Case 3:21-cv-02304-LB Document 1 Filed 03/31/21 Page 1 of 12
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`FREEDMAN+TAITELMAN, LLP
`Michael A. Taitelman, Esq. (SBN 156254)
`mtaitelman@ftllp.com
`Sean M. Hardy, Esq. (SBN 266446)
`smhardy@ftllp.com
`1801 Century Park West, Fifth Floor
`Los Angeles, California 90067
`Tel: (310) 201-0005
`Fax: (310) 201-0045
`
`Attorneys for Plaintiff O’SHEA JACKSON, SR. (p/k/a “ICE CUBE”)
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`Civ. No.
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`COMPLAINT FOR:
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`O’SHEA JACKSON, SR. (p/k/a “ICE CUBE”),
`an individual,
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`Plaintiff,
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`v.
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`ROBINHOOD MARKETS, INC., a Delaware
`corporation; ROBINHOOD FINANCIAL LLC,
`a Delaware limited liability company,
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`Defendants.
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`(1) Violation of Lanham Act (15 U.S.C. §
`1125(a));
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`(2) Violation of California Civil Code §
`3344(a);
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`(3) Misappropriation of Likeness Under
`California Common Law;
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`(4) Unfair Competition under California
`Business and Professions Code §§ 17200
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`DEMAND FOR TRIAL BY JURY
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`Case 3:21-cv-02304-LB Document 1 Filed 03/31/21 Page 2 of 12
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`Plaintiff, O’SHEA JACKSON, SR., professionally known as ICE CUBE (“Ice Cube” or
`“Plaintiff”), by and through his undersigned counsel, brings this Complaint against Defendants,
`ROBINHOOD MARKETS, INC. (“Robinhood”) and ROBINHOOD FINANCIAL LLC (“Robinhood
`Financial”) (Robinhood and Robinhood Financial are, collectively, the “Defendants”), for damages and
`injunctive relief, and in support thereof states as follows:
`INTRODUCTION
`Robinhood is an unscrupulous and predatory conglomerate that professes to be a financial
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`services company for the everyday person. In truth, Robinhood is a wolf in sheep’s clothing. It is the
`archetypal example of an amoral corporation that places profits over people. Robinhood’s corporate
`malfeasance is no secret. Over the course of its brief existence, Robinhood has been: (a) the subject of
`investigations too numerous to list, but currently by not less than five separate governmental bodies; (b)
`fined several times by federal regulatory agencies, including most recently a $65 million settlement with
`the SEC in December 2020; and (c) named as a defendant in hundreds of lawsuits, including currently
`over 50 class action lawsuits. No wonder. In 2020 alone, it was widely reported that Robinhood’s stock
`trading app – which depends on trigger-finger immediacy – went down not less than 90 separate times.
`Robinhood is selling a garbage trading platform to the American public and laughing all the way to the
`bank.
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`At this point, the evidence is clear that Robinhood is selling a dangerous bill of goods to
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`unsuspecting consumers across the nation. Robinhood CEO Vlad “the Stock Impaler” Tenev recently
`offered corporate crocodile tears during sworn Congressional testimony when confronted with the fact
`that an inexperienced 20-year-old Robinhood user committed suicide after he was wrongly told he owed
`over $730,000 due to some risky Robinhood trades. There was no Robinhood helpline for the user to
`call and several emails for help went unanswered by Robinhood until the date of his suicide. Human
`lives are simply collateral damage as Robinhood single-mindedly rushes toward an initial public offering,
`so its feckless and apathetic Millennial founders can jump ship and live out their days in luxury and
`hedonism. Robinhood is simply another get-rich-quick scheme for the most privileged people in
`America. Robinhood flagrantly displays its belief that it is exempt from the rules and laws that govern
`everyone else in the United States.
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`In a cynical effort to appeal to a young demographic, Robinhood has engaged celebrity
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`endorsers such as Jay-Z, Nas, and Jared Leto to endorse its products and services. However, in an act of
`unmitigated gall and transparent retribution, Robinhood and its subsidiary have now used the image and
`likeness of Ice Cube – without his permission – to promote Robinhood’s terrible products and services.
`Robinhood has picked on the wrong man this time.
`4.
`Robinhood’s wholly-owned subsidiary Robinhood Financial serves as a propaganda arm
`for Robinhood. Through its “Robinhood Snacks” website and app, Robinhood Financial advertises and
`promotes Robinhood’s financial services and products to millions of consumers across the United States.
`5.
