Case 1:19-cv-08418-SDA Document 1 Filed 06/25/19 Page 1 of 13
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`State Bar No. 299819
`fornia 92562
`(9s1) 600-2733
`(es1) 600-4ee6
`, and Church United
`ttorneys for James Domen
`a California not-for-profit corporation
`UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`JAMES DOMEN, an individual; and
`CHURCH UNITED. a California not-
`for-profi t corporati oir
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`Plaintiffs,
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`V
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`VIMEO, INC., a Delaware for-profit
`coqporation; and DOES I throu^gh 25,
`rnclustve,
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`Defendants.
`
`Case No.
`PLAINTIFF'S JAMES DOMEN AND
`CHURCH UNITED'S COMPLAINT
`1. Free Speech Claim under
`Article I I2 of the California
`Constitution;
`2. Free Speech Claim under
`Amendment I to the United
`States Constitution;
`3. Unruh Act Claim under
`California Civil Code $ 51,
`et seq.).
`IJury Trial DemandedJ
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`Plaintiffs James Domen and Church United, a California not-for-profit
`corporation, and (collectively referred to herein as, "Plaintiffs"), by and through their
`attorneys, bring this complaint for damages and equitable relief against Defendant
`Vimeo, Inc. ("Defendant"), a Delaware for-profit corporation.
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`Plaintiffs assert that Defendant violated Califomia law by restraining Plaintiffs'
`speech and expression in violation of Article One, Section 2 of the California
`Constitution (the "Liberty of Speech Clause") and by discriminating against Plaintiffs
`based on religious, sexual orientation, or other discriminatory animus in violation of
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`PLAINTIFFS JAMES DOMEN AND CHURCH UNITED'S COMPLATNT
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`Case 1:19-cv-08418-SDA Document 1 Filed 06/25/19 Page 2 of 13
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`the Unruh Civil Rights Act, section 51, et seq. of the California Civil Code (the
`“Unruh Act”).
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`JURISDICTION AND VENUE
`This court has complete subject matter jurisdiction over this matter based
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`on diversity under 28 U.S.C. section 1332(a) (1). This suit involves a controversy
`between citizens of two different states and exceeds the jurisdictional amount of
`$75,000, exclusive of costs and interest.
`At all relevant times, Plaintiffs resided in Orange County, State of
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`California, and Defendant was headquartered in New York.
`Defendant intentionally conducts business in the State of California,
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`intentionally avails itself to the California market, and should expect to be hailed into
`court in California based on its substantial connections with the state. Because
`Defendant intentionally avails itself to the benefits of conducting business in
`California, this court’s exercise of jurisdiction is consistent with traditional notions of
`fair play and substantial justice.
`The causes of action asserted are governed by the California
`4.
`Constitution, the United States Constitution, and California law.
`Defendant’s liability arose in Orange County, the wrongful acts occurred
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`in Orange County, and each cause of action set forth herein arose in Orange County.
`Venue is proper in the United States District Court for the Central
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`District of California because the events, acts, or omissions at issue in this matter
`occurred therein.
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`PARTIES
`Plaintiffs
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`Church United
`Church United is organized as a California non-profit Religious
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`Corporation.
`Church United was founded in 1994.
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`PLAINTIFFS JAMES DOMEN AND CHURCH UNITED’S COMPLAINT
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`Church United’s mission is to equip pastors to positively impact the
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`political and moral culture in their communities. Church United currently has over
`750 affiliated pastors.
`10. Church United’s primary strategy is to equip pastors as culture-changers
`by sending them to Washington, D.C. and Sacramento, California for “Awakening
`Tours,” and to pray with government leaders.
` “Awakening Tours” focus on the spiritual heritage of the United States
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`and California with nationally-known speakers, including elected officials (U.S.
`senators, congress members, state senators, and assembly members) who vote to
`support a biblical worldview.
`12. Church United aids pastors in advocating for public policy based on a
`biblical worldview. Church United advocates for biblical worldviews by informing
`pastors about legislation and public policy issues.
`13. Church United and its affiliated pastors desire to positively impact the
`State of California and the nation with hope and to preserve their individual rights as
`pastors to exercise their faith without unlawful infringement.
