Electronically FILED by Superior Court of California, County of Los Angeles on 05/16/2019 08:09 AM Sherri R.

Carter, Executive Officer/Clerk of Court, by R. Clifton,Deputy Clerk

19STCV16928
Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: Holly Fujie

1 AKIN GUMP STRAUSS HAUER & FELD LLP

SUSAN K. LEADER (SBN 216743)
2 sleader@akingump.com
BRETT M. MANISCO (SBN 318351)
3 bmanisco@akingump.com
1999 Avenue of the Stars, Suite 600
4 Los Angeles, CA 90067-6022
Telephone: 310.229.1000
5 Facsimile: 310.229.1001
6 HYONGSOON KIM (SBN 257019)
kimh@akingump.com
7 4 Park Plaza, Suite 1900
Irvine, CA 92614
8 Telephone: 949.885.4100
Facsimile: 949.882.4101
9
ATTORNEYS FOR PLAINTIFFS
10 IICOMBINED CO., LTD., D/B/A GENTLE MONSTER,
IICOMBINED U.S.A., INC., D/B/A GENTLE MONSTER
11

12
SUPERIOR COURT OF THE STATE OF CALIFORNIA
13
FOR THE COUNTY OF LOS ANGELES
14

15 Case No.
IICOMBINED CO., Ltd., d/b/a Gentle
16 Monster, a Korean corporation;
IICOMBINED U.S.A., Inc., d/b/a Gentle
17 Monster, a New York corporation,
COMPLAINT FOR:
18
Plaintiffs, 1. FRAUD AND INTENTIONAL DECEIT
19
v. 2. BREACH OF CONTRACT
20
MALIK YUSEF, an individual; BURUNDI 3. BREACH OF THE IMPLIED
21 PARTLOW, an individual; MALIK YUSEF COVENANT OF GOOD FAITH AND
JONES, INC., an Illinois corporation; FAIR DEALING
22 BURUNDI PARTLOW CONSULTING,
INC., an Illinois corporation; SONJA 4. UNFAIR COMPETITION UNDER CAL.
23 NUTTALL, an individual; JYAKUEN BUS. & PROF. CODE § 17200 ET SEQ.
GLOBAL LLC, a New Jersey limited
24 liability corporation; and DOES 1-10
inclusive,
25 JURY TRIAL DEMANDED
26
Defendants.
27

28

COMPLAINT
 1 Plaintiffs IICOMBINED Co., Ltd., and IICOMBINED U.S.A., Inc., d/b/a Gentle Monster,
2 (collectively “Gentle Monster”), allege as follows:
3 SUMMARY OF THE ACTION
4 1. This case is about the deception and fraud Defendants Malik Yusef (“Yusef”) and his
5 co-conspirators perpetrated to con Gentle Monster, a Korean-based fashion brand best known for its
6 cutting-edge eyewear, into paying millions of dollars in sham fees. Yusef used his seemingly close
7 relationship with Kanye West (“Kanye”) to deceive Gentle Monster into believing that he could bring
8 some of the world’s most talented artists together to produce a series of videos designed to increase
9 Gentle Monster’s global brand recognition. In reality, Yusef and his co-conspirators had neither the
10 ability nor the intent to deliver on their promises. Rather, Yusef, his manager Burundi Partlow
11 (“Partlow”), and his friend Sonja Nuttall (“Nuttall”) (collectively “Defendants”), were only interested
12 in swindling as much money from Gentle Monster as possible before their scheme was exposed.
13 2. From their earliest interactions with Gentle Monster, Defendants went out of their way
14 to describe Yusef’s star-studded connections. They never missed an opportunity to mention that Yusef
15 routinely works with artists like Beyoncé and Kanye, that he tours with Jay–Z, or that he vacations
16 with Pharrell Williams (“Pharrell”). They repeatedly highlighted Yusef’s six Grammy Awards to create
17 the perception of legitimacy.
18 3. Yusef even arranged an intimate meeting between Kanye and Gentle Monster’s U.S.
19 CEO, Won Lee (“Lee”), where they discussed, at a high level, the concept of using music to connect
20 people globally. Based on this meeting, Gentle Monster reasonably believed that Yusef was being
21 honest about the commitments he claimed that he had procured from Kanye and other artists to work
22 on Gentle Monster’s ambitious campaign to market its latest line of designer sunglasses, “Project 13.”
23 4. Unfortunately, as Gentle Monster discovered, this was only a façade, orchestrated to
24 earn Gentle Monster’s trust and confidence. Over the next nine months, Defendants engaged in a
25 series of deceptive acts and made a number of fraudulent misrepresentations designed to induce Gentle
26 Monster not only to engage Yusef to work on Project 13, but to wire more than $2.5 million to
27 Defendants. Defendants’ deception was both flagrant and brazen. Specifically, they forged Kanye’s
28 signature, created a shell entity named after Kanye’s deceased mother, issued fraudulent invoices made

