Dr. Iman Sadeghi v. Pinscreen Inc., et al.

Lawsuit:

Dr. Iman Sadeghi v. Pinscreen Inc., et al.


Parties:

Dr. Iman Sadeghi ("Sadeghi"), Plaintiff,
    v.
Pinscreen Inc. ("Pinscreen"), Dr. Hao Li ("Li"), Yen-Chun Chen, Liwen Hu ("Hu"), Han-Wei Kung ("Kung"), and Does 1-100 (collectively "defendants").


Jurisdiction:

Superior Court of the State of California, County of Los Angeles, Central District


Case No.:

BC709376


Contents:


Coverage:

WHEN
WHAT
WHERE
June 20, 2018
Lawsuit accuses Los Angeles start-up Pinscreen of misrepresenting its technology
Los Angeles Times
Los Angeles Times
July 17, 2018
Lawsuit alleges fabricated results at Pinscreen led by Hao Li
Reddit
Reddit
97% upvoted
July 17, 2018
USC 大学教授、Pinscreen CEO Hao Li 是否存在论文造假、产品虚假宣传等问题?
Zhihu
Zhihu
500,000+ views
July 18, 2018
Techie sues ex-bosses, claims their AI avatar tech was faked and he was allegedly beaten up after crying foul - Punch up at Cali startup
The Register
The Register
October 30, 2018
Viterbi professor embattled in lawsuit with his former employee
USC Annenberg Media
USC Annenberg Media


Documents:

[October 5, 2018]
Verified Amended Complaint
[ Dr-Iman-Sadeghi-v-Pinscreen-Inc-et-al.pdf ]
Verified Amended Complaint

Exhibit E: Li’s and Pinscreen’s Data Fabrication and Academic Misconduct
[ Exhibit-E-Li’s-and-Pinscreen’s-Data-Fabrication-and-Academic-Misconduct.pdf ]


[June 11, 2018]
Verified Complaint
[ Dr-Iman-Sadeghi-v-Pinscreen-Inc-et-al-Jun-11-2018.pdf ]
Verified Complaint


[November 5, 2018]
USC v. Dr. Hao Li Truth Challenge
[ USC-v-Dr-Hao-Li-Truth-Challenge.pdf ]
USC v. Dr. Hao Li Truth Challenge

[October 8, 2018]
Scientific Integrity v. Pinscreen Truth Challenge
[ Scientific-Integrity-v-Pinscreen-Truth-Challenge.pdf ]
Scientific Integrity v. Pinscreen Truth Challenge

[July 9, 2018]
Dr. Iman Sadeghi v. Dr. Hao Li Truth Challenge
[ Dr-Iman-Sadeghi-v-Dr-Hao-Li-Truth-Challenge.pdf ]
Dr. Iman Sadeghi v. Dr. Hao Li Truth Challenge

Timeline:

WHEN
WHAT
WHERE
June 11, 2018
Verified Complaint: Dr. Iman Sadeghi v. Pinscreen Inc., et al.

I, Dr. Iman Sadeghi, filed a verified complaint in the Superior Court of California against Pinscreen Inc., et al.

I allege that Pinscreen and its CEO, Dr. Hao Li, perpetrated Fraud and Deceit, Data Fabrication, and Academic Misconduct supported by conclusive evidence.

Superior Court of California
June 20, 2018

Li responded in the Los Angeles Times that "All the Allegations Are 100% False."

LA Times
July 9, 2018
Dr. Iman Sadeghi v. Dr. Hao Li Truth Challenge

I challenge Li on Facebook , Twitter , LinkedIn , Google+ , and Instagram to confirm his position on a small subset of community relevant allegations, under penalty of perjury, by signing the challenge form and sharing it publicly on his social media.

I appeal to my coauthors, collaborators, and colleagues; my fellow scientists, academics, researchers, and engineers; Computer Science, Computer Graphics, ACM and SIGGRAPH communities; friends, family, and individuals who value #science, #integrity, and the #truth to invite Li to accept the challenge. #truthchallenge

Facebook Twitter LinkedIn Google+ Instagram
July 18, 2018
"I dare Dr. Hao Li to accept my Truth Challenge," Sadeghi told The Register.
The Register
July 19, 2018
Li responded on Facebook and LinkedIn and alleged "[…] that individual has taken aggressive actions to defame us publicly with false accusations, and has fabricated communications and other evidences [sic] to portray us negatively to our peers […] " [view]
Facebook LinkedIn
August 2, 2018
Pinscreen and Li filed for Extension of Time with the Superior Court of California. [view]
Superior Court of California
August 31, 2018
Pinscreen and Li filed for Extension of Time with the Superior Court of California. [view]
Superior Court of California
October 5, 2018
Verified Amended Complaint: Dr. Iman Sadeghi v. Pinscreen Inc., et al.

I filed the verified amended complaint with additional conclusive evidence for Pinscreen's and Li's data fabrication, acaemic misconduct, and other unlawful practices.

Superior Court of California
October 8, 2018
Scientific Integrity v. Pinscreen Truth Challenge
I appeal to my coauthors, collaborators, and colleagues; my fellow scientists, academics, researchers, and engineers; Computer Science, Computer Graphics, and SIGGRAPH communities; ACM, ETH Zürich, USC, USC ICT, and USC Viterbi School of Engineering; friends, family, and individuals who value #science, #integrity, and the #truth to demand and challenge Pinscreen and its affiliates to identify any communication or item of evidence within the verified amended complaint that they allege to be “fabricated.” #truthchallenge
Facebook Twitter LinkedIn Google+ Instagram
October 30, 2018
Li responded through USC Annenberg Media that he doesn't refute the existence of the screenshotted messages, but said in a recent email to Annenberg Media that they are easy to misinterpret.
Li also stated that “the messages and screenshots are presented in a manner that allows them to be taken out of context quite easily.”
USCAnnenbergMedia
November 5, 2018
USC v. Dr. Hao Li Truth Challenge
I appeal to all individuals who value #science, #integrity, and the #truth to invite USC to challenge Li to explain the context for his use of the word “cheating,” which he used to characterize Pinscreen’s conduct and to invite Li to accept the challenge. #truthchallenge
Facebook Twitter LinkedIn Google+ Instagram
TBA
Pinscreen's and Li's production of the security camera footage of the Assault and Battery through discovery.
Superior Court of California
TBA
Pinscreen's and Li's official verified answer to the verified amended complaint with Superior Court of California.
Superior Court of California
TBA
Jury Trial in Superior Court of California.
Superior Court of California

Causes of Action:

  1.   Fraudulent Inducement of Employment Contract by Intentional Misrepresentation
  2.   Fraudulent Inducement of Employment Contract by Intentional Concealment
  3.   Battery
  4.   Violation of Cal. Labor Code § 1102.5 - Retaliation Against Whistleblowing
  5.   Breach of Employment Contract
  6.   Breach of Implied Contract for Research Integrity
  7.   Wrongful Termination in Violation of Public Policy
  8.   Intentional Interference with Contract
  9.   Intentional Infliction of Emotional Distress
  10.   Negligent Hiring, Supervision or Retention
  11.   Violation of Cal. Labor Code § 2802
  12.   Violation of Cal. Labor Code § 203
  13.   Breach of Constructive Bailment
  14.   Invasion of Privacy
  15.   Violation of Cal. Unfair Competition Law (UCL), Bus. & Prof. Code § 17200 et seq.