`Ice Cube is one of the world’s best-known artists – a rapper, actor, and entrepreneur whose
`life story has served as an inspiration to millions. From his days as one of the founding members of the
`seminal rap group N.W.A., to his platinum-record selling solo career, to his successful acting endeavors,
`Ice Cube’s image and likeness have become a well-established brand. Ice Cube is also a noted activist
`for social justice and civil rights, having shepherded and promoted A Contract with Black America in
`2020 to address the systemic racism affecting Black Americans.
`6.
`In March 2021, in the midst of Robinhood’s meltdown, Defendants deliberately and
`shamelessly misappropriated Ice Cube’s image and likeness to promote Robinhood’s horrible products
`and services – the last things in the world to which Ice Cube would ever attach his image and likeness.
`This blatant theft of Ice Cube’s image and likeness to endorse Robinhood’s dangerous products and
`services has resulted in substantial damage to Ice Cube. In short, just as Robinhood’s recent well-known
`conduct has resulted in Congressional investigations and numerous class action lawsuits, so too has it
`stolen and diminished the hard-earned image and brand of Ice Cube, one of the most prominent Black
`voices in America.
`7.
`Ice Cube has spent years meticulously building the value of his image and overall brand
`by carefully scrutinizing the products and services he is asked to endorse. This highly selective process
`has established Ice Cube’s name and image as a respected brand in multiple categories, ranging from
`music to sports. Robinhood is the antithesis of everything that Ice Cube stands for. It represents corporate
`greed on a massive scale. In Ice Cube’s view, Robinhood is a textbook example of a greedy corporation
`taking advantage of its unwitting consumers. Despite Ice Cube’s written demand that Defendants cease
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`and desist from their continued commercial use of his image and likeness, they shockingly failed and
`refused to do so. Knowing that Ice Cube was offended and wished his image and likeness to be removed
`should have been enough for Robinhood to do the right thing. But Robinhood just doesn’t care about
`people – whether they are famous or not. Robinhood and its puppet Robinhood Financial act with
`impunity out of malice and greed, under the mistaken belief that they are above the law. Given their
`intransigence, Ice Cube now brings this action to set the record straight: Robinhood is a scam that Ice
`Cube wants nothing to do with.
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`JURISDICTION AND VENUE
`This is an action arising under the Lanham Act, 15 U.S.C. § 1121, California Civil Code
`8.
`§ 3344.1, and California common law.
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`This Court has federal question subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331
`and 1338.
`This Court has supplemental jurisdiction over the California Civil Code and common law
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`claims pursuant to 28 U.S.C. § 1367(a).
`11.
`Defendants are subject to personal jurisdiction in California.
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`Venue is proper in this district under 28 U.S.C. § 1391(b) and (c) because the events
`giving rise to the claims occurred in this district, Defendants’ principal place of business is in this
`district, Defendants engaged in their wrongful acts and infringement on Plaintiff’s rights in this district,
`and Defendants are subject to personal jurisdiction in this district.
`THE PARTIES
`Plaintiff Ice Cube is, and at relevant times was, a citizen of a California, residing in the
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`City of Los Angeles, Los Angeles County, California.
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`Plaintiff alleges, on information and belief, that Defendant Robinhood is a Delaware
`corporation and is headquartered in this district, in the City of Menlo Park, San Mateo County,
`California.
`Plaintiff alleges, on information and belief, that Defendant Robinhood Financial is a
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`Delaware limited liability company and is headquartered in this district, in the City of Menlo Park, San
`Mateo County, California.
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`Plaintiff alleges, on information and belief, that Defendant Robinhood Financial is a
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`wholly owned subsidiary of Robinhood.
`GENERAL ALLEGATIONS
`Ice Cube is a world-renowned artist. Ice Cube first achieved recognition and commercial
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`success as one of the founding members of the pioneering rap group N.W.A. in 1987. In 1990, Ice Cube
`embarked on a successful solo recording career. Among Ice Cube’s many chart-topping albums, his
`1992 album The Predator featured his certified-platinum single “Check Yo Self.”
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`“Check Yo Self” has become one of Ice Cube’s signature recordings and is an indelible
`part of his image and likeness. Indeed, the lyric and phrase “Check Yo Self” has become nothing less
`than Ice Cube’s catchphrase. If Ice Cube uses his signature catchphrase, “Check Yo Self,” the public
`has come to understand that he “means business” and is serious.
`19.
`In addition to his successful music career, Ice Cube has also regularly worked as an actor
`in motion pictures, beginning with 1991’s highly regarded Boyz n the Hood.
`20.
`Ice Cube has also leveraged his image and likeness in successful entrepreneurial
`endeavors. For instance, in 2017, Ice Cube co-founded Big3, a 3-on-3 basketball league that went on to
`achieve great success.
