CLASS ACTION COMPLAINT; CASE NO.

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ADAM WANG, (SBN 201233)
(adamqwang@gmail.com)
LAW OFFICES OF ADAM WANG
12 S. First Street, Suite 708
San Jose, CA 95113
Telephone: (408) 421-3403
Facsimile: (408) 416-0248

Attorneys for Plaintiff CHEN MA and the Putative Class


UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

CHEN MA, on behalf of herself and all
others similarly situated,

Plaintiffs,

vs.

APPLE INC., a California corporation;
DOES 1 to 10, inclusive,

Defendants.

Case No.

CLASS ACTION

COMPLAINT FOR DAMAGES AND DEMAND
FOR JURY TRIAL:

COMMON LAW TORT FOR INVASION OF
PRIVACY

DEMAND FOR JURY TRIAL

Case5:14-cv-03344-RMW Document1 Filed07/24/14 Page1 of 6

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NATURE OF CLAIM
1. Plaintiff Chen Ma (hereinafter referred to as Plaintiff) brings this action on behalf
of herself and a proposed class of similarly situated individuals against Defendant Apple Inc.
(hereinafter referred to as Apple), for their damages arising out of Apples blunt violation of
iPhone users privacy.
2. Apple is a California corporation headquartered in Cupertino California. Apple is the
manufacturer of iPhon 4S, iPhone 5, iPhone 5C and iPhone 5S (hereinafter collectively referred to as
iPhones). According to information and belief, these phones were sold to hundreds of millions, if
not billions, of users around the globe.
3. In or around September 2012, Apple released iPhone 4 which contains an iOS
operating system software that enables iPhone 4 to track its users whereabouts down to every
minute, record the duration that users stay at any given geographical point, and periodically transmit
these data stored on the users devices to Apples data base for future references. This function is
hereinafter referred to as Location Service.
4. According to information belief, the succeeding iPhone 4S, iPhone 5, iPhone 5C and
iPhone 5S continue to provide such Location Service.
5. Plaintiff alleges that while using her iPhones, including her current iPone 5S, she was
not given notice that her daily whereabouts would be tracked, recorded, and transmitted to Apple
database to be stored for future reference. She was not asked for and thus has not given her consent,
approval and permission nor was she even made aware that her detailed daily whereabouts would be
tracked, recorded and transmitted to Apple database.
6. On or about July 11, 2014, Chinas Central Television (CCTV) announced its
investigation into iPhones Location Service, revealing for the first time that her iPhone 5S tracks
and records her daily whereabouts without her knowledge, and Apple has been surreptitiously
acquiring the data of her daily whereabouts down to every minutes without her knowledge, consent
approval and permission.
7. According to information and belief, iPhone users are not given any meaningful
choice enabling them to turn off the Location Service without substantially compromising significant
Case5:14-cv-03344-RMW Document1 Filed07/24/14 Page2 of 6

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number of functionalities of iPhones.
8. According to the CCTV, and Plaintiff alleges thereupon, in response to inquiries by
CCTV respondent, Apple only stressed that it will not disclose to any third party the data concerning
iPhone consumers detailed daily whereabouts, but did not deny that these iPhones are indeed
transmitting such highly sensitive and private consumers data to its database to be stored for future
reference.
9. Plaintiff alleges that through the conduct alleged above, Apple has intentionally
intruded on and into Plaintiff and each respective putative class members solitude, seclusion or private
affairs, and such intrusion is highly offensive to a reasonable person.
10. According to belief and information, Plaintiff further alleges that Apple has released
and disclosed the above described private information of iPhone users to third parties, including but
not limited to US government who, according to information, has made more than 1,000 information
requests to Apple.
11. At this point, Plaintiff is not aware of any details of any procedure, if any, that has
been used by Apple in responding to US governments information requests. Based thereon,
Plaintiff alleges that the disclosure and release of iPhone users highly sensitive and private
information has not been for a legitimate public concern.
12. Plaintiff alleges that Apples disclosure and release of such highly private information
is extremely offensive and objectionable to an reasonable person.
13. Plaintiff brings this lawsuit as a class action under Rules 23(a), 23(b)(1), 23(b)(2)
and/or 23(b)(3) of the Federal Rules of Civil Procedure on behalf of a class of similarly situated
persons consisting of all persons who have purchased any iPhone device manufactured by Apple
during the period from September 1, 2012 to the present.
14. The members of the Class, who are ascertainable from Apples records, are so
numerous that joinder of all members is impracticable. The Class is likely to exceed 100 million
members from reported iPhone device sales figures.
15. Plaintiffs claims are typical of the claims of the members of the Class. Plaintiff and
all members of the Class purchased one or more identified Apple iPhone device and have sustained
Case5:14-cv-03344-RMW Document1 Filed07/24/14 Page3 of 6