`James Domen
`James Domen is the President and Founder of Church United. He is a
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`pastor and has a masters of divinity degree.
`James Domen’s personal history shapes his role as a pastor and leader of
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`Church United.
`16. For three years, James Domen was a homosexual. However, because of
`his desire to pursue his faith in Christianity, he began to identify as a former
`homosexual.
`In July 2009, James Domen married his wife. Together, they have three
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`biological children.
`James Domen is like many others in California who were formerly
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`homosexual but now identify as heterosexual.
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`James Domen bases his identity on his life as a Christian husband, father,
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`and leader in ministry.
`James Domen served on staff as a pastor at a church for several years.
`20.
`His service in the church was extremely fulfilling to his life and his identity as a
`Christian man.
`21. Through Church United, he shares his experience with other pastors and
`helps pastors counsel others that are on their own journey toward a heterosexual
`identity through a biblical perspective and a Christian worldview.
`Defendants
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`Vimeo, Inc.
`22. Vimeo is a Delaware for-profit corporation.
`23. Vimeo is headquartered in the state of New York.
`24. Vimeo was founded in 2004.
`25. Vimeo is a video-sharing website. It allows users to upload, view, share,
`and comment on videos. Available content includes video clips, music videos, short
`and documentary films, live streams, and other content such as video blogging and
`educational videos.
`26. Vimeo’s website boasts that it is home to more than 90,000,000 video
`creators worldwide.
`27. The true names and capacities, whether individual, corporate, associate,
`or otherwise, of Defendants Does 1 through 25, inclusive, are presently unknown to
`Plaintiffs, and for that reason these defendants are sued by such fictitious names.
`Plaintiffs are informed and believes and thereon alleges that each of the Doe
`defendants is in some way legally responsible for the violations of law and injuries
`and harm caused as alleged herein. If and when appropriate, Plaintiffs will seek leave
`of court to amend this complaint when the true names and capacities of said
`defendants are known.
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`Case 1:19-cv-08418-SDA Document 1 Filed 06/25/19 Page 5 of 13
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`ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
`28. On or about October 2016, Plaintiffs obtained an account with Vimeo
`for the purpose of hosting various videos, including videos addressing sexual
`orientation as it relates to religion.
`29. During the past two years, Plaintiffs used Vimeo’s video hosting service
`to publish approximately eighty-nine (89) videos. These videos captured various
`activities of Plaintiffs, including interviews, press conferences, pastors’ briefings, and
`tours.
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`30. Church United originally created its account with a free basic
`membership. Once the account reached its maximum capacity, Church United
`upgraded to a Pro Account. A Pro Account requires a monthly fee and allows more
`features and bandwidth for uploads.
`31. On or about November 23, 2018, the day after Thanksgiving, Defendant
`sent an email to James Domen informing him that a Vimeo moderator marked the
`account for review. Attached hereto as Exhibit “A” is a true and correct copy of this
`email.
`32. The email explained that “Vimeo does not allow videos that promote
`Sexual Orientation Change Efforts (hereinafter, “SOCE”).” In support of Vimeo’s
`grounds for the alleged policy violation included but was not limited to five (5) cited
`videos “that espouse this theory.”
`33. The first video flagged for review was two minutes and thirty-six
`seconds long wherein James Domen briefly explained his life story, his preferred
`sexual orientation, the discrimination he faced, and his religion.
`34. The second video flagged for review was a promotional video for
`Freedom March Los Angeles. Freedom March is a nationwide even where individuals
`like James Domen, who identify as former homosexuals, former lesbians, former
`transgenders, and former bisexuals assemble with other likeminded individuals.
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`35. The third video flagged for review was an NBC produced documentary
`segment titled, Left Field, which documented and addressed SOCE.
`36. The fourth video flagged for review was a Press Conference with
`Andrew Comiskey, the founder of Desert Stream, relating to his religion and sexual
`orientation
`37. The fifth video flagged for review was an interview with Luis Ruiz, a
`survivor of the horrific attack at the Pulse Nightclub in Florida in March 2018.
`Plaintiffs are informed and believe that Pulse Nightclub was a nightclub for
`individuals who identify as homosexual. In the video, Luis Ruiz shares his
`background as a former homosexual and his experience as a survivor of the attack.