`21. Most importantly, Ice Cube has devoted his life to the cause of social justice and civil
`rights, standing up for the disenfranchised in American society. In 2020, Ice Cube’s social activism
`culminated in the publishing of A Contract with Black America, a covenant to right the centuries of
`wrongs that have been inflicted on Black Americans.
`22.
`The image of Ice Cube is famous and valuable.
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`The likeness of Ice Cube is famous and valuable.
`24.
`“Ice Cube” is further a registered trademark with the United States Patent and Trademark
`Office, bearing the Registration Number 3717252. This registered trademark underscores the fame and
`value attributable to Ice Cube’s brand and persona.
`25.
`Ice Cube’s business partner, Jeff Kwatinetz, is a civil rights attorney who recently filed a
`class action lawsuit against Robinhood, and has publicly voiced his disapproval of Robinhood and its
`business practices on several media outlets. It is public knowledge that Mr. Kwatinetz is associated with
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`Ice Cube, as they partnered in developing the highly successful Big3 basketball league.
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`On March 8, 2021, Defendants impermissibly used Ice Cube’s image and likeness in
`connection with an advertisement (the “Advertisement”) for Robinhood’s financial services and
`products on the “Robinhood Snacks” website and app. The Advertisement uses Ice Cube’s image and
`likeness, including his signature catch phrase, in order to create the false impression that Ice Cube
`actually endorses Robinhood, its products, and its services. A true and correct copy of the
`Advertisement is attached hereto as Exhibit 1.
`27.
`The Advertisement creates the false impression that Ice Cube supports and endorses
`Robinhood’s products and services. This is especially true as the Advertisement (mis)quotes the most
`well-known lyric from Ice Cube’s hit single, “Check Yo Self.” In truth, Ice Cube absolutely does not,
`and never would, support Robinhood’s products and services.
`28.
`The fact that the Advertisement suggests that Ice Cube endorses Robinhood and its
`services and products is supported by the fact the Robinhood has a demonstrable pattern and practice of
`using established celebrities, such as Nas and Jay-Z, to endorse its products and services. Robinhood
`brazenly relied on its well-publicized association with such prominent rappers when it unlawfully used
`Ice Cube’s image and likeness to create the false impression that Ice Cube supports and endorses
`Robinhood’s products and services.
`29. Moreover, on information and belief, Robinhood and Robinhood Financial specifically
`sought to punish and make an example out of Ice Cube due to the fact that his business partner, Jeff
`Kwatinetz, had sued Robinhood and publicly held the company to account. Although Ice Cube has no
`involvement in that lawsuit, Defendants’ resulting actions speak volumes about their petty, vindictive,
`and malicious nature.
`30.
`At no time prior has Ice Cube authorized Defendants to use his image or likeness for
`commercial purposes of any sort, let alone the Advertisement.
`31.
`On March 10, 2021, Ice Cube notified Defendants in writing that the use of his image and
`likeness in the Advertisement was not authorized. Ice Cube demanded that Defendants immediately
`cease and desist from any further unauthorized uses of his image and likeness.
`32.
`Despite this notice, Defendants have continued to exploit Ice Cube’s image and likeness
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`without permission from Ice Cube and without compensating Ice Cube, causing significant damage to
`Ice Cube and adversely affecting the value of Ice Cube’s image and likeness.
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`FIRST CLAIM FOR RELIEF
`(For Violation of Lanham Act Under 15 U.S.C. § 1125(a))
`Plaintiff incorporates by reference all preceding paragraphs of this Complaint at if set
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`forth in full in this claim.
`34.
`Ice Cube’s image and likeness has secondary meaning, as that term is understood
`in trademark law. As described above, Defendants have falsely used Ice Cube’s likeness in the
`Advertisement, creating the false impression that Ice Cube endorses Robinhood and its products and
`services. Members of the public have come to recognize Ice Cube’s image and likeness as belonging to
`him. This was done to promote and attract customers to Defendants’ website , products, and services,
`and to thereby generate revenue for Defendants. Thus, this was done in furtherance of Defendants’
`commercial benefit. Ice Cube is in the business of commercializing his identity and selling his image,
`likeness and identity to reputable brands and companies for profit. By virtue of Ice Cube’s use of his
`image, likeness, and identity to build his brand, his image and likeness have acquired a distinctiveness
`through secondary meaning. Ice Cube’s image and likeness either suggests the basic nature of his
`product or service, identifies the characteristics of his product or service, or suggests the characteristics
`of his product or service that requires an effort of the imagination by the consumer in order to be
`understood as descriptive.
`35.