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damages arising out of Apples conduct in having their highly sensitive and private information
tracked, recorded and transmitted to Apple database without their knowledge, consent, approval and
permission, and have their private information subject to the publication.
16. Common questions of law and fact exist as to all members of the Class and
predominate over any questions solely affecting individual members. Questions of law and fact
common to the Class include:
(1) Whether identified iPhone devises track, record, and transmit users daily whereabouts?
(2) Whether consumers were given a notice about the Location Service that is included in
the identified iPhone devices?
(3) Whether consumers can choose to turn off the Location Service without substantially
compromising a significant number of functionalities of a devise?
(4) Whether Apple has sought and obtained consent, approval and permission to transmit the
consumer data generated by the Location Service to Apple database?
(5) Whether Apple has sought and obtained consent, approval and permission to store
consumers data generated by the Location Service in Apple database?
(6) Whether acquisition of such highly sensitive and highly private consumer data without
the consent, approval and permission of the consumer violated tight of privacy?
(7) Whether Apple should be ordered to destroy such consumer data obtained without
consent, approval and permission of customers?
(8) Whether Apple has published the said consumer data for no public concerns?
(9) Should Apple be allowed to continue possessing the highly sensitive and highly private
consumer data generated by Location Service and transmitted to Apple database without
user consent, approval and permission, what procedure Apple should put in place to
safeguard such information from disclosure to any third person?
(10) What is the proper measure and amount of damages, if any, that is available to the Class?
(11) Should the Court award Plaintiff and the Class punitive damages under California Civil
Code 3294?
17. Plaintiff will fairly and adequately represent the interests of the Class and has no
Case5:14-cv-03344-RMW Document1 Filed07/24/14 Page4 of 6

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interests adverse to or in conflict with other class members. Plaintiffs retained counsel will
vigorously prosecute this case, have previously been designated class counsel on cases in this
judicial district, and are highly experienced in class and complex, multi-party litigation matters.
18. A class action is superior to other available methods for the fair and efficient
adjudication of this controversy because, among other things, joinder of all class members is
impracticable and a class action will reduce the risk of inconsistent adjudications or repeated
litigation on the same conduct. Further, the expense and burden of individual lawsuits would make it
virtually impossible for class members, Apple, or the Court to cost effectively redress separately the
unlawful conduct alleged. Thus, absent a class action, Apple would unjustly retain the benefits of its
wrongdoings. Plaintiff knows of no difficulties to be encountered in the management of this action
that would preclude its maintenance as a class action, either with or without sub-classes.
19. The State of California has sufficient state interest through a significant contact or
aggregation of contacts to the claims asserted by each member of the Class so that the choice of
California law is not arbitrary or unfair.
20. Adequate notice can be given to Class members directly using information
maintained in Apples records, or through notice by publication.
21. Accordingly, class certification is appropriate under Rule 23.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for relief on behalf of herself and the Class against Apple as
follows:
1. Certification of this action as a class action pursuant to Fed. R. Civ. P. 23 and
appointment of Plaintiff and Plaintiffs counsel to represent the Class;
2. Permanent injunctive relief prohibiting Apple from continuing acquiring highly
sensitive and highly private consumer data generated by Location Service without giving consumer a
meaningful notice and without first obtaining an explicit consent, approval, permission before
transmitting such data out of the consumer device
3. Compensatory damages to adequately address injuries suffered by Plaintiff and the
Class arising out of the conduct of Defendant;
Case5:14-cv-03344-RMW Document1 Filed07/24/14 Page5 of 6

