Case 4:21-cv-02856 Document 1 Filed on 09/01/21 in TXSD Page 1 of 36
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF TEXAS
`HOUSTON DIVISION
`
`
` Jane Doe (D.R,)
`
`
`Plaintiff
`
`v.
`
`
`SALESFORCE.COM, INC. and
`BACKPAGE.COM, LLC,
`
`
`Defendants.
`
`
`
`
`
`
`Civil Action No. 4:21-cv-02856
`
`
`
`
`
`
`
`
`
`PLAINTIFF’S ORIGINAL COMPLAINT
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`Comes Now, Jane Doe (D.R.), Plaintiff in the above-styled and numbered cause, and files
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`this Original Complaint complaining of Salesforce.com, Inc. and Backpage.com, Inc. as
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`Defendants, and would respectfully shows the Court and Jury as follows:
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`I.
`
`OVERVIEW OF THE LAWSUIT
`
`1.
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`Backpage was the largest sex trafficking website in the world until it was seized by
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`the U.S. Department of Justice and shut down in 2018. The key to Backpage’s dominance of the
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`sex trafficking market was its relationship with Salesforce. Salesforce is a technology company
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`that provides customizable software and personalized support to help its clients operate their
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`businesses, manage their relationships with their customers, and market themselves to new
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`customers.
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`2.
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` Beginning in 2013, Salesforce entered into the first of several lucrative contracts
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`with Backpage. Through providing technology and support to Backpage, Salesforce succeeded in
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`greatly expanding Backpage’s business to become the dominant force in online sex trafficking. The
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`relationship between Backpage and Salesforce endured for years, even while Backpage was under
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`criminal investigation and even after its CEO was arrested on sex crimes charges. Although
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`Salesforce knew that Backpage was engaged in criminal trafficking and knew that its own actions
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`facilitated trafficking on Backpage, Salesforce continued to do business with Backpage until it was
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`shut down.
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`3.
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`The venture between Salesforce and Backpage left many trafficking victims in its
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`wake. Plaintiff was one victim. Between early 2014 and mid 2017, Plaintiff was trafficked on
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`Backpage and was repeatedly sold for illegal sex against her will. Plaintiff’s trafficker paid money
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`to Backpage to post explicit ads through which Plaintiff was sold. The trafficking of Plaintiff on
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`Backpage occurred during the contractual relationship between Backpage and Salesforce and was
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`facilitated by the tools and operational support that Salesforce provided to Backpage.
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`4.
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`Both Texas and federal statutes permit sex trafficking victims like Plaintiff to
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`recover civilly against both sex traffickers and those who benefit financially from facilitating sex
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`trafficking. Plaintiff files this lawsuit to hold Backpage and Salesforce accountable under these
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`anti-trafficking laws.
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`
`
`II.
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`JURISDICTION AND VENUE
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`5.
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`This Court has original jurisdiction pursuant to 28 U.S.C. § 1331 because this action
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`involves a federal question under the Trafficking Victims Protection Act (“TVPA”), 18 U.S.C.
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`§ 1581, et seq. The Court also has supplemental jurisdiction over Plaintiff’s state law claims
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`pursuant to 28 U.S.C. § 1367 because they form part of the same case or controversy as her federal
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`claims.
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`6.
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`Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b) because a substantial
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`part of the events or omissions giving rise to this claim occurred in this District and Division.
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`7.
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`Plaintiff was trafficked in this District and Division.
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`III.
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`THE PARTIES
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`8.
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`Plaintiff is a natural person who is a resident and citizen of Texas. Plaintiff was at
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`all relevant times a trafficked person as that term is understood under the TVPA and the Texas Civil
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`Practice and Remedies Code Chapter 98. Given the nature of these allegations, this complaint
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`identifies Plaintiff as Jane Doe (D.R.) throughout. She may be contacted through her counsel. There
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`is a collective and compelling interest in keeping Plaintiff’s identity anonymous.
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`9.
