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Below is a cache of http://www.gambling-law-us.com/Articles-Notes/Fantasy-Complaint.pdf. It's a snapshot of the page taken as our search engine crawled the Web.
The web site itself may have changed. You can check the current page or check for previous versions at the Internet Archive. Yahoo! is not affiliated with the authors of this page or responsible for its content. IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI GARDY & NOTIS, LLP
Mark C. Gardy (MG-0338)
James S. Notis (JN-4189)
440 Sylvan Avenue, Suite 110
Englewood Cliffs, New Jersey 07632
Tel: 201-567-7337
Fax: 201-567-7377
Counsel for Plaintiff
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY
CHARLES E. HUMPHREY, JR.,
Plaintiff, v.
VIACOM INC.,
CBS CORPORATION,
CBS TELEVISION NETWORK,
SPORTSLINE.COM, INC.,
THE WALT DISNEY COMPANY,
ESPN, INC.,
THE HEARST CORPORATION,
VULCAN, INC.,
VULCAN SPORTS MEDIA and
THE SPORTING NEWS,
Defendants.
No.
COMPLAINT
JURY TRIAL DEMANDED
Plaintiff, by his undersigned counsel, alleges the following upon personal knowledge as to himself and upon information and belief as to all other matters. The allegations based upon information and belief were formed after an inquiry reasonable under the circumstances. Case 2:33-av-00001 Document 107-1 Filed 06/20/2006 Page 1 of 29 ALLEGATIONS PURSUANT TO LOCAL CIVIL RULE 10.1 1. The names and addresses of the parties are as follows: Defendants Viacom, Inc.
1515 Broadway
New York, New York 10036
CBS Corporation
51 West 52nd Street
New York, New York 10019
Plaintiff Charles E. Humphrey, Jr.
c/o Gardy & Notis, LLP
440 Sylvan Avenue, Suite 110
Englewood Cliffs, New Jersey 07632 CBS Television Network
1515 Broadway
New York, New York 10036
Sportsline.Com, Inc. 2200 West Cypress Creek Road
Fort Lauderdale, Florida 33309
The Walt Disney Company
500 South Buena Vista Street
Burbank, California 91521
ESPN, Inc. 935 Middle Street
Bristol, Connecticut 06010
The Hearst Corporation 959 Eighth Avenue
New York, New York 10019
Vulcan, Inc. 505 5th Avenue South
Seattle, Washington 98104
Vulcan Sports Media
10176 Corporate Square Drive
St. Louis, Missouri 63132
The Sporting News
475 Park Avenue South
New York, New York 10016
2 Case 2:33-av-00001 Document 107-1 Filed 06/20/2006 Page 2 of 29 NATURE OF THE ACTION 2. Plaintiff brings this action against the major operators of Internet fantasy sports leagues for violations of the anti-gambling and gambling loss recovery laws of New Jersey and other states with similar prohibitions. 3. Each of the defendants operated and promoted Internet fantasy sports leagues in which the participants agree to pay a specified amount of money to participate; the determination of winners is based predominantly on chance rather than skill; and the winners receive a monetary or other valuable prize. Defendants receive the wagers made by participants to play in the fantasy sports leagues. These wagers represent gambling losses. The wagers are the source of revenues and profits to defendants from operating these Internet fantasy sports leagues. 4. Despite the illegal nature of such gambling in New Jersey and the United States in general, defendants actively and knowingly facilitate illegal Internet gambling by operating fantasy sports leagues through their Internet websites throughout the United States. The revenues that defendants earn from the operation of these Internet fantasy sports leagues are derived directly from the wagers made by players, denominated by defendants as membership or participation fees charged to the participants in the league. Such wagers range from $9.95 to $499.95 per team. 5. During the past year, revenues from the operation of fantasy sports leagues are estimated to have been over $1.5 billion, resulting in defendants having received and retained substantial gambling losses incurred by players who are members of the general public throughout the United States. 3 Case 2:33-av-00001 Document 107-1 Filed 06/20/2006 Page 3 of 29 JURISDICTION AND VENUE 6. This Court has subject matter jurisdiction over all causes of action asserted herein pursuant to 28 U.S.C.