`The goodwill and reputation associated with Ice Cube’s image and likeness has
`continuously grown throughout the general public. Ice Cube’s image and likeness are now known
`throughout the United States, the State of California, and the world, as a source of origin for his services
`and endorsements.
`36.
`Defendants use of Ice Cube’s image and likeness is designed to create and does create the
`false and deceptive commercial impression that Defendants and their products are associated with and/or
`endorsed by Ice Cube. The use by Defendants of Ice Cube’s image and likeness is likely to cause
`confusion, mistake, or deception of consumers as to Ice Cube’s endorsement of goods and services.
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`The image and likeness of Ice Cube are famous and valuable.
`37.
`The image and likeness of Ice Cube are the sole property of Ice Cube.
`38.
`Consumers are likely to be attracted to Defendants’ products and services through the
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`Advertisement, creating an initial interest in the products and services upon seeing them and creating a
`lasting appreciation, believing them to endorsed by or otherwise associated with Ice Cube, thereby
`resulting in consumer confusion. Defendants’ conduct will damage Ice Cube’s ability to enjoy,
`maintain, and exploit his hard-won recognition - and indeed, threatens to disrupt his contractual
`relationships with current and pending third-party endorsements.
`40.
`By Defendants’ conduct alleged here, Defendants have wrongfully appropriated for
`themselves the business and goodwill value that properly belongs to Ice Cube and that Ice Cube has
`invested time, money, and energy in developing.
`41.
`By reason of Defendants’ acts of unfair competition as alleged herein, Ice Cube has
`suffered and will continue to suffer substantial monetary damage to his business in the form of diversion
`of trade, loss of profits, and a dilution in the value of his rights and reputation, all in amounts which are
`not yet ascertainable but which are estimated to be not less than the jurisdictional minimum of this court.
`42.
`By virtue of Defendants’ acts hereinafter described, Defendants have committed, and are
`continuing to commit, unlawful, unfair, and fraudulent acts in violation of, inter alia, 15 U.S.C. §
`1125(a).
`Defendants’ acts of unfair competition in violation of 15 U.S.C. § 1125(a) have caused,
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`and will continue to cause, damage and irreparable harm to Ice Cube (as described above) and are likely
`to continue unabated, thereby causing further damage and irreparable harm to Ice Cube, and to the
`goodwill associated with Ice Cube’s valuable and well-known image and likeness; and Ice Cube’s
`business relationships, unless preliminarily and permanently enjoined and restrained by the Court.
`44.
`Ice Cube has no adequate remedy at law and will suffer irreparable injury if Defendants
`are allowed to continue to engage in the wrongful conduct herein described.
`SECOND CLAIM FOR RELIEF
`(For Violation of California Civil Code § 3344 (a))
`Plaintiff incorporates by reference all preceding paragraphs of this Complaint as if set
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`forth in full in this claim.
`46.
`California Civil Code § 3344(a) provides:
`“Any person who knowingly uses another’s name, voice, signature, photograph, or
`likeness, in any manner on or in products, merchandise, or goods, or for purposes of
`advertising or selling, or soliciting purchases of products, merchandise, goods or services,
`without such person’s prior consent, or, in the case of a minor, the prior consent of his
`parent or legal guardian, shall be liable for any damages sustained by the person or persons
`injured as a result thereof. In addition, in any action brought under this section, the person
`who violated the section shall be liable to the injured party or parties in an amount equal to
`the greater of seven hundred fifty dollars ($750) or the actual damages suffered by him or
`her as a result of the unauthorized use, and any profits from the unauthorized use that are
`attributable to the use and are not taken into account in computing the actual damages. In
`establishing such profits, the injured party or parties are required to prove his or her
`deductible expenses. Punitive damages may also be awarded to the injured party or parties.
`The prevailing party in any action under this section shall also be entitled to attorney’s fees
`and costs.”
`47.
`Defendants’ conduct alleged above, constitutes a violation of Section 3344 of the
`California Civil Code, because Defendants knowingly used Ice Cube’s image and likeness for
`commercial purposes without authorization.
`48.
`Each such use was unequivocally and directly for purposes of advertising or selling, or
`soliciting purchases of products, merchandise, goods or services by Defendants, such that prior consent
`was required.
`As a direct and proximate result of Defendants’ wrongful acts, Ice Cube has been
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`damaged in an amount that is not yet fully ascertainable, but which exceeds the jurisdictional minimum
`of this court.
