All the participants received this notification on their mobile in the F8 app of Facebook. The news was first reported by TechCrunch. Here is what the notification looked like:

It can be speculated that the ambitious CEO of Facebook, Mark Zuckerberg might have to add to a list of his unparalleled achievements by launching app that could be a game-changer in virtual reality. Facebook teleportation app can turn things around in the internet of things and wearable tech. It is also reported that Facebook teleportation station is on the F8 conference agenda and will be discussed later on.

]]> https://socialmediaseo.net/2015/03/25/leaked-facebook-working-on-teleportation-app/feed/ 0 https://socialmediaseo.net/2014/03/20/the-top-5-most-charitable-ceos/#utm_source=rss&utm_medium=rss&utm_campaign=the-top-5-most-charitable-ceos https://socialmediaseo.net/2014/03/20/the-top-5-most-charitable-ceos/#respond Thu, 20 Mar 2014 15:20:04 +0000 http://preview.socialmediaseo.net/?p=31634 When asked about his profits, Bill Gates famously said, “I can understand wanting to have a million dollars… but once you get beyond that, I have to tell you, it’s the same hamburger.” This is an attitude that has been directly reflected in Gates’s philanthropic efforts, and in the efforts of charitable CEOs across the spectrum. If you’re wondering who belongs to this brotherhood of magnanimous elite, check out these five corporate owners, each of whom brings their own style to local and national philanthropy.

Bill Gates: Microsoft

Image via Flickr by DFID

The Bill and Melinda Gates Foundation is one of the most prominent examples of educational charity efforts in the United States. By 2010, head of Microsoft Bill Gates had donated over half of his net worth to education, research, and a variety of other philanthropic efforts. Between his private foundation and individual donations, Gates has given over $36.85 billion to causes as diverse as downtown parks and arts, the United Nations, transnational organizations, and the International AIDS Vaccine Initiative.

Mark Zuckerberg: Facebook

Image via Flickr by TechCrunch

The Facebook CEO may present a self-interested face to his stakeholders, owning 28% of Facebook shares and not hesitating to remind anybody who questions his decisions that he’s the primary stakeholder. Zuckerberg and his wife, Chan, have their own ideas about how to use their wealth, however, giving 18 million shares (valued at $990 million) via the Silicon Valley Community Foundation in 2013. The value of Facebook shares have nearly doubled since his first such donation in 2012, and Zuckerberg now sets the example for young entrepreneurs in Silicon Valley.

Daniel Stanton: Stanton Optical

Image via Flickr by NIAID

CEOs such as Daniel Stanton at Stanton Optical are increasingly reaching out to their immediate communities to foster development and progress. The optical store donates to local and national charities from its primary office in Palm Springs, Florida, as well as several other locations throughout the United States. Stanton Optical has received The Sphere of Influence Award for community outreach efforts like Epilepsy Society benefits, toy drives, National Down Syndrome Society charitable functions, and philanthropic efforts for the Leukemia and Lymphoma Society.

Tim Cook: Apple

Image via Flickr by igrec

The new Apple CEO Tim Cook has donated $100 million to charities since taking over from the late Steve Jobs. Cook gave considerable amounts to Stanford’s hospitals along with disease-fighting organization Product RED, and encourages employee participation by promising to match employee donations up to $10,000 each year. Cook has been outspoken about Apple’s new philanthropic direction and will likely continue to donate in the years to come.

Muriel Siebert: Muriel Siebert & Co, Inc.

Image via Flickr by david.nikonvscanon

Called “the first woman of finance,” the late Muriel Siebert was widely considered a trailblazer for future women CEOs. The stockbroker established the Seibert Entrepreneurial Philanthropic Plan to give half of her profits from municipal bond underwriting to support and encourage women’s organizations. Over $5 million has gone to various charities through this plan as of 2006.

Amidst media and public outrage over questionable business practices, the outreach efforts of some of the nation’s leading CEOs are often overlooked. It is important to look to the positive examples and continue acting as a source of progress in the community.

Yann LeCun, a professor of computer and neural sciences from the New York University claimed about this new development in Facebook and surprisingly Google+ too!  According to Mr. LeCun, collaboration has been setup between the popular social networking website and the NYU’s center for data science. The function of this joint venture is to carry out cutting edge research in AI, media sciences and machine learning. Mark Zuckerberg has given the go ahead for this inauguration of this project on Dec 9, sounds too good to be true eh?

The new task group will have locations in Menlo Park, CA in London, UK and the Facebook’s new facility in New York itself. This event may seem to be a response to Google’s own venture into the AI field with the popular search engine also stepping up its efforts in the AI business. They have already convinced top AI research scientist Ray Kurzveil to head its AI and deep learning efforts. So it is time that the mighty Facebook responds right? With the opening of its own AI research organization, Facebook has flexed its muscles in the field. Many believe that these advancements in AI might lead to an “arms race” in the global tech companies to have sole control over the growing AI demands of more complex markets and users.

This, however isn’t Facebook’s first venture into the AI field as the group was actually formed according to the comments made by Mark Zuckerberg during recent earning’s call of Facebook. The main focus will be to research and study the approaches to the AI and apply them to understand the whole lot of content that people share so new insights into the human preferences, likes and dislikes can be found out which actually is what social networking is all about. Cool right?

Instagram team is all fired up to launch the private messaging feature to its users as the holiday seasons has started and Instagram meters record highest number of hits these days because of intense photo sharing activity. Pinned together with this hot season, a new, perked up and interesting private messaging service must attract Instagram fans around the globe which haven’t experienced much revamps and improvements lately.

Another famous tech blog TechCrunch also reported that a plethora of Instagram power users(including TechCrunch) were given private and “personal Instagram.com email addresses” in order to start a testing frenzy. Private messaging service will most likely enable the users to share the photos with specific number of users, individuals through inbox messaging and also to chat group environments which was not possible before.

Instagram officially didn’t add anything to this but this news certainly can’t be graded in the category of rumors because of its much credible source and substantial context. Facebook already offered is user’s to have Facebok.com email addresses and it seems the company is trying to elevate the grasp on the users spread across the globe. These steps will enable the social media giant to not only offer its users what they want, it will also help them build user interaction and social connection.

@instagram.com email address allocation to power users were taken as a figment of the upcoming instant messaging feature activity. iMessaging by Apple, Facebook instant messaging and many other messaging services have really proved the important and value of instant messaging for the masses and Instagram’s instant messaging will certainly bring benefits to thousands of users.

Apparently deeply frustrated by this brush off from the Facebook team, Khalil used the glitch to bring home the point pointedly, by hacking into Zuckerberg’s Facebook profile page. He also apparently send a post to Zuckerberg (deleted immediately), apologizing for breaking into the privacy of his FB account.

The Facebook team swung into action by suspending Khalil’s account, alarmed that Mark Zuckerberg’s Facebook Page has been hacked. Facebook’s security engineer sent a mail to Khalil requesting him to provide details of his exploit. After receiving the details from Khalil, the security engineer mailed that the details provided were not enough to reproduce an issue, and thus effectively denied Khalil the credit for bringing this glitch to the notice of Facebook.

Facebook has a proven policy of paying money to any hacker who finds security flaws in the social network. The minimum bounty amounts to $500. But the company denied Khalil the money on the ground that Khalil had violated Facebook’s Terms of Service, through his actions.

Facebook’s security team have claimed to have fixed the bug, while admitting that the company should have asked Khalil for more details when he had first reported the glitch, instead of brushing him off.