The web site itself may have changed. You can check the current page or check for previous versions at the Internet Archive. Yahoo! is not affiliated with the authors of this page or responsible for its content. IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI GARDY & NOTIS, LLP
Mark C. Gardy (MG-0338)
James S. Notis (JN-4189)
440 Sylvan Avenue, Suite 110
Englewood Cliffs, New Jersey 07632
Tel: 201-567-7337
Fax: 201-567-7377
Counsel for Plaintiff
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY
CHARLES E. HUMPHREY, JR.,
Plaintiff, v.
VIACOM INC.,
CBS CORPORATION,
CBS TELEVISION NETWORK,
SPORTSLINE.COM, INC.,
THE WALT DISNEY COMPANY,
ESPN, INC.,
THE HEARST CORPORATION,
VULCAN, INC.,
VULCAN SPORTS MEDIA and
THE SPORTING NEWS,
Defendants.
No.
COMPLAINT
JURY TRIAL DEMANDED
Plaintiff, by his undersigned counsel, alleges the following upon personal knowledge as to himself and upon information and belief as to all other matters. The allegations based upon information and belief were formed after an inquiry reasonable under the circumstances. Case 2:33-av-00001 Document 107-1 Filed 06/20/2006 Page 1 of 29 ALLEGATIONS PURSUANT TO LOCAL CIVIL RULE 10.1 1. The names and addresses of the parties are as follows: Defendants Viacom, Inc.
1515 Broadway
New York, New York 10036
CBS Corporation
51 West 52nd Street
New York, New York 10019
Plaintiff Charles E. Humphrey, Jr.
c/o Gardy & Notis, LLP
440 Sylvan Avenue, Suite 110
Englewood Cliffs, New Jersey 07632 CBS Television Network
1515 Broadway
New York, New York 10036
Sportsline.Com, Inc. 2200 West Cypress Creek Road
Fort Lauderdale, Florida 33309
The Walt Disney Company
500 South Buena Vista Street
Burbank, California 91521
ESPN, Inc. 935 Middle Street
Bristol, Connecticut 06010
The Hearst Corporation 959 Eighth Avenue
New York, New York 10019
Vulcan, Inc. 505 5th Avenue South
Seattle, Washington 98104
Vulcan Sports Media
10176 Corporate Square Drive
St. Louis, Missouri 63132
The Sporting News
475 Park Avenue South
New York, New York 10016
2 Case 2:33-av-00001 Document 107-1 Filed 06/20/2006 Page 2 of 29 NATURE OF THE ACTION 2. Plaintiff brings this action against the major operators of Internet fantasy sports leagues for violations of the anti-gambling and gambling loss recovery laws of New Jersey and other states with similar prohibitions. 3. Each of the defendants operated and promoted Internet fantasy sports leagues in which the participants agree to pay a specified amount of money to participate; the determination of winners is based predominantly on chance rather than skill; and the winners receive a monetary or other valuable prize. Defendants receive the wagers made by participants to play in the fantasy sports leagues. These wagers represent gambling losses. The wagers are the source of revenues and profits to defendants from operating these Internet fantasy sports leagues. 4. Despite the illegal nature of such gambling in New Jersey and the United States in general, defendants actively and knowingly facilitate illegal Internet gambling by operating fantasy sports leagues through their Internet websites throughout the United States. The revenues that defendants earn from the operation of these Internet fantasy sports leagues are derived directly from the wagers made by players, denominated by defendants as membership or participation fees charged to the participants in the league. Such wagers range from $9.95 to $499.95 per team. 5. During the past year, revenues from the operation of fantasy sports leagues are estimated to have been over $1.5 billion, resulting in defendants having received and retained substantial gambling losses incurred by players who are members of the general public throughout the United States. 3 Case 2:33-av-00001 Document 107-1 Filed 06/20/2006 Page 3 of 29 JURISDICTION AND VENUE 6. This Court has subject matter jurisdiction over all causes of action asserted herein pursuant to 28 U.S.C.