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`Defendant Salesforce.com, Inc. (“Salesforce”) is a foreign corporation organized
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`under the laws of Delaware with its principal place of business in California. Salesforce can be
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`served with process by service on its registered agent in Texas, C T Corporation System, 1999 Bryan
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`St. Ste. 900, Dallas TX 75201-3136. Salesforce does business in a systematic and continuous
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`manner throughout this District and Division. All references to Salesforce include any department,
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`division, office, agency, subsidiary, or corporate affiliate whether domestic, foreign, and/or
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`international. The term also includes any director, officer, agent (either with direct/actual authority
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`and implied/apparent authority), employee, person, firm, or corporation acting on behalf of
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`Salesforce now or at any time relevant to the claims herein.
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`10. Defendant Backpage.com, LLC (“Backpage”) is a Delaware Limited Liability
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`Corporation registered to do business and doing business in Texas. Backpage may be served through
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`its attorney of record, Mark Castillo, 901 Main Street, Suite 6515, Dallas, Texas 75202. All
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`references to Backpage include any department, division, office, agency, subsidiary, or corporate
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`affiliate whether domestic, foreign, and/or international. The term also includes any director, officer,
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`agent (either with direct/actual authority and implied/apparent authority), employee, person, firm,
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`or corporation acting on behalf of Backpage now or at any time relevant to the claims herein.
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`IV.
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`ASSUMED OR COMMON NAME
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`11. Plaintiff brings this petition against each Defendant in its assumed or common
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`name and expressly reserves the right under Federal Rule of Civil Procedure 17 to substitute the
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`true name of any Defendant if needed or in response to a Court order. Moreover, Plaintiff expressly
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`invokes the right to amend under the doctrine of misnomer if any Defendants are properly served,
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`but sued and served under the wrong legal name.
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`V.
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`CONDITIONS PRECEDENT
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`12. All conditions precedent to the filing of this lawsuit have been performed or have
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`occurred.
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`VI.
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` FACTUAL ALLEGATIONS
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`A. The Reach of Human Trafficking Has Greatly Expanded in Recent Years
`Through The Use of Technology And With The Support Of Modern Technology
`Companies.
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`13. Human trafficking is a public health crisis that has reached epidemic proportions.
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`Sex trafficking comprises a significant portion of overall trafficking and the majority of
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`transnational modern-day slavery.1 There are an estimated 4.8 million victims of sex trafficking
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`worldwide, with the United States leading all other nations in driving demand.2 And it is estimated
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`that there are more than 300,000 victims of human trafficking in the State of Texas, and nearly
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`80,000 of those are identified as minors.3 Human trafficking earns profits of roughly $150 billion
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`per year, with two-thirds of these dollars resulting from sexual exploitation of the victims.4
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`14. The number of human trafficking victims has grown exponentially in recent years.5
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`Online exploitation of victims has transformed the commercial sex trade and, in the process, has
`
`
`1 Trafficking in Persons Report 2008, U.S. Department of State, https://2001-2009.state.gov/g/tip/rls/tiprpt/2008/
`index.htm.
`2 U.S. Institute Against Human Trafficking, https://usiaht.org/.
`3 Tex. H.R. Con. Res. 35, 86th Leg. R.S.
`4 Human Trafficking by the Numbers, Human Rights First (2017), https://www.humanrightsfirst.org/sites/default/
`files/TraffickingbytheNumbers.pdf.
`5 Tex. H.R. Con. Res. 35, 86th Leg. R.S.
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`contributed to the explosion of domestic sex trafficking. Social networks and online-classified sites
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`are being used by traffickers to market, recruit, sell, and exploit victims for criminal purposes. The
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`internet and other modern technologies give traffickers the unprecedented ability to exploit a greater
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`number of victims and advertise their services across geographic boundaries.6 These technologies
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`impact various aspects of trafficking, from grooming, recruitment, and control of victims to
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`advertising, movement, and financial transactions.7
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`15. Traffickers need the technology and support provided by these businesses to
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`operate, and they have found many businesses that will assist them as long as they are paid.8 These
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`businesses affirmatively facilitate, assist, and support sex trafficking ventures and have participated
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`in the significant expansion of sex trafficking in recent years.
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`
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`B. Backpage Was the Internet’s Largest Sex Trafficking Hub.
