Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 1 of 25 Page ID #:1
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`RUFUS-ISAACS ACLAND & GRANTHAM LLP
`ALEXANDER RUFUS-ISAACS, State Bar No. 135747
` aisaacs@rufuslaw.com
`9420 Wilshire Blvd., 2nd Floor
`Beverly Hills, California 90212
`Telephone: (310) 770-1307
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`RODNEY A. SMOLLA
` rodsmolla@gmail.com
`4601 Concord Pike
`Wilmington, Delaware 19803
`Telephone: (864) 373-3882
`Pro Hac Vice Application Pending
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`Attorneys for plaintiff Nona
`Gaprindashvili
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`UNITED STATES DISTRICT COURT
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`CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
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`NETFLIX, INC., a Delaware
`corporation, and DOES 1-50,
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`Defendants.
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`Plaintiff Nona Gaprindashvili (“Gaprindashvili”) complains of defendants
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`Netflix, Inc. (“Netflix”), and Does 1 through 50, and alleges as follows:
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`INTRODUCTION
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`1.
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`This is an action for false light invasion of privacy and defamation per
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`se arising from a knowingly false statement of fact made about Gaprindashvili in the
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`popular Netflix miniseries, The Queen’s Gambit (“Series”).
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`Gaprindashvili is a pioneer of women’s chess and a much-loved icon in
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`her native country of Georgia. Throughout her extraordinary career, she won many
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`championships, beat some of the best male chess players in the world, and was the
`8658.3.1A
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`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
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`Tel (310) 770-1307 • Fax (310) 860-2430
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`BEVERLY HILLS, CALIFORNIA 90212
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`9420 WILSHIRE BLVD., 2ND FLOOR
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`GRANTHAM LLP
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`RUFUS-ISAACS ACLAND &
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`NONA GAPRINDASHVILI, an
`individual,
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`Plaintiff,
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`v.
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` CASE No.
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`COMPLAINT FOR:
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`(1) FALSE LIGHT INVASION OF
`PRIVACY; AND
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`(2) DEFAMATION PER SE
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`REQUEST FOR JURY TRIAL
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`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 2 of 25 Page ID #:2
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`first woman in history to achieve the status of international chess grandmaster
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`among men.
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`In 1983, author Walter Tevis wrote a novel entitled The Queen’s
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`Gambit (“Novel”) which tells the story of a fictional American woman named
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`Elizabeth Harmon, also known as Beth, mostly set in the 1960’s. Harmon is an
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`orphan who rises from humble beginnings to become a great chess player despite
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`prejudice against female players. The Novel’s final chapter is set at a prestigious
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`chess tournament in Moscow called the Moscow Invitational where she dramatically
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`defeats several top male players, including a Russian who was the world champion.
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`The main characters are fictional, but the Novel references a few real chess players,
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`including Gaprindashvili, who is described in the context of the Moscow
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`Invitational as having “met all these Russian Grandmasters many times before.”
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`Although Gaprindashvili is mentioned in the Novel only in passing,
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`Harmon’s character plainly draws on her achievements. Harmon is in many respects
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`an Americanized and fictionalized version of the real-life female Georgian prodigy
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`who was the first to break gender barriers in international chess in the 1960’s by
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`competing with and defeating top male players.
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`5.
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`The Series was based on the Novel and for the most part follows it
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`closely. However, in the final episode, just after Harmon beats a fictional Russian
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`Grandmaster called Viktor Laev at the Moscow Invitational, a commentator
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`observes that the male players in the tournament believed that:
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`Tel (310) 770-1307 • Fax (310) 860-2430
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`BEVERLY HILLS, CALIFORNIA 90212
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`9420 WILSHIRE BLVD., 2ND FLOOR
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`GRANTHAM LLP
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`RUFUS-ISAACS ACLAND &
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`“Harmon’s level of play wasn’t at theirs. Someone like Laev probably didn’t
`spend a lot of time preparing for their match. Elizabeth Harmon’s not at all an
`important player by their standards. The only unusual thing about her, really, is
`her sex. And even that’s not unique in Russia. There’s Nona Gaprindashvili,
`but she’s the female world champion and has never faced men. My guess is
`Laev was expecting an easy win, and not at all the 27-move thrashing Beth
`Harmon just gave him.” (Emphasis added).1
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`1 The scene can be viewed at https://www.youtube.com/watch?v=gUB6P59CUko
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`8658.3.1A
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`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
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`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 3 of 25 Page ID #:3
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`As Gaprindashvili’s name is mentioned in this scene, the camera pans
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`onto an actor sitting in the audience, watching the game, who is obviously meant to
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`be Gaprindashvili.