Case Summary:

CASE SUMMARY

   1.    Sadeghi holds a doctorate in Computer Science/Computer Graphics from the University of California, San Diego (“UCSD”). He developed, published, and patented a novel digital hair appearance framework for Walt Disney Animation Studios’ movie Tangled and has presented his work in prestigious scientific forums. After having worked at Google as a Software Engineer for more than five years, Sadeghi was solicited by Pinscreen to join the company’s leadership.

   2.    Pinscreen is a software start-up specializing in automatically generating animated 3D face models, called avatars, using only a photograph of a person. Li, an assistant professor at University of Southern California (“USC”), is one of the co-founders and the Chief Executive Officer (“CEO”) of Pinscreen.

   3.    Defrauding Sadeghi, Pinscreen, through Li, knowingly misrepresented Pinscreen’s avatar generation capabilities to Sadeghi and concealed its various illegal practices from him. Pinscreen’s and Li’s unlawful conduct involved a variety of fraudulent activities including misrepresenting manually prepared avatars as automatic, which is at the heart of Pinscreen’s technical claims.

   4.    In reliance on Li’s fraudulent misrepresentations to him, Sadeghi resigned from Google and joined Pinscreen as its VP of Engineering. While working to improve the quality of Pinscreen’s infrastructure and avatars, Sadeghi gradually discovered Li’s and Pinscreen’s various illegal practices, including deliberately misreporting purportedly scientific experiments or their results (data fabrication), academic misconduct, fraud on investors, labor law violations, and immigration law violations.

   5.    When confronted by Sadeghi regarding the data fabrication and academic misconduct, Li asserted that Pinscreen would achieve its inflated claims in time for subsequent publications, which Li considered to be crucial for Pinscreen’s industry exposure and success. Li promised Sadeghi that Pinscreen would never fabricate its results in public representations.

   6.    Li broke this promise on August 1, 2017, when Pinscreen and Li publicly mispresented fabricated avatars on the stage of ACM’s SIGGRAPH 2017 Real-Time Live (“RTL”) to an audience of thousands.

   7.    In retaliation for Sadeghi’s objections and whistleblowing regarding Li’s data fabrication, academic misconduct, fraud on investors, labor law violations, immigration law violations, and other unlawful practices, Pinscreen illegally terminated Sadeghi, on August 7, 2017, within Sadeghi’s first working hour after Pinscreen’s fabricated demo at RTL.

   8.    On the day of the wrongful termination, various defendants committed multiple other torts against Sadeghi, including assault and battery and invasion of privacy. As a result of the battery, Sadeghi has suffered severe physical, mental, and emotional distress as well as physical injuries requiring medical attention, physical therapy, and psychotherapy.

   9.    Following the wrongful termination, Pinscreen committed additional breaches of contract and engaged in other unlawful conduct, such as withholding business expense reimbursements, withholding the check for penalties for late wage payments, and damaging Sadeghi’s personal property.

   10.    Sadeghi brings this action to vindicate his legal rights, and more importantly, to benefit the public; to preserve the integrity of scientific research; to safeguard Computer Science, Computer Graphics, ACM and SIGGRAPH communities; and to protect Pinscreen’s employees and investors, while preventing Li, Pinscreen, and other defendants from engaging in further unlawful practices.


Visual TL;DR:

THE PARTIES

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JURISDICTION AND VENUE

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FACTS RELATED TO CAUSES OF ACTION

Sadeghi’s Qualifications

   23.    Sadeghi earned his B.Sc. degree in Computer Engineering in 2006 and graduated first in class from Sharif University of Technology. Shortly after, Sadeghi started graduate school at the University of California, San Diego (“UCSD”) in the field of Computer Science.

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   24.    In 2007, Sadeghi was awarded the Grand Prize in UCSD’s Rendering Competition. Rendering is the process of automatically generating the appearance of digital objects using computers. In 2008, Sadeghi collaborated with Walt Disney Animation Studios (“Disney”) on hair rendering (i.e. digital hair appearance) and received his M.Sc. degree in Computer Science/Computer Graphics on the topic. (Exhibits A1, A2)

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   25.    Sadeghi worked at Disney during 2008 and 2009 and developed a novel hair rendering framework for the production of the movie Tangled. In 2010, Sadeghi presented the framework at the Association for Computing Machinery’s SIGGRAPH conference. The Association for Computing Machinery (“ACM”), is the world’s largest scientific and computing society and the organizer of annual conference SIGGRAPH, widely recognized by experts as the most reputable conference in the field of Computer Graphics. Sadeghi is also a co-inventor of the patent on the framework filed by Disney. The following figure features some of the results of the hair rendering framework: (Exhibits A2, A3, A4)

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   26.    Li later introduced Sadeghi as “the guy behind all the hair rendering tech for Disney and DreamWorks” and, on information and belief, referred to Sadeghi as “the best hair rendering guy.” (Exhibits A5, A6)

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   29.    In 2010, Sadeghi worked at Industrial Light & Magic (“ILM”) and became acquainted with Li. On information and belief, Li was attending graduate school also in the field of Computer Graphics. During the same year, Li requested that Sadeghi connect with him on Facebook and LinkedIn. Sadeghi and Li stayed in touch over the years and referred to each other as good friends. (Exhibits A7, A8)

   30.    On June 11, 2011, Sadeghi was ceremonially honored when he received his Ph.D. from UCSD in Computer Science/Computer Graphics. Later, Sadeghi presented his scientific research from his Ph.D. dissertation, in the field of rendering and appearance modeling, at SIGGRAPH 2012 and SIGGRAPH 2013. (Exhibits A9, A10, A11)

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   31.    Sadeghi joined Google as a Software Engineer on August 15, 2011 and gained experience with Robust Software System Architectures, Reliable Scalable Distributed Systems, and Deep Convolutional Neural Networks. Among other achievements, Sadeghi is also a co-inventor of five patents filed by Google.