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`16. Backpage.com was established in 2004 and initially began as an online marketplace
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`for various goods and services. However, in 2008, the leading online marketplace, Craigslist, took
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`steps that reduced sex ads on its platform. For Backpage, this led to a period of “explosive growth”
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`by “[o]ptimizing [its] geography strategy” and “capitalizing on displaced Craigslist ad volume.”9
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`17. During the late 2000s, it became apparent that classified ad platforms and social
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`media sites were facilitating and profiting from commercial sex and trafficking.10
`
`
`6 Mark Latonero et al., Human Trafficking Online: The Role of Social Networking Sites and Online Classifieds,
`University of Southern California (2011), https://technologyandtrafficking.usc.edu/files/2011/09/
`HumanTrafficking_FINAL.pdf.
`7 Mark Latonero et al., The Rise of Mobile and the Diffusion of Technology-Facilitated Trafficking, University of
`Southern California (November 2012), https://technologyandtrafficking.usc.edu/files/2012/11/
`HumanTrafficking2012_Nov12.pdf.
`8 On-Ramps, Intersections, and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human
`Trafficking, The Polaris Project (2020), https://polarisproject.org/wp-content/uploads/2018/08/A-Roadmap-for-
`Systems-and-Industries-to-Prevent-and-Disrupt-Human-Trafficking.pdf.
`9 U.S. Senate Permanent Subcomm. on Investigations, Backpage.com’s Knowing Facilitation of Online Sex
`Trafficking, https://www.hsgac.senate.gov/imo/media/doc/Backpage%20Report%202017.01.10%20FINAL.pdf.
`10 Latonero, supra note 6.
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`18. As early as 2008, Backpage had been publicly identified by law enforcement,
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`United States Attorneys General, and every state Governor as the biggest and most notorious sex
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`trafficking and pimping website in the United States.
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`19. Backpage nonetheless worked to expand its role in online sex trafficking.
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`Backpage’s gross revenues increased from $5.3 million in 2008, to $11.7 million in 2009, and to
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`$29 million in 2010.11
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`20. By 2010, Backpage.com was the unchallenged leader in online advertising for
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`human trafficking and exploitation of women and children. The National Association of Attorneys
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`General described Backpage as a “hub” of “human trafficking, especially the trafficking of
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`minors.”12
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`21.
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`In September 2010, a group of 21 state attorneys general called on the then-owner
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`of Backpage.com (Village Voice Media) to shut down its adult services section.13 Backpage.com
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`refused and continued to profit from the exploitation of women and children, during which time it
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`sought to portray the company as a defender of freedom of speech by challenging and seeking to
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`discredit any person or entity that criticized the company and its business practices.
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`22. For years, Backpage.com continued to profit from the exploitation of women and
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`children. Any reasonably prudent person who took even a cursory look at the Backpage.com
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`website or did an internet search of the company would know immediately that Backpage was a
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`purveyor of sex, not a general online marketplace. In fact, Backpage.com was the largest and most
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`notorious sponsor of commercial and coerced sex in the history of the internet.14 Backpage was the
`
`
`11 U.S. Senate Permanent Subcomm. on Investigations, supra note 9.
`12 Letter from the Nat’l Ass’n of Attorneys General to Samuel Fifer, Esq., Counsel for Backpage.com LLC (Aug.
`31, 2011), https://agportal-s3bucket.s3.amazonaws.com/uploadedfiles/Home/News/Press_Releases/2011/
`NAAG_Backpage_Signon_08-31-11_Final.pdf.
`13 Id.
`14 U.S. Senate Permanent Subcomm. on Investigations, supra note 9.
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`predominant force in online sex trafficking until it was shut down by federal law enforcement
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`authorities on April 6, 2018.
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`23.
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` During 2013-2015, Backpage earned over 99% of its revenue from adult
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`advertisements.15 Based on publicly available documents, Backpage earned approximately $71
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`million in revenue in 2012. In the next 29 months, from January 2013 through May 2015,
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`Backpage earned approximately $346 million in revenue, with nearly $340 million being from adult
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`advertisements.