1
COMPLAINT
 1 to appear as though they had been issued by legitimate talent agencies, lied about their contacts and
2 work with artists, and, in the end, pocketed more than $2.5 million from Gentle Monster.
3 5. Relying on Defendants’ elaborate misrepresentations, Gentle Monster entered into a
4 contract (the “MOU”) with Yusef, under which he agreed, inter alia, to engage artists like Kanye,
5 Pharrell, Jaden Smith, and Paris Jackson, to produce music and appear in videos for Project 13. The
6 goal for Project 13 was simple: by engaging high profile and influential artists to create content aimed
7 at promoting its new and innovative line of sunglasses, Gentle Monster could increase its brand
8 awareness around the world.
9 6. As a condition of its performance, Gentle Monster insisted that either Kanye or Pharrell
10 provide written confirmation that they agreed to participate in the project. Shortly after executing the
11 MOU, Defendants sent Gentle Monster an “Acknowledgment” form, which included what appeared to
12 be Kanye’s signature. Upon receipt, Gentle Monster wired Defendants $250,000, in accordance with
13 the agreement. As Gentle Monster later learned, however, the signature appearing on the form was
14 forged, illegitimate and unauthorized.
15 7. Forging Kanye’s signature was just the first in a long series of lies and
16 misrepresentations that Defendants used to deceive Gentle Monster into believing that Project 13 was
17 on track, and that they were fulfilling their contractual obligations. Over the next several months,
18 Defendants repeatedly led Gentle Monster to believe that Kanye and Pharrell were recording music
19 specifically for Project 13, and that other well-known actors like Rosario Dawson and Jaden Smith had
20 agreed to appear in the videos. Defendants made these misrepresentations to induce Gentle Monster to
21 distribute additional Project 13 funds into bank accounts controlled by Defendants.
22 8. To perpetuate their scheme, Yusef and Partlow sent Gentle Monster fraudulent invoices
23 designed to appear as though they had been issued by legitimate talent agencies such as Roc Nation.
24 9. Defendants also routinely misrepresented the status of Project 13. Under the MOU,
25 Yusef was obligated to produce four videos by no later than December 25, 2018. When Defendants
26 began to miss deadlines and Gentle Monster pressed them about production status, Defendants lied and
27 made up excuses. For instance, when Gentle Monster asked to hear some of the music that Kanye and
28 Pharrell were working on, Defendants delayed and stated that the music would be ready “soon,” and

2
COMPLAINT
 1 that Kanye and Pharrell were busy in the studio working on production. Of course, December 25,
2 2018 came and went, and Yusef had not produced a single video.
3 10. When Gentle Monster finally received the first video just hours before its scheduled
4 release on February 14, 2019, it looked nothing like what Gentle Monster had in mind when it entered
5 into the MOU with Yusef. While the end credits stated that both Kanye and Pharrell wrote and
6 produced the music, there was no indication from viewing the video that either artist was substantively
7 involved in any way. Indeed, most of the artists Gentle Monster paid for did not appear in the video.
8 11. What’s worse, after Gentle Monster released the video on February 14, 2019, it
9 discovered that neither Kayne West nor Pharrell was actually involved in Project 13. Specifically, on
10 February 17, 2019, just days after the first video was released, Kanye’s wife, Kim Kardashian West,
11 tweeted that Kanye was not involved in producing the video. Stunned, Gentle Monster quickly
12 removed the video from its platforms.
13 12. The full extent of Defendants’ scheme is still unknown. While Defendants have
14 defrauded Gentle Monster out of over $2.5 million, its damages are far greater.
15 Defendants’ deceptive, wrongful and malicious conduct has caused substantial economic and
16 reputational harm to Gentle Monster. Accordingly, Gentle Monster is entitled to damages and other
17 relief as requested herein.
18 PARTIES, JURISDICTION, AND VENUE
19 13. Plaintiff IICOMBINED Co., Ltd, d/b/a Gentle Monster, is a Korean corporation whose
20 principal place of business is located in Seoul, Korea.
21 14. Plaintiff IICOMBINED U.S.A., Inc is a subsidiary of IICOMBINED Co., Ltd., which
22 maintains offices in Los Angeles, California and New York, New York.
23 15. Plaintiffs are informed and believe, and on that basis allege, that Defendant Malik Yusef
24 is an individual who resides in Chicago, Illinois.
25 16. Plaintiffs are informed and believe, and on that basis allege, that Defendant Burundi
26 Partlow is an individual who resides in Chicago, Illinois.
27 17. Plaintiffs are informed and believe, and on that basis allege, that Defendant Sonja
28 Nuttall is an individual who resides in Montclair, New Jersey.