Facebook has claimed to have paid over $1 million to hundreds of reporters who have brought glitches to the notice of the company. The company admits that most of the genuine glitches are reported by people who are not comfortable with English, but at the same time the company claimed to have received hundreds of reports which were nonsense or misguided, and thus Khalil’s report, could have been an error creeping into the system of scanning reports. This brings down the curtain on the sensational breaking news that a security expert hacks Mark Zuckerberg\s Facebook Page

There’s a new lawsuit which is stating that Mark Zuckerberg made a quick billion off of inside information.  The class action lawsuit claims the 28-year-old CEO had inside info that the stock was grossly overvalued, and he protected his own financial hide by quickly unloading a ton of Facebook stock.  This Class action lawsuit was filed by angered Facebook shareholders after the collapse of the stock. The lawsuit is stating that he hid the fact that there is a known flaw int he Facebook business model and that there is not enough advertising revenue to support stock valued at $38 a share.  The stock is at $26 today after the big drop, but seems to be slowly raising.  Who knows what will happen next with the Facebook / Zuckerberg lawsuits.

Ceglia made the move in filings in federal court in Buffalo on Monday. He has had a revolving door of lawyers in the long-running dispute with Facebook. Milberg is a New York firm that built its reputation representing consumers and investors in class-action litigation. It was previously known as Milberg Weiss Bershad Hynes & Lerach before an investigation sent four former partners to prison.

Ceglia claims he signed a 2003 contract with Zuckerberg, then a student at Harvard, that entitles him to a large stake in the Menlo Park, Calif., firm, which is on the verge of an initial public offering that could value the company at $100 billion or more. Facebook says the partnership agreement was doctored.

Ceglia has retained multiple attorneys in his quest to win a legal judgment against Facebook.

“We took a good hard look at all of the information available, including evidence in Ceglia’s favor, and we believe he deserves to have his day in court,” Milberg attorney Sanford Dumain said in the statement.

He added, “We look forward to examining records from computers that Mr. Zuckerberg used when he was a freshman at Harvard and other records that will help answer questions about the ownership of Facebook.”

Attorneys for Facebook, which won a motion for expedited discovery last summer, won the right last week to inspect the contents of Google Inc. (GOOG) email accounts owned by Ceglia including getzuck@gmail.com, according to court filings. The email address is a reference to Zuckerberg’s nickname, Zuck.

The video below is of a young, 21 year old kid who at the very forefront of something that the world has never before witnessed.  This interview of Mark Zuckerberg from June 2005 was posted by HuffPost and is part of a longer 40 minute interview about Facebook.

In the interview, its interesting and amazing to hear Mark Zuckerberg talk about how he’s unsure as to where the company will go from here.  How he sees Facebook remaining a focused social network for colleges, and how he’s really just trying to build something cool for college students.

So here you go, a rare interview of Mark Zuckerberg right before Facebook was about to acquire nearly 2 million new visitors in one month:

Here’s a funny parody where Mark Zuckerberg is hanging out in a bar when suddenly he meets Tom from MySpace.  The discussion continues until finally Tom from MySpace laughs at Zuckerberg because “Facebook is the new MySpace!”

Ultimately, the point here is that many believe Google+ can easily top Facebook as the most popular social network on the web.  Although I don’t quite believe that to be true, the video is kind of funny – check it out:

Wow, the Winklevoss twins just refuse to stop hammering Mark Zuckerberg and Facebook.

Just a day after dropping the suit that would have gone to the Supreme Court, the Winklevii have opened another law suit against Zuckerberg and Facebook.

Filed with the U.S. District Court of Massachusetts, the Winklevoss twins along with business partner Divya Narendra, said they would they would move the court for discovery on whether Facebook “intentionally or inadvertently suppressed evidence” during settlement proceedings over claims that Zuckerberg stole their idea for a college social networking website.

I’m now convinced that no matter what, Mark Zuckerberg will always have people trying to get their hands on a piece of the social network that is becoming synonymous with the web…. that being Facebook.

via HuffPost

The Winklevoss twin’s battle with Facebook (Mark Zuckerberg) appears to be finally coming to close.

A recent filing by Cameron and Tyler Winklevoss, and Divya Narendra, shows that “appellants do not intend to seek further appellate review.”

This coming after a federal appeals court ruled against the Winklevoss twins when they tried to get more money from the Facebook settlement they won back in 2008.

The twins felt they were entitled to more money in the light of the current valuation of Facebook.

If the Winklevoss twins did pursue an appeal, the case would have to be heard by the Supreme Court.

WESTERN DISTRICT OF NEW YORK

– – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – X

PAUL D. CEGLIA, an individual,

Plaintiff,

-against-

MARK ELLIOTT ZUCKERBERG,

an individual, and FACEBOOK, INC., formerly known as TheFaceBook, Inc.,

a Delawarecorporation,Defendants.::::::

:CIVIL ACTION NO. 10-569(RJA) FIRST AMENDED COMPLAINT TRIAL BY JURY DEMANDED- – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – X

Plaintiff PAUL D. CEGLIA (“Ceglia”) alleges:

NATURE OF THE ACTION

1.

On April 28, 2003, Mark Elliott Zuckerberg (“Zuckerberg”) entered a writtencontract (the “Agreement”) with Ceglia “for the continued development of the software, programand for the purchase and design of a suitable website for the project Seller [Zuckerberg] hasalready initiated that is designed to offer the students of Harvard university (sic) access to awesite (sic) similar to a live functioning yearbook with the working title of ‘The Face Book.’”

The Agreement further provides that: “It is agreed that Purchaser [Ceglia] will own a halfinterest (50%) in the software, programming language and business interests derived from theexpansion of that service to a larger audience.”

2.

As a matter of law, the Agreement established a general partnership betweenCeglia and Zuckerberg for the development and commercialization of “The Face Book,” theconcept and website with the initial title of “thefacebook.com” and the business interests derivedtherefrom (the “General Partnership”).

As described in the Agreement, Ceglia contributed-2-capital to the General Partnership. And, according to the Agreement, Zuckerberg contributed thesoftware, programming language and website in its then-current form that he had started todesign to offer the students of Harvard University access to a website similar to a livefunctioning yearbook with the working title “The Face Book.”

The course of conduct betweenCeglia and Zuckerberg, after the formation of the General Partnership, shows Ceglia alsocontributed his time, ideas, knowhow and other “sweat equity” to the General Partnership. Asdescribed in the Agreement and the course of conduct after the formation of the GeneralPartnership, Zuckerberg also contributed his time, ideas, knowhow and other “sweat equity” tothe General Partnership.

Their respective contributions resulted in the creation of software,programming language, a website, other intellectual property and business interests, all of whichbecame property of the General Partnership — of which the parties intended and the Agreementspecified that Ceglia is the 50% owner.

3.

As of February 2, 2004, Zuckerberg had not completed “The Face Book” website.

On that same day — February 2, 2004 — Zuckerberg sent to Ceglia emails complaining that aprovision in the Agreement giving Ceglia an additional 1% interest in the business for each dayafter January 1, 2004 that “The Face Book” website was not complete, was unfair because itwould give Ceglia over 80% ownership of the business, including thefacebook.com website.

OnFebruary 3, 2004, Ceglia agreed to waive the provisions in the Agreement that increased hisownership interest in the General Partnership to over 80%. Perhaps not coincidentally, the verynext day, on February 4, 2004, Zuckerberg informed Ceglia by email that the “thefacebook.com”website had launched.

4.

After the website launched, the website was an immediate success.

Zuckerbergthen embarked upon a secret scheme to misappropriate the General Partnership’s assets and-3-opportunities for himself. Zuckerberg did this by concealing the website’s success from Cegliaand misrepresenting to Ceglia that Harvard students were not interested in the website, that hewas losing interest in the venture and was considering abandoning it.

Zuckerberg thenmisappropriated the General Partnership’s

(1) opportunity to expand the website and the FaceBook project beyond Harvard University students and

(2) assets, and contributed them to acorporation formed in July 2004, but never informed Ceglia or accounted for them to the GeneralPartnership or Ceglia.

The corporation is now known as Facebook, Inc. Whatever interestZuckerberg received from contributing the assets of the General Partnership to the corporation— including, but, not limited to, cash, stock, stock options, restricted stock units or any otherconsideration received by or promised to Zuckerberg — was and is property of the GeneralPartnership. Ceglia brings this action to recover, among other things, his 50% share of theinterest acquired by General Partnership as a result of Zuckerberg’s actions.PARTIES

5.