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Li’s and Pinscreen’s Solicitation of Sadeghi

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   38.    In early October of 2016, during a scientific conference in Amsterdam, Netherlands, Li, the CEO and co-founder of Pinscreen, and Fursund, the CTO of Pinscreen, approached Sadeghi and invited him to join the company, which Li followed up through Facebook messages, in November of 2016. Pinscreen’s solicitation of Sadeghi included dining with Kim in Seattle, dining with Li in Santa Monica, a remote video conference call with Fursund who was in Denmark, as well as a phone conversation with Zuberi. Li’s continual attempts to persuade Sadeghi to join Pinscreen lasted until late January of 2017. (Exhibits B1, B2, B3, B4, B7, B12, B13, B17)

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   48.    Li offered Sadeghi the “leadership role” of “VP of Engineering” and described it as “potentially having a more important role than CTO.” Li told Sadeghi that his responsibilities would be to “make sure other people work,” “coordinate teams and also ensure efficient deliverables,” and to “oversee the technology development of everyone and push it to the next level.” (Exhibits B18, B19)

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   49.    In response to Sadeghi’s concern for potential risks, Li stated “I don’t think there are any risks” for Sadeghi in joining Pinscreen, and that “I’m quite sure the reward is bigger than what [sic] the other companies, not only in terms of impact but also financially.” (Exhibits B10, B12)

   50.    After claiming that “for startup at our stage the biggest benefit is in stock options,” Li offered Sadeghi $165,000 in salary and 2.3% of Pinscreen’s shares. Sadeghi’s employment contract stated that Pinscreen shall provide Sadeghi equity awards equal to 2.3% ownership of Pinscreen over a four-year vesting period, plus additional stock options to “counteract the dilutive effect” of company’s Series A round of financing on Sadeghi. (Exhibits B5, B11, B20, G)

   51.    [December 26, 2017] Li: “♥️”

   52.    [December 26, 2017] Li: “I can discuss again with the board, but I would like to offer you for the polar bear heart: 165K + 2.3%”

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Pinscreen’s Technology and Terminology

   55.    Pinscreen is a software start-up specializing in automatically generated animated 3D face models, called avatars, using only an input image. Competitor companies include Loom.ai, ObEN, and FaceUnity.

   56.    The following diagram demonstrates subprocesses of Pinscreen’s avatar generation technology which are relevant to this complaint. Subprocesses marked with an asterisk ( * ) are among the ones that Pinscreen has misrepresented. The Hair Appearance subprocess, marked with an obelisk ( † ), is within Sadeghi’s expertise and was significantly improved by his contributions:

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   57.    Relevant components of Pinscreen’s technology include the following:

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   65.    Relevant terminology to this complaint includes the following:

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Li’s and Pinscreen’s Fraud and Deceit of Sadeghi

   70.    Li deceived Sadeghi by intentionally misrepresenting Pinscreen’s technical capabilities to Sadeghi and intentionally concealing its numerous illegal practices from him.

   71.    On information and belief, Li persuaded Sadeghi to join Pinscreen in order to gain access to Sadeghi’s expertise and experience in digital hair appearance and software engineering.

   72.    On January 22, 2017, before Sadeghi had signed the contract to join Pinscreen, Li sent him, through Facebook messages, two examples of purportedly automatically generated avatars. Sadeghi specifically inquired of Li as to whether the hair of the presented avatars had been automatically generated (“autogenerated”), to which Li responded “yes.” (Exhibit C1)

   73.    [January 22, 2017] Sadeghi: “Autogenerated hair?”

   74.    [January 22, 2017] Li: “Yes”

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   75.    Li’s claim that the presented avatars and their hair were automatically generated was a brazen lie. Even up to six months after Li’s initial presentations to Sadeghi, Li and Pinscreen repeatedly fabricated avatars in various representations, including by misrepresenting manually prepared hair shapes as automatically generated.

   76.    For instance, Pinscreen misrepresented manually prepared hair shapes as automatically generated in its SIGGRAPH RTL submission on April 4, 2017; SIGGRAPH Asia Technical Papers submission on May 23, 2017; SIGGRAPH RTL public demo on August 1, 2017; as well as business representations to investors including, on information and belief, Softbank.

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   79.    Li also deceived Sadeghi by intentionally concealing that Li and Pinscreen were involved in data fabrication, academic misconduct, labor law violations, immigration law violations, and unlawful practices that Sadeghi learned about only after resigning from Google and joining Pinscreen.

   80.    On January 23, 2017, after reasonably relying on Li’s representations, and after months of negotiation, Sadeghi accepted an offer from Pinscreen and signed the contract to join the company as its VP of Engineering. Sadeghi sent out his resignation letter to Google, on January 25, 2017, and a sentimental farewell letter to his colleagues at Google, on January 26, 2017, and stated that his last day at Google would be on February 1, 2017. Sadeghi began working for Pinscreen the next day on February 2, 2017, per Li’s request to have Sadeghi on board for a Public Relations (“PR”) event. (Exhibits B11, G)

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   81.    Sadeghi would not have resigned from Google to join Pinscreen if Li had not misrepresented and concealed Pinscreen’s data fabrication and academic misconduct from Sadeghi.

   82.    Sadeghi would not have resigned from Google to join Pinscreen if Li had not concealed Pinscreen’s labor law violations and immigration law violations from Sadeghi.

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Sadeghi’s Contributions

Hair Appearance

   86.    During his employment at Pinscreen, Sadeghi significantly improved the quality of Pinscreen’s avatars and digital hair appearance (i.e. hair rendering, or hair shading) from “below the SIGGRAPH standard” to well above.

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   89.    The following diagram compares the quality of Pinscreen’s avatars before and after Sadeghi’s contributions to Pinscreen’s digital hair appearance: (Exhibit D3) The following diagram compares the quality of Pinscreen’s avatars before and after Sadeghi’s contributions to Pinscreen’s digital hair appearance: (Exhibit D3)

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Hair Shape

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Infrastructure

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Leadership

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Li’s and Pinscreen’s Data Fabrication and Academic Misconduct

   97.    After joining Pinscreen, Sadeghi gradually realized that Li, although an assistant professor, disrespected academics and was involved in data fabrication and various academic misconduct. (Exhibit E1)

   98.    [February 4, 2017] Li: “Just a bunch of academic loosers [sic] 😊”

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   99.    Li would embellish Pinscreen’s technical capabilities in scientific research submissions and then use deadline pressure to overwork the employees to achieve his inflated claims, and if the employees eventually failed, he would order them to fake the deliverables.