3
COMPLAINT
 1 18. Plaintiffs are informed and believe, and on that basis allege, that Defendant Jyakuen
2 Global LLC is a New Jersey Limited Liability Corporation.
3 19. Plaintiffs are informed and believe, and on that basis allege, that Defendant Malik Yusef
4 Jones, Inc. is an Illinois corporation.
5 20. Plaintiffs are informed and believe, and on that basis allege, that Defendant Malik Yusef
6 Jones, Inc. is Defendant Malik Yusef’s alter ego, and that it therefore is, in effect, Defendant Malik
7 Yusef.
8 21. Plaintiffs are informed and believe, and on that basis allege, that Defendant Burundi
9 Partlow Consulting, Inc. is an Illinois corporation.
10 22. Plaintiffs are informed and believe, and on that basis allege, that Defendant Burundi
11 Partlow Consulting, Inc. is Defendant Burundi Partlow’s alter ego, and that it therefore is, in effect,
12 Defendant Burundi Partlow.
13 23. Collectively, Yusef, Partlow, Nuttall, Malik Yusef Jones, Inc., Burundi Partlow
14 Consulting, Inc., and Jyakuen Global LLC are referred to herein as “Defendants.” At all relevant
15 times, Defendants were acting as co-conspirators.
16 24. Jurisdiction and venue are proper in this Court because Los Angeles County is where
17 the parties negotiated aspects of the agreement, where the parties intended performance would occur,
18 and/or where the breaches occurred. Representatives from Gentle Monster met with Defendants Yusef
19 and Partlow about Project 13 in Los Angeles repeatedly over the course of several months. Defendant
20 Sonja Nuttall also met with Gentle Monster representatives and Defendants Yusef and Partlow in Los
21 Angeles more than three times.
22 25. Gentle Monster is unaware of the true names or capacities, whether individual,
23 corporate, associate, or otherwise, of Defendants sued herein as DOES 1 through 10, inclusive, and
24 therefore sues these Defendants by such fictitious names. Gentle Monster will seek leave of the Court
25 to amend this pleading to set forth the true names and capacities of said Doe Defendants when the
26 same are ascertained. Gentle Monster is informed and believes, and on that basis alleges, that each of
27 the fictitiously named defendants is responsible in some manner for the occurrences herein alleged, or
28

4
COMPLAINT
 1 was acting in concert with, and with the permission, approval, and authorization of, the specifically
2 named Defendants.
3 FACTUAL ALLEGATIONS
4 A. Gentle Monster Is Fraudulently Induced Into Contracting With Defendants
5 26. Gentle Monster is a global fashion brand headquartered in Seoul, Korea. Best known
6 for its cutting-edge eyewear designs, Gentle Monster combines arts with functional designs and
7 innovative technology. Currently, Gentle Monster has 46 stores across Asia, Europe, and North
8 America.
9 27. Seeking to increase its brand recognition across the globe, Gentle Monster started
10 planning a promotional campaign for its new line of glasses, ‘13’, that would feature high profile talent
11 like Pharrell performing unique songs created and produced for the campaign while wearing Gentle
12 Monster ‘13’ glasses. Gentle Monster charged Lee, the CEO of its U.S. subsidiary, with the task of
13 identifying and retaining talent to participate in the project. Gentle Monster labeled this ambitious
14 project, “Project 13.”
15 28. In or about October 2017, Lee began his search for anyone who might have connections
16 with the level of talent Gentle Monster needed to engage for a successful campaign. One of the first
17 people Lee turned to was a friend and former business associate, Nuttall, because she had previously
18 represented to Lee that she had a relationship with Pharrell’s agent.
19 29. When Lee told Nuttall about Gentle Monster’s vision for Project 13, she immediately
20 suggested that instead of meeting Pharrell’s agent, Lee ought to meet her friend, Malik Yusef.
21 According to Nuttall, Yusef was a Grammy winning songwriter who worked with stars like Beyoncé
22 and Kanye. Nuttall stated that although it was normally very difficult to meet with Yusef, she could
23 arrange for him to DJ an event at Gentle Monster’s store in New York so the two men could meet.
24 Based on Nuttall’s representations, Lee hired Yusef to perform as a DJ at the Gentle Monster launch
25 event in January 2018.
26 30. Shortly after Lee met Yusef at the event, Nuttall organized a phone call among Lee,
27 Yusef, Nuttall, and Yusef’s manager and business partner, Partlow, to discuss Project 13. When Lee
28