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`7.
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`The allegation that Gaprindashvili “has never faced men” is manifestly
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`false, as well as being grossly sexist and belittling. By 1968, the year in which this
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`episode is set, she had competed against at least 59 male chess players (28 of them
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`simultaneously in one game), including at least ten Grandmasters of that time,
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`including Dragolyub Velimirovich, Svetozar Gligoric, Paul Keres, Bojan Kurajica,
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`Boris Spassky, Viswanathan Anand and Mikhail Tal. The last three were also world
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`champions during their careers.
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`8.
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`These facts were well known to Netflix, both from the Novel which
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`stated that she had “met all these Russian Grandmasters many times before,” and
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`because it had hired two of the world’s leading chess authorities as consultants for
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`the Series: the legendary Garry Kasparov, a Russian former world champion, and
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`American national master Bruce Pandolfini, considered to be America's most
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`experienced chess teacher and a consultant to Tevis when he wrote the Novel.
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`Netflix brazenly and deliberately lied about Gaprindashvili’s
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`achievements for the cheap and cynical purpose of “heightening the drama” by
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`making it appear that its fictional hero had managed to do what no other woman,
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`including Gaprindashvili, had done. Thus, in a story that was supposed to inspire
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`women by showing a young woman competing with men at the highest levels of
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`world chess, Netflix humiliated the one real woman trail blazer who had actually
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`faced and defeated men on the world stage in the same era.
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`Tel (310) 770-1307 • Fax (310) 860-2430
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`BEVERLY HILLS, CALIFORNIA 90212
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`9420 WILSHIRE BLVD., 2ND FLOOR
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`GRANTHAM LLP
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`RUFUS-ISAACS ACLAND &
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`10. Piling on additional insult to injury, Netflix described Gaprindashvili as
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`Russian, despite knowing that she was Georgian, and that Georgians had suffered
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`under Russian domination when part of the Soviet Union, and had been bullied and
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`invaded by Russia thereafter.
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`8658.3.1A
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`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
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`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 4 of 25 Page ID #:4
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`11. Netflix had no need to use Gaprindashvili’s name and to disparage her
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`achievements for dramatic purposes. It could have used a fictional character instead;
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`or it could have referred to her by name, but not told the lie that she had never
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`competed against men. Instead, Netflix deliberately eschewed these non-defamatory
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`alternatives because it believed that the lie made for a more dramatic story.
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`12. After the Series was broadcast, Gaprindashvili confronted Netflix over
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`its lie and demanded a public statement acknowledging the falsity of the statement,
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`an apology, and a retraction. Netflix could have responded in any number of
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`inexpensive and morally honorable ways of making redress, but instead it responded
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`with extraordinary hubris, dismissing Gaprindashvili’s assertion of defamation by
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`claiming that the false statement was “innocuous.” This arrogant refusal to take
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`responsibility for its actions was shockingly tone-deaf, given the sexism and
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`offensiveness of its lie.
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`13. This lawsuit is simple in its factual and legal predicates. Netflix lied
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`about Gaprindashvili in a profound and obvious manner, impugning her professional
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`standing by falsely stating she had not competed against men, and thereby
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`insinuating that she lacked the skills to successfully compete against men. This was
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`a devastating falsehood, undermining and degrading her accomplishments before an
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`audience of many millions. Netflix broadcast this statement with knowledge of
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`falsity and reckless disregard for the truth. Gaprindashvili brings this suit to
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`vindicate herself and seek redress for the damage to her good name and human
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`dignity, and to serve as an example to wronged women by reminding them that they
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`have the right to fight back against such cynical misconduct.