Plaintiff Ceglia is a resident of Wellsville, New York with an address of 2558Hanover Hill Road, Wellsville, New York.

6.

Defendant Zuckerberg currently resides in California.

7.

Defendant Facebook, Inc. is a corporation organized under the laws of the State ofDelaware and maintains its principal place of business in Palo Alto, California. Facebook, Inc.was incorporated on July 29, 2004, under the name of TheFaceBook, Inc. On September 30,2005, it changed its name to Facebook, Inc.JURISDICTION AND VENUE

8.

On July 9, 2010, this matter was removed to this Court by Defendants on theground of complete diversity under 28 U.S.C. § 1332. Complete diversity jurisdiction exists-4-under 28 U.S.C. § 1332 as this action is between citizens of different states and the amount incontroversy exceeds $75,000, exclusive of interest and cost.

9.

This Court has supplemental jurisdiction over the Plaintiff’s causes of actionarising under New York State statutory and common law pursuant to 28 U.S.C. § 1367(a).

10.

This Court has personal jurisdiction over the Defendant Facebook, Inc. becausethis Defendant is authorized by the New York Department of State to do and does business inthis State.

11.

This Court has personal jurisdiction over Defendant Zuckerberg as he hascommitted tortious acts within the State of New York and/or tortious acts outside the State ofNew York which impact a New York resident.

This Court also has personal jurisdiction overDefendant Zuckerberg as he is engaged in substantial activity within this State and because hemaintains an interactive website that is directed towards this State’s persons and entities.Defendant is doing business and has done business in this State and District by offering for usehis products and services.

12.

Venue is proper in this Court pursuant to 28 U.S.C. § 1391(a)(3) because asubstantial part of the events or omissions giving rise to the claims occurred in this District.FACTS COMMON TO ALL CLAIMS FOR RELIEF

13.

In 2002 and 2003, Ceglia was developing an on-line database that would be, andwas, deployed through a website known as StreetFax.com.

StreetFax.com compiled into adatabase photographs and other information related to traffic intersections that were intended toallow insurance adjusters to easily obtain such information to assist them in handling claims.-5-

14.

From time-to-time, Ceglia hired programmers, web developers and otherindividuals to assist him with developing StreetFax.com. He frequently located such individualsthrough on-line, help wanted advertisements on craigslist.com.

15.

In 2003, Ceglia posted advertisements seeking programmers who would be ableto develop the search engine feature for StreetFax.com that would provide non-specific name searching, synonymous term linking and the ability to comment on specific photographs. Those features, along with others, would allow someone with an account to search for and find thename and location of a specific intersection, and offering the top closest results if an exact matchcould not be found.

This allowed a user to find the right name even if the user misspelled thatname or used an abbreviation that did not match what was entered into the database.

16.

In early 2003, Zuckerberg responded to Ceglia’s craigslist.com advertisement.

17.

Upon learning Ceglia’s requirements, and after several lengthy conversationsabout the possibility and strategy of creating a search engine that could find a specific name aslong as the spelling was “close,” in a telephone conversation in April 2003, Zuckerberg toldCeglia that he was working on a great project.

Zuckerberg told Ceglia if Ceglia hired him towork on the StreetFax.com project and helped fund the development of his other project,Zuckerberg would give Ceglia a one-half interest in Zuckerberg’s other project.

18.

Zuckerberg explained to Ceglia that the other project would involve an on-line,interactive yearbook, which initially would be targeted at students attending Harvard University,where Zuckerberg was also a student.

Zuckerberg told Ceglia that this project was inspired bythe on-line year book used at the boarding school that he attended. Zuckerberg further explainedto Ceglia that the project could be expanded beyond Harvard University.

Zuckerberg told Cegliathat the project’s working title was “The Face Book.”-6-

19.

Ceglia accepted Zuckerberg’s offer and agreed to pay Zuckerberg $1,000 for hiswork on StreetFax.com and $1,000 for work to be performed to continue to develop “The FaceBook.”

20.

Ceglia and Zuckerberg agreed to meet at the Radisson Hotel in Boston,Massachusetts, on April 28, 2003 to sign a written contract.

21.

From his home office in Wellsville, New York, on April 25, 2003, Ceglia prepared the agreement on his computer, combining two different forms of agreements that weregiven to him in the past and modifying them to capture the terms that Zuckerberg and Cegliaagreed to over the telephone.

The agreement covered both the work Zuckerberg agreed to do forStreetFax.com and their agreement concerning The Face Book.

Ceglia printed and saved theagreement on April 25, 2003.

22.

On April 28, 2003, Ceglia, accompanied by Karin Petersen, met Zuckerberg in thelobby of the Radisson Hotel in Boston.

Ceglia provided the agreement to Zuckerberg, who spenta significant amount of time reviewing the agreement. Zuckerberg asked for one change on thefirst page of the agreement, which was handwritten on to the first page of the document andinitialed by Zuckerberg and Ceglia.

Zuckerberg and Ceglia then signed the Agreement, which isattached hereto as Exhibit A. Except for the handwritten interlineations made on April 28, 2003,Ceglia made no changes to the agreement after printing it on April 25, 2003.

23.

The Agreement provides in pertinent part that:

[I]t is for the continued development of the software, program andfor the purchase and design of a suitable website for the project Seller has already initiated that is designed to offer the students ofHarvard university (sic) access to a wesite (sic) similar to a livefunctioning yearbook with the working title of “The Face Book”It is agreed that Purchaser will own a half interest (50%) in thesoftware, programming language and business interests derivedfrom the expansion of that service to a larger audience.-7-

24.

The Agreement defines “Seller” as “Mark Zuckerberg, his agents, employees,suppliers, or sub-contractors, furnishing materials equipment, or services.” The Agreementdefines “Purchaser” as “Paul Ceglia.”

25.

The Agreement further provides that:The Agreed upon Cost that the Seller and the Buyer (sic) haveagreed upon are as follows: Buyer (sic) agrees to pay the seller(sic) the Sum of $1000 a piece for the work to be performed forStreetfax and $1,000 for the work to be performed for ”The PageBook” (sic).

26.

During their conversations before the execution of the Agreement and thereafter,Ceglia and Zuckerberg discussed using the name “The Face Book” and “The Page Book” fortheir venture and, thus, the terms were synonymous.

Indeed, when viewed in the context of theAgreement (along with the other typographical errors, misspellings and failures to consistentlyuse defined terms found in the Agreement), in this provision, the Agreement’s reference to “ThePage Book” clearly is to the same “The Face Book” venture, which is referenced in other parts ofthe Agreement.

27.

The Agreement provides immediately below the interlineations on the first pageof the agreement and adjacent to Zuckerberg’s initials:The agreed upon completion for the expanded project withworking title ”The Face Book” shall be Janruary (sic) 1 (sic) 2004and an additional 1% interest in the business will be due the buyerfor each day the website is delayed from that date.

28.

The Agreement provides continued performance as follows:For “The Face Book” Seller agrees to maintain and act as the sites(sic) webmaster and to pay for all domain and hosting expensesfrom the funds received under this contract, and Seller agrees thathe will maintain control of these services at all times.-8-

29.

Ceglia paid Zuckerberg the $1000 called for in the Agreement for the continueddevelopment of The Face Book. Ceglia also paid Zuckerberg for the work on StreetFax.com,some of which was used for The Face Book.

30.

As a matter of law, the Agreement created a general partnership (defined above asthe “General Partnership”) between Zuckerberg and Ceglia. Zuckerberg’s and Ceglia’scontributions to the General Partnership became, and would become, property of the GeneralPartnership.

The fruits of those contributions — such as the creation of the software, program,the purchase and design of a suitable website and business interests derived from the expansionof that service or website to a larger audience — also became property of the GeneralPartnership.

Further, as a result of the formation of the General Partnership, Zuckerberg andCeglia owed each other fiduciary duties of, among other things, candor, loyalty and good faith.

31.

After Zuckerberg and Ceglia signed the Agreement, they began to communicatewith each other concerning both the StreetFax.com project and The Face Book project.

