1 2 B. Declaring that Defendant is strictly liable for defects, as described above, in its algorithms and system; and that Defendant, as described above, acted negligently; 3 C. Awarding the Class compensatory damages for wrongful death, personal injury, 4 pain and suffering, emotional distress, and loss of property, in the amount of at least $150 5 billion; 6 7 8 9 10 11 12 D. Awarding Plaintiff and the Class punitive damages in an amount to be determined E. Awarding Plaintiff and the Class their reasonable litigation expenses and at trial. attorneys’ fees; F. Awarding the Plaintiff and the Class pre- and post-judgment interest, to the extent allowable; and G. Awarding such other and further relief as equity and justice may require. 13 14 JURY TRIAL Plaintiff demands a trial by jury for all issues so triable. 15 Respectfully Submitted, 16 JANE DOE, individually and on behalf of all others similarly situated, 17 18 19 Dated: December 6, 2021 20 By: One of Plaintiff’s Attorneys Rafey S. Balabanian (SBN 315962) rbalabanian@edelson.com EDELSON PC 150 California Street, 18th Floor San Francisco, California 94111 Tel: 415.212.9300 Fax: 415.373.9435 21 22 23 24 25 Jay Edelson* jedelson@edelson.com J. Eli Wade-Scott* ewadescott@edelson.com Michael Ovca* 26 27 28 CLASS ACTION COMPLAINT 70 Case No. __________________