   100.    Li discussed ways to “tweak data to get the results we want” and referred to data fabrication as “faking things,” “cheating,” “shitty cheating,” and “doing it manually.” Li mandated data fabrication by stating that he “doesn’t think we can make it automatic,” that “we probably have no choice but to cheat,” and that he thinks “it’s the only way.” (Exhibits E2, E3, E4, E5, E6, E7, E8)

   101.    [June 29, 2017] Li: “I’m really worried that nothing will work by tje [sic] rehearsal and we have to [sic] some shitty cheating again.”

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   102.    Li’s Skype profile with Skype ID “hao.li.ethz”:

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   105.    Under Li’s leadership, Pinscreen intentionally misrepresented manually prepared data as automatically generated in various scientific and business presentations. This dishonest practice is universally recognized by academic ethics codes as data fabrication and data falsification, which are also universally condemned as academic misconduct. Data fabrication and data falsification are classified as “Research Misconduct,” and instances of “Scientific Misconduct,” by USC’s official policy and are in violation of ACM’s “Code of Ethics and Professional Conduct.” (Exhibit E41)

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SIGGRAPH 2017 Technical Papers Submission

   112.    Shortly after joining Pinscreen, Sadeghi realized that under Li’s leadership, Pinscreen included fabricated and falsified results in their SIGGRAPH Technical Papers submission, submitted on January 16, 2017, prior to Sadeghi’s employment. In that scientific research submission, among other misrepresentations, Pinscreen had misrepresented manually prepared hair shapes as automatically generated. This submission was eventually rejected and later re-submitted to SIGGRAPH Asia 2017 Technical Papers.

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   113.    When Sadeghi questioned Li about these misrepresentations, for instance on March 9, 2017, Li claimed that they were “not important” because the submissions were “not public.” Li stated that Pinscreen had been practicing the strategy of “Fake it ‘til you make it” and declared that “it has been working great.” Li claimed that should Pinscreen’s fabricated submissions be accepted, Pinscreen would have sufficient time to actually develop the claims before publication. Li claimed that it was crucial to the success of Pinscreen to get into these conferences for industry exposure. Li stated that scientific publications and technical presentations would result in media coverage by technology news outlets, such as TechCrunch, and will substantially “increase the valuation of the company.” Li later claimed similar statements, writing “TechCrunch coverage should be our target.” (Exhibit E10)

   114.    [May 22, 2017] Li: “TechCrunch coverage should be our target”

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SIGGRAPH 2017 Real-Time Live Submission

   115.    In preparation for SIGGRAPH RTL submission, due on April 4, 2017, Li wrote on multiple team threads, on March 27, 2017, that “the issue is that we don’t have time,” and that “even if we fake things there is no time,” and that for the hair reconstruction (i.e. hair shape estimation) “we probably have no choice but to cheat.” (Exhibits E3, E7)

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   118.    Among other misrepresentations in the submission, on information and belief, Li commissioned a freelance artist, located in Germany, named Leszek, to manually prepare the hair shapes for all avatars presented in the submission. On March 30, 2017, Li stated that it would take “3 hours” for an artist to create a hair shape and the cost would be “100 Euros.” Pinscreen misrepresented these hair shapes as automatically generated, when in fact they were created through this lengthy and expensive manual process. (Exhibit E11)

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   119.    On April 18, 2017, Leszek shared his manually prepared hair shapes for Ryan Gosling’s and Hailey Dunphy’s avatars with Sadeghi: (Exhibit E11)

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   120.    Leszek’s Skype profile with Skype ID “spawnie76”:

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   121.    Pinscreen’s technology has been and still is, nearly a year and a half after the submission, incapable of automatically generating hair shapes with intricacies demonstrated in Leszek’s hand-made hair shape for Haley Dunphy’s avatar. (Exhibit K2)

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   123.    On April 4, 2017, Pinscreen, under Li’s leadership, submitted fabricated avatars with manually prepared hair shapes created by Leszek to SIGGRAPH RTL.

   124.    Pinscreen’s submission to SIGGRAPH 2017 RTL; titled “Pinscreen: Creating Performance-Driven Avatars in Seconds”; co-authored by Li, Saito, Wei, Sadeghi, Hu, Seo, Nagano, Fursund, Yen-Chun Chen, and Stephen Chen; containing fabricated avatars with manually prepared hair shapes; published on ACM Digital Library:

   125.    https://dl.acm.org/citation.cfm?id=3107546

SIGGRAPH Asia 2017 Technical Papers Submission

   126.    Pinscreen revised its previously rejected submission to SIGGRAPH 2017 Technical Papers and resubmitted it to SIGGRAPH Asia Technical Papers, on May 23, 2017.

   127.    For the resubmission, Pinscreen was asked to present 100 avatars for 100 input images. (Exhibit E13)

   128.    Li commissioned artists to manually prepare hair shapes for the requested avatars and misrepresented them in the submission as automatically generated.

   129.    Li stated, on April 18, 2017, “then I have an artist create 100 hairs ahahaha,” and on May 17, 2017, “basically, I need to create 3D hair models for 100 people or get 3D modelers to do it.” (Exhibits E14, E15)

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   134.    Pinscreen also fabricated the process of estimating the eye color in the submission. On May 18, 2017, five days before the submission deadline, Li stated that Pinscreen’s eye color estimation was “total shit,” “completely random” and ordered Pinscreen employees to “manually fix all the eye colors” for the avatars. Pinscreen then fraudulently claimed in the publication that “several key components, such as […] eye color recognition, are only possible due to recent advances in deep learning.” (Exhibits E6, E16, E17, E18, E19, E20)

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   146.    In addition, Pinscreen fabricated the process of estimating the hair color in the submission. On May 18, 2017, five days before the submission deadline, Li stated, “we also have nothing that can guess hair color.” Subsequently, Pinscreen’s CTO, Fursund, was assigned the task to “manually pick up hair color” for the avatars. Pinscreen then fraudulently stated in the submission that “the eye color texture is computed using a similar convolutional neural network […] as the one used for hair color classification.” (Exhibits E18, E21, E22)

   147.    Pinscreen misrepresented other manually prepared data as automatically generated in its submission including, on information and belief, the “focal length” estimation, a sub component of face shape estimation, and “hair segmentation,” a sub component of hair shape estimation. (Exhibits E19, E21)

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   151.    On May 22, 2017, one day before the submission deadline, Li ordered the team, on “PinscreenTeamAll” Skype thread, including Saito, Nagano, Wei, Yen-Chun Chen, Hu, Fursund, Sun, Kung, Seo, Yu, Xiang, Stephen Chen, Zhou, and Sadeghi to fabricate the Hair Polystrip Patch Optimization process stating “we spent 1 day on it,” that is a lot, and that “if in an hour it’s not working, let’s do it manually and give up on it. I don’t think we can make it automatic.” (Exhibit E8)

   152.    [May 22, 2017] Saito: “Is the patch optimization working now?”