Those communications occurred over the telephone and through the use of emails. In particular, Zuckerberg and Ceglia communicated with each other concerning the design and functionality of The Face Book website, various ways that they could generate income from The Face Bookwebsite, various ways they could expand The Face Book to a larger audience beyond HarvardUniversity, and technical and other challenges in developing The Face Book website.

32.

On July 30, 2003, Zuckerberg sent an email to Ceglia informing Ceglia that:. . .

I’ve been tweaking the search engine today [referring to theStreetFax.com project] and I’m pleased with its results. I’d like touse it for the Harvard site [referring to The Face Book], I think itwill really help people find each other, even if they spell namesincorrectly.

Would it be agreeable with you if I adapt the sourcecode? Thanks!

33.

On September 2, 2003, Zuckerberg sent an email to Ceglia explaining that:-9-I have been away for a few days without internet, during that time Irevised the business plan for the Harvard site.

I would like to talkto you on the phone about it in detail. As you mentioned last week,the issue we must resolve is how to produce a revenue stream fromthe users.

My conclusion this past week is to charge Alumni$29.95 a month. With this in mind, considering just 300 people,and the projection of a $9000 monthly revenue, we could, as yousuggested, rapidly expand to other colleges.

Further, since the planinvolves more than one college, the name can’t have Harvard in itand remains unresolved. Additionally, both original names>facebook.com and pagebook.com are unavailable, so there is noactual domain name either. thefacebook.com and thepagebook.comare both available but are clearly not a premium quality domain asthey are much harder to remember.

34.

On September 2, 2003, Ceglia responded to Zuckerberg:I like your thinking about funding expansion, I’m not sure amonthly fee is the way to go though, we are having a hard timegetting adjusters to pay it and it’s their business.

I’d be concernedthat we wouldnt (sic) get enough people on there to keep anyoneinterested. Maybe we could make it free until it was popular andthen start charging? I wouldn’t worry too much about a name ifthey are both already gone, are any of them due to expire?

It tookus ages to find Streetfax.com and the minute I did I just knew thatis what I was waiting for. Let’s talk about it on the phone, call metonight if you get this in time.

I suggest we look into a licencing(sic) agreement with Harvard (sic), I had one once with SyracuseUniversity and it was pretty easy, then we could have a store on thesite and sell sweatshirts, mugs, t shirsts (sic) and stuff to alumniand have some money coming in right away.

35.

Ceglia provided Zuckerberg an additional $1000 in November 2003.

36.

On November 22, 2003, Zuckerberg sent Ceglia an email that read in the subjectline, “Urgent! Let’s Talk.”

The email informed Ceglia that:

I have recently met with a couple of upperclassmen here atHarvard that are planning to launch a site very similar to ours. Ifwe don’t make a move soon, I think we will lose the advantage wewould have if we release before them.

I’ve stalled them for thetime being and with a break if you could send another $1000 forthe facebook (sic) project it would allow me to pay my roommateor Jeff to help integrate the search code and get the site live beforethem. Please give me a call so that we can talk more about this.-10-

37.

Communications between Zuckerberg and Ceglia concerning their developmentof The Face Book and the website planned by the Harvard upperclassmen described inZuckerberg’s November 22, 2003 email continued through the balance of 2003.

38.

On January 1, 2004, the date on which the The Face Book website was due to belaunched, Zuckerberg sent an email to Ceglia informing him that:I just wanted to extend to you a Happy New Year and tell you thatall individual parts for the back end of the site have been completed.

The extra $1000 really helped get us further ahead andif there is any way you can send some additional funding I believewe will be online in a few weeks.

I think it is unnecessary at thispoint, with all of the extra work I have done for you, to hold me tothe original completion date.

I should not be penalized for delaysthat were out of my control, namely that there have been so manyunspecified requests from the Streetfax project that you wanted tobe placed as a priority, thereby delaying my start on our secondproject.

Thus, I am requesting a written waiver on your partexempting me from the obligation to give you additionalownership in the project that is outlined in our original contract.

39.

Ceglia responded on the same day with an email explaining to Zuckerberg that hecould not remember the relevant terms of the Agreement and did not have access to it.

Consequently, he could not respond to Zuckerberg’s request for a waiver.

Zuckerberg replied by email to Ceglia, informing him that he would scan the Agreement and send it to him.

40.

The same day, Ceglia then responded by email:Mark, Thanks I’ll look forward to reviewing the details, just a quick question, we seem to be having an issue with the backend that has really been causing us some grief, I know that you’re position is that you’ve (sic) done all the work in the contract andthen some, I guess I am somewhat torn as on one hand in your interest you want me to consider not enforcing my contract while also then making it clear that more money is owed to you for things that weren’t a part of yours, does that make sense to you? It doesnt (sic) to me ..

I am wondering if you see where I am coming from here? You can’t have it both ways Mark

41.

Zuckerberg replied: “I’ll just get this site online as quickly as I can …”-11-

42.

On January 5, 2004, Ceglia sent an email to Zuckerberg, asking him when TheFace Book website would be launched:

It is well past January 1st and to my knowledge you don’t have asingle thing done for the site, (sic) I gave you an extra $lk inNovember so we could rush it ahead of these other guys and as faras I know you don’t even have a domain name or a home pagebuilt, let alone the actual database.

For now I suggest you use mysearch engine and we work out the details. I’m starting to thinkyou just blew that money Mark. You know perfectly well that youcan’t just take a persons (sic) investment and then spend it onwomen and beer or whatever you do up there in Harvard. I’ve beenstalled long enough on this thing and if I don’t see something soon(sic) I’ll have no choice but to contact the school and perhaps yourparents in Dobbs Ferry and let them know whats (sic) been goingon.

43.

Zuckerberg responded on January 6, 2004:Threats to call my parents are uncalled for and unprofessional andyou would be seriously violating our trust by doing so, I have donewhat I can with the small amount of money you have invested andI will have something live for you to view soon.

Again I want tostate that under no circumstances do you have my permission tocontact my parents as they have nothing to do with my businessand just because I am young doesnt (sic) mean I’m afraid of myparents (sic) response. Please do not contact them about this issue,they would probably just laugh you off anyway.

44.

On January 13, 2004 and January 16, 2004, Ceglia and Zuckerberg exchangedemails concerning the functionality of The Face Book’s website and whether they should adaptthe search engine built for StreetFax.com to it.

45.

Recognizing that the delay in launching The Face Book website had the potentialto seriously dilute his interest in the venture, Zuckerberg sent an email to Ceglia on February 2,2004, that read:

Paul, I have a rather serious issue to discuss with you, according toour contract I owe you over 30% more of the business in late penalties which would give you over 80% of the company.

First I want to say that I think that is completely unfair because I did so much extra work for you on your site that caused those delays in-12-the first place and second I don’t even think it is legal to charge such a huge penalty.

Mostly though I just won’t even bother putting the site live if you are going to insist on such a large percentage.

I’d like to suggest that you drop the penalty completelyand that we officially return to 50/50 ownership. [Emphasis added.]

46.

On February 3, 2004, Ceglia responded:OK fine Mark 50/50 just as long as we start making some moneyfrom this thing. I’m looking forward to hearing how it goes but Iam so busy right now with a few other projects that my time isvery thin .. Let’s get it live and open up the store.

Have you had achance to inquire about getting a merchandizing license? We reallywill need that soon so we can start bringing in some money,everyone buys t shirts and mugs, especially the parents .. theydeserve bragging rights at home with the tuition they have to pay.Also what about putting in something like a Christian corner? I’veonly been to Harvard a few times but the idea of being able to findother Christians online without having to do the un PC thing ofasking someone face to face sounds to me like it would have somereal value, if only the spiritual kind. :-) and the other thing is linksto hotlines, why couldnt (sic) we have the rape crisis hotline, thesuicide hotline, drug rehab and so on right there so when someonereally needs something they could link over to the site theywanted? Same thing for local pizza and chinese (sic) or whatever,that way it could really be a resource that a person could use.