`38. On or about December 6, 2018, Vimeo terminated Church United’s
`account because those five videos allegedly violated the following Vimeo guideline:
`“Vimeo does not allow videos that harass, incite hatred, or include discriminatory or
`defamatory speech.” The Vimeo guideline is attached hereto as Exhibit “B.”
`39. These five (5) videos centered on Church United’s Christian principles
`and James Domen’s sexual orientation as a former homosexual.
`40. Specifically, the videos involved an effort by Church United to challenge
`California Assembly Bill 2943 (hereinafter “AB 2943”), which aimed to expand
`California’s existing prohibition on SOCE.
`41. AB 2943 was eventually pulled by its author, Assembly Member Evan
`Low, because of the vocal opposition of organizations like Church United and
`personal testimonies of former homosexuals like James Domen.
`42. Neither those five (5) videos regarding AB 2943, nor any of Church
`United’s eighty-nine (89) videos, harass, incite hatred, or include discriminatory or
`defamatory speech. Plaintiffs are informed, believe, and thereupon allege that Church
`United’s account was deleted in an effort to censor James Domen from speaking about
`his preferred sexual orientation and his religious beliefs.
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`43. Plaintiffs are informed, believe, and thereupon allege that Vimeo allows
`similar videos relating to sexual orientation, including but not limited to videos from
`GLSEN, Inc., which advocate for lesbian, gay, bisexual, transgender, queer and
`questioning (“LGBTQ”) students who are bullied or discriminated against.
`44. Plaintiffs are informed, believe, and thereupon allege that Vimeo allows
`similar stories and testimonials from individuals relating to their sexual orientation
`including: “LGBTQ barber in NYC”, “LGBTQ Asian American San Gabriel Valley
`Stories”, “Happy Pride! LGBTQ Pride Month 2016” and the like.
`45. Vimeo did not provide Plaintiffs with an explanation for the distinction
`between Church United’s videos relating to sexual orientation, testimonials, events
`relating to sexual orientation, and the thousands of similar videos related to LGBTQ
`and sexual orientation.
`46. Plaintiffs are informed, believe, and thereupon allege that the violation
`of Vimeo guidelines was merely a pretext to justify restricting and censoring Church
`United and James Domen’s videos.
`CAUSES OF ACTION
`FIRST CAUSE OF ACTION
`Against Vimeo; and DOES 1 through 25, inclusive.
`(Free Speech Claim under Article I, Section 2 of the California Constitution)
`47. Plaintiffs incorporate by reference all the above paragraphs as if each
`were fully alleged herein.
`48. Article I, Section 2 of the California Constitution protects individual’s
`liberty of speech and association in public, quasi-public, and limited public spaces.
`49. Vimeo created an online public forum, or the equivalent of a public
`forum, when it created the website, Vimeo.com.
`50. Vimeo.com is similar to a public forum because it solicits views from
`the general public. Furthermore, Vimeo hosts millions of videos which encourage
`creativity, speech, and freedom of expression.
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`51. Plaintiffs are informed, believe, and thereupon allege that Vimeo created
`the website to establish an avenue for filmmakers to share their artistic creations with
`friends. Vimeo is open to the public and allows users to engage in a variety of
`activities including, but not limited to, political advocacy.
`52. Vimeo created the modern day equivalent of a town square, which
`provides individuals with a forum to express their ideas. Vimeo’s act of deleting
`accounts based on their viewpoints or expression is the modern day equivalent of
`removing an individual from a shopping center.
`53. Plaintiffs are informed, believe, and thereupon allege that Vimeo is a
`public forum and subject to the California Constitution which mandates a viewpoint
`neutral regulation of speech in public forums.
`54. Vimeo is akin to a state actor because it attempts to moderate and
`regulate freedom of expression in public forums. Vimeo should be held to the same
`standard as a state actor in its regulation of speech. Speech regulations by Vimeo
`must be viewpoint neutral, and cannot unreasonably or discriminatorily exclude,
`regulate, or restrict Plaintiffs’ speech and expression under the Liberty of Speech
`Clause.
`James Domen uses these videos to share his personal story and his
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`experience as a former homosexual, his preferred sexual orientation.
`56. Church United seeks to engage in religious expression relating to
`important public policy issues that affect Christians, especially pastors.
