful Death

Uninsured Motorist (46) {ifthecase involves an uninsuredmotoristclaim subject toarbitration, check this iteminstead of Auto)

Other PI/PD/WD (Personal Injury/Property Damage/Wrongful Death)Tort

Asbestos (04)Asbestos Property DamageAsbestosPersonalInjury/

Wrongful DeathProduct Liability (notasbestos or

toxic/environmental) (24)Medical Malpractice (45)

Medical Malpractice-Physicians &Surgeons

Other Professional Health CareMalpractice

Other PI/PD/WD (23)Premises Liability (e.g.,slipand fall)Intentional Bodily Injury/PD/WD

(e.g., assault, vandalism)Intentional Infliction of

Emotional DistressNegligent Infliction of

Emotional DistressOther PI/PD/WD

Non-PI/PD/WD (Other) TortBusiness Tort/Unfair Business

Practice (07)Civil Rights (e.g., discrimination,-^false arrest) (not civil^•harassment) (08)Defamation (e.g., slander, libel)"(13)

Fr,aud(16)IntellectualProperty (19)Professional Negligence (25), Legal Malpractice''-OtherProfessional Malpractice

(notmedical orlegal)Other Non-PI/PD/WD Tort (35)

EmploymentWrongful Termination (36)Other-..Employment (15)

CM-O!0liW July I, 2007|

CASE TYPES AND EXAMPLESContract

Breach ofContract/Warranty (06)Breach of Rental/Lease

Contract (not unlawful detaineror wrongful eviction)

Contract/Warranty Breach-SellerPlaintiff (not fraud ornegligence)

Negligent Breach of Contract/Warranty

Other Breach ofContract/WarrantyCollections (e.g., money owed, open

book accounts) (09)Collection Case-Seller PlaintiffOther Promissory Note/Collections

Case

Insurance Coverage (not provisionallycomplex) (18)Auto SubrogationOther Coverage

OtherContract(37)Contractual FraudOther Contract Dispute

Real PropertyEminent Domain/Inverse

Condemnation (14)Wrongful Eviction (33)Other Real Property (e.g., quiet title) (26)

Writ ofPossessionofReal PropertyMortgage ForeclosureQuiet TitleOther Real Property (noteminentdomain, landlord/tenant, orforeclosure)

Unlawful DetainerCommercial (31)Residential (32)Drugs (38) (if the case involves illegal

drugs, checkthisitem; otherwise,report as Commercial orResidential)

Judicial ReviewAsset Forfeiture (05)Petition Re: Arbitration Award ((1)Writof Mandate (02)

Writ-Administrative MandamusWrit-Mandamus on Limited Court

Case MatterWrit-Other Limited Court Case

ReviewOtherJudicial Review (39)

Review of Health Officer OrderNotice of Appeal-Labor

Commissioner Appeals

CIVIL CASE COVER SHEET

CM-010

Provisionally Complex Civil Litigation (Cal.Rulesof Court Rules3.400-3.403)

Antitrust/Trade Regulation (03)Construction Defect(10)Claims Involving MassTort (40)Securities Litigation (28)Environmental/Toxic Tort (30)Insurance CoverageClaims

(arising from provisionally complexcase type listed above) (41)

Enforcement of JudgmentEnforcement ofJudgment(20)

Abstractof Judgment (OutofCounty)

Confession of Judgment (non-domesticrelations)

Sister State JudgmentAdministrative AgencyAward

(not unpaidtaxes)Petition/Certification of Entry of

Judgment on Unpaid TaxesOtherEnforcement ofJudgment

CaseMiscellaneous Civil Complaint

RICO (27)Other Complaint (notspecified

above) (42)Declaratory Relief OnlyInjunctive ReliefOnly (non-

harassment)Mechanics LienOtherCommercial Complaint

Case (non-tort/non<omplex)Other Civil Complaint

(non-tort/non-complex)Miscellaneous Civil Petition

Partnership and CorporateGovernance (21)

Other Petition (notspecifiedabove) (43)Civil HarassmentWorkplace ViolenceElder/Dependent Adult

Abuse

Election ContestPetition for Name ChangePetition for Relief From Late

ClaimOther Civil Petition

Page 2 of 2

American legalNei, Inc.www. Forms Workllow.com

SHORT TITLE;

IMAX Corporation v. GDC Technology (USA), LLC, et al. CASS NUMBER

BC518132CIVIL CASE COVER SHEET ADDENDUM AND

,^^.r-.~ STATEMENT OF LOCATION(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

This form is required pursuant to Local Rule 2.0 in all new civi. case filings in the Los Angeles Superior Court.

Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:JURY TRIAL? _3YES CLASS ACTION? QYES LIMITED CASE? QYES TIME ESTIMATED FOR TR.AL 7 GHOURS/ WPAY.