47.

After finally learning that Ceglia would waive the provision in the Agreement fordelivering The Face Book website late, Zuckerberg then informed Ceglia on February 4, 2004that the website was live: “Paul, [¶] ‘thefacebook.com’ opened for students today, when you geta chance take a look at it. I’ll let you know how it goes.”

48.

Ceglia responded on February 4, 2004:Congrats Mark! The site looks great, Just wondering if we mightthink of another title for it without the the, but plenty of time forthat, I’ll try and think of some names, I looked for weeks to finallyfind streetfax.com and that is how I named it, backwards from theavailability, (sic) I’m sure you checked to see if just facebook.comwas available? you (sic) know another thing i’ve (sic) beenthinking of that I perfected in Streetfax is going city to city, (sic) Ifyou went city to cityh (sic) with this I think it would be far easier-13-than just trying to open it up to all ivy league (sic) schools at once,actually get on the ground in each place, we send a half dozen guysinto the city on bikes and within a few weeks we have photos ofevery intersection in the place, so the same thing could be doneonlyh (sic) putting up flyers to promote the site, just brainstormingsome ideas on how we can start making some money.

49.

On February 6, 2004, Zuckerberg then writes to Ceglia:Sorry it’s taken me a few days to respond, (sic) Now that the sites(sic) live I feel I must take creative control and I just can not riskinjuring my sites (sic) reputation by cheapening it with your ideaof selling college junk, nor do I wish to spend my time shippingout coffee mugs to rich alumni. The site is cool as it is and I don’tcare about making any money on it right now, I just want to see ifpeople will use it. If I had the rest of the money I was owed by youfor all that extra work I did I wouldn’t even need to make money atall on this site. That is money I am entitled to and is rightfullymine.

50.

Taken aback by Zuckerberg’s February 6 email, Ceglia responded on February 7,2004:

Mark, all I can think is your parents have handed you everythingyour entire life and after all this time and energy and MONEY thatyou think in your head that an Ok way to act is to just say- oh I’vechanged my mind I don’t think it’s cool to make money and thatthat should be that.

Then you have the nerve to suggest that Ishould pay you more money if I get you right, so that you dont(sic) have to try to make money on the site we’ve built?? It’s onething to say you don’t want to sell coffee mugs but I don’t see whysince the margins are excellent and with minimal effort we couldgenerate some decent revenue for us while keeping the site free tostudents.

It’s one thing to say “I’d like to discuss with you otherways we could produce revenue for the site, like advertising, wecould sell ads locally I am sure and to places that already sellalumni stuff (but we will be losing the margins) angel investors are just con men and until we have some decent revenue we aren’tgoing to get a dime from them without giving up the whole thingand anyway at this point it’s just a freaking harvard (sic) thing.

I need to be able to get on the actual site and see where we can placesome ads and we need to get some bike couriers to go aroundpromoting the site so we can get some people using it FIRST!

But we need to get some advertising on the site right away if you likethat route better so alumni are used to seeing some ads from thebeginning. Isn’t there a way to count how many people click to-14-their site from ours?

51.

On April 6, 2004, Zuckerberg wrote Ceglia an email, representing to him that heis considering abandoning The Face Book website, claiming he was too busy to work on it andthere was a lack of interest in it among students:

Paul, I have become too busy to deal with the site and no onewants to pay for it, so I am thinking of just taking the server down.My parents have a fund that I can tap into for my college expensesand I would just like to give you your two thousand dollars backand call it even on the rest of the money you owe me for the extrawork. At this point I won’t even really be able to work on thefacebook until Summer.

52.

Ceglia responded almost immediately:You’ve got some nerve talking about me owing you with theCRIMINAL stunts you’ve pulled (sic) Reasonable people go tocourt to resolve their differences they don’t go stealing thingsdude, you stole code, not once, not twice but THREE TIMES! Doyou have any idea the damage you’ve done??? Grow up, take afucking ethics class, choke yourself with that silver spoon of yours.

53.

The “CRIMINAL stunts” and other activities referred to in Ceglia’s April 6, 2004email involved Zuckerberg’s efforts to sabotage the StreetFax.com website on multiple occasionsby hacking into it and altering the code, causing it to shutdown. Zuckerberg did that becauseCeglia refused to pay Zuckerberg more than what they agreed for the work Zuckerberg had doneon the StreetFax.com website.

54.

Contrary to Zuckerberg’s representations to Ceglia, and unknown to Ceglia,thefacebook.com website was an immediate success and well received by the students atHarvard. In fact, the website was so well received that other Harvard students and otherindividuals expressed an interest in investing in the website and participating in its development.Beginning with Zuckerberg’s February 6, 2004 email to Ceglia, Zuckerberg was intentionallyattempting to sour their business relationship in order to convince Ceglia to abandon it.-15-

55.

On July 22, 2004, Zuckerberg wrote to Ceglia an email, that read:Paul,I am guessing that you don’t want to talk to me but I wanted to sayhappy birthday and that I hope to resolve our differences. I see thatwhat I did was wrong and I am really sorry that I behaved as I did.Please give me your address and I will mail you back the $2000 foryour trouble, more if it will repair our business relationship.Another summer is here and I still don’t have any time to build oursite, I understand that I promised I would, but other things havecome up and I am out in California working during break. I justdon’t want the obligation of having to answer to you for notfollowing through and I won’t be able to.Best,Mark

56.

At the time Zuckerberg wrote his July 22, 2004 email, he had received or wasabout to receive funding from angel investors and was in the process of meeting with venturecapital funds to provide additional capital. At no time did Zuckerberg inform Ceglia of thesefacts.

57.

On July 29, 2004, Zuckerberg either incorporated or participated in theincorporation of an entity under the laws of the State of Delaware now known as Facebook, Inc.Zuckerberg misappropriated the General Partnership’s (1) opportunity to expand the website andthe Face Book project beyond Harvard University students and (2) assets, and contributed themto Facebook, Inc., but never informed Ceglia or accounted for them to the General Partnership orCeglia. To the contrary, Zuckerberg misrepresented to Ceglia that he was not continuing to workon further development of The Face Book, further expanding of The Face Book to a largeraudience or commercializing The Face Book for profit. In exchange for contributing the GeneralPartnership’s assets to Facebook, Inc. and in taking the General Partnership’s opportunity forhimself, Zuckerberg received and/or was promised to later receive cash, stock, stock options,restricted stock units and/or other consideration.-16-

58.

Ceglia never accepted a repayment of investment in The Face Book project andnever relinquished his 50% interest in the General Partnership.FIRST CLAIM FOR RELIEF(Declaratory Relief Against Zuckerberg)

59.

Ceglia realleges paragraphs 1 through 58, inclusive, and by this referenceincorporates the same as though fully set forth herein.

60.

Ceglia contends that:a. The Agreement, together with the course of conduct between Zuckerbergand Ceglia after the execution of the Agreement, as matter of law, created a General Partnershipunder New York Partnership law, of which Ceglia was a 50% owner;b. Pursuant to New York Partnership Law § 10(a), “A partnership is anassociation of two or more persons to carry on as co-owners a business for profit;”c. The respective contributions of Ceglia and Zuckerberg became, and wouldbecome, property of the General Partnership; andd. The fruits of those contributions — such as the creation of the software,program, the purchase and design of a suitable website, thefacebook.com, and business interestsderived from the expansion of that service or website to a larger audience — also becameproperty of the General Partnership.

61.

Ceglia is informed and believes and thereon alleges that Zuckerberg disputes theforegoing contentions.

62.

Consequently, an actual controversy and dispute exists between Ceglia andZuckerberg concerning the formation, operation and assets of the General Partnership.

63.

All necessary parties are before the Court so that it can grant declaratory relief.-17-

64.

Therefore, Ceglia is entitled to declaratory relief under 28 U.S.C. §§ 2201 and2202.

65.

As a result of the foregoing dispute, a judicial determination of the parties’ rightsand obligations is necessary.SECOND CLAIM FOR RELIEF(Breach of Fiduciary Against Zuckerberg)

66.

