NY_DOCS:607859.1

2 2)

Venue is proper in this District because the Agreement applies the law of the District of Columbia, Defendant is domiciled in this District, and Defendant maintains its principal places of business in this Dist rict.

PARTIES

3)

At all times hereinafter mentioned, Plaintiff Bernie 2016, Inc. (the “Campaign”) was, and is, a not-for-profit corporation and political organization organized under the laws of the State of Vermont, consistent with the Federal Election Campaign Act of 1971. The Campaign is the election vehicle for 2016 national presidential candidate Bernie Sanders. The Campaign maintains its principal place of business at 131 Church Street, Suite 300, Burlington, Vermont. 4)

Upon information and belief, DNC Services Corporation, d/b/a Democratic National Committee (the “DNC”) at all times relevant hereto was, and is, a not-for-profit corporation organized under the laws of the District of Columbia, as the operating body of the United States Democratic Party. Upon information and belief, the DNC maintains its principal place of business at 430 South Capitol Street Southeast, in Washington, District of Columbia.

FACTS

The Agreement

5)

On or about October 26, 2015, the Campaign and the DNC entered an agreement captioned “Agreement Between the DNC and Presidential Campaign Committees Regarding use of DNC National Voter File Data” (the “Agreement”). A true and correct copy of t he Agreement, with appendices, is annexed hereto as “Exhibit A.” 6)