in seventeen

individual news channels

 

https://assets.documentcloud.org/documents/20399666/doe-v-google.pdf

 

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

JOHN DOE, an individual; MICHAEL

DOE, an individual; JAMES DOE, an

individual; HENRY DOE, an individual;

ROBERT DOE, an individual;

CHRISTOPHER DOE, an individual;

MATHEW DOE, an individual; POLLY

ST. GEORGE, an individual; SCOTT

DEGROAT, an individual; DAVID J.

HAYES, an individual; DANIEL LEE,

an individual, MISHEL McCUMBER, an

individual; JEFF PEDERSEN, an

individual; JORDAN SATHER, an

individual; SARAH WESTALL, an

individual,

Plaintiffs,

vs.

GOOGLE, LLC., a Delaware limited

liability company; YOUTUBE LLC, a

Delaware limited liability company;

DOES 1 through 10, inclusive.

 

Defendants.

Case No.

COMPLAINT FOR BREACH OF

CONTRACT, BREACH OF THE

COVENANT OF GOOD FAITH

AND FAIR DEALING AND

VIOLATION OF THE FIRST

AMENDMENT

[Demand for Jury Trial]

[Emergency Injunctive Relief

Req

 

Just informed Talk Jordan Sather

SGT Report Michael Doe

X22 Report James Doe

SpaceShot76 Henry Doe

TRUreporting Robert Doe

RedPill78 Christopher Doe

Edge of Wonder Matthew Doe

Amazing Polly Polly St George

Woke Societies Scott DeGroat

Praying Medic Dave Hayes

dnajion7 Daniel Lee

DeceptionBytes Mishel McCumber

In The Matrixx Jeff Pedersen

Sarah Westall Sarah Westall channel

 

Brief Overview of Plaintiffs and Their Channels: The fifteen Plaintiffs are

journalists, videographers, advocates, commentators and other individuals who regularly exercise

their right to free speech under the First Amendment of the Constitution of the United States.

Plaintiffs have created seventeen individual news channels and published those channels on the

YouTube platform. Plaintiffs’ channels were categorized on YouTube as “News” or “News and

Politics.” Plaintiffs’ commentaries, channels and videos have had an enormous audience reach

both in the United States and throughout the world. On October 15, 2020, Plaintiffs’ reach was so

widespread that they collectively had more than 4.5 million subscribers to their channels and had

attracted more than 771 million views. Taken together, these subscriber counts far exceed the

individual viewership of the YouTube accounts maintained by legacy cable, journalism, and news

networks such as C-SPAN (806K subscribers), The New York Times (3.21M subscribers), Fox

News (6.52M subscribers), MSNBC (3.62M subscribers), NBC News (4.1M), and CBS News

(3.06M subscribers). Although it is clear that millions of Americans get their news, information

and commentary on issues of national importance from the Plaintiffs’ conservative channels,

YouTube excised them and their political viewpoints off the YouTube platform without notice,

just days 19 before the 2020 Presidential Election.