Jane Doe No. 1 v. Uber Technologies, Inc.

FACTS AND PROCEEDINGS BELOW

In reviewing a judgment of dismissal after a demurrer, “we must assume the truth of all facts properly pleaded by the plaintiffs, as well as those that are judicially noticeable.” (Howard Jarvis Taxpayers Assn. v. City of La Habra (2001) 25 Cal.4th 809, 814.) The operative complaint and select information of which we take judicial notice1 provide the following factual background.

1 The Jane Does moved this court to take judicial notice of various documents filed in Doe v. Uber Technologies, Inc. (N.D.Cal. May 1, 2020, No. 19-CV-03310-JSC) 2020 WL 2097599, a federal lawsuit against the Uber entities alleging facts very similar to those alleged here (the federal Uber action). The plaintiff in the federal Uber action, a woman sexually assaulted by a criminal posing as an Uber driver, alleged California law negligence claims against the Uber entities, claiming, as do the Jane Does here, that Uber’s business model created the risk of the fake Uber scheme

3 A. The Uber Business Model The Uber entities operate a technology company that connects individuals looking for transportation with authorized drivers. Users request a ride through the Uber app on…