Ceglia realleges paragraphs 1 through 65, inclusive, and by this referenceincorporates the same as though fully set forth herein.

67.

As alleged above, starting in approximately April 2004 through July 2004,Zuckerberg misrepresented to Ceglia that thefacebook.com was not successful, that he was toobusy to deal with the website, that he had lost interest in the website and that he was shutting thewebsite down.

68.

Ceglia relied on the foregoing misrepresentations in that after July 2004, he hadno reason to follow up on whether the website and the business interests of the GeneralPartnership was a success or failure or to determine whether Zuckerberg was continuing with theactivities of the General Partnership.

69.

On or around July 29, 2004, having lulled Ceglia into believing the GeneralPartnership would go nowhere, Zuckerberg misappropriated the opportunity of the GeneralPartnership to expand the website and The Face Book project beyond Harvard Universitystudents and the assets of the General Partnership and contributed those assets to Facebook, Inc.and took the partnership opportunity for himself. Zuckerberg also concealed his contribution ofthe General Partnership’s assets to Facebook, Inc., and the existence of Facebook, Inc., fromCeglia. Zuckerberg did so for his own personal gain.-18-

70.

In taking the actions described above, Zuckerberg breached his fiduciary duties ofcandor, loyalty and good faith.

71.

As a result of Zuckerberg’s breach of fiduciary duty, all consideration received byhim or was promised to him in exchange for the General Partnership’s assets, including, but notlimited to, cash, stock, stock options, restricted stock units and/or any other consideration, werereceived, and continue to be held, by him in constructive trust for the benefit of the GeneralPartnership and Ceglia as a 50% owner of the General Partnership.THIRD CLAIM FOR RELIEF(Constructive Fraud Against Zuckerberg)

72.

Ceglia realleges paragraphs 1 through 71, inclusive, and by this referenceincorporates the same as though fully set forth herein.

73.

As alleged above, starting in approximately April 2004 through July 2004,Zuckerberg knowingly misrepresented to Ceglia that thefacebook.com was not successful, thathe was too busy to deal with the website, that he had lost interest in the website and that he wasshutting the website down.

74.

Ceglia relied on the foregoing misrepresentations in that after July 2004, he hadno reason to follow up on whether the website and the business interests of the GeneralPartnership was a success or failure or to determine whether Zuckerberg was continuing with theactivities of the General Partnership.

75.

On or around July 29, 2004, having lulled Ceglia into believing the GeneralPartnership would go nowhere, Zuckerberg misappropriated the opportunity of the GeneralPartnership to expand the website and The Face Book project beyond Harvard Universitystudents and the assets of the General Partnership and contributed those assets to Facebook, Inc.and took the partnership opportunity for himself. Zuckerberg also knowingly concealed his-19-contribution of the General Partnership’s assets to Facebook, Inc., and the existence ofFacebook, Inc., from Ceglia despite his duty to disclose such information to Ceglia. Zuckerbergdid so for his own personal gain.

76.

Zuckerberg’s actions described above constitute constructive fraud.

77.

As a result of Zuckerberg’s constructive fraud, as a member of the GeneralPartnership, Ceglia has been deprived of his 50% interest in all consideration received byZuckerberg or promised to Zuckerberg in exchange for the General Partnership’s assets,including, but not limited to, cash, stock, stock options, restricted stock units and/or any otherconsideration.

78.

As a result of Zuckerberg’s constructive fraud, all consideration received by himor was promised to him in exchange for the General Partnership’s assets, including, but notlimited to, cash, stock, stock options, restricted stock units and/or any other consideration, werereceived, and continue to be held, by him in constructive trust for the benefit of the GeneralPartnership and Ceglia as a 50% owner of the General Partnership.

79.

As a further result of Zuckerberg’s actions, Ceglia has suffered actual damages inan amount to be determined at trial.FOURTH CLAIM FOR RELIEF(Actual Fraud Against Zuckerberg)

80.

Ceglia realleges paragraphs 1 through 79, inclusive, and by this referenceincorporates the same as though fully set forth herein.

81.

As alleged above, starting in approximately April 2004 through July 2004,Zuckerberg knowingly misrepresented to Ceglia that thefacebook.com was not successful, thathe was too busy to deal with the website, that he had lost interest in the website and that he wasshutting the website down.-20-

82.

Ceglia relied on the foregoing misrepresentations in that after July 2004, he hadno reason to follow up on whether the website and the business interests of the GeneralPartnership was a success or failure or to determine whether Zuckerberg was continuing with theactivities of the General Partnership.

83.

On or around July 29, 2004, having lulled Ceglia into believing the GeneralPartnership would go nowhere, Zuckerberg misappropriated the opportunity of the GeneralPartnership to expand the website and The Face Book project beyond Harvard Universitystudents and the assets of the General Partnership and contributed those assets to Facebook, Inc.and took the partnership opportunity for himself. Zuckerberg also knowingly concealed hiscontribution of the General Partnership’s assets to Facebook, Inc., and the existence of Facebook, Inc., from Ceglia despite his duty to disclose such information to Ceglia. Zuckerbergdid so for his own personal gain.

84.

Zuckerberg’s actions described above constitute actual fraud.

85.

As a result of Zuckerberg’s fraud, as a member of the General Partnership, Cegliahas been deprived of his 50% interest in all consideration received by Zuckerberg or promised to Zuckerberg in exchange for the General Partnership’s assets, including, but not limited to, cash,stock, stock options, restricted stock units and/or any other consideration.

86.

As a further result of Zuckerberg’s actions, Ceglia has suffered actual damages inan amount to be determined at trial.FIFTH CLAIM FOR RELIEF(Declaratory Relief Against Zuckerberg and Facebook, Inc.)

87.

Ceglia realleges paragraphs 1 through 86, inclusive, and by this referenceincorporates the same as though fully set forth herein.

88.

Ceglia contends that:-21-a. Zuckerberg misappropriated the opportunities and the assets, includingbusiness interests, of the General Partnership for himself;b. Zuckerberg contributed the misappropriated assets of the GeneralPartnership to Facebook, Inc. and took the General Partnership’s opportunity for himself;c. In exchange for the misappropriated assets of the General Partnership that Zuckerberg contributed to Facebook, Inc., Zuckerberg received and was promised to receivecash, stock, stock options, restricted stock units and/or other consideration;d. The cash, stock, stock options, restricted stock units and/or otherconsideration property received by or promised to Zuckerberg in exchange for themisappropriated assets were, and are, the property of the General Partnership; ande. By virtue of his 50% ownership interest in the General Partnership, Cegliais entitled to receive 50% of the total equity interest in Facebook, Inc. received by, and promisedto Zuckerberg, including, but not limited to, stock, stock options and restricted stock units.

89.

Ceglia is informed and believes and thereon alleges that Zuckerberg andFacebook, Inc. dispute the foregoing contentions.

90.

Consequently, an actual controversy and dispute exists between Ceglia andZuckerberg and Facebook, Inc. concerning the foregoing.

91.

All necessary parties are before the Court so that it can grant declaratory relief.

92.

Therefore, Ceglia is entitled to declaratory relief under 28 U.S.C. §§ 2201 and2202.

93.

As a result of the foregoing dispute, a judicial determination of the parties’ rightsand obligations is necessary.-22-SIXTH CLAIM FOR RELIEF(Breach of Contract Against Zuckerberg)

94.

Ceglia realleges paragraphs 1 through 93, inclusive, and by this referenceincorporates the same as though fully set forth herein.

95.

The Agreement constituted a valid contract between Ceglia and Zuckerberg.

96.

Ceglia has performed all conditions and covenants required of him under theAgreement and was not, and is not, in breach of any terms of the Agreement.

97.

Zuckerberg breached the Agreement on or about July 29, 2004, when heincorporated or participated in the incorporation of Facebook, Inc. and failed to provide Ceglia50% of the capital stock of Facebook, Inc.

98.