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`24. The U.S. Senate Report provides the following summary of the true character of
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`the Backpage.com business model:
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`Internal Backpage documents make clear that this growth was attributable
`to “adult” advertisements. In a 2011 internal memorandum, for example, the
`company stated that it “possesse[d] the most popular adult online classified site on
`the Internet” and that it “use[d] the Adult categories to drive traffic to other
`categories [of classified ads].” According to internal documents, Backpage
`reported that although ads in the adult section represented only 15.5% of total ad
`volume in 2011, the company generated 93.4% of its average weekly paid ad
`revenue from adult ads. Backpage’s adult section dwarfed other categories on the
`site in the number of paid ads, with over 700,000 as of May 2011, compared to just
`over 3,000 for “Jobs” and 429 for “Automotive.” Adult ads also received
`significantly more page views than the ads in other categories: As of May 2011,
`ads in the “Jobs” section had approximately 2 million page views and
`“Automotive” had approximately 580,000. By contrast, adult ads had over one
`billion page views, and no other single category had more than 16 million page
`views.16
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`25. On April 5, 2018, Backpage’s CEO Carl Ferrer entered into a plea agreement with
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`the Department of Justice in which he admitted Backpage had operated as a site for the sale of
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`illegal sex since 2004.17
`
`
`15Declaration in Support of Arrest Warrant and Warrant, State v. Ferrer (Cal. Super. Ct), https://oag.ca.gov/system/
`files/attachments/press_releases/signed%20dec%20for%20arrest%20warrant%20pdf_Redacted.pdf.
`16 U.S. 24 Permanent Subcomm. on Investigations, supra note 9.
`17 Plea Agreement, United States v. Ferrer, No. 2:18-cr-00464-DJH
`https://www.justice.gov/opa/press-release/file/1052531/download.
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`(D. Ariz. Apr. 5, 2018),
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`26. On the same date, Backpage.com signed a plea agreement that contained the same
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`admissions.18
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`27. Backpage also admitted to its role in sex trafficking and related violations of law in
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`a proceeding in Texas. Backpage confessed that it did “knowingly receive a benefit from
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`participating in a venture that involved the trafficking…of a child younger than 18 years of age,
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`and by any means caused [the child] to engage in or become the victim of conduct prohibited by
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`Section 43.05 Compelling Prostitution.”19
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`28. Backpage has thereby conceded it is a sex trafficker and criminal venture. The
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`nature of the venture was clear: venturing with individual traffickers and its corporate partners to
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`engage in sex trafficking, exploitation of women and children, and related criminal behavior.
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`C. Salesforce Provides Customer Relationship Management Software and
`Support To Companies to Help Them Operate and Expand Their Businesses.
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`29. Salesforce is the world’s number one customer relationship management (CRM)
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`platform. CRM is a technology for managing a company’s relationships and interactions with
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`customers and potential customers. The goal is simple: improve business relationships to grow
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`one’s business and profits.
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`30. CRM systems help companies stay connected to customers, streamline processes,
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`and improve profitability.
`
`
`18 Plea Agreement, United States v. Backpage, No. 2:18-cr-00465-DJH (D. Ariz. Apr. 5, 2018),
`https://www.justice.gov/opa/press-release/file/1052536/download.
`19 Judicial Confession and Stipulation and Certification of Discovery, State v. Backpage.com, No. 18FC-1653C
`(Tex. Dist. Ct. Apr. 9, 2018), https://digitalcommons.law.scu.edu/cgi/viewcontent.cgi?article=2709&context
`=historical.
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`31. The CRM technology created and sold by Salesforce is called “software as a
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`service” (SaaS). Using Salesforce technology, a company has access to a coordinated set of
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`applications tailored to its business model, including applications that:
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`
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`
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`
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`
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`
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`
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`
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`
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`manage sales and customer support;
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`manage all marketing functions, e.g., email, social media, ads;
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`assist with customer service and support and problem solving;
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`permit communications with employees, customers, et al.
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`provide customer data integration and support;
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`offer business intelligence analytics;
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`help develop custom apps or programs; and
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`process Internet of Things (IoT) data.
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`These Salesforce tools are designed and intended to enhance the efficiency and success of any
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`business.
