Coinlab v. Mt. Gox

COMPLAINT- 2

LAW OFFICES

BRESKIN JOHNSON & TOWNSEND

PLLC

1111 THIRD AVENUE, SUITE 2230SEATTLE, WASHINGTON 98104-4088(206) 652-8660, (206) 652-8290 FAX

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CoinLab to provide digital currency exchange services to North American customers. CoinLaboffered its credibility, market insights, relationships with established banks and investors, and intellectual property and agreed to manage and market the exchange services in North America.2.

Mt. Gox has willfully failed to perform its obligations under this contract. Mt.Gox has continued to market to customers in North America and has accepted business fromcustomers there. Mt. Gox has also failed to provide CoinLab with account reconciliation data,server access, and other information promised in the agreement that is essential for CoinLab tomarket exchange services and service its customers as contemplated in the agreement. These breaches have caused CoinLab to lose customers and threaten to cause substantial damage toCoinLab’s business. As a result, CoinLab brings this action for breach of contract and related claims.

II.

JURISDICTION AND VENUE

3.

Jurisdiction is proper in this Court under 28 U.S.C. § 1332. Plaintiff CoinLab is aresident of Delaware and Washington State. Defendants Mt. Gox and Tibanne are residents of Japan. This is an action for damages in excess of $75,000,000.00 excluding interest, attorneys’fees and costs.4.

CoinLab is a Delaware corporation with its principal place of business in KingCounty Washington.5.

On information and belief, Mt. Gox and Tibanne (collectively “Defendants”) arecorporations organized under the laws of Japan with their principal places of business in Tokyo,Japan.6.

On or about November 22, 2012, Defendants and CoinLab entered into a fullyintegrated “Exclusive License Agreement for the USA & Canada agreement” (the “Agreement”).

Case 2:13-cv-00777 Document 1 Filed 05/02/13 Page 2 of 12