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   165.    [May 22, 2017] Li: “If in an hour it s [sic] not working let s [sic] do it manually

   166.    [May 22, 2017] Li: “And give up on it”

   167.    [May 22, 2017] Li: “I don’t think we can make it automatic”

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   168.    On May 23, 2017, Sadeghi confronted Li regarding the data fabrication and academic misconduct committed in Pinscreen’s SIGGRAPH Asia 2017 Technical Papers submission. Li stated that he wanted “Pinscreen to be the first” in research and the industry. Li claimed that by the time of the conference, in November of 2017, Pinscreen would have had a public product launch and would have achieved Li’s embellished claims in the submission. Sadeghi asked Li, “what if for unforeseeable reasons we don’t have everything by then?” Li promised Sadeghi that Pinscreen’s data fabrication would be limited to nonpublic representations and never shown in public and stated:

   169.    [May 23, 2017] Li: “We won’t present something we don’t have”

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   170.    On May 23, 2017, Pinscreen, under Li’s leadership, submitted fabricated avatars with manually prepared eye colors, hair colors, and hair shapes to SIGGRAPH Asia.

   171.    Pinscreen’s SIGGRAPH Asia 2017 Technical Paper; titled “Avatar Digitization from a Single Image for Real-Time Rendering”; co-authored by Hu, Saito, Wei, Nagano, Seo, Fursund, Sadeghi, Sun, Yen-Chun Chen, and Li; containing fabricated avatars with manually prepared eye colors, hair colors and hair shapes; published on ACM Digital Library:

   172.    https://dl.acm.org/citation.cfm?id=31310887

   173.    After the filing of the complaint, the Los Angeles Times reported, on June 20, 2018, that Li told its reporter, on a phone interview, that Pinscreen’s app is “proof that Pinscreen’s technology works.” However, third parties have produced evidence that Li’s proof is inadequate since Pinscreen’s app produces inferior results compared to Pinscreen’s representations. The following figure compares one of Pinscreen’s fabricated avatars with manually prepared eye color, hair color, and hair shape in the submission (middle) to Pinscreen’s actual automatically generated avatar produced by a third party more than a year after the submission using Pinscreen’s app (right). Pinscreen’s actual automatically generated hair shape, hair color, eye color and overall avatar is inferior to its prior fabricated representations. (Exhibits K1, K2)

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SIGGRAPH 2017 Real-Time Live Public Demo

   174.    Li considered SIGGRAPH Real-Time Live (“RTL”) as the “best event at SIGGRAPH,” “the hardest thing to get in,” and “the only show that matters at SIGGRAPH.” Li claimed that RTL gets “much more visibility than papers” and emphasized that “there will be TechCrunch at SIGGRAPH RTL.” (Exhibits E10, E23)

   175.    However, as Pinscreen approached the RTL public presentation date of August 1, 2017, on information and belief, Li realized that Pinscreen would not be able to deliver on Li’s inflated claims put forth in the submission, months earlier on April 4, 2017, despite Pinscreen employees’ long hours and hard work. Li stated, on June 29, 2017, that he was “really worried that nothing would work” by the RTL rehearsal and that Pinscreen would have to do “some shitty cheating again.” (Exhibit E5)

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   179.    While Sadeghi was away on vacation, Li decided to misrepresent pre-cached avatars as real-time during Pinscreen’s public demo at SIGGRAPH Real-Time Live, on August 1, 2017, to an audience of thousands. In Sadeghi’s absence, Li revealed his intention to deceive the RTL audience, in writing, on July 20, 2017, when he proposed on “PinscreenTeamAll” Skype thread that Pinscreen would “give the people the feeling the avatar is not pre-built” and that “we should give them a sense that it is computing.” In reality, the avatars were pre-built and pre-computed. Li’s decision to fabricate data in a public presentation was in violation of the law and his promise to Sadeghi. (Exhibit E26)

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   184.    On July 22, 2017, upon returning from his anniversary vacation, Sadeghi met other Pinscreen employees at a scientific conference in Hawaii. Sadeghi tested Pinscreen’s avatar generation and reported on “PinscreenTeamAll” Skype thread that it took around a minute and half. Sadeghi’s report also indicated that the automatically estimated hair shape was not accurate and represented a different hairstyle. (Exhibit E27)

   185.    [July 22, 2017] Sadeghi: “The creation took ~90 seconds.”

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   186.    Sadeghi’s Skype profile with Skype ID “iman.sadeghi”:

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   187.    Shortly after, Sadeghi messaged Li to clarify Li’s plan to present a brand-new avatar generation from the webcam at the RTL demo. Sadeghi informed Li that the speed of avatar generation was around a minute and half and that there was “some risk for a hairstyle miss” meaning inaccurate hair shape estimation. Li did not respond to Sadeghi’s message: (Exhibit E28)

   188.    [July 22, 2017] Sadeghi: “So for the live webcam avatar generation at RTL, are you [Li] thinking we will compute everything from scratch (~90 seconds now with some risk for a hairstyle miss) or we cache some stuff?”

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   193.    Li: “Let’s talk about this after the RTL demo.”