As a result of Zuckerberg’s breach of contract, Ceglia has suffered damages in anamount to be proven at trial.SEVENTH CLAIM FOR RELIEF(Breach of the Implied Covenant of Good Faith and Fair Dealing Against Zuckerberg)

99.

Ceglia realleges paragraphs 1 through 98, inclusive, and by this referenceincorporates the same as though fully set forth herein.

100.

The Agreement constituted a valid contract between Ceglia and Zuckerberg.

101.

Ceglia has performed all conditions and covenants required of him under theAgreement and was not, and is not, in breach of any terms of the Agreement.

102.

Zuckerberg breached the implied covenant of good faith and fair dealing arisingfrom the Agreement on or about July 29, 2004, when he incorporated or participated in theincorporation of Facebook, Inc. and failed to provide Ceglia 50% of the capital stock ofFacebook, Inc.-23-

103.

As a result of Zuckerberg’s breach of contract, Ceglia has suffered damages in anamount to be proven at trial.WHEREFORE, Plaintiff PAUL D. CEGLIA, prays for the following relief:

A. For the First Claim for Relief1. A declaration that:a. The Agreement, together with the course of conduct between Zuckerbergand Ceglia after the execution of the Agreement, as matter of law, created a general partnershipof which Ceglia was a 50% owner;

b. The respective contributions of Ceglia and Zuckerberg became, and wouldbecome, property of the General Partnership; and

c. The fruits of those contributions — such as the creation of the software,program, the purchase and design of a suitable website, thefacebook.com, and business interests derived from the expansion of that service or website to a larger audience — also became property of the General Partnership.

B.

For the Second, Third and Fourth Claims for Relief

2. An accounting of all consideration received by Zuckerberg or was promised tohim in exchange for the General Partnership’s opportunities and assets, including, but not limitedto, cash, stock, stock options, restricted stock units and/or any other consideration, and inproperty or other interests into which the foregoing has been transmuted.

3. The imposition of a constructive trust for the benefit of the General Partnershipand Ceglia as a 50% owner of the General Partnership on all consideration received by Zuckerberg or was promised to him in exchange for the General Partnership’s assets, including,-24-but not limited to, cash, stock, stock options, restricted stock units and/or any otherconsideration, and in property or other interests into which the foregoing has been transmuted.

4. Damages according to proof.5. Putative and exemplary damages.C. For the Fifth Claim for Relief6. A declaration that:

a. Zuckerberg misappropriated the opportunities and the assets, includingbusiness interests, of the General Partnership for himself;

b. Zuckerberg contributed the misappropriated assets of the GeneralPartnership to Facebook, Inc. and took the General Partnership’s opportunity for himself;

c. In exchange for the misappropriated assets of the General Partnership that Zuckerberg contributed to Facebook, Inc., Zuckerberg received and was promised to receive cash, stock, stock options, restricted stock units and/or other consideration;

d. The cash, stock, stock options, restricted stock units and/or otherconsideration property received by or promised to Zuckerberg in exchange for themisappropriated assets were, and are, the property of the General Partnership; and

e. By virtue of his 50% ownership interest in the General Partnership, Cegliais entitled to receive 50% of the total equity interest in Facebook, Inc. received by, and promisedto Zuckerberg, including, but not limited to, stock, stock options and restricted stock units.

D. For the Sixth and Seventh Claims for Relief

7. Damages according to proof.E. For All Claims for Relief

8. All recoverable court costs and fees.-25-

9. Attorneys’ fees, expenses and costs, including expert witness fees, to the extentavailable by law or contract.

10. Such other and further relief as the Court deems just and proper.

JURY DEMAND

Plaintiff demands trial by jury on all issues so triable.

Dated:

New York, New York.

April 11, 2011

Respectfully submitted, DLA PIPER LLP (US) John Allcock (seeking admission)

Robert W. Brownlie (seeking admission)

Gerard A. Trippitelli (seeking admission)

By: /s/Christopher P. (Kip) HallChristopher P. (Kip) Hallkip.hall@dlapiper.com

Carrie S. Parikhcarrie.parikh@dlapiper.com

1251 Avenue of the Americas, 27th FloorNew York, NY 10020-1104

212.335.4500

Attorneys for Plaintif fPAUL D. CEGLIA

Paul Argentieri (co-counsel) paul.argentieri@gmail.com

188 Main St. Hornell, NY 14843 607.324.3232

Dennis C. Vacco (co-counsel) dvacco@lippes.com

Kevin J. Cross (co-counsel) kcross@lippes.com 665 Main Street, Suite 300 Buffalo, NY 14203 716.853.5100

EAST\44501966.2

Ceglia is actually taking Facebook to court over this issue claiming that Facebook CEO Mark Zuckerberg signed an agreement in 2003 that have Ceglia half of the business, plus more if the site launched late.

Well, Ceglia says that he will agree to waive the late penalty clause, and drop his ownership stake to only 50%.

That was nice of him…

I’m sure Mark Zuckerberg is pleased with this whole thing as well (not).

The Buffalo federal court lawsuit says Ceglia gave Zuckerberg $1,000 to help Zuckerberg get Facebook off the ground.

Facebook attorney Orin Snyder calls Ceglia a scam artist. In July, another Facebook attorney said Zuckerberg and Ceglia worked together on another website, but not Facebook.

via MiamiHerald

I asked a question yesterday via Facebook about what price tag would Mark Zuckerberg, Facebook’s co-founder and CEO, be willing to sell Facebook.

Some people responded with $4 billion, others though maybe $50 billion, and one person even thought a couple of bucks would do it.

One response that really caught my attention was from Matt that read:

Considering Forbes magazine has stated his net worth is at 6.2 Billion, more than Steve Jobs, and that Facebook is becoming such an integral part of mainstream cultural every where I would say that the price of Facebook is on the same level as Da Vinci’s Mona Lisa….priceless. I don’t think he would or will ever sell Facebook (I wouldn’t)

That’s interesting isn’t it?

Is is possible that Facebook has elevated to a level that it is now priceless?  Like a priceless piece of art or artifact?

What do you think about this?

Is Facebook, at this point, really priceless?

Mark Zuckerberg, Facebook’s co-founder, CEO and president, announced today that he plans on giving away the majority of his fortune to charity. According to Mark Zuckerberg, “People wait until late in their career to give back. But why wait when there is so much to be done?  People wait until late in their career to give back. But why wait when there is so much to be done?”

Zuckerberg is currently ranked #36 on Forbes 400 list of Richest Americans with an estimated net worth of $6.9 billion.

Earlier this year, on September 23rd, Mark Zuckerberg gave away $100 million to support the Newark, New Jersey’s eroding school districts.

via Forbes

It’s almost like when the President makes a big announcement on his legislative initiative. He makes the pitch on prime time tv, then takes to the town hall meetings to push for support.

This might be a bit of a stretch I know, but Facebook CEO Mark Zuckerberg is hot on the conference trail only 2 days after his big announcement on the new Facebook messaging platform.

Below is Mark Zuckerberg at the Web 2.0 conference – and this is the complete 1 hour, 6 minutes, and 14 second version:

Here’s Mark Zuckerberg at the Bing press conference last week:

and here’s Mark Zuckerberg at Y Combinator today:

So you tell me… it looks like Mark Zuckerberg has under-gone some interview posture classes lately.

Thoughts?

2nd image via TechCrunch

Next time you’re on Facebook (which is probably now…) take a look around at the aesthetics of the site. What color do you notice as being the dominant color? Your first response should be blue. That’s right, blue is the dominant color of Facebook and that is not by accident. According to an article I just read by USAToday, blue is the dominant color on Facebook because Marck Zuckerberg (Facebook’s founder and CEO) is red-green colorblind.

Who knew…?

In an interesting twist in Facebook news today, word has it that Mark Zuckerberg and company are trying to actually trademark the word face.

I’m not sure I even know what that means?

I mean, what would happen to shows like Face The Nation, and others like it that have the word face in it.

Can Facebook do such a thing?