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`JURISDICTION AND VENUE
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`14. Plaintiff Nona Gaprindashvili is a citizen and resident of the Republic
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`of Georgia. Defendant Netflix, Inc. is a corporation organized and existing under
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`the laws of the State of Delaware with its principal place of business in Santa Clara
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`County, California. This Court has diversity of citizenship subject matter
`8658.3.1A
`4
`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
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`Tel (310) 770-1307 • Fax (310) 860-2430
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`BEVERLY HILLS, CALIFORNIA 90212
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`9420 WILSHIRE BLVD., 2ND FLOOR
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`GRANTHAM LLP
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`RUFUS-ISAACS ACLAND &
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`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 5 of 25 Page ID #:5
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`jurisdiction under 28 U.S.C. § 1332. There is complete diversity among the parties,
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`and the amount in controversy exceeds $75,000.
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`15. Venue is proper in this District pursuant to 28 U.S.C. § 1332 (b)(3) and
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`(c)(3), because Netflix is subject to the court’s personal jurisdiction with respect to
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`this action because its principal place of business is located in California. It also has
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`offices in this District at 5808 Sunset Boulevard, Los Angeles, California 90028.
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`16. Gaprindashvili was born in Georgia in 1941. She began playing
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`professionally at the age of 13, and when she was 14, she won the semi-final of the
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`Women’s Soviet Union Championship. In 1961, aged 20, she became female World
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`Champion. She did not relinquish her crown until 1978 when she was defeated by
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`another Georgian, 17-year-old Maia Chiburdanidze, who had grown up inspired by
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`Gaprindashvili as a role model.
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`17. Gaprindashvili participated in and received 25 medals in Chess
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`Olympiads, including 1963, 1966, 1969, 1972, 1974, 1978, 1980, 1982, 1984, 1986,
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`1990 and 1992. She won a total of eleven team gold medals and nine individual gold
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`medals. At the 1986 Olympiad in Dubai, she won all ten games she played.
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`18. Beginning in 1962-63, Gaprindashvili competed against and frequently
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`defeated male chess players. In 1965, she played 28 male players at once,
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`Tel (310) 770-1307 • Fax (310) 860-2430
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`BEVERLY HILLS, CALIFORNIA 90212
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`9420 WILSHIRE BLVD., 2ND FLOOR
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`GRANTHAM LLP
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`RUFUS-ISAACS ACLAND &
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`8658.3.1A
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`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
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`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 6 of 25 Page ID #:6
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`19. Gaprindashvili encountered severe prejudice when she started to
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`compete against men. As she said in a recent interview, “At first they all wanted to
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`play with me to the end, they didn’t agree to draws, the games were postponed
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`according to the then regulations, they had to finish the game the next morning.
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`Even a draw against a woman infringed on the pride of rivals, so they fought with
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`me to the last. I myself have always played all the games to the end, even if the first
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`place in the tournament is already guaranteed. Over time, of course, they began to
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`treat me differently, they accepted me, one might say, into their company.” See
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`World Today News, November 20, 2020, https://www.world-today-news.com/the-
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`series-queens-move-lied-about-the-soviet-champion-she-supposedly-didnt-play-
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`with-men/.
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`20.
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`In 1976, Gaprindashvili wrote a book in which she spoke about her
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`devotion to chess and her inability to imagine life without a chessboard. In a chapter
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`called “Fighting Discrimination,” she explained how difficult it was to overcome a
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`generally accepted perception that women chess players are weaker than men, and
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`passionately argues that women are equally talented in chess: “Women chess
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`players do not need any privileges or exemptions… The term ‘Women’s chess’ has
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`expired. I am proud that I have my share in promoting the creative emancipation of
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`women in chess. I had my share in helping women to overcome psychological
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`barriers separating them from ‘man’s chess.’”
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`21. Gaprindashvili’s notable successes against men began with her
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`successful entry into the Challengers Section of the Hastings International Chess
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`Congress in England in 1963, which she won, defeating male players Heinrich Juhe,
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`Ove Kinnmark, John Taylor, Dragoljub Baretic, and Henry Catozzi.
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`22. Gaprindashvili was the only female participant in a chess tournament in
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`Reykjavik in 1964. The male chess players at this tournament included the youngest
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`world champion in history at that time (Grandmaster Mikhail Tal), a twelve-time
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`champion of Yugoslavia (Grandmaster Svetozar Gligoric), and a six-time Iceland
`8658.3.1A
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`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
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`Tel (310) 770-1307 • Fax (310) 860-2430
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`BEVERLY HILLS, CALIFORNIA 90212
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`9420 WILSHIRE BLVD., 2ND FLOOR
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`GRANTHAM LLP
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`RUFUS-ISAACS ACLAND &
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`

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`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 7 of 25 Page ID #:7
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`champion (Fridrik Ólafsson). Gaprindashvili competed against 13 male chess
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`players, including the Grandmasters mentioned above, and won three games.
