..Gary Dretzka
..Noah Forrest
..Leonard Klady
..R.J. Matson
..David Poland
..Douglas Pratt
..Ray Pride
..Michael Wilmington

November 24 , 2003

COMPLAINT
Indies vs. MPAA
page 6

PRAYER FOR RELIEF
WHEREFORE, Plaintiffs respectfully request the following judgments with respect to this Complaint:
1. An order from this Court declaring the Joint Screener Ban unlawful under Sections 1 & 2 of the Sherman Act;

2. An order temporarily, preliminarily and permanently enjoining the MPAA from enforcing the Joint Screener Ban against its signatory members or their subsidiaries; or, in the alternative,

3. An order temporarily, preliminary and permanently requiring the MPAA to allow distributors to make screeners available to all awards-granting trade associations, critics organizations and similar groups on the same terms as were offered to the Academy;

4. An order from this Court temporarily, preliminarily and permanently enjoining defendant from unlawful acts in restraint of trade as described above, pursuant to Section 16 of the Clayton Act, 15 U.S.C. 26;

5. An order requiring the MPAA to negotiate in good faith to develop a policy regarding piracy and screeners that is fair to all members of the industry or an order requiring the MPAA to develop a forum in which all constituencies of the industry have a voice in policy formation;

6. An award of compensatory damages for the antitrust and other economic injury that Plaintiffs have suffered and will suffer as a direct and proximate result of Defendant's unlawful and anticompetitive acts in an amount not yet known, but expected to exceed twenty-five million dollars ($25,000,000), trebled according to Section 4 of the Clayton Act, 15 U.S.C. §15;

7. An award of compensatory damages for the economic injuries Plaintiffs have suffered and will suffer as a direct and proximate result of Defendant's tortious interference with Plaintiffs' existing contracts and prospective economic advantage;

8. An award of punitive and exemplary damages for the injuries caused by Defendant's tortious interference with Plaintiffs' actual and prospective contractual relations,

9. The costs of bringing this action, including reasonable attorneys' fees, pursuant to Sections 4 and 16 of the Clayton Act, 15 U.S.C. §§ 15, 26; and

10. Such other relief as the Court in its judgment deems necessary to restore competition to the industry and /or in the interests of justice.

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