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KRISTOPHER JOHNS, on Behalf of Himself and for the Benefit of All with the Common or General Interest, Any Persons Injured, and All Others Similarly Situated,
vs.
SONY COMPUTER ENTERTAINMENT AMERICA LLC, a Delaware Limited Liability Company; SONY NETWORK ENTERTAINMENT INTERNATIONAL LLC, a Delaware Limited Liability Company,
Plaintiff KRISTOPHER JOHNS (“JOHNS” or “Plaintiff,”) brings this action against SONY COMPUTER ENTERTAINMENT AMERICA LLC (“SCEA”) and SONY NETWORK ENTERTAINMENT INTERNATIONAL LLC (“SNEI”) (collectively, “SONY” or “Defendant”), on behalf of himself, all others similarly situated and the general public, and alleges upon information and belief, except as to his own actions, the investigation of his counsel, which included, inter alia, review and analysis of Defendant’s press releases, Defendant’s websites, web forums, and various news articles, as follows:
OVERVIEW
1. This action is brought on behalf of plaintiff individually, as representative of the common or general interest and as class representatives for all others similarly situated nationwide against SONY to redress defendant’s breach of warranty, negligent data security, violations of consumers’ rights of privacy, failure to protect those rights, and failure and on-going refusal to timely inform consumers of unauthorized third party access to their credit card account and other nonpublic and private financial information.