`57. Plaintiffs are informed, believe, and thereupon allege that Vimeo deleted
`Church United’s account based on Vimeo’s subjective perception of Christianity and
`sexual orientation.
`58. Plaintiffs are further informed, believe, and thereupon allege that Vimeo
`deleted Church United’s account because of Vimeo’s subjective belief that one may
`not change their sexual orientation. Specifically, Vimeo’s acts were premised on their
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`discriminatory belief that James Domen preferred identification as a former
`homosexual is harmful, fraudulent, and culturally inacceptable.
`59. Plaintiffs are informed, believe, and thereupon allege that Vimeo’s acts
`are a restriction of Plaintiffs’ speech and expressive rights as guaranteed under Article
`I, Section 2 of the California Constitution.
`60. Plaintiffs are informed, believe, and thereupon allege that Vimeo has
`restricted Church United’s videos discussing sexual orientation while refusing to
`censor similar content discussing sexual orientation.
`61. Vimeo’s act of censoring Plaintiffs through the deletion of Church
`United’s Vimeo account amounts to a violation of Plaintiffs’ rights to free speech
`under the California Constitution. Vimeo’s actions effectively prevent potential
`viewers from accessing these videos discussing sexual orientation.
`62. Vimeo has no compelling, significant, or legitimate reason which could
`justify its actions in this matter. Even if such an interest existed, Vimeo would bear
`the burden of demonstrating that its policies are narrowly or reasonably tailored to
`further their interest. Vimeo’s policy is not reasonably tailored to any such articulable
`interest. Due to Vimeo’s selective restrictions of allowed content, Plaintiffs are
`unable to post videos or access their previous audience.
`63. Plaintiffs’ are informed and believe that Vimeo’s actions were taken
`solely for the purpose of harassment, censorship, oppression, and malice. Such
`actions were carried out through Vimeo’s staff pursuant to subjective and
`discriminatory beliefs regarding sexual orientation and religion. Moreover, Vimeo’s
`actions were taken with the intent of depriving Plaintiffs’ of the ability to exercise
`their speech and expression under the California Constitution.
`64. Plaintiffs incurred a direct and proximate harm due to Vimeo’s actions
`in this matter. Plaintiffs respectfully request that this court grant the relief set forth in
`the prayer for relief.
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`SECOND CAUSE OF ACTION
`Against Vimeo; and DOES 1 through 25, inclusive.
`(Free Speech Claim under Amendment I to the United States Constitution)
`65. Plaintiffs incorporate by reference all the above paragraphs as if each
`were fully alleged herein.
`66. Plaintiffs are informed, believe, and thereupon allege that Defendants
`violated Plaintiffs’ right to freedom of speech by censoring and ultimately removing
`Church United’s Vimeo account amounting to an unlawful and discriminatory
`enforcement of impermissible restrictions which are not applied in a content neutral
`manner.
`67. Vimeo created the modern day equivalent of a town square, which
`provides individuals with a forum to express their ideas. Vimeo’s act of deleting
`accounts based on their viewpoints or expression is the modern day equivalent of
`removing an individual from a shopping center.
`68. Plaintiffs’ are informed, believe, and thereupon allege that Vimeo is a
`public forum and subject to the United States Constitution which mandates a
`viewpoint neutral regulation of speech in public forums.
`69. Vimeo is akin to a state actor because it attempts to moderate and
`regulate freedom of expression in public forums. Vimeo should be held to the same
`standard as the states in its regulation of speech. Speech regulations by Vimeo must
`be viewpoint neutral, and cannot unreasonably or discriminatorily exclude, regulate,
`or restrict Plaintiffs’ speech and expression.
`70. Vimeo’s actions on November 23, 2018, failed to apply its policy in a
`content neutral manner where Vimeo censored and removed Church United’s videos
`relating to sexual orientation despite the fact that Vimeo allows thousands of similar
`videos relating to sexual orientation its website.
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`71. Plaintiffs are informed and believe that Vimeo’s actions were taken
`solely for the purpose of depriving Plaintiffs’ of the ability to exercise their speech
`and expression under the United States Constitution.