   194.    Sadeghi reluctantly accepted Li’s proposal and focused on finalizing Pinscreen’s RTL demo.

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   195.    On July 24, 2017, Fursund, Pinscreen’s CTO, admitted in writing that Pinscreen was “just using pre-cached avatars” and therefore “it’s important that we know exactly who is using the webcam to generate the avatar”: (Exhibit E30)

   196.    [July 24, 2017] Fursund: “Anyway… It’s important that we know exactly who is using the webcam to generate the avatar”

   197.    [July 24, 2017] Fursund: “Since we’re just using pre-cached avatars”

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   198.    Fursund’s Skype profile with Skype ID “alt_er_ego”:

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   199.    Li defined tasks such as “creating all avatars, hair models, tweak for perfect hair color” and “hair models/avatars” and assigned them to Sun. Pinscreen presented multiple avatars during its RTL demo including an avatar of the program chair Cristobal Cheng (“Cristobal”). Sun manually prepared the hair shapes for many of the avatars presented at RTL, including for Sadeghi’s, Cristobal’s, Nagano’s, and her own avatar. (Exhibit E31, E38, E39, E40)

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   200.    On July 25, 2017, 7 days before RTL, Sadeghi gave feedback regarding the hair shapes for Sun’s and Sadeghi’s avatars, which were manually prepared by Sun. Sadeghi wrote to Sun, “you might want to redo the hair for your avatar” and that “around my ears the hair is missing” to which Sun responded “I’ll add the hair around your ears today.” (Exhibits E38, E39)

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   202.    [July 25, 2017] Sadeghi: “Looks like around my ears the hair is missing.”

   203.    [July 26, 2017] Sun: “I’ll add the hair around your ears today”

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   204.    On July 26, 2017, 6 days before RTL, Nagano, wrote to Sun, on “PinscreenTeamAll” Skype thread, and requested “for my hair if you can lower it down a bit if it’s not too hard, that would be nice,” and that Nagano doesn’t think his “forehead is that large.” The requested manual modification of the hair shape was done after around 2 days: (Exhibit E31)

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   209.    On July 28, 2017, 4 days before RTL, Sadeghi wrote to Sun, on “PinscreenTeamAll” Skype thread, and requested that she manually add more hair around the ears for Cristobal’s avatar. It took Sun more than 2.5 hours to add the missing hair around Cristobal’s ears. (Exhibit E40)

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   214.    Sun’s Skype profile with Skype ID “live:carrie.k.sun”:

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   215.    On August 1, 2017, Pinscreen, under Li’s leadership, during its SIGGRAPH RTL public demo in front of thousands of attendees and online viewers, misrepresented manually prepared hair shapes as automatic, pre-cached avatars as brand-new and in real-time, and the speed of its avatar generation of around a minute and half as around 5 seconds.

   216.    Pinscreen’s public demo at SIGGRAPH 2017 RTL, titled “Pinscreen: Creating Performance-Driven Avatars in Seconds” was co-presented by Li, Sadeghi, Nagano, Seo, and Sun and contained fabricated avatars with manually prepared hair shapes. This demo is published on ACM digital library and ACM SIGGRAPH’s YouTube channel:

   217.    https://dl.acm.org/ft_gateway.cfm?id=3107546&ftid=1920365

   218.    https://www.youtube.com/watch?v=hpuEdXn_M0Q&t=31m6s

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   221.    Pinscreen was scheduled to showcase its technology at RTL 2018, more than a year after Pinscreen’s fabricated demo at RTL 2017, and shortly after the media coverage of the lawsuit which accused Pinscreen of misrepresenting manually prepared hair shapes as automatically generated. On August 14, 2018, Pinscreen made no attempts or claims to generate any hair shapes in real-time during its demo and chose to generate only one brand-new avatar from the webcam. For its live webcam avatar generation, Pinscreen chose a bald subject which did not involve any hair shape generation. Subsequently, Pinscreen’s RTL 2018 demo gained around only 5.5% of the popular votes. (Exhibit K3)

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Li’s Miscellaneous Data Fabrication and Academic Misconduct

   222.    Li’s academic misconduct included sharing confidential under-review scientific paper submissions from competitor research groups within Pinscreen and suggesting to look for “details that can be used.” This exploitation of his position as a reviewer violates established scientific ethics. Sharing papers he was reviewing, for his own commercial gain, is another instance of Li’s academic misconduct. (Exhibit E33)

   223.    Li made public claims about having scientific contributions to the iPhone X until Dr. Sofien Bouaziz (“Bouaziz”), a research scientist from Apple Inc., the manufacturer of the iPhone X, posted on Li’s Facebook on October 25, 2017, suggesting that Li “avoid propagating fake information.” Bouaziz informed Sadeghi during the SIGGRAPH 2018 conference (located in Vancouver, BC on August 13, 2018) that Li unfriended and blocked Bouaziz on Facebook after Bouaziz posted on Li’s Facebook for a second time regarding Li’s repeated misrepresentations of his own contributions to the iPhone X. On information and belief, Li has deleted both Facebook posts by Bouaziz. (Exhibit E34)

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   226.    Li’s data fabrication extended to business representations for investors and venture capitalists (“VCs”), whom Li neither trusted nor respected. For instance, Li misrepresented Pinscreen’s technical capabilities to Softbank by falsely representing manually “picked” hair shapes as automatic. The day the investment agreement between the parties was close to being finalized, Li stated on “PinscreenTeamAll” Skype thread: (Exhibits E35, E36, E37)

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   227.    [June 17, 2017] Li: “Pinscreen just fucked Softbank”

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Li’s and Pinscreen’s Labor Law Violations

   228.    Li used deadline pressure to overwork Pinscreen employees and unlawfully refused to pay them overtime. Li repeatedly asked for updates during the nights, weekends, and expected student employees to work on holidays. For instance, on Father’s Day, Sunday, June 18, 2017, Li wrote to Sadeghi and asked “please push the students more, they are getting lazy and only work half of the day.” (Exhibit F1)

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   232.    While unlawfully refusing to pay overtime, Li posted on his Facebook about overworked Pinscreen employees, who were passed out on couches inside Pinscreen’s office, referring to them as “casualties.” Li referred to Saito, as “Salariman [sic]” multiple times. Li also publicly paid tribute to death from overwork on his Facebook, posting “Karoshi! Let me tell you! Sleep is for the weak.” (Exhibits F4, F5, F6)

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   233.    Sadeghi dined with Seo and Nagano on July 24, 2017, during a scientific conference in Hawaii. During the dinner, they told Sadeghi about their excessive amount of overtime work without receiving any financial compensation from the company. Seo further stated that he and Nagano “have no life” and that this amount of work “would not be sustainable.” Later, both of the employees confirmed in writing that they had each worked, on average, around 110 hours per week for the months of May, June, and July of 2017. Sadeghi promised them he would talk to Li after the SIGGRAPH Real-Time Live demo and try to persuade him to pay overtime and “to make sure we are fair to everyone.” (Exhibits F7, F8)

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   234.    [August 6, 2017] Sadeghi: “Hey my man Jaewoo [Seo], what would be your best estimate on the average hours you worked per day/week in the past 3 months and upto RTL? 😊”