5
COMPLAINT
 1 explained the concept for the project to Yusef and Partlow, Yusef told Lee that he could “easily” get
2 Pharrell to participate.
3 31. But there was one caveat. Yusef said that the only way he could make the project work
4 within Gentle Monster’s budget was to bypass the agents and allow Yusef to negotiate directly with the
5 talent. Otherwise, Yusef explained, when agents get involved the costs skyrocket. Thus, in order for
6 this to work, Yusef said, it was imperative that all communications and payments to the artists go
7 through him, as he had the relationships. If Gentle Monster agreed to this, Yusef represented, he could
8 ensure that Project 13 was completed within budget. It is not uncommon in Asia to negotiate directly
9 with talent, so Gentle Monster did not question the strategy.
10 32. Shortly after this initial call, Lee met with Partlow to discuss Project 13. According to
11 Partlow, Yusef could not attend this meeting because he was vacationing with Pharrell in Paris.
12 Partlow even showed Lee Yusef’s itinerary with Pharrell. Partlow stated that because Yusef and
13 Pharrell were such close friends, Pharrell would “probably” be interested in working on Project 13.
14 33. On or about April 5, 2018, Partlow sent Lee a list of artists, actors and influencers that
15 he represented based on Yusef’s connections he could engage to work on Project 13. This list
16 included, but was not limited to, Kanye West, Pharrell Williams, Jaden Smith, Paris Jackson, Rosario
17 Dawson, Carmen Electra, Naomi Campbell, Tiffany Haddish, and other high profile talent.
18 34. Based on the representations that Yusef and Nuttall made about their ability to engage
19 these artists for Project 13, Gentle Monster agreed to enter into a consultant agreement with Nuttall’s
20 company, Jyakuen Global LLC 1. Upon executing the contract, Gentle Monster paid Nuttall $60,000
21 for introducing Gentle Monster to Yusef, and for obtaining Yusef’s commitment to participate in
22 Project 13. “As a direct result of the introduction of Malik Yusef[,]” the agreement reads, “the
23 Company is in the process of obtaining Commitments from Kanye West, Pharrell, Paris Jackson and
24 Jaden Smith who were each introduced to the Company by and through Malik Yusef.”
25

26

27 1
In the contract, Nuttall’s company is referred to as “Jyakyen Global LLC.” Plaintiffs assume
that this was a typographical error. The correct spelling of Nuttall’s company, as depicted on the New
28 Jersey Secretary of State’s website is “Jakuen Global LLC.”

6
COMPLAINT
 1 35. As Gentle Monster later discovered, this recitation was simply false––Yusef had not
2 started the process of obtaining commitments from any of these artists to participate in Project 13.
3 36. In or about the first week of May, 2018, Lee met Yusef and Partlow in a Universal
4 Studios music studio in Los Angeles, California. Surrounded by seven or eight other people crammed
5 into the recording studio, Yusef was busy making music. In between his recording sessions, Yusef took
6 time to speak with Lee about his vision for Project 13. Again, Yusef referenced his connections with
7 Pharrell and Kanye, even offering to set up a meeting with Kanye. While they did not discuss any
8 logistics or specifics, Lee left the meeting feeling confident that Yusef was right for Project 13.
9 37. Based on Defendants’ representations about Yusef’s relationships with high-profile
10 talent, on or about May 9, 2018, Gentle Monster and Yusef’s company, Malik Yusef Jones, Inc. 2,
11 finalized and executed an MOU, which outlined the respective obligations of the parties.
12 38. Under the MOU, Gentle Monster agreed to pay Yusef a total of $820,000, including an
13 up-front deposit of $410,000. In exchange, the MOU required Defendants to co-create four videos
14 and/or vignettes aimed at increasing Gentle Monster’s overall brand awareness. The MOU specified
15 that Defendants would “[p]roduce visuals and/or vignettes that include Pharrell Williams, Kanye West,
16 Jaden Smith, Paris Jackson, or an equivalent artist, as a director, talent, or any creative position or
17 impresario influencer as decided by [Gentle Monster] and [Yusef].” Defendants were also required to,
18 inter alia, “[a]cquire, manage, and maintain the following celebrity talent, producers, artists, executive
19 producers and oversee the entire process to final product: Paris Jackson, Jaden Smith, Kanye West, and
20 Pharrell[.]”
21 39. Critically, the MOU provided that Gentle Monster “shall not incur any responsibility
22 until and unless Kanye or Pharrell confirm in writing to participate in the Project at remuneration
23 acceptable to the [Gentle Monster].”
24 40. Pursuant to the MOU, Yusef and Partlow promptly sent Gentle Monster an
25 “acknowledgement form” purportedly signed by Kanye West to serve as written confirmation that
26 Kanye agreed to participate in the project. Upon receiving the executed form from Kanye West, Gentle
27
2
For ease, Plaintiffs will refer to both Malik Yusef and his company, Malik Yusef Jones, Inc.,
28 collectively as “Yusef.”