Item II. Indicate the correct district and courthouse location (4 steps - If yOU checked "Limited Case", skip to Item III, Pg. 4):

^seinLTZT""IT" ^™^ ^ ^ ^ ^ "" ma'n CivN CaS6 C°V6r Sheet headin3 *>' your-ase in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected.

Step 2: Check one Superior Court type of action in Column Bbelow which best describes the nature of this

5S_i: L" C°IUmn °' drCle ,hS r6aS0n f0r ,he court location choice thaf applies to the type of action vou have-hecked: For any exception to the court location, see Local Rule 2.0. Y

case.

Applicable Reasons for Choosing Courthouse Location (see Column Cbelow) |2M^DlStnT/rlr^Sin the 5tanley Mosk Courthouse, central district.i' >^J?Z ^ central (<?her countv' or no bocfily injury/property damaae)3. Location wherecause ofactionarose y uc""d3e'-4. Location where bodily injury, death or damage occurreda. Location where performance required ordefendant resides

6.Location of property orpermanently garaged vehicle7. Location where petitioner resides.8. Location wherein defendant/respondent functions wholly9.Location where one ormore ofthe parties reside '

10. Locationof Labor Commissioner Office

Step 4: Fill in the information requested on page 4in Item III; complete Item IV. Sign the declaration.

CivilCase Cover SheetCategory No.

Auto (22)

BType of Action

(Checkonlyone)

DA7100 Motor Vehicle -Personal Injury/Property Damage/Wrongful Death

Applicable Reasons •See Step 3 Above

1.. 2., 4.

Uninsured Motorist (46) DA7110 Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist 1., 2., 4.

Asbestos (04)

Product Liability (24)

• A6070 Asbestos Property DamageLJ A7221 Asbestos -Personal Injury/Wrongful Death

U A7260 Product Liability (not asbestos or toxic/environmental)

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(23)

LAClV 109 (Rev. 03/11)LASC Approved 03-04

U A7250 Premises Liability (e.g., slip and fall)• A7230 Intentional Bodily Injury/Property Damage/Wrongful Death fe a

assault, vandalism, etc.)

• A7270 Intentional Infliction of Emotional DistressD A7220 Other Personal Injury/Property Damage/Wrongful Death

CIVIL CASE COVER SHEET ADDENDUMAND STATEMENT OF LOCATION

1., 2., 3., 4., 8.

1„ 4.

1., 4.

1.,4.

1.,4.

1..3.

1..4.

Local Rule 2.0Page 1 of 4

American LegalNct. Inc.ww«r.inn»W,,rt:IWl,|.,„r.

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IMAX Corporation v. GDC Technology (USA) LLC, et al. CASE NUMBER

ACivil Case Cover Sheet

Category No.

BType of Action

(Check onlyone)

cApplicable Reasons

See Step 3 AboveI '

Jon-PersonalInjury/Property)amage/WrongfulDeathTortBusinessTort (07) • A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1..3. - [Civil Rights (08) LJ A6005 Civil Rights/Discrirriination

1., 2., 3.

Oefamation(13) LJ A6010 Defamation (slander/libel)1,2., 3.

Fraud (16) LJ A6013 Fraud (no contract) J1,2., 3.

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Professional Negligence (25) LJ A6017 Legal Malpractice

• A6050 Other Professional Malpractice (not medical or legal)1., 2., 3.

1..2..3.

i Other (35) E__ A6025 Other Non-Personal Injury/Property Damage tort (f}3.

went

Wrongful Termination (3€t LJ A6037 Wrongful Termination1,2., 3.

Emploj

OtherEmployment (15) U A6024 Other Employment Complaint Case1LJA6109 Labor Commissioner Appeals

1..2..3.

10.

Contract

Breach ofContract/ Warranty(06)

(not insurance)

• A6004 Breach of Rental/Lease Contract (not unlawful detainer or wronqfuleviction) 3

• A6008 ContractAVarranty Breach -Seller Plaintiff (no fraud/negligence)• A6019 Negligent Breach of Contract/Warranty (no fraud)• A6028 Other Breach of Contract/Warranty (not fraud or negligence)

2.. 5.

2., 5.

1..2..5.

1., 2., 5.

Collections (09) U A6002 Collections Case-Seller Plaintiff

D A6012 Other Promissory Note/Collections Case2., 5., 6.

2., 5.

Insurance Coverage(18) LJ A6015 Insurance Coverage (not complex)1,2., 5., 8. i

OtherContract(37)DA6009 Contractual FraudLJ A6031 Tortious Interference

• A6027 Other Contract Dispute(not breach/insurance/fraud/negligence)

1,2., 3, 5.

1.,2.,3.,5.

1.,2.,3.,8.

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Other Real Property (26)LJ A6018 Mortgage ForeclosureDA6032 Quiet Title

• A6060 Other Real Property {not eminent domain, landlord/tenant, foreclosure)

2„ 6.