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4. Punitive damages against Defendant pursuant to California Civil Code 3294;
5. Award of reasonable attorneys fees and costs
6. Such other and further relief as the Court may deem appropriate.
DEMAND FOR JURY TRIAL
Plaintiff hereby demands a trial by jury of each and every cause of action so triable.

Dated: July 24, 2014 LAW OFFICES OF ADAM WANG


By:
Adam Wang
Attorneys for Plaintiff and the Putative Class










Case5:14-cv-03344-RMW Document1 Filed07/24/14 Page6 of 6

JS 44 (Rev. 12/12) cand rev (1/15/13)
CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6
Foreign Country
IV. NATURE OF SUIT (Place an X in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 400 State Reapportionment
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 410 Antitrust
140 Negotiable Instrument Liability 367 Health Care/ 430 Banks and Banking
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 450 Commerce
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 460 Deportation
151 Medicare Act 330 Federal Employers Product Liability 830 Patent 470 Racketeer Influenced and
152 Recovery of Defaulted Liability 368 Asbestos Personal 840 Trademark Corrupt Organizations
Student Loans 340 Marine Injury Product 480 Consumer Credit
(Excludes Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY 490 Cable/Sat TV
153 Recovery of Overpayment Liability PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 850 Securities/Commodities/
of Veterans Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) Exchange
160 Stockholders Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Management 863 DIWC/DIWW (405(g)) 890 Other Statutory Actions
190 Other Contract Product Liability 380 Other Personal Relations 864 SSID Title XVI 891 Agricultural Acts
195 Contract Product Liability 360 Other Personal Property Damage 740 Railway Labor Act 865 RSI (405(g)) 893 Environmental Matters
196 Franchise Injury 385 Property Damage 751 Family and Medical 895 Freedom of Information
362 Personal Injury - Product Liability Leave Act Act
Medical Malpractice 790 Other Labor Litigation 896 Arbitration
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 791 Employee Retirement FEDERAL TAX SUITS 899 Administrative Procedure
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: Income Security Act 870 Taxes (U.S. Plaintiff Act/Review or Appeal of
220 Foreclosure 441 Voting 463 Alien Detainee or Defendant) Agency Decision
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRSThird Party 950 Constitutionality of
240 Torts to Land 443 Housing/ Sentence 26 USC 7609 State Statutes
245 Tort Product Liability Accommodations 530 General
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION
Employment Other: 462 Naturalization Application
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration
Other 550 Civil Rights Actions
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an X in One Box Only)
1 Original
Proceeding
2 Removed from
State Court
3 Remanded from
Appellate Court
4 Reinstated or
Reopened
5 Transferred from
Another District
(specify)
6 Multidistrict
Litigation
VI. CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Brief description of cause:
VII. REQUESTED IN
COMPLAINT:
CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P.
DEMAND $ CHECK YES only if demanded in complaint:
JURY DEMAND: Yes No
VIII. RELATED CASE(S)
IF ANY
(See instructions):
JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
IX. DIVISIONAL ASSIGNMENT (Civil L.R. 3-2)
(Place an X in One Box Only) ( ) SAN FRANCISCO/OAKLAND ( ) SAN JOSE ( ) EUREKA
Case5:14-cv-03344-RMW Document1-1 Filed07/24/14 Page1 of 2