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`32. The cornerstone of the Salesforce platform is the “customer org.” The “org” is the
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`portal that serves as one continuing point of interaction between Salesforce and its customers. It is
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`an entity that consists of users, data, and automation corresponding to an individual customer. The
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`Salesforce “org” is confidential to the Salesforce customer and is not a platform accessible by public
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`internet users.
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`33. All of the software marketed by Salesforce is designed for specific customers and
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`their unique needs. Salesforce likewise provides personalized support to its customers to help them
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`achieve their business goals. The design, implementation, and support of Salesforce’s service is a
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`complex endeavor, personalized to every business. The essence of the Salesforce business model
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`is both the technology offered and the affirmative support provided by Salesforce, both of which
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`are designed to aid in the success of the customer’s business operations.
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`D. Salesforce Knowingly Participated in a Sex Trafficking Venture with
`Backpage and Financially Benefitted Through Its Participation.
`
`
`1. Salesforce participated in a sex trafficking venture with Backpage by
`facilitating sex trafficking on Backpage.
`
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`34. By 2013, Backpage found itself in need of a partner who could facilitate and support
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`the company’s exponential growth.
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`35. Backpage did not have the ability to keep pace with increasing customer demand
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`and scale its platform into an international sex-trafficking hub without operational support,
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`marketing innovation, guidance and better “customer relationship management” tools and
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`capabilities.
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`36. Salesforce, and its powerful tools used to improve Backpage’s business functions
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`and growth, bridged this gap by providing targeted support and solutions essential for Backpage’s
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`operational needs. Salesforce advertises itself as a company that can drive business growth through
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`the use of customer relationship management, marketing consultation and implementation,
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`financial processing implementation and support, bespoke analytics, and other applications and
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`technology. Each of these components are designed to aid in the success of the customer’s venture.
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`37.
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`In 2013, Backpage signed the first of many contracts with Salesforce and paid
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`Salesforce for its technology and support. Thereafter, until Backpage was seized by federal law
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`enforcement authorities in April 2018, Salesforce assisted, supported, and facilitated Backpage in
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`its trafficking operations through providing its CRM software, associated support and facilitation
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`of Backpage’s development.
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`38. Salesforce sold Backpage access to several products and features including, but not
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`limited to, Salesforce’s premier level product (the Enterprise Edition) and Pardot (an advanced
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`marketing technology).
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`39. Salesforce affirmatively and independently provided Backpage with the tools
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`Backpage needed to operate and grow and the support Backpage needed to take advantage of those
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`tools. With a solid CRM strategy in place, a business—such as Backpage—can collect detailed, in-
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`depth customer data and use the data to streamline communications and overall business practices.
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`Salesforce’s software and support therefore impacted all aspects of Backpage’s business, including
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`customer service, sales, and marketing.
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`40. Salesforce affirmatively provided unique technological tools and instruments to
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`Backpage as part of its internet-based online selling of sex, sex trafficking, and compelled
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`prostitution, including the trafficking of Plaintiff. And Salesforce provided personalized support
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`for the technological tools and instruments that made it possible for Backpage to engage in the
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`internet based on-line selling of sex, sex trafficking and compelled prostitution, including the
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`trafficking of Plaintiff.
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`41. Salesforce was the driving force that enabled Backpage to scale its operations and
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`increase the trafficking conducted on Backpage. By providing technology, implementation skills,
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`and ongoing support that all constitute affirmative acts by Salesforce that encouraged the
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`wrongdoing in which Backpage.com was engaged and facilitated the sex trafficking operation.
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`42. The sophisticated CRM tools and support provided by Salesforce to Backpage
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`directly resulted in unprecedented growth of the Backpage.com website, its sex trafficking venture,
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`and profits for Backpage and its corporate partners (including Salesforce). Salesforce’s technology
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`and support helped grow Backpage from a small Dallas-based company with a handful of
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`employees to an international powerhouse with over 250 employees spanning three continents.