7
COMPLAINT
 1 Monster reasonably believed that Defendants had delivered on their initial obligation under the MOU
2 and wired $250,000 to a bank account controlled by Defendants.
3 B. Yusef Uses His Proximity To Kanye West to Defraud Gentle Monster
4 41. Yusef referenced his close relationship with Kanye West in virtually every
5 communication he had with Lee and Gentle Monster. Yusef has worked on several of Kanye’s most
6 successful albums, and is credited as a writer on six of Kanye’s Grammy nominated songs. 3 As
7 alleged herein, Yusef used this proximity to Kanye to mislead Gentle Monster into believing that
8 Kanye had actually agreed to work on Project 13.
9 42. Indeed, the week after Defendants sent Gentle Monster the signed acknowledgment
10 form, Yusef arranged for Lee to meet with him and Kanye in Kanye’s private room in Jackson Hole,
11 Wyoming. 4 Thrilled that Kanye had agreed to participate in Project 13, Lee arrived to the meeting
12 with a bag full of sample Gentle Monster sunglasses that he planned to show Kanye. However, just
13 before he entered Kanye’s room, Yusef took the bag of sunglasses from Lee and told him that he could
14 not show them to Kanye because it would seem like Lee was “trying to sell something.”
15 43. Although Lee was initially concerned, the meeting with Kanye went well. Yusef and
16 Kanye embraced upon seeing each other and engaged in a spirited philosophical conversation about
17 Kanye’s new album. At one point, the three discussed, at a high level, some of the themes that Gentle
18 Monster was hoping to incorporate into its latest promotional campaign. Lee felt honored that Kanye
19 West allowed him into his room and treated him with such respect.
20 44. Although Yusef did not mention the specifics of Project 13, Lee left Kanye’s room with
21 a sense of excitement. There was no urgency to discuss logistics, as Lee understood that more
22 meetings would follow, and that they would soon hammer out the details of Project 13. Unfortunately,
23

24
3
25 While Yusef brands himself as a “6x Grammy Award Winner,” he has been nominated for six
Grammys for his credited work on five different Kanye West songs. He has won only one Grammy for
26 his work as a credited artist on “All of The Lights” by Kanye West, which won Best Rap Song of 2011.
See https://www.grammy.com/grammys/artists/malik-yusef-jones
27 4
Kanye held a listening party in Jackson Hole, Wyoming just before the release of his eighth
studio album, “Ye”. See https://www.rollingstone.com/music/music-news/inside-kanye-wests-
28 wyoming-listening-party-628250/

8
COMPLAINT
 1 this was the last time Lee would ever meet with Kanye. Unbeknownst to Gentle Monster, Kanye had
2 not signed the MOU or agreed to participate in Project 13.
3 45. After their meeting with Kanye, Yusef handed Lee a Universal Music Publishing Group
4 song agreement, which purportedly granted Yusef the authority to release a song titled “New Angels,”
5 to Gentle Monster. The notarized agreement purportedly included Kanye’s signature and a copy of
6 Kanye’s driver’s license. As Gentle Monster later learned, however, Yusef procured this agreement
7 without Kanye’s knowledge or consent.
8 46. Shortly after their meeting with Kanye, Yusef represented to Lee that Kanye might be
9 interested in entering into an agreement with Gentle Monster to design a line of Gentle Monster
10 sunglasses. On June 20, 2018, Yusef and Partlow sent Lee an agreement purportedly executed by
11 Kanye for the work (“Sunglasses Agreement”). Under the agreement, Gentle Monster agreed to pay an
12 upfront fee of $500,000, as well as 15% royalty on all sunglasses sales. However, unbeknownst to
13 Gentle Monster, Kanye’s signature on this agreement was also forged.
14 47. After executing the agreement, Gentle Monster wired $500,000 to an account controlled
15 by an entity called “Donda Social Agency, Inc.” Defendants indicated that Donda Social Agency, Inc.,
16 named after Kanye’s deceased mother, was Kanye’s Chicago-based charity organization. Gentle
17 Monster understood that the $500,000 went directly to Kanye’s charity and that the money would help
18 fund programs aimed at combatting problems with poverty, education, and gun violence in Chicago.
19 48. Gentle Monster later learned, however, that while Kanye was involved in a charity
20 referred to as Donda’s House, this was not related in any way to Donda Social Agency, Inc. Rather,
21 Yusef and Partlow formed this entity on June 21, 2018, the day after they forged Kanye’s signature on
22 the Sunglasses Agreement. Indeed, the bank information, routing number and SWIFT code that Yusef
23 and Partlow provided for Donda Social Agency, Inc., is identical to that which appears on invoices that
24 Defendants later issued for services by Defendant entity Burundi Partlow Consulting, Inc.
25 C. Defendants Issue Fraudulent Invoices
26 49. Over the course of the next eight months, Defendants made countless
27 misrepresentations to Gentle Monster about the status of Project 13, the talent they had purportedly
28 engaged to work on Project 13, the entities involved, the amount of money due, and the Sunglasses