`72. As a direct and proximate result of Vimeo’s actions, Plaintiffs’ rights
`under the First Amendment to the United States Constitution were violated. Plaintiffs
`respectfully request that this court grant the relief set forth in the prayer for relief.
`THIRD CAUSE OF ACTION
`Against Vimeo; and DOES 1 through 25, inclusive.
`(Unruh Act)
`73. Plaintiffs incorporate by reference all the above paragraphs as if each
`were fully alleged herein.
`74. Vimeo’s business qualifies as a business establishment under the Unruh
`Civil Rights Act where Vimeo grants individuals unrestricted access to its website,
`Vimeo.com, for the purposes of expression and political speech. The purpose of
`Vimeo’s business is to provide an avenue for individuals and creators to share their
`expressions with others.
`75. Vimeo’s failure to apply and enforce its policies in a viewpoint neutral
`matter amounts to a pattern and practice of intentional discrimination in the provision
`of Vimeo’s services based on their subjective and discriminatory beliefs relating to
`religion and sexual orientation. Vimeo intentionally deprived Church United from its
`freedom of speech by its unreasonable censorship based upon Vimeo’s interpretation
`of James Domen’s preferred sexual orientation and identity.
`76. Plaintiffs are informed, believe, and thereupon allege Vimeo’s acts
`effectively deprived Plaintiffs of the full and equal accommodations, advantages,
`privileges, and services by deleting Church United’s Vimeo account based on
`Vimeo’s discriminatory beliefs.
`77. Plaintiffs are informed and believe that Vimeo’s actions were taken
`solely for the purpose of harassment, censorship, oppression, and malice. Such
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`actions were carried out through Vimeo’s staff pursuant to discriminatory and narrow
`minded beliefs regarding sexual orientation and identity.
`78. Plaintiffs are informed, believe, and thereupon allege that Vimeo failed
`to act in good faith when it refused to address Church United’s concerns or engage in
`a progressive conversation relating to James Domen’s sexuality.
`79. Plaintiffs incurred a direct and proximate harm due to Vimeo’s actions
`in this matter.
`80. Vimeo’s violation of the Unruh Act entitles Plaintiff to recover statutory
`damages of up to three times the amount of actual damages. Plaintiff incurred
`substantial damages due to the loss of its viewer base in an amount to be proven at
`trial, and in no event less than a minimum of $75,000.00. Plaintiffs request that the
`court grant the relief set forth in the prayer for relief.
`PRAYER FOR RELIEF
`On their foregoing causes of action, Plaintiffs respectfully request the court to
`grant the following relief:
`A.
`For monetary damages, general and special, but in no event less than
`$75,000.00 exclusive of costs and interests.
`B. An award to Plaintiffs of statutory damages, in an amount not less than
`$4,000 for each of the instances Plaintiffs encountered a violation of the Unruh Act,
`pursuant to Civil Code section 52(a).
`C.
`For a declaratory judgment that Vimeo violated Plaintiffs’ rights under
`Article I, Section 2 of the California Constitution, the First Amendment of the United
`States Constitution, and the Unruh Act.
`D.
`For an injunction requiring Vimeo to reinstate Church United’s account
`with the approximately eighty-nine (89) videos that were on the account.
`For attorney’s fees and costs pursuant to 42 U.S.C. section 1988 as
`D.
`Plaintiffs’ were forced to seek private counsel in order to vindicate their legal rights
`under the California and United States constitutions. In the alternative, attorney's fees
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`Case 1:19-cv-08418-SDA Document 1 Filed 06/25/19 Page 13 of 13
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`according to proof, pursuant to Civil Code section 52, or Code of Civil Procedure
`section 1021.5, or 42 U.S.C. section 1988, or other applicable law.
`F. For such other and further relief as this court deems just and proper.
`
`DATED: June 25,2019
`
`TYLER & BURSCH, LLP
`
`By: lslNada N. Higuera
`Nada N. Higuera, Esq.
`Attorney for James Domen and Church
`United
`
`1 2 -
`
`tJ
`
`4 5 6 7 8 9
`
`10
`
`11
`t2
`l3
`t4
`
`15
`
`t6
`t7
`
`18
`I9
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`t3
`PLAINTIFFS JAMES DOMEN AND CHURCH UNITED'S COMPLAINT
`
`