`Ice Cube is informed and believes and based thereon alleges that Defendants in
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`committing the above described actions, acted willfully, maliciously, and oppressively, and with full
`knowledge of the adverse effects of their actions on Ice Cube, and with willful and deliberate disregard
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`for the consequences to Ice Cube. Moreover, Ice Cube is informed and believes that Defendants’
`officers, directors, and/or managers authorized and ratified the foregoing wrongful acts. By reason
`thereof, Ice Cube is entitled to recover punitive and exemplary damages from Defendants in an amount
`to be determined at the time of trial.
`51.
`Ice Cube also seeks a preliminary and permanent injunction to prohibit Defendants from
`any further use of his image and likeness for Defendants’ advantage.
`THIRD CLAIM FOR RELIEF
`(For Misappropriation of Likeness under California Common Law)
`Plaintiff incorporates by reference all preceding paragraphs of this Complaint as if set
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`forth in full in this claim.
`53.
`Defendants’ conduct alleged above, constitutes a violation of Ice Cube’s common law
`rights of publicity, because Defendants knowingly used Ice Cube’s image and likeness for their
`advantage and without his authorization.
`54.
`As a direct and proximate result of Defendants’ wrongful acts, Ice Cube has been
`damaged in an amount that is not yet fully ascertainable, but which exceeds the jurisdictional minimum
`of this court.
`Ice Cube is informed and believes and based thereon alleges that Defendants in
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`committing the above described actions, acted willfully, maliciously, and oppressively, and with full
`knowledge of the adverse effects of their actions on Ice Cube, and with willful and deliberate disregard
`for the consequences to Ice Cube. Moreover, Ice Cube is informed and believes that Defendants’
`officers, directors, and/or managers authorized and ratified the foregoing wrongful acts. By reason
`thereof, Ice Cube is entitled to recover punitive and exemplary damages from Defendants in an amount
`to be determined at the time of trial.
`
`FOURTH CLAIM FOR RELIEF
`(For Unfair Competition under California Business and Professions Code §§ 17200)
`Plaintiff incorporates by reference all preceding paragraphs of this Complaint as if set
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`forth in full in this claim.
`57.
`The aforementioned acts and practices of Defendants as set forth above constitute unfair,
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`unlawful, wrongful and fraudulent business practices in violation of California’s Unfair Competition
`Law (“UCL”), Business and Professions Code §§ 17200, et seq.
`58.
`As a direct and proximate result of Defendants’ unfair business practices, as set forth
`herein, Ice Cube has lost money or property as a result of Defendants’ multiple violations of the UCL,
`and has suffered, and will continue to suffer injury in an amount to be proven at trial.
`59.
`Ice Cube seeks restitution of all amounts wrongfully obtained by Defendants as a result
`of the aforementioned conduct.
`60.
`Ice Cube is informed and believes that Defendants have engaged, and are continuing to
`engage, in unfair competition as prohibited by California Business and Professions Code §§ 17200, et
`seq., including without limitation engaging in the aforementioned acts and practices which are patently
`unfair, fraudulent, unlawful, substantially injurious to the general public, and offensive to public policy.
`61.
`As a direct and proximate result of Defendants actions, Ice Cube is entitled to injunctive
`relief against Defendants and all those in concert with them to enjoin the aforementioned conduct, and
`for restitution according to proof.
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`PRAYER FOR RELIEF
`WHEREFORE, the Plaintiff prays for judgment against the Defendants that:
`a.
`Defendants be preliminarily and permanently enjoined from committing the acts alleged
`herein in violation of 15 U.S.C. § 1125, California Civil Code § 3344.1, and California
`common law;
` Defendants be ordered to pay Plaintiff’s actual, consequential, incidental, and special
`damages, as well as the Defendants’ profits attributable to the violations alleged;
`Defendants be ordered to pay Plaintiff’s attorneys’ fees and costs to the extent available
`under the statutes sued hereunder;
`Plaintiff be awarded punitive damages; and
`Plaintiff be awarded such other and further relief as the Court deems just and
`proper.
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`b.
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`c.
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`d.
`e.
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`/ / /
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`JURY DEMAND
`Plaintiff respectfully requests a jury trial on all issues triable thereby.
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`DATED: March 31, 2021
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`By: /s/M. Taitelman
`Michael A. Taitelman
`Sean M. Hardy
`FREEDMAN + TAITELMAN, LLP
`1801 Century Park West, Fifth Floor
`Los Angeles, CA 90067
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`Tel: (310) 201-0005
`Fax: (310) 201-0045
`mtaitelman@ftllp.com
`smhardy@ftllp.com
`Attorneys for Plaintiff O’Shea Jackson, Sr.
`(p/k/a “Ice Cube”)
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`12
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`COMPLAINT
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`1 2 3 4 5 6 7 8 9
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`10
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