9
COMPLAINT
 1 Agreement. As part of their scheme, Defendants repeatedly generated fraudulent invoices that were
2 designed to appear as though they had been issued by legitimate companies. In reality, however,
3 Gentle Monster is informed and believes, and thereupon alleges, that Yusef and Partlow controlled the
4 bank accounts listed on the invoices.
5 50. For example, on or about December 19, 2018, Partlow sent Gentle Monster an invoice
6 in the amount of $305,000, purportedly for “Music Performance and Video Appearance(s)” by Jaden
7 Smith and Vic Mensa. The invoice bore the logo for Roc Nation, Jay-Z’s talent agency. As Gentle
8 Monster later learned, however, Roc Nation did not prepare the invoice, nor did it authorize
9 Defendants to act on its behalf. Not knowing the invoice to be a forgery, Gentle Monster wired
10 $305,000 to Defendants on December 24, 2018.
11 51. Similarly, on or about December 20, 2018, Defendants sent Gentle Monster an invoice
12 purportedly from Illusive Media, Shomi Partwary’s legitimate film production company. Illusive
13 Media did not actually issue this invoice, nor did it receive the $122,445 payment that Gentle Monster
14 made pursuant to the invoice. In fact, again, the bank information, routing number, and SWIFT code
15 included on the invoice were identical to those on the invoices issued by Defendant Burundi Partlow
16 Consulting, Inc.
17 52. Defendants sent a similar invoice to Gentle Monster on December 20, 2018 in the
18 amount of $550,000. This invoice was purportedly for the “Song Performance and[/or]
19 Appearance(s)” of Pharrell Williams and Paris Jackson, and for the appearance of Michael K.
20 Williams. Gentle Monster is informed and believes, and thereon alleges, that neither Pharrell
21 Williams nor Paris Jackson was actually involved in the Project in any way. Rather, Defendants
22 simply misrepresented their involvement to induce Gentle Monster into wiring $550,000 into an
23 account under their control.
24 53. By the end of 2018, as a direct result of the extreme measures Defendants took to
25 defraud Gentle Monster, it had wired Defendants more than $2.5 million.
26 ///
27 ///
28

10
COMPLAINT
 1 D. Defendants Delay Performance and Breach The MOU
2 54. From the moment the parties executed the MOU, Lee was in constant contact with
3 Defendants. He regularly communicated with Defendants about Project 13 via email, phone calls, and
4 text messages.
5 55. Lee met with Defendants Yusef and Partlow about Project 13 more than ten times in Los
6 Angeles, often at a Universal Studios music studio. Similarly, Nuttall travelled to Los Angeles at least
7 three times to meet with Lee, Yusef, and Partlow regarding the status of Project 13.
8 56. Despite this constant dialogue, Defendants repeatedly delayed and made up excuses for
9 why it was taking so long for Kanye and/or Pharrell to make a song for Project 13. Under the MOU,
10 Yusef was required to produce four videos by no later than December 25, 2018. However, by August
11 2018, Defendants had yet to produce any music or videos for the project.
12 57. Concerned about the status of the project, Gentle Monster sent its Chief Marketing
13 Officer for the U.S., Taye Yun (“Yun”), to meet with Yusef in his Oakland, California music studio.
14 When Yun arrived at Yusef’s studio, he was impressed. Yusef sat in a beautiful studio surrounded by
15 around seven or eight teenagers and young adults, teaching them how to make music. Yusef spent the
16 evening meeting with Yun and assured him that Project 13 was on track.
17 58. Lee also continued to press Defendants as to when the songs would be ready. Each time
18 Lee inquired, Defendants stated that Kanye and Pharrell were busy working on songs, and that the
19 music would be ready “soon” or “next week” and “not to worry.” Invariably, next week came and
20 went, and Defendants failed to send Gentle Monster the promised music.
21 59. Defendants made countless excuses as to why they had to delay shooting. For instance,
22 they represented that Paris Jackson had pulled out of a shoot last minute because she “didn’t like the
23 music.” Other excuses related to last minute changes in the artist’s schedules or adjustments that
24 purportedly needed to be made to the songs.
25 60. When the first video was finally ready for release on February 14, 2019, Gentle Monster
26 was shocked. While the end credits of the video indicated that Pharrell Williams, Vic Mensa, and
27 Kanye West wrote and produced the music (along with Yusef), none of these artists could be heard on
28

11
COMPLAINT
 1 the song, with the exception of Yusef. Moreover, only two artists––Michael K. Williams and Vic
2 Mensa––appeared in the video.
3 61. Not able to risk further delay, Gentle Monster published the video on its site. Three
4 days later, a popular Twitter account “@HYPEBAE” picked up the video and tweeted a link to it
5 stating, “@kanyewest produced the music for Gentle Monster’s latest campaign.”
6 62. Under normal circumstances, this kind of a tweet from a popular Twitter account
7 should have resulted in enormous positive brand exposure for Gentle Monster. This was precisely the
8 kind of social media impact Gentle Monster contemplated when it first developed the concept for
9 Project 13.
10 63. Unfortunately, this success was short-lived. On February 17, 2019, Kim Kardashian
11 West, whose Twitter account boasts nearly 60.2 million followers, responded to @HYPEBAE’s post,
12 tweeting, “This is not true. Kanye is not involved and did not produce this song.”
13 64. Later that day, Gentle Monster received a letter from Kanye’s counsel, informing them
14 that Kanye had not authorized Gentle Monster to use his name or music in its campaign, and
15 demanding that Gentle Monster remove all references to Kanye from its website. Stunned, Gentle
16 Monster immediately removed the video from its website, and asked Defendants to cease all
17 outstanding work on Project 13.
18 65. The full extent of Defendants’ scheme is still unknown. While Defendants have
19 defrauded Gentle Monster out of well over $2.5 million, its damages far exceed this amount. Gentle
20 Monster invested countless hours and resources attempting to perform its obligations under the MOU
21 and bring Project 13 to fruition. It retained outside consultants, flew several officers and employees
22 from Korea and New York to Los Angeles on multiple occasions to monitor the project, and spent
23 substantial resources developing and manufacturing Project 13 eyewear. Not only did Gentle Monster
24 suffer monetary harm as a result of its lost investment in Project 13, but, more significantly, its brand
25 and public perception has suffered substantial and irreparable harm.
26 ///
27 ///
28 ///