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`23. Gaprindashvili returned to Hastings for the 1964-65 tournament, this
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`time in the top-tier Premier Section, and won notable chess victories over highly
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`ranked male players such Victor Mardle, Norman Littlewood, Peter Lee, Owen
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`Hindle. In a particularly famous chess match at this tournament, Gaprindashvili
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`battled Grandmaster Paul Keres to a draw.
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`24.
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`In 1968, Gaprindashvili successfully competed in a tournament against
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`9 men, including Grandmaster Evfim Geller of the Soviet Union. The New York
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`Times reported: “Nona Gaprindashvili of the Soviet Union, the women's world
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`chess champion, was the only woman in the recent strong International Tournament
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`at Goteborg, Sweden. She finished third in the ten-player round robin.” And it
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`praised about her “never-say-die spirit.” New York Times, April 15, 1968
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`https://timesmachine.nytimes.com/timesmachine/1968/04/15/91225493.html?pageN
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`25. Gaprindashvili successfully competed in other tournaments against
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`men, including a tie for second place at Sandomierz in 1976, a tie for first place at
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`Lone Pine in 1977, and a tie for second place at Dortmund in 1978. She was the
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`only woman invited to the Lone Pine Tournament and did not lose a game, defeating
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`John Peters, James Tarjan, Leonid Shamkovich, Eugene Martinovsky, Oscar Panno,
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`Peter Biyiasas, Burkhard Malich, Thomas Casper, William James Lombardy, and
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`Grandmaster Anatoly Lein. The New York Times reported: “Nona Gaprindashvili
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`of the Soviet Union, the world women’s champion, achieved the greatest triumph
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`ever by a woman in tying for first place in the Louis D. Statham International
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`Tournament in Lone Pine, Calif., with Grandmaster Yuri Balashov, also of the
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`Soviet Union. Grandmaster Oscar Panno of Argentina and International Master
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`Sahovic of Yugoslavia.” New York Times, “Chess,” June 29, 1977
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`8658.3.1A
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`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
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`Tel (310) 770-1307 • Fax (310) 860-2430
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`BEVERLY HILLS, CALIFORNIA 90212
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`9420 WILSHIRE BLVD., 2ND FLOOR
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`GRANTHAM LLP
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`RUFUS-ISAACS ACLAND &
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`

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`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 8 of 25 Page ID #:8
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`https://www.nytimes.com/1977/06/29/archives/chess-miss-gaprindashvili-strikes-a-
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`blow-for-womens-equality.html.
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`26. Other famous male players against whom she competed constitute a
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`“who’s who” of highly ranked players and Grandmasters, including Dragolyub
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`Velimirovich, Svetozar Gligoric, Rudolf Servaty, Bojan Kurajica, Boris Spassky,
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`Viswanathan Anand and Mikhail Tal. Tal, Anand and Spassky were world
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`champions. Although she never beat these three, she did draw with Anand. Tal, in
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`his autobiography, tells a story of their game in Reykjavik in 1964. Not wishing to
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`win on time in his winning endgame, Tal would occasionally not press his clock
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`after moving. Gaprindashvili caught onto him and confirmed her sporting nature by
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`telling him she would resign immediately if he continued to go easy on her.
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`27. Gaprindashvili was known for her aggressive style. A famous match
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`against Velimirovich at a tournament in Yugoslavia progressed until there were
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`virtually no pieces left on the board, when the two players agreed to a draw. The
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`match was later declared to be the best chess game of the year by the Soviet Chess
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`Federation, which was the first time that this accolade had been bestowed on a game
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`ending in a draw. The match took a psychological toll on Velimirovich who did not
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`participate in tournaments for a year afterwards.
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`28. Following her stunning success at Lone Pine, Gaprindashvili became
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`the first woman in history to be awarded the honor and rank of International Chess
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`BEVERLY HILLS, CALIFORNIA 90212
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`9420 WILSHIRE BLVD., 2ND FLOOR
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`GRANTHAM LLP
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`RUFUS-ISAACS ACLAND &
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`Grandmaster among men.
