According to the complaint, the plaintiff alleges that he suffered damages as a result of an invalid click activity on a pay-per-click advertising campaign through Google's AdWords program. The plaintiff holds Google Inc. responsible because the defendant allegedly represented that invalid clicks account for only less than 10 percent of all clicks in AdWords ads, but upon testing plaintiff found out that it was much more than what the defendant advertised. Because of the invalid clicks, the plaintiff alleges the defendant receives billions of dollars in additional profits annually.

15. As a result, Plaintiff conducted a series of experiments to determine whether his Google Display Network advertisements were being fraudulently manipulated, and if so to calculate the extent of such fraud.
16. Upon completion, Plaintiff’s experiments revealed rampant, wide-spread invalid click activity on ads within Plaintiff’s advertising campaign, at a rate between forty (40) and forty-eight (48) percent of total clicks on the Google Display Network, for each of which Google collects thirty-two percent of the total advertising proceeds. Across the entirety of AdWords’ United States user base, these invalid clicks result in billions of dollars in additional profits for Google on an annual basis. As a result, Plaintiff conducted a series of experiments to determine whether his Google Display Network advertisements were being fraudulently manipulated, and if so to calculate the extent of such fraud.