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WHEREFORE, Plaintiff Donald J. Trump and the Class respectfully requests that the Court enter an Order certifying this case as a class action, appointing Plaintiff as Class Representative and appointing Plaintiff’s counsel as Lead Class Counsel and that the Court Order, adjudge, and decree in favor of Plaintiff and the Class against the Defendants for:
A. An award of Compensatory and Punitive damages to the Plaintiff and the Class in an amount to be determined at trial;
B. An injunction and declaratory judgment ordering YouTube to immediately reinstate access of Plaintiff and Putative Class Members to their YouTube account;
C. An injunction and declaratory judgment ordering YouTube to remove its warning labels and misclassification of all content of the Plaintiff and the Class and to desist from any further warnings or classifications;
D. Adjudgment declaring Sections 230(c)(1) and (c)(2) of the Communications Decency Act of 1996 unconstitutional;
E. An award of attorneys’ fees and costs to Plaintiff and the Class in an amount to be determined at trial; and
F. An award of punitive damages to Plaintiff and the Class in an amount to be determined at trial.
G. An award of such other and further relief as the Court may deem just and proper.
Date: July 7, 2021
IN THE UNITED STATES DISTRICT
COURT
FOR THE SOUTHERN DISTRICT OF
FLORIDA
MIAMI DIVISION
DONALD
J. TRUMP, the Forty-Fifth President
of the United States, KELLY VICTORY,
AND AUSTEN FLETCHER, INDIVIDUALLY
AND ON BEHALF OF THE
CLASS, Plaintiffs,
v.
YOUTUBE,
LLC., and SUNDAR PICHAI Defendants.
CLASS ACTION
COMPLAINT FOR: FIRST AMENDMENT VIOLATION
JURY TRIAL REQUESTED
COMPLAINT FOR INJUNCTIVE AND
DECLARATORY RELIEF
COUNT ONE
VIOLATION OF THE FIRST AMENDMENT TO THE UNITED STATES
CONSTITUTION
COUNT TWO
DECLARATORY JUDGEMENT OF UNCONSTITUTIONALITY OF SECTION 230
AND THE COMMUNICATIONS DECENCY ACT
CLASS ACTION ALLEGATIONS
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Donald J. Trump and the Class respectfully requests that the Court enter an Order certifying this case as a class action, appointing Plaintiff as Class Representative and appointing Plaintiff’s counsel as Lead Class Counsel and that the Court Order, adjudge, and decree in favor of Plaintiff and the Class against the Defendants for:
A. An award of Compensatory and Punitive damages to the Plaintiff and the Class in an amount to be determined at trial;
B. An injunction and declaratory judgment ordering YouTube to immediately reinstate access of Plaintiff and Putative Class Members to their YouTube account;
C. An injunction and declaratory judgment ordering YouTube to remove its warning labels and misclassification of all content of the Plaintiff and the Class and to desist from any further warnings or classifications;
D. Adjudgment declaring Sections 230(c)(1) and (c)(2) of the Communications Decency Act of 1996 unconstitutional;
E. An award of attorneys’ fees and costs to Plaintiff and the Class in an amount to be determined at trial; and
F. An award of punitive damages to Plaintiff and the Class in an amount to be determined at trial.
G. An award of such other and further relief as the Court may deem just and proper.
Date: July 7, 2021
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