Shang v. Twitch Interactive, Inc.

CourtDistrict Court, N.D. California
DecidedJanuary 9, 2025
Docket3:24-cv-06664
StatusUnknown

This text of Shang v. Twitch Interactive, Inc. (Shang v. Twitch Interactive, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shang v. Twitch Interactive, Inc., (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 BO SHANG, Case No. 3:24-cv-06664-JSC

8 Plaintiff, ORDER RE: DEFENDANTS’ MOTION TO DISMISS v. 9 Dkt. No. 8 10 TWITCH INTERACTIVE, INC., et al., 11 Defendants.

12 13 Plaintiff, a Massachusetts resident proceeding without attorney representation, filed a 14 lawsuit against Twitch Interactive, Inc. and Samantha Briasco-Stewart (together, “Defendants”) in 15 San Francisco Superior Court. Defendants removed to federal court pursuant to federal question 16 jurisdiction. Now pending before the Court is Defendants’ motion to dismiss. 17 JURISDICTION 18 As drafted, the Court construed “Plaintiff’s complaint as setting forth a single cause of 19 action: a violation of California Business and Professions Code Section 17200 et seq.” (Dkt. No. 20 14.)1 So, the Court ordered Plaintiff to identify the causes of action to determine whether the 21 Court had subject-matter jurisdiction. (Id.) In an effort to further clarify, the Court issued a 22 second order to show cause. (Dkt. No. 18.) 23 In response, Plaintiff clarified he “would like to revise the Complaint by removing the 1st 24 and 14th Amendment claims the Plaintiff made.” (Dkt. No. 16 at 1.) Plaintiff stated “[f]or Twitch 25 as a company, [he] intends to have only California Business and Professions Code – Section 26 17200 et seq as a cause of action.” (Dkt. No. 19 at 1.) Plaintiff alleged Twitch violated the 27 1 “unlawful,” “unfair,” and “fraudulent” prongs. (Id. at 1-3.) Plaintiff supported the “unlawful” 2 prong with two federal criminal statutes: 18 U.S.C. § 1955 and 18 U.S.C. § 1084. (Id. at 1.) In his 3 response to the order to show cause, Plaintiff also introduced California Civil Codes sections 1709 4 and 1710 against Ms. Briasco-Stewart, alleging she has “committed at least 3-4 counts of 5 California or Federal criminal perjury (California Penal Code 118 and 18 USC 1621).” (Id.) 6 Given Plaintiff’s clarification, the lawsuit was properly removed to federal court. Plaintiff 7 stated he “would like to revise the Complaint by removing the 1st and 14th Amendment claims the 8 Plaintiff made,” (Dkt. No. 16 at 1), thus establishing the removed complaint alleged a federal 9 claim and therefore the Court has federal subject matter jurisdiction. 10 MOTION TO DISMISS 11 A. Complaint Allegations 12 Twitch is an “online platform for streaming video games and other content.” (Dkt. No. 1-1 13 at 5.) Plaintiff “started using Twitch in 2017.” (Id. at 15.) 14 The complaint alleges Twitch engages in unfair competition, deceptive advertising, and 15 false representation of its services, including by: (1) “mis[leading] users about the nature, quality, 16 and availability of its services, such as its content moderation policies”; (2) “favor[ing] certain 17 streamers and content creators over others, based on arbitrary and discriminatory criteria”; (3) 18 “censoring, suppressing, or manipulating user content and communications”; and (4) “interfer[ing] 19 with [Plaintiff] and other users’ ability to seek legal recourse or public accountability.” (Id. at 8.) 20 Plaintiff also alleges Twitch “victimizes [its] users who almost all suffer from ICD-11 Addictive 21 Behaviors: Gaming Disorder” “by enticing . . . users to watch endless hours of streams, donate 22 money to their favorite streamers, and subscribe to channels that promise perks and benefits” 23 when the promised perks and benefits constitute false advertising. (Id. at 8-11.) 