   235.    [August 7, 2017] Seo: “I don't know. Maybe around 100-120 hrs/wk? :-[“

   236.    [August 7, 2017] Sadeghi: “Yes that's a lot of hours. Alright cool. Will talk to Hao [Li] today to make sure we are fair to everyone. Especially the full time employees 😊”

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   237.    Additionally, Li harassed, bullied, and discriminated against a Pinscreen employee who it was generally assumed among employees to suffer from autism-spectrum disorder. Li stated, on June 23, 2017, that the employee “should not be autistic” and that it will be Li’s “new project” to teach him “manners.” Li stated that the employee allegedly “does not have the ability to respond,” does not behave “like an adult,” and that Li feels like he “is talking to a wall” when he is talking to the employee. Li verbally abused the employee and used demeaning language such as “are u [sic] fucking shitting me???” and “we are not fucking paying u [sic] for that!” when addressing the employee. Sadeghi requested on June 28, 2017 that Li be respectful towards the employee, but Li dismissed Sadeghi’s request, stating that the employee is “used to it” and that the demeaning language was how Li was able to “push them to work more.” (Exhibit F9)

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   238.    Furthermore, Li discussed firing Pinscreen’s CTO, Fursund, while he was expecting a newborn. Li claimed that if Li and Sadeghi do not check on Fursund, “he is just doing nothing,” and that “Jens [Fursund] is sick at every deadline we have.” Li stated, “out of a sudden [sic] he [Fursund] had a child” and attributed Fursund’s alleged lack of performance to having a baby. On information and belief, Li’s resentment toward Fursund was because Fursund prioritized his family over work during the weekends. Li told Sadeghi that Fursund was a “bad hombre” because “he doesn’t work on the weekends.” Li later claimed, on May 23, 2017, that “Jens [Fursund]’s baby has cost Pinscreen a shit ton of money.” In order to clarify Fursund’s performance, Sadeghi suggested that Li ask Fursund to share detailed progress reports with Li and Sadeghi. Furthermore, Sadeghi suggested that Li “make sure he [Fursund] doesn't feel micromanaged or disrespected.” (Exhibits F10, F11)

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   239.    Pinscreen committed further labor law violations after wrongfully terminating Sadeghi by withholding his business expense reimbursements in violations of California Labor Code § 2802. Pinscreen also phrased the purpose of a check mailed to Sadeghi for late wage payment penalties as a settlement offer “to resolve any wage issues,” in violation of California Labor Code § 203.

Li’s and Pinscreen’s Immigration Law Violations

   240.    On information and belief, Li was ineligible to work at Pinscreen as its CEO and has performed work for the company illegally because Li did not have a work visa for Pinscreen. On information and belief, Li is not a US Citizen, his permanent residency (i.e. green card) application has been rejected, and he lacks a proper visa to perform any role at Pinscreen. On information and belief, Li has an H-1B visa sponsored by USC, which only allows him to work at the university and not at Pinscreen. In response to Sadeghi’s inquiry about Li’s work authorization and eligibility, Li claimed that he does not need a visa to work for Pinscreen because he is not receiving any salary from the company. Li’s working at Pinscreen without a proper visa would violate the Immigration Reform and Control Act of 1986.

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   241.    On information and belief, Li pressured other Pinscreen employees to perform work for Pinscreen illegally including without a work visa, before their work visa’s start date or while employed at other companies as summer interns. On information and belief, at least one of Pinscreen’s employees illegally performed work for the company without a proper work visa. On information and belief, at least one of Pinscreen’s employees illegally performed work for the company before their work visa’s start date. On information and belief, at least one of Pinscreen’s employees illegally performed work for Pinscreen while hired as a summer intern at another company.

   242.    On information and belief, Pinscreen’s CFO, Yen-Chun Chen, illegally performed work for Pinscreen before her work visa’s start date. Yen-Chun Chen admitted in Facebook messages to Sadeghi that she did not have a proper work visa to perform work for the company as of February 7, 2017. However, Yen-Chun Chen had performed work for Pinscreen prior to that date, including the paperwork for Sadeghi’s hiring processes. (Exhibit F12, F13)

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   248.    On March 9, 2017, Sadeghi raised concerns about Pinscreen’s immigration law violations and requested that Li consult Pinscreen’s counsel to ensure Pinscreen’s compliance. In response, Li stated that he is “pretty sure that it's OK” and that he will “double check with the lawyers.”

   249.    On June 28, 2017, Sadeghi confronted Li about Pinscreen’s immigration law violations again. Sadeghi then followed up to inquire about the response from company's counsel. Li refused to give a response from Pinscreen’s counsel and told Sadeghi:

   250.    [June 28, 2017] Li: “You do not need to worry about these issues. Let me handle them.”

Li’s and Pinscreen’s Retaliation and Wrongful Termination of Sadeghi

   251.    Since Li had promised to address Sadeghi’s concerns after Pinscreen’s SIGGRAPH 2017 RTL demo, Sadeghi requested, on Sunday, August 6, 2017, through e-mail to Li and Yen-Chun Chen, to set up a meeting with Li “to talk about multiple important topics.” Li agreed to have the meeting the next day, on Monday, August 7, 2017, at 5 p.m.:

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   257.    [August 7, 2017] Li: “Maybe I don’t want to further damage your reputation.”

   258.    [August 7, 2017] Li: “I don’t think you need to worry about these anymore.”

   259.    Sadeghi received the termination letter within his first working hour after Pinscreen’s fabricated RTL demo, which was during the meeting that Sadeghi had previously requested to discuss “multiple important topics” regarding Li’s and Pinscreen’s unlawful activities.

   260.    During the meeting, Sadeghi requested to meet Pinscreen’s full board of directors, including Kim, before the termination decision was final, to which Li responded, “sure.”

   261.    In response to Sadeghi’s inquiry for the reason of the termination, Li and Yen-Chun Chen stated:

   262.    [August 7, 2017] Sadeghi: “Tell me what are the reasons?”

   263.    [August 7, 2017] Li: “I don’t have to answer”

   264.    [August 7, 2017] Li: “I don’t have to tell you why”

   265.    [August 7, 2017] Li: “I think we are too small. We are not like Google.”

   266.    [August 7, 2017] Yen-Chun Chen: “The main reason is that we are too small for you.”