CHEN MA, on behalf of herself and all others similarly situated,
Adam Wang
P.O. 10881, Pleasanton, CA 94588
Tel: 408-421-3403

APPLE INC., a California corporation
Apple iPhone Location Service Invades privacy
07/23/2014 /s/ Adam Wang

Print Save As... Reset

JS 44 Reverse (Rev. 12/12)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.
V. Origin. Place an "X" in one of the six boxes.
Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407.
When this box is checked, do not check (5) above.
VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service
VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
Case5:14-cv-03344-RMW Document1-1 Filed07/24/14 Page2 of 2
JS 44 (Rev. 12/12) cand rev (1/15/13)
CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6
Foreign Country
IV. NATURE OF SUIT (Place an X in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 400 State Reapportionment
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 410 Antitrust
140 Negotiable Instrument Liability 367 Health Care/ 430 Banks and Banking
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 450 Commerce
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 460 Deportation
151 Medicare Act 330 Federal Employers Product Liability 830 Patent 470 Racketeer Influenced and
152 Recovery of Defaulted Liability 368 Asbestos Personal 840 Trademark Corrupt Organizations
Student Loans 340 Marine Injury Product 480 Consumer Credit
(Excludes Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY 490 Cable/Sat TV
153 Recovery of Overpayment Liability PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 850 Securities/Commodities/
of Veterans Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) Exchange
160 Stockholders Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Management 863 DIWC/DIWW (405(g)) 890 Other Statutory Actions
190 Other Contract Product Liability 380 Other Personal Relations 864 SSID Title XVI 891 Agricultural Acts
195 Contract Product Liability 360 Other Personal Property Damage 740 Railway Labor Act 865 RSI (405(g)) 893 Environmental Matters
196 Franchise Injury 385 Property Damage 751 Family and Medical 895 Freedom of Information
362 Personal Injury - Product Liability Leave Act Act
Medical Malpractice 790 Other Labor Litigation 896 Arbitration
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 791 Employee Retirement FEDERAL TAX SUITS 899 Administrative Procedure
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: Income Security Act 870 Taxes (U.S. Plaintiff Act/Review or Appeal of
220 Foreclosure 441 Voting 463 Alien Detainee or Defendant) Agency Decision
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRSThird Party 950 Constitutionality of
240 Torts to Land 443 Housing/ Sentence 26 USC 7609 State Statutes
245 Tort Product Liability Accommodations 530 General
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION
Employment Other: 462 Naturalization Application
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration
Other 550 Civil Rights Actions
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an X in One Box Only)
1 Original
Proceeding
2 Removed from
State Court
3 Remanded from
Appellate Court
4 Reinstated or
Reopened
5 Transferred from
Another District
(specify)
6 Multidistrict
Litigation
VI. CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Brief description of cause:
VII. REQUESTED IN
COMPLAINT:
CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P.
DEMAND $ CHECK YES only if demanded in complaint:
JURY DEMAND: Yes No
VIII. RELATED CASE(S)
IF ANY
(See instructions):
JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
IX. DIVISIONAL ASSIGNMENT (Civil L.R. 3-2)
(Place an X in One Box Only) ( ) SAN FRANCISCO/OAKLAND ( ) SAN JOSE ( ) EUREKA
Case5:14-cv-03344-RMW Document1-2 Filed07/24/14 Page1 of 2

CHEN MA, on behalf of herself and all others similarly situated,
Adam Wang
P.O. 10881, Pleasanton, CA 94588
Tel: 408-421-3403

APPLE INC., a California corporation
Class Action Fairness Act, 28 U.S.C. Sections 1332(d), 1453, and 17111715
Apple iPhone Location Service Invades privacy
07/23/2014 /s/ Adam Wang

Print Save As... Reset

JS 44 Reverse (Rev. 12/12)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.
V. Origin. Place an "X" in one of the six boxes.
Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407.
When this box is checked, do not check (5) above.
VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service
VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
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