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`29. Gaprindashvili is a national hero in Georgia. In addition to being a
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`chess champion, she participated in politics, holding positions within the Georgian
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`Parliament and participating in protests against corruption within Georgia and
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`against Russian aggression and subjugation. In 2015, the President of Georgia,
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`Giorgi Margvelashvili, awarded Gaprindashvili the Georgia Order of Excellence.
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`The Tbilisi Chess Palace is dedicated to her.
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`8658.3.1A
`8
`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
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`

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`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 9 of 25 Page ID #:9
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`30. Gaprindashvili was the subject of the film, Glory to the Queen, which
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`honored the female chess-greats of Georgia. Unlike the Netflix Series, which
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`gratuitously insulted Gaprindashvili, Glory to the Queen properly honored her as a
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`woman who helped revolutionize female chess by taking on male competitors across
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`the globe—and who in the process became a Georgian icon of female emancipation.
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`Her example inspired later generations of Georgian women chess champions such as
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`Maya Chiburdanidze and Ketevan Arakhamia, who both also became Grandmasters.
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`31. Now aged 80, Gaprindashvili still competes in senior chess
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`tournaments and in 2014, 2015 and 2019, she was world champion among seniors
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`agreed over 65. Also in 2019, she was awarded the FIDE prestigious prize of
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`Golden Pawn for Lifetime achievement at the same time that Garry Kasparov was
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`awarded the title chess legend. She continues to be a role model and exemplar of
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`what a woman can achieve in a male-dominated arena.
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`32. Netflix is a dominant world media giant with its headquarters in Los
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`Gatos, California. Its programming is available world-wide, with over 209 million
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`subscribers. In 2020, it reported total revenue of over 24.9 billion dollars. It has a
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`major production office located at Sunset Bronson Studios, 5808 Sunset Boulevard,
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`Los Angeles, California 90028.
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`33. Plaintiff is unaware of the true names and capacities of defendants
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`named herein as Does 1 through 50, inclusive, but is informed and believes, and
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`thereon alleges, that each of the fictitiously named defendants engaged in, or is in
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`some manner responsible for, the wrongful conduct alleged herein. Plaintiff
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`therefore sues these defendants by such fictitious names and will amend this
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`complaint to state their true names and capacities when such names have been
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`discovered.
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`Tel (310) 770-1307 • Fax (310) 860-2430
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`BEVERLY HILLS, CALIFORNIA 90212
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`9420 WILSHIRE BLVD., 2ND FLOOR
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`GRANTHAM LLP
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`RUFUS-ISAACS ACLAND &
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`THE QUEEN’S GAMBIT MINISERIES
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`34. All seven episodes of the Series were released simultaneously on
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`October 23, 2020. The scene which forms the predicate for this lawsuit is in the final
`8658.3.1A
`9
`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
`
`
`
`
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`

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`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 10 of 25 Page ID #:10
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`episode, “End Game.” By October 28, 2020, the Series reached the number one
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`rating spot on Netflix. On November 23, 2020, Netflix announced that the Series
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`had been watched by 62 million households since its release. The Series topped
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`United States television Nielsen’s streaming rankings for the weeks of October 26 to
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`November 1, November 2 to 8, and November 9 to 15, 2020, making it the first
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`series in history to top those Nielsen ratings for three straight weeks.
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`35. The Series gained substantial artistic recognition, including winning
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`two Golden Globe Awards, for Best Limited Series or Television Film, and for Best
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`Actress in a Miniseries or Television Film (for Anya Taylor-Joy who played
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`Harmon). It has been nominated for 18 awards at the 73rd Annual Primetime Emmy
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`Awards.
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`36. The Series is about a female chess prodigy, and in numerous respects
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`parallels the real-world life of Gaprindashvili, particularly when Harmon competes
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`against male chess players. It is set in the years 1958-1968. These years parallel
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`Gaprindashvili’s own meteoric rise in the world of chess, including her impressive
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`victories against men at Hastings in 1963 and 1964-65, and her spectacular display
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`in 1965 where she played simultaneously against 28 male players.
