BUSHNELL, CAPLAN & FIELDING, LLP
ALAN M. CAPLAN, (49315)
221 Pine Street, Suite 600
San Francisco, CA 94104-2715
Telephone: 415/217-3800
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
BRETT BRUCE, On Behalf of Himself and All ) No.
Others Similarly Situated, )) CLASS
Plaintiff, )) COMPLAINT
vs. ) OF 18
) §§ 2510,
DOUBLECLICK, INC., ) §§ 2701,
) INVASION
Defendant. )
) DEMAND
Plaintiff, by his undersigned attorneys, for his class action complaint, alleges the
herein. Plaintiff's claims as to himself and his own actions, as set forth in ¶ 4, are based upon
knowledge. All other allegations are based upon information and belief pursuant to the
counsel. Based upon such investigation, plaintiff believes that substantial evidentiary support
allegations herein or that such allegations are likely to have evidentiary support after a
opportunity for further investigation and/or discovery.
NATURE OF THE ACTION
1. Plaintiff brings this action on behalf of himself and all other users affected by
DoubleClick, Inc.'s ("DoubleClick") Internet advertising products and services that are covertly
to and have secretly intercepted users' personal data and web surfing habits and transmitted this
and private information to DoubleClick. Plaintiff seeks injunctive relief and monetary damages,
SNIPPETS:
BUSHNELL, CAPLAN & FIELDING, LLP ALAN M. CAPLAN,
Plaintiff, by his undersigned attorneys, for his class action complaint, alleges the claims
plaintiff believes that substantial evidentiary support exists for the
allegations herein or that such allegations are likely to have evidentiary support after a
DoubleClick, Inc.'s Internet advertising products and services that are covertly designed
to and have secretly intercepted users' personal data and web surfing habits and transmitted
consumers' personal and private information without their consent or proper disclosure.
This Court has jurisdiction over plaintiffs claims pursuant to 28 U.S.C. §§133 l and 1367,
18 U.S.C. § 2701 ET SEQ., AND FOR INVASION OF PRIVACY
Assignment of this action to the San Francisco Division is appropriate as substantial
Defendant DoubleClick is a New York corporation with its principal place of business
services for advertisers and Web site owners worldwide.
There are over 11,500 Web sites using DoubleClick's Internet advertising products
that plaintiff seeks to represent is composed of all persons in the United States whose
any questions that may affect only individual Class members.
Whether the defendant's conduct constitutes the violations of law alleged herein;
communications while in storage by defendant;
In 1998 alone, DoubleClick's DART technology delivered
DoubleClick has two principal service offerings: the DoubleClick Network and the DART
sophisticated tracking and reporting functionality incorporated into DART secretly intercepts
DoubleClick's secret tracking and profiling technology uses cookies to intercept and collect
DoubleClick created the Abacus Online Alliance.
At all relevant times, DoubleClick's advertising, technology contained a secret information
or indication that it was collecting or transmitting personal and private information from
maintain the confidentiality of that information.
Plaintiff realleges and incorporates herein by reference as though set forth in full the
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