1 m B. WBQNER, SBN 101486
IZTHAN P. PETSM&a, 8BN 196046
2 GIESON DUNN & CRUTCHJZFLLLP
333 Saudi Gmd Avtius
3
4
5 IUNDY
___ .- M. hlAsTRo*
GIES ON, DUNN & CRUTCH-= UP
B 200 Pw-k Aveaue
New York, New York 10166-0193
7
B
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ia UNITED STATES DISTRICT COURT
11 CEJ?TFLG DISTRICT OF CALIFORNIA
12 WESTERN DTVISICI~
15
IA ANNA KOURNECWA,
15
18
V.
17 GENEML MEDIA COMMUNICQTXONS,
18 INC., a Nsw York corporatioIq
10 befendsmt.
29
21
22
23 I Plaintiff M KQurnikava alleges for her Complaint: herein as follows:
24 JUM3DXCTION AND VENUE
25 1, This Complakt arise# under 15 U.S.C, 8 1125(a), as amen&& and the
26 and common law of the State of California. This Court has subject IIIB#W juritiction u&r
21 19 U.S,C. 0 1121,28 U,S.C. 6 1331 and% U,S.C. 8 1367(a), TIis C~I.W Bso b subjwt
2E juriadict;ion under 28 U.&C. 0 1332(a), there be& complete divers& of
SNIPPETS:
GIESON DUNN & CRUTCHJZFLLLP
B 200 Pw-k Aveaue New York,
IA ANNA KOURNECWA, 15
18 INC., a Nsw York corporatioIq
26 and common law of the State of California.
mats g-h&g rise to the claim occutiti in this Ntrict Encl this is a PWFiCt in Which the
trumpeted to the world a total f&&&ion that it was printing nude photographs of B
11 accompanied these photographs povided a lurid and detailed account of %ur ticlusive
14 spring, I I as she peels off her top, " That story was total fiction, and Penthouse knew
18 likeness in the basbst, most hwmiliating way for its own crass commeroinl purposes.
26 Kournikova is an &nationally renowned tennis player whose endmement f.m commercial
She spends gcvard weeks b year in California, among other thing, playiag in tournaments and
residence in Florida, pla3 iu tomaments pnd exbibitians the=, and ha& filed Florida m retuma
General Media Commuuications, Inc. is a corporation duly orga&ed and existing un& the laws of
Koumikava joined the professional tennis circuit at the age of fif&een, playiag in tie 1996
to the content of the magazine.
Plaintiff is furfher infmmed azld believes that 20 Defend&L yearly advertising ~vemres bmed
12 P&house Magazine that tkse pi&m were, in fact, pictures of Plaintiff.
27 (one `V&e shot"' and f&r of Plaintiff on the tennig court), and thirteen pi&m of a woman
ne thirteen pictures of L wman mmbz&iq {tweke of thm cle+ing the woman topless}, found on
Defendant or Pentbcm IV&p&s in my knner whatksr.
27 Defendad's acts of misappropriation.
to the public irr a false and misleading light.
amount of mmpemation that would afford Plaintiff adequate relief fofot such continuing tits,
intending to appropriate to its& without compensation what it hew to be II Plaintiff's
'1 PXaiWf's common law rQhta of publiciv mder the wnunon law of California and many 2 otha
25 damages as a result of Defendant% kwing, malicious, oppressive and fcaudulent con&,
23 Magazine arrd on Fenthouso.com~ These phomgraphs are not, however, photogmPhs of the
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