24 As it pertains to Plaintiff specifically, the complaint alleges he “signed up to follow 25 Twitch’s top female broadcaster . . . with a subscription agreement including ‘everlasting love and 26 appreciation’” but “did not receive these promised perks.” (Id. at 15.) Plaintiff was “unlawfully 27 detained in Tewksbury Hospital . . . from 2020 to 2021 due to the misdiagnoses influenced by 1 linked to Twitch.” (Id.) In 2023, he reached out to Ms. Briasco-Stewart, at the time a Twitch 2 employee, about the harassment and cyberattacks. (Id. at 14-15.) “Although Defendant Briasco- 3 Stewart confirmed receipt of the communication, there was no subsequent action taken to halt the 4 harassment.” (Id.) In July 2024, Ms. Briasco-Stewart sought a civil restraining order against 5 Plaintiff. (Id. at 21; Dkt. 8-1.) 6 In August 2024, Plaintiff sued Twitch and Ms. Briasco-Stewart. Plaintiff seeks 7 compensatory damages for Twitch’s negligence in responding to the harassment, “compensatory 8 (punitive) damages . . . for the distress and pain caused by the far-reaching actions of the 9 Defendants,” and “[a]n injunction requiring Twitch to stop engaging in unfair competition, 10 deceptive advertising, and false representation of its services.” (Dkt. No. 1-1 at 23-24.) 11 B. Legal Standard 12 Under Federal Rule of Civil Procedure 8(a)(2) a party is only required to make “a short and 13 plain statement of the claim showing that the pleader is entitled to relief, in order to give the 14 defendant fair notice of what the claim is and the grounds upon which it rests.” Bell Atl. Corp. v. 15 Twombly, 550 U.S. 544, 555 (2007) (internal citations and quotations omitted). For purposes of 16 ruling on a Rule 12(b)(6) motion, the court “accept[s] factual allegations in the complaint as true 17 and construe[s] the pleadings in the light most favorable to the non-moving party.” Manzarek v. 18 St. Paul Fire & Marine Ins. Co., 519 F.3d 1025, 1031 (9th Cir. 2008). However, even under the 19 liberal pleading standard of Federal Rule of Civil Procedure 8(a)(2), “a plaintiff’s obligation to 20 provide the grounds of his entitlement to relief requires more than labels and conclusions, and a 21 formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555 22 (internal citations and quotations omitted). “Determining whether a complaint states a plausible 23 claim for relief . . . [is] a context-specific task that requires the reviewing court to draw on its 24 judicial experience and common sense.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). 25 C. Request for Judicial Notice 26 Defendants request the Court take judicial notice of matters in the civil harassment 27 restraining order proceedings initiated by Ms. Briasco-Stewart against Plaintiff, including the 1 declaration, and the order issued by the San Francisco Superior Court. (Dkt. No. 8-1 at 2.) Under 2 Federal Rule of Evidence 201, “[t]he court may judicially notice a fact that is not subject to 3 reasonable dispute because it: (1) is generally known within the trial court’s territorial jurisdiction; 4 or (2) can be accurately and readily determined from sources whose accuracy cannot reasonably 5 be questioned.” A court “may take notice of proceedings in other court.” Bennett v. Medtronic, 6 Inc., 285 F.3d 801, 803 n.2 (9th Cir. 2002). So, Defendants’ request is GRANTED. The Court 7 takes judicial notice of Exhibits A through C in Docket No. 8-1 “for the fact that the documents 8 exist and were filed” but “not for the truth of the facts recited therein.” See Su v. United States 9 Postal Serv., 730 F. Supp. 3d 1120, 1127 (D. Or. 2024).

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Bell Atlantic Corp. v. Twombly
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Ashcroft v. Iqbal
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Bennett v. Medtronic, Inc.
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Manzarek v. St. Paul Fire & Marine Insurance
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Bluebook (online)
Shang v. Twitch Interactive, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/shang-v-twitch-interactive-inc-cand-2025.