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`43. The goods and services sold by Salesforce and purchased by Backpage were for
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`internal Backpage use only and were designed and intended to be for the exclusive use of Backpage
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`employees in the pursuit of customers for the Backpage.com site. Salesforce did not host a platform
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`or otherwise provide access to the internet or another public forum for the expression of public
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`views, the exchange of marketable items, or any other publicly accessible purpose.
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`44. Further, Salesforce did not merely sell an off-the-shelf product that enabled
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`Backpage to grow without the input of Salesforce. Rather, Salesforce sold Backpage targeted
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`solutions addressed to the needs of Backpage’s business.
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`45.
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`Indeed, an in-house Salesforce executive recommended that Backpage’s needs
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`would be best served by Salesforce’s Enterprise CRM edition. As described on its website, the
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`Enterprise edition is “fully customizable,” providing a “deeply customizable sales CRM for
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`[Backpage]’s business” of prostitution and sex trafficking.20 In any event, an integral component
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`of the Salesforce product suite is active, ongoing support that is necessarily tailored to the needs of
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`the customer seeking support.
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`46. Salesforce provided Backpage with personalized services tailored specifically to
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`the needs of its illegal business. For example, in 2015, Backpage was under intense public scrutiny
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`surrounding credit card companies’ refusal to process their transactions due to the nature of
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`Backpage’s business. Backpage was in fear of imminent law enforcement seizure in the United
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`States and therefore sought to establish and maintain a duplicate copy of the Backpage operations
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`system and platform for use overseas. Salesforce knowingly assisted, supported, and facilitated
`
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`20 Sales Cloud Pricing, Salesforce, https://www.salesforce.com/editions-pricing/sales-cloud/.
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`this system reorganization and provided the technical infrastructure for Backpage to move and
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`operate its business overseas. In other words, Salesforce addressed a need unique to Backpage’s
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`business—the need for a duplicate of Backpage’s system—and in doing so directly assisted
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`Backpage in evading law enforcement scrutiny in the United States. These type of tailored services
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`were not “generic” or “off the shelf.”
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`47. Throughout the time Salesforce did business with Backpage, Salesforce retained
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`ownership and control of the Salesforce platform and technology, including the Backpage “org”
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`that was hosted by Salesforce. As set forth in the binding Master Service Agreements applicable to
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`the time period Backpage was a customer, Salesforce retained the right to delete or restrict access
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`to the Backpage org if the actions or content of the user was found to be unlawful or tortious. And
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`Salesforce retained complete ownership of its technology and products as specifically set forth in
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`the contracts with Backpage.
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`48. Each time a new application was purchased, support requested, or a contract
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`renewed, Backpage consulted with Salesforce to assess its operational needs. This occurred, at a
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`minimum, on the following dates: November 12, 2013; November 16, 2016; December 13, 2016;
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`January 28, 2017; and April 27, 2017.
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`49. At any one of those dates, Salesforce, as the owner with retained control over the
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`Salesforce platform and Backpage “org” had the ability to literally pull the plug on Backpage’s use
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`of the Salesforce technology and expertise. Salesforce instead continued to facilitate Backpage’s
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`trafficking operation.
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`50. Between 2013 and 2018, there was a continuous business relationship between
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`Salesforce and Backpage. The parties established a pattern of conduct or tacit agreement by which
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`they jointly facilitated the trafficking of victims through Backpage, including Plaintiff.
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`51. Backpage.com would have been unable to achieve its status as the behemoth of
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`human trafficking and child sexual exploitation without the support, facilitation, expertise, and
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`maintenance of Salesforce.
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`2. Salesforce knew or should have known that its sex trafficking venture with
`Backpage was engaged in violations of anti-trafficking laws.
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`
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`52. When Salesforce consummated a business relationship with Backpage, Salesforce
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`knew—or, at minimum, should have known—that Backpage was a serial violator of human rights,
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`a criminal enterprise guilty of violating state and federal law, and a rampant facilitator of human
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`trafficking and sexual exploitation of minors.