12
COMPLAINT
 1 FIRST CAUSE OF ACTION
2 (Fraud and Intentional Deceit)
3 (Against All Defendants)
4 66. Gentle Monster incorporates by reference the allegations in the foregoing paragraphs as
5 if fully set forth herein.
6 67. Defendants repeatedly made numerous false statements to Gentle Monster which were
7 intended to induce, and which did induce, Gentle Monster to: (1) enter into the MOU; (2) enter into a
8 consultant agreement with Sonja Nuttall; (3) enter into the Sunglasses Agreement; and (4) pay millions
9 of dollars for work that was never performed. Defendants’ misrepresentations included, but are not
10 limited to the following:
11 (a) Defendants represented that they had the ability to obtain agreements from Kanye,
12 Pharrell, Jaden Smith and Paris Jackson to participate in Project 13.
13 (b) Defendants represented to Gentle Monster that Kanye agreed to participate in and
14 create music for Project 13.
15 (c) Defendants represented to Gentle Monster that Kanye agreed to collaborate with
16 Gentle Monster on designing a sunglasses line.
17 (d) Defendants represented to Gentle Monster that Pharrell agreed to appear in Project
18 13 videos and create music for Project 13.
19 (e) Defendants represented that Roc Nation issued an invoice on behalf of Jaden Smith
20 and Vic Mensa.
21 (f) Defendants represented that that Illusive Media issued an invoice for services
22 performed.
23 (g) Defendants represented to Gentle Monster that Jaden Smith agreed to appear in
24 Project 13 videos.
25 (h) Defendants represented to Gentle Monster that Paris Jackson agreed to appear in
26 Project 13 videos.
27 (i) Defendants represented to Gentle Monster that Amber Rose agreed to appear in
28 Project 13 videos.

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COMPLAINT
 1 (j) Defendants represented to Gentle Monster that Rosario Dawson agreed to appear in
2 Project 13 videos.
3 (k) Defendants represented to Gentle Monster that they distributed payments made
4 under various invoices to the artists and talent listed therein.
5 (l) Defendants represented multiple invoices to be from various agencies associated
6 with the artists (and not accounts owned and controlled by Defendants).
7 (m) Defendants repeatedly represented that Project 13 was on track for production by
8 December 25, 2018.
9 (n) Defendants represented to Gentle Monster that Kanye and Pharrell were recording
10 music specifically for Project 13.
11 68. Defendants knew that these representations were false at the time they were made, or
12 they made these representations recklessly and without regard for their truth.
13 69. Defendants intended that Gentle Monster would rely on their misrepresentations and
14 omissions in entering into and performing under the consultant agreement with Nuttall.
15 70. Defendants intended that Gentle Monster would rely on their misrepresentations and
16 omissions in entering into and performing under the MOU.
17 71. Defendants intended that Gentle Monster would rely on their misrepresentations and
18 omissions in entering into and performing under the Sunglasses Agreement.
19 72. Defendants intended that Gentle Monster would rely on their misrepresentations and
20 omissions in paying money to various entities controlled by Defendants for services that were never
21 performed.
22 73. Gentle Monster actually relied on Defendants’ misrepresentations and omissions in
23 entering into the consultant agreement, the MOU, and the Sunglasses Agreement, in performing under
24 the consultant agreement, the MOU, and the Sunglasses Agreement, and in paying the money
25 purportedly owed for services that were never performed.
26 74. Gentle Monster’s reliance was justifiable, as Defendants used their proximity to Kanye
27 to portray access to the artists with whom Gentle Monster wanted to work. Had Gentle Monster
28 known the truth, it never would have entered into, nor performed under, any of these agreements.