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`37. The Series opens with a description of how Harmon is orphaned when
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`her mother dies in a car accident. She is taken to live in an orphanage where the
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`janitor teaches her chess. After she is adopted, she begins playing chess
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`competitively aged 12. From the beginning, she is constantly confronted with the
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`reality that chess is a man’s world. As she tries to register for her first tournament,
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`she is asked, “are you sure you want to do this?” and told that “we don’t have a
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`women’s section.” Like Gaprindashvili, Harmon surprises her male competitors. In
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`her first major tournament in Cincinnati, Ohio, she finds herself competing against
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`and holding her own against a slate of male players. She wins the tournament, and
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`collects her first significant prize money.
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`8658.3.1A
`10
`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
`
`
`
`
`
`Tel (310) 770-1307 • Fax (310) 860-2430
`
`BEVERLY HILLS, CALIFORNIA 90212
`
`9420 WILSHIRE BLVD., 2ND FLOOR
`
`GRANTHAM LLP
`
`RUFUS-ISAACS ACLAND &
`
`

`

`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 11 of 25 Page ID #:11
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`38. Harmon emerges as a chess prodigy and a model for women, becoming
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`a national cultural celebrity during a time in American history when the rights of
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`women were beginning to be asserted across the country. For example, in Episode
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`Three, there is a scene in which Harmon is interviewed by a reporter from Life
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`Magazine. The reporter, also a woman, asks Harmon, “Tell the readers of Life how
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`it feels to be a girl among all those men?” and concludes the interview with the
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`remark that Harmon should take up the game of “bridge.” The remark underscores
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`how Harmon’s battle with systemic sexism is a major leitmotif of the Series, as the
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`remark is manifestly intended by the reporter to convey the prevailing view of the
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`era that there was no place for women at the highest echelons of chess.
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`39. The Series depicts Harmon’s struggles with drug and alcohol abuse,
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`and her see-saw struggle between confidence and insecurity. Throughout the Series,
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`she is confronted with sexism, to which she typically responds with pluck and
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`resolve. For example, in Episode 6, she is in Paris when a male interviewer asks her,
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`“What do you say to those in the Chess Federation who accuse you of being too
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`glamorous to be a serious chess player?” She quickly retorts, “I would say that it’s
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`much easier to play chess without the burden of an Adam’s Apple.”
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`40. The dramatic final episode begins with Harmon still struggling with
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`depression, alcohol, and drug abuse. While she is the fictional 1967 American
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`United States Champion, she is still reeling from a defeat in the prior episode by
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`fictional Russian Grandmaster, Vasily Borgov, the reigning World Champion.
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`41. Harmon is able to overcome her depression and addiction. She gets
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`herself together to prepare to enter the “Moscow Invitational” tournament in Russia.
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`Her first-round match pits her against another fictional character, an older male
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`chess player named Viktor Laev whom Harmon had long admired.
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`42. After the match between Harmon and Laev unfolds, the announcer for
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`the tournament, in a voice-over “play-by-play” (or “move-by-move”) commentary,
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`8658.3.1A
`11
`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
`
`
`
`
`
`Tel (310) 770-1307 • Fax (310) 860-2430
`
`BEVERLY HILLS, CALIFORNIA 90212
`
`9420 WILSHIRE BLVD., 2ND FLOOR
`
`GRANTHAM LLP
`
`RUFUS-ISAACS ACLAND &
`
`

`

`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 12 of 25 Page ID #:12
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`comments on Harmon’s gender, observing that the male players in the tournament
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`did not take Harmon seriously as an opponent. Here is the exact language he used:
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`[The male players believe] Harmon’s level of play wasn’t at theirs. Someone
`like Laev probably didn’t spend a lot of time preparing for their match.
`Elizabeth Harmon’s not at all an important player by their standards. The only
`unusual thing about her, really, is her sex. And even that’s not unique in Russia.
`There’s Nona Gaprindashvili, but she’s the female world champion and
`has never faced men. My guess is Laev was expecting an easy win, and not at
`all the 27-move thrashing Beth Harmon just gave him.
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`43. As Gaprindashvili’s name is mentioned, an actor is shown sitting in the
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`audience, watching the game, who is obviously meant to be Gaprindashvili.
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`44. The Series ends with a “Hollywood ending.” After her first-round win
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`against Laev, Harmon goes on to defeat a series of fictional male Russian chess
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`masters, culminating in a final dramatic victory over her nemesis, Borgov, whom
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`she defeats in the final match, playing the “Queen’s Gambit” chess opening, and
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`winning the Moscow Invitational.