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`53. Salesforce learned about Backpage’s illegal trafficking operations through its direct
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`contact with Backpage representatives. During Salesforce’s initial negotiations with Backpage on
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`or about November 6, 2013, a Certified Salesforce Consulting Partner met with Backpage CEO
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`Carl Ferrer and another high-level Backpage executive for introductions and to assess and evaluate
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`Backpage’s needs and goals. The Consulting Partner reported back to a Salesforce executive in an
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`e-mail on November 7, 2013 that he “spent most of the time learning of [Backpage] as a business,”
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`noting the need for security and advanced integration.
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`54. On or about November 12, 2013, an in-house Salesforce Account Executive
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`confirmed ongoing conversations with the Backpage executives and was confident that the
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`partnership would soon be consummated stating, “I think this is trending strongly in our favor.”
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`55. While Salesforce may claim that it was technically employed by a Backpage
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`affiliate, Salesforce knew at all relevant times it was working directly with Backpage through direct
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`communications with Backpage executives and exchanging correspondence with Backpage at its
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`business address and email addresses (@backpage.com) and taking money directly from Backpage.
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`14
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`Case 4:21-cv-02856 Document 1 Filed on 09/01/21 in TXSD Page 15 of 36
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`56. From inception, therefore, Salesforce had actual knowledge of the nature of
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`Backpage.com and the company’s ardent need to conceal its internal business operations from
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`public scrutiny. Indeed, as noted above, Salesforce affirmatively assisted, supported, and facilitated
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`Backpage in moving a duplicate copy of its system overseas for the purpose of evading law
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`enforcement scrutiny. Further, because Salesforce’s services and support are personalized to the
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`needs of each business, Salesforce could not have provided effective assistance to Backpage
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`without understanding the needs of its business. Therefore, Salesforce knew that its software and
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`the support it provided to Backpage were directly advancing the sex trafficking of adults and minors
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`through Backpage.
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`57. Moreover, it was public knowledge that Backpage was a trafficking website
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`throughout the course of Salesforce’s relationship with Backpage. Prior to and including 2014,
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`Backpage.com was in the news regularly. The articles ran the gamut, but the common theme was
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`that Backpage.com was the leading platform for the facilitation of sex trafficking and other forms
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`of human degradation.21
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`58. Salesforce’s hometown newspaper, the San Francisco Chronicle, published no less
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`than 400 prominent news articles concerning Backpage.com during the time period 2009 to 2017.
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`59. Among other news stories published in the Chronicle during the time Salesforce
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`was nurturing its relationship with Backpage.com were the following:
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`Man charged with sexual assault of a child
`March 10, 2012 | Michelle Casady
`The girl told police Parton also advertised her as a prostitute on the
`website Backpage.com and kept the money she made.
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`Protesters: Village Voice helps sell kids for sex
`
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`21 See, e.g., Deborah Feyerick & Sheila Steffen, A Lurid Journey Through Backpage, CNN (May 10, 2012),
`https://thecnnfreedomproject.blogs.cnn.com/2012/05/10/a-lurid-journey-through-backpage-com/; Nicholas Kristof,
`How Pimps Use the Web to Sell Girls, N.Y. Times (Jan. 25, 2012), https://www.nytimes.com/2012/01/26/opinion/
`how-pimps-use-the-web-to-sell-girls.html.
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`Case 4:21-cv-02856 Document 1 Filed on 09/01/21 in TXSD Page 16 of 36
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`March 29, 2012 | Verena Dobnik
`They want the weekly’s parent company to shut down its Backpage.com adult classified
`section, which they say includes ads linked to child sex-trafficking.
`
`McGinn urges Backpage.com to check ages on sex ads
`May 7, 2012 | P-I Staff and News Services
`Backpage.com critics say the site is used to advertise underage prostitutes who are often
`victims of sex trafficking.
`
`Charge: Online pimp rented out, raped runaway girl
`September 18, 2012 | Levi Pulkkinen
`Anderson, 29, posted provocative photos of the girl on Backpage.com along with his cell
`phone number. ... A Google search of Anderson’s cell phone number returned several
`prostitution advertisements on Backpage.
`
`Man sentenced to 26 years for forcing teen to work as prostitute
`September 25, 2012 | Audrie Palmer
`He then listed the girl’s “services” through the website Backpage.com.
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`Prosecutors: Seattle man started pimping g