2., 6.

2,6.

Jnlawful Oetainer-Commercial(31) • A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2., 6.

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CiviiCase Cover SheetCategory No.

Asset Forfeiture (05)

Petition re Arbitration (11)

Writ of Mandate(02)

OtherJudicial Review (39)

BType of Action

(Check only one)

• A6108 Asset Forfeiture Case

• A6115 Petition to Compel/Confirm/Vacate Arbitration

D A6151 Writ -Administrative Mandamus• A6152 Writ -Mandamus on Limited Court Case Matter• A6153 Writ -Other Limited Court Case Review

D A6150 Other Writ/Judicial Review

Antitrust/Trade Regulation (03) O A6003 Antitrust/Trade RegulationConstruction Oefect (10)

Claims Involving Mass Tort(40)

Securities Litigation (28)

Toxic TortEnvironmental (30)

Insurance CoverageClaimsfrom Complex Case (41)

Enforcementof Judgment (20)

• A6007 Construction Defect

LJ A6006 Claims Involving MassTort

• A6035 Securities Litigation Case

LJ A6036 Toxic Tort/Environmental

• A6014 Insurance Coverage/Subrogation (complex case only)

J

DA6141 Sister State Judgment• A6160 Abstract of Judgment|_J A6107 Confession of Judgment (non-domestic relations)• A6140 Administrative Agency Award (not unpaid taxes)• A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax[_J A6112 Other Enforcement of Judgment Case

RICO (27)

Other Complaints(Not Specified Above) (42)

Partnership CorporationGovernance (21)

Other Petitions(Not Specified Above)

(43)

J

D A6033 Racketeering (RICO) Case

LJ A6030 Declaratory Relief Only

• A6040 Injunctive Relief Only (not domestic/harassment)• A6011 Other Commercial Complaint Case (non-tort/non-complex)• A6000 Other Civil Complaint (non-tort/non-complex)

• A6113 Partnership and Corporate Governance Case

DA6121 Civil Harassment• A6123 Workplace Harassment• A6124 Elder/Dependent Adult Abuse CaseLJ A6190 Election Contest

LJA6110 Petition for Change of Name• A6170 Petition for Relief from Late Claim LawD A6100 Other Civil Petition

LACI(y5109 (Rev. 03/11)LASC Approved 03-04 CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATION

Applicable ReasonsSee Step 3 Above

2,6.

2., 5.

2., 8.

2.

2.

2., 8.

1., 2., 8.

1., 2., 3.

1., 2., 8.

1., 2., 8.

1., 2., 3., 8.

1., 2„5.,8.

2., 9.

2,6.

2., 9.

2., 8.

2,8.

2., 8., 9.

1. 2.,8.

1., 2., 8.

2., 8.

1,2., 8.

1,2., 8.

2,8.

2,3., 9.

2., 3., 9.

2.. 3., 9.

2.

2,7.

2., 3., 4., 8.

2., 9.

Local Rule 2.0Page 3 of 4

American LcgalNcI, !itc.wwW.lnrmaV,,rti|.11„„,1|n|

SHORT TITLE: w

IMAX Corporation v. GDC Technology (USA), LLC, et al. CASE NUMBER

Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance or othercircumstance mdicated in Item II., Step 3on Page 1, as the proper reason for filing in the court location you selected.

REASON: Check the appropriate boitesforthe numbers shownunder Column Cfor the typeofaction that you haveselectedforthis case.

• 1. _S2. H3. D4. Q5.D6. D7. Ds. •_. DmCITY:

BurbankSTATE:

CAZIP CODE:

91506

ADDRESS:

1016 W. Magnolia Blvd.

Item IV. Declaration ofAssignment: Ideclare under penalty of perjury under the laws of the State of California that the foregoing is trueand correct and that the above-entitfed matter is properly filed for assignment to the Stanley Mosk courthouse in the

.District of the Superior Court of California, County of Los Angeles [Code Civ. Proa, §392 et seq., and LocalCentral

Rule 2.0, subds. (b), (c) and (d)J.

Dated: August 12, 2013

(SIGNATURE OFATTORNEY/FILING PARTY)Chad S. Hummel

^St^XS^^^^imS^i C0MPLETED AND READY T0 BE FILED ,N ORDER ™pr°perly1. Original Complaint or Petition.

2. If filing a Complaint, a completed Summons form for issuance by the Clerk.

3. Civil Case Cover Sheet, Judicial Council form CM-010.

4. Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.w/l I j.

5. Payment in full of the filing fee, unless fees have been waived.

6. Asigned order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is aminor under18 years ofage will be required byCourt in orderto issue a summons.

7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendummust be served along with the summons and complaint, or other initiating pleading in the case.

CI)

Co

j—<*

u/

i_i

LACiy,jl09 (Rev. 03/11)

LASC Approved 03-04CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATIONLocal Rule 2.0

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