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`FALSITY
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`45. Netflix sought to create a drama in which not only did a woman
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`triumph over men in an arena traditionally dominated by men, but also in which an
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`American woman triumphed over Soviet men at the height of the cold war. To serve
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`its dramatic purposes, Netflix gratuitously proclaimed to the world the egregious
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`falsehood that Gaprindashvili never competed against men, and was not capable of
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`Tel (310) 770-1307 • Fax (310) 860-2430
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`BEVERLY HILLS, CALIFORNIA 90212
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`9420 WILSHIRE BLVD., 2ND FLOOR
`
`GRANTHAM LLP
`
`RUFUS-ISAACS ACLAND &
`
`
`
`8658.3.1A
`12
`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
`
`
`
`
`
`

`

`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 13 of 25 Page ID #:13
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`the level of play of the fictional Beth Harmon. Because the truth would have
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`undercut this narrative, Netflix cynically and deliberately chose to ignore it. This
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`deliberate falsehood was highly offensive and defamatory, on multiple levels.
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`46. Adding insult to defamatory injury, Netflix falsely portrayed the real
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`Gaprindashvili as Russian, despite knowing that she came from Georgia, which still
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`today struggles to resist aggression, subjugation, and war at the hands of Russia.
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`47. The false defamatory meaning of the statement is apparent on the face
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`of the broadcast. Yet perhaps the best evidence of how average viewers would have
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`understood the lie is a demonstration of how it reverberated among actual viewers,
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`with commentary on social media and by major news organizations.
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`48. News organizations reported on and called out Netflix for its false
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`statement concerning Gaprindashvili, such as the article entitled “The series
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`‘Queen’s Move’ lied about the Soviet champion. She supposedly didn’t play with
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`men,” World Today News, November 20, 2020, https://www.world-today-
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`news.com/the-series-queens-move-lied-about-the-soviet-champion-she-supposedly-
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`didnt-play-with-men/ which described the key scene in the Series as follows:
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`A brunette looks at the young champion from the podium with a sad look.
`“This is Nona Gaprindashvili, the world champion among women, who has
`never played against men,” the tournament commentator says. In fact, this is a
`lie. Nona Gaprindashvili passed all the steps to the pedestal that were submitted
`to the fictional Elizabeth Harmon in the series.
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`49. Similarly, an article in The Calvert Journal underscored the
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`offensiveness of the lie by noting the parallels between the fictional Harmon and the
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`real Gaprindashvili, observing that a “similar story happens to Elizabeth Harmon on
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`the show when she faces the US champion. So, the amount of overlap between the
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`Series and Nona Gaprindashvili’s career hints that her path has had a great influence
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`on the writers of the script and the original book.” Fatima Hudoon, “The real-life
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`Queen’s Gambit: how Georgia’s Nona Gaprindashvili conquered the chess world,”
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`The Calvert Journal, November 27, 2020
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`8658.3.1A
`13
`COMPLAINT FOR (1) FALSE LIGHT INVASION OF PRIVACY; AND (2) DEFAMATION PER SE; REQUEST
`FOR JURY TRIAL
`
`
`
`
`
`Tel (310) 770-1307 • Fax (310) 860-2430
`
`BEVERLY HILLS, CALIFORNIA 90212
`
`9420 WILSHIRE BLVD., 2ND FLOOR
`
`GRANTHAM LLP
`
`RUFUS-ISAACS ACLAND &
`
`

`

`Case 2:21-cv-07408 Document 1 Filed 09/16/21 Page 14 of 25 Page ID #:14
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`https://www.calvertjournal.com/features/show/12351/real-life-queens-gambit-nona-
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`gaprindashvili-georgian-women-chess-beth-harmon-netflix
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`50. The following paragraphs contain social media posts which strongly
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`complain and protest about the false statement about Gaprindashvili.
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`51. Anthony Shaw, Twitter, @anthonypjshaw (Nov. 29, 2020),
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`https://twitter.com/anthonypjshaw/status/1333249169796939781?s=20
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`52. Steve Coyle, Twitter, @SEHCoyle (Nov. 20, 2020),
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`https://twitter.com/SEHCoyle/status/1329835286927380481?s=20
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