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COMPLAINT
 1 Moreover, had Gentle Monster known the truth about what services were actually being performed (or,
2 more accurately, not performed), it never would have paid the money purportedly owed under the
3 invoices.
4 75. As a direct and proximate result of Defendants’ fraud and intentional deceit, Gentle
5 Monster has suffered substantial and irreparable harm, in an amount to be proven at trial.
6 76. Moreover, Defendants’ conduct was willful and malicious. Accordingly, Gentle
7 Monster is entitled to punitive damages in an amount to be proven at trial.
8 SECOND CAUSE OF ACTION
9 (Breach of Contract)
10 (Against Malik Yusef and Malik Yusef Jones, Inc.)
11 77. Gentle Monster incorporates by reference the allegations in the foregoing paragraphs as
12 if fully set forth herein.
13 78. Malik Yusef and Malik Yusef Jones, Inc. (collectively referred to as “Yusef”), and
14 Gentle Monster, entered into the MOU, which is a valid and enforceable written contract.
15 79. Under the MOU, Gentle Monster agreed to pay Yusef a total of $820,000, including an
16 up-front deposit of $410,000. In exchange, Yusef agreed, inter alia, to create and produce four videos
17 aimed at increasing overall brand awareness for Gentle Monster by no later than December 25, 2018.
18 Yusef also agreed to “[a]cquire manage, and maintain the following celebrity talent, producers, artist,
19 executive producers, and oversee the entire process to final product: Paris Jackson, Jaden Smith,
20 Kanye West, and Pharrell[,]” and to ensure that no intellectual property rights were infringed.
21 80. Gentle Monster has satisfied its obligations under the MOU, or its performance is
22 excused.
23 81. Yusef materially breached the terms of the MOU by failing to acquire any of the listed
24 talent for participation in the project, by failing to timely produce four videos as required under the
25 MOU, and by failing to ensure that intellectual property rights were not infringed.
26 82. As a direct and proximate result of Yusef’s breach, Gentle Monster has been damaged in
27 an amount to be proven at trial.
28

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COMPLAINT
 1 THIRD CAUSE OF ACTION
2 (Breach of the Implied Covenant of Good Faith and Fair Dealing)
3 (Against All Defendants)
4 83. Gentle Monster incorporates by reference the allegations in the foregoing paragraphs as
5 if fully set forth herein.
6 84. Implicit in the MOU, the Sunglasses Agreement, and Nuttall’s consultant agreement, is
7 a covenant of good faith and fair dealing that prohibits the parties from doing anything that would
8 render performance of the agreement impossible or deny the other party the benefits of the agreement.
9 Additionally, the implied covenant of good faith and fair dealing requires that Defendants use their
10 good faith and efforts to give effect to the terms of each agreement.
11 85. Defendants breached the implied covenant of good faith and fair dealing by engaging in
12 the conduct alleged herein, including, but not limited to:
13 a. Representing that they had engaged Kanye West, Pharrell Williams, Jaden Smith, and
14 Paris Jackson to participate in Project 13, when in reality, Defendants had not done so.
15 b. Forging and/or stealing Kanye’s signature and representing that he agreed to participate
16 in Project 13 and the Sunglasses Agreement, without his consent.
17 86. As a direct and proximate result of Defendants’ breaches of the implied covenant of
18 good faith and fair dealing, Gentle Monster has been damaged in an amount to be proven at trial.
19 FOURTH CAUSE OF ACTION
20 (Unfair Competition under Cal. Bus. & Prof. Code §17200 et seq.)
21 (Against All Defendants)
22 87. Gentle Monster incorporates by reference the allegations in the foregoing paragraphs as
23 if fully set forth herein.
24 88. Defendants’ conduct as alleged herein constitutes unlawful and/or unfair business acts
25 or practices under Cal. Bus. & Prof. Code § 17200 et seq.
26 89. Defendants’ conduct has caused, and if not enjoined will continue to cause, substantial
27 and irreparable damage to Gentle Monster’s brand. Gentle Monster is entitled to relief under Cal. Bus.
28 & Prof. Code § 17203.

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COMPLAINT
 1 90. As a consequence of Defendants’ violations, Gentle Monster has suffered damages in an
2 amount to be established at trial.
3 PRAYER FOR RELIEF
4 WHEREFORE, Plaintiffs respectfully request that the Court issue relief as follows:
5 A. For compensatory and general damages, according to proof.
6 B. For punitive damages, according to proof;
7 C. For restitution and disgorgement of all ill-gotten gains;
8 D. For legal interest;
9 E. For injunctive relief, including a permanent injunction enjoining and restraining Defendants
10 and their agents from using Gentle Monster’s brand without authorization; and
11 F. For such other and further relied as the Court deems just and proper.
12
Dated: May 16, 2019 AKIN GUMP STRAUSS HAUER & FELD LLP
13 SUSAN K. LEADER
HYONGSOON KIM
14 BRETT M. MANISCO
15
BY
16 Susan K. Leader
Attorneys for IICOMBINED CO., LTD., d/b/a
17 GENTLE MONSTER and IICOMBINED U.S.A.,
18 INC., d/b/a GENTLE MONSTER

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COMPLAINT