Unlockd Media, Inc. Liquidation Trust v. Google LLC

I. BACKGROUND

19 Plaintiff, Unlockd Media, Inc. Liquidation Trust (“Plaintiff” or “Unlockd”), is a New York 20 trust established under an August 2021 trust agreement between the bankruptcy estates of Unlockd 21 Media, Inc. and Unlockd Operations U.S., Inc. Compl. ¶ 12. Unlockd alleges that its smartphone 22 application allowed users to “receive full-screen mobile ads or content upon unlocking their 23 Android smartphones, and in exchange, they received virtual ‘points’ that they could redeem for 24 rewards such as mobile credit, subsidized streaming services, additional loyalty points, or in-app 25 26 1 The trust is authorized by the United States Bankruptcy Court for the Southern District of New 27 York’s Order Confirming the Fourth Amended Small Business Debtors’ Combined Plan of benefits like extra lives in mobile games.” Compl. ¶ 4, 51-56. Unlockd was a customer and competitor of Google in the digital advertising market. Compl. ¶ 7. Beginning in 2015, Unlockd operated on the Google Play Store, the store for Android app distribution. Compl. ¶¶ 6, 60, 63. In 2016, Unlockd started to utilize Google AdMob, a mobile advertising network that…