According to HuffPost, via TechCrunch:

It is not just the word “book” at the end of a company or product name that Facebook might object to. If it has its way, the word “Face” at the beginning of a name might also bring out its lawyers. In fact, Facebook is currently trying to register the word “Face” as a trademark.

Thoughts?

Fact: The Facebook application accounts for half of all app usage on the phone (excluding phone and email). On the iPad, the Facebook percentage is even higher.

Fact: Facebook Places, being a “location aware” application, will rely heavily on both the iPhone and iPad for usage data, integration, and feedback.

So with Facebook playing such a large roll of usage on the iPhone and iPad, is it fair to say that the success of the iPhone and iPad can be attributed to Facebook?

After all, Facebook has 500 million (that’s half a billion in case you were wondering) users world wide.

If this is true, then the implication is that Apple is dependent upon Facebook for selling the iPhone and iPad.

Take that thought one step further and you have the question of whether Facebook is the reason Apple is successful.

Thoughts?

via Motley Fool, Digital Surgeons

It’s to tell at the moment, but some Myspace users were reporting login issues at the popular (although seriously declining) social networking site. One user reported via Twitter that the Myspace login issue was isolated to the Firefox web browser only.

Myspace can’t really afford to be having any major technical difficulties at this point, if the login problems are true that is. They are literally been hemoraghing users from their site and Facebook is already more popular than Myspace.

On Wednesday, news broke that Facebook reached the 500 million users. Facebook CEO Mark Zuckerberg is “fully confident” that Facebook will achieve 1 billion users in the not too distant future.

Mark Zuckerberg, founder and CEO of Facebook (you may have heard of it), is becoming quite a hit on the big screen lately. The Social Network, a movie about Zuckerberg and the rise of Facebook, is set to be released on October 1st. But just prior to that, it is being reported that Mark Zuckerberg will be lending his voice – actually has already made the recordings – for the upcoming season of The Simpsons.

According to NYMag.com, in the episode, dubbed “Loan-A Lisa,” Lisa decides to help fund Nelson’s new bike company. While attending an entrepreneurs convention, the two encounter Zuckerberg, who reminds the kids just how many famous billionaires — including himself — have dropped out of school. The rest of the plot is a secret, but we’re pretty sure Zuckerberg then steals their idea for the bike company and ends up making another billion dollars. Look for the episode to air as soon as October, perhaps just in time for the Oct. 1 release of The Social Network.

Just yesterday, Facebook reached 500 million users. And to celebrate this great achievement, Mark Zuckerberg released a video and did an interview with Diane Sawyer.

Facebook CEO Mark Zuckerberg sat down today with ABC’s Diane Sawyer to talk about Facebook reaching 500 million users. During the interview (watch below), Sawyer asked Zuckerberg about the allegations by Paul Ceglia that he has a contract stating he has a right to 84% ownership in Facebook. Zuckerberg answered the question with this: “I don’t think we — that — if we said that we were unsure, I think that was likely taken out of context,” he said. “Because I think we were quite sure that we did not sign a contract that says that they have any right to ownership over Facebook.”

Here’s Diane Sawyer’s interview of Mark Zuckerberg:

The growth of Facebook has really only just begun. It was only about 5 months ago when Facebook hit 400 million active users. And that 5 to 6 month time period is about how long it took them to go from 300 million to 400 million.

So at this rate, it would seem reasonable that Facebook would be hitting the 1 billion user mark soon – perhaps sometime next year? Or do you think that Facebook is starting to peek and the new user registration is going to start tapering off?

Mark Zuckerberg says no way – in fact, he made an official statement saying just last month, at the Cannes Lions International Advertising Festival,that it is “almost a guarantee that it will happen”.

So think  about this for minute – can you remember when you joined Facebook? That is, when did you officially create and start using your Facebook profile? Was it within the last 2 years, last year, or perhaps even the last six months? If you’re like most Facebook users, you haven’t had your Facebook profile for much more than a year, or two at most.

You can see Mark Zuckerberg tonight on ABC’s “World News” in an interview with Diane Sawyer where he will be talking more about the amazing growth rate of Facebook.

Here’s Facebook founder and CEO Mark Zuckerberg announcing 500 million users:

Facebook Breaks 500 Million Users

Yeah, that’s a lot of people who are up on Facebook!

The WSJ has just released some preliminary numbers that are suppose to be coming from ComScore later today – and these numbers are going to break down the top dogs on the web who are driving the most traffic.

Here’s what WSJ is saying about it right now:

According to comScore’s numbers, which are set to be released later Tuesday, Facebook saw 519 million visitors world-wide, in fourth place. Google had 921 million users, second-place Microsoft had 728 million and Yahoo had 588 million.

519 million visitors hit Facebook worldwide in the Month of April.

And with that many visitors, odds are you were one of them (I know I was).

What is shocking with these prelim numbers coming out of ComScore is that Microsoft came in 2nd place with 728 million users visiting their site and web properties.

I thought for sure that Facebook was beating Microsoft in web traffic, and I even wrote an article about how Facebook actually got more traffic than Google one month.

I guess it just depends on how you are defining traffic: absolute unique visitors, visits, hits, etc.. depending on how you measure it, the outcome will be different.

So today, let’s just suffice it to say that Facebook now generates over 500 million unique visitors a month – which is A LOT!!!

A lot of people are talking about the soon to be released movie about Facebook called The Social Network.  The movie is really more about the Facebook creator Mark Zuckerberg and from initial reviews, there are some harsh realities about Zuckerberg that are presented.

For example, the movie shows Zuckerberg trying to make up for his sexual insecurities by having sex with random women in bars. And also sheds light on the breakup from his girlfriend at Harvard, and the following website created by Zuckerberg that compares women to barnyard animals.

According to the ex, the reason girls didn’t like Zuckerberg had nothing to do with being a tech geek, as he often said. It was just because he was “an asshole”.

The video doesn’t go into indepth details about the redesign, but you do come away with a much better sense of the changes, what they mean, and where those changes are.

Check out the complete video:

In a recent blog post about Facebook site maintenance, users are expressing their frustration with their profiles being unavailable.  One prominent error message that people keep seeing is “Your account is temporarily unavailable due to site maintenance. It should be available again within a few hours. We apologize for the inconvenience.“

Some people are claiming that they’ve been locked out of Facebook for over 36 hours, and have yet been able to log back in.

At this point, the only suggestion that makes sense as to why so many people are now experiencing outages with Facebook is because of their new redesign rolling out.  The roll out must be taxing some users’ profiles more than others.

Like my Facebook profile, I don’t yet see any changes – whereas others have the new changes and already expressing their various views on the new redesign.

How about you?  Do you have the new Facebook redesign already?

And if so, what are your thoughts about it?

Finally, is your Facebook profile still down due to maintenance?

The new Facebook Lite just released last week, and it’s kind of obvious when you’re looking at it that there are no apps displayed and only an occasional advertiser. And I can’t help but think that the new Facebook Lite version might mean revenue trouble for all parties involved – Facebook, advertisers, and app developers.

The new platform called Facebook Lite is designed to make Facebook more accessible in remote regions of the world where Internet connections are slow, but also for those of us here in the US that are still operating off dial up connections.

The Looming Trouble

If Facebook Lite is to remain stripped down, void o f the heavy java script and PHP consuming apps, then where do the app developers and advertisers fit in with this new model?

And not only the application developers and advertisers, but what about Facebook themselves?  Aren’t they suppose to be generating a primary source of their revenue from advertisers?

I can’t imagine that Facebook didn’t consider this when developing Facebook Lite – so they must have considered all the implications.

A Possible Scenario

And it’s also likely that Mark Zuckerberg, the founder of Faceb0ok, is developing the site with users in mind first, and revenue generation second.  I do believe I’ve seen a video where Zuckerberg states that Facebook, and all their development, is designed with users in mind – if the site always keeps the users of Facebook in mind first, then everything else will take care of itself.

I do like that way of thinking in fact.  I’m just concerned about the fact that advertisers and app developers might need to find a way to generate revenue within this new world of Facebook Lite.