   267.    Sadeghi’s termination letter titled “Termination Information and Severance Agreement and General Release” stated that “the Company appreciates your service and is prepared to offer you severance in exchange for a release.” The letter did not mention any reason for the termination and was signed by Li and Yen-Chun Chen. (Exhibit H)

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   268.    Pinscreen’s “Severance Agreement and General Release of Claims” letter offered Sadeghi one-month compensation in the amount of $13,750 in exchange for a release of claims and was signed by Li; Sadeghi did not sign Pinscreen’s severance offer. (Exhibit I)

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   269.    On August 9, 2017, two days after the termination, Sadeghi’s counsel requested Sadeghi’s “personnel file and all other records which Pinscreen maintains relating to Mr. Sadeghi’s employment, including without limitation, employee handbooks, policies, procedures, and investigative reports” pursuant to Labor Code § 1198.5, as well as “all documents Mr. Sadeghi signed that relate to his employment by Pinscreen” pursuant to California Labor Code § 432. Pinscreen’s response, dated September 8, 2018, contains no document whatsoever indicating any concerns with Sadeghi’s performance or employment. Pinscreen’s response contained no employee handbook, company policies, or codes of conduct. Sadeghi’s counsel also mentioned that Sadeghi “may have, among other things, a Labor Code § 1102.5 whistleblower retaliation claim and a claim for wrongful termination in violation of public policy” and demanded Pinscreen to “act immediately to preserve potentially relevant Electronically Stored Information (‘ESI’).”

   270.    There is no mention of any reason for Sadeghi’s termination in his employment personnel file, in his termination letter, or in his severance offer. There is no mention of any concern with Sadeghi’s performance or any other issue bearing on his qualities as an employee. Sadeghi received the termination letter “unexpectedly” as confirmed by Sadeghi’s statement in his Unemployment Insurance Claim application, filed on August 13, 2017. Employment Development Department (“EDD”) consequently approved Sadeghi’s application, on information and belief, after verifying the information provided by Sadeghi with Pinscreen.

   271.    [August 13, 2017] Sadeghi: “I received the termination and general release letter on Monday 8/7/2017 unexpectedly.”

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   272.    Sadeghi’s termination was in retaliation for his objections to Li regarding Li’s and Pinscreen’s illegal practices and in violation of California’s whistleblowing protection laws provided in California Labor Code § 1102.5.

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Defendants’ Assault and Battery on Sadeghi

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   281.    [August 7, 2017] Sadeghi to Li and the other defendants: “Don’t touch me. Don’t touch me.”

   282.    The battery, on information and belief, has been captured on the security cameras of the building and the recordings have been preserved by the building security team. The security officers on duty described the battery as Sadeghi being “grabbed,” “brought to the ground,” and “taken to the ground” by Pinscreen employees.

   283.    During the battery, Sadeghi suffered injuries to his eye and his previously dislocated shoulder, requiring medical attention and multiple physical therapy sessions.

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Defendants’ Post Termination Violations

   285.    After Sadeghi’s termination, Pinscreen withheld business expense reimbursements including Sadeghi’s COBRA health insurance premiums despite prior written agreements. Pinscreen has subsequently acknowledged that reimbursements were owed but refused to pay them unless there was a successful settlement and/or Mutual Non-Disclosure Agreement (“MNDA”). After more than nine months delay, Pinscreen paid only a small portion of the past due reimbursements, in breach of Sadeghi’s contract, violation of prior written agreements, and in violation of California Labor Code § 2802. (Exhibits J3, J5)

   286.    Additionally, Pinscreen delayed paying Sadeghi his final wage payments, which according to California Labor Code § 203, entitled Sadeghi to waiting time penalties. On August 16, 2017, Pinscreen sent Sadeghi an undated letter with no signature, as well as a check for the late wage payment penalties in the amount of the waiting time penalties owed. Pinscreen phrased the purpose of the check as a settlement offer “to resolve any wage issues.” Sadeghi’s counsel requested Pinscreen, multiple times, including September 17, 2017, and December 29, 2017, to reissue another check for the waiting time penalties only and to exclude the settlement agreement verbiage. Pinscreen subsequently refused to do so and stated through Kim, on January 16, 2018, that reissuing a check would be “subject to execution of a mutually agreeable MNDA by and between Pinscreen and you [Sadeghi]” in violation of California Labor Code § 203. After more than nine months delay, on May 23, 2018, Pinscreen reissued another check without the settlement agreement verbiage. Sadeghi is entitled to his salary for 30 additional days. (Exhibits J2, J5)

   287.    The letter of Sadeghi’s counsel on August 9, 2017, 2 days after the termination, requested for Sadeghi’s personal property, pointing out that Sadeghi’s personal belongings are “valuable” and “fragile.” Nonetheless, Pinscreen damaged Sadeghi’s personal property remaining at Sadeghi’s desk at Pinscreen’s office. In storing it negligently, Pinscreen broke Sadeghi’s handmade sculpture, which has sentimental value. Sadeghi has demanded Pinscreen to reimburse him for the personal property damages. Subsequently, Pinscreen has refused to do so and stated through Kim, on January 16, 2018, that such reimbursement would be “subject to execution of a mutually agreeable MNDA” between Pinscreen and Sadeghi. (Exhibits J1, J5)

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   288.    On January 16, 2018, Kim, a co-founder and a board member of Pinscreen, joined Sadeghi for a Google Hangout video conference call to talk about Sadeghi’s employment related claims. During the call, Sadeghi asked Kim whether he was aware of Li and Pinscreen’s data fabrication. Kim did not deny the fabrication in his response: (Exhibit J4)

   289.    [January 16, 2018] Sadeghi: “I don’t know if you knew about the data fabrication. Did you?”

   290.    [January 16, 2018] Kim: “Not in real time.”

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   291.    After the video conference, on the same day, Kim send Sadeghi an e-mail with subject line “Re: Iman Sadeghi - Notice of Claim and Litigation Hold.” In his e-mail, Kim stated that Pinscreen would provide a check for the reimbursements, reissue a check to substitute for previous time penalty check, and provide a check for the personal property damage “subject to execution of mutually agreeable MNDA by and between Pinscreen and you.” (Exhibit J5)

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Li’s Unfitness, Incompetence, and Ineligibility to Work for Pinscreen

   294.    Li was and is unfit and incompetent to perform the duties required for the CEO role at Pinscreen due to numerous instances of fraud, data fabrication, academic misconduct, disregard for California labor laws, disregard for federal immigration laws, and other illegal practices.

   295.    On information and belief, Li was and is ineligible to perform any role at Pinscreen due to his lack of proper work visa.

   296.    Li’s actions have been reckless, vicious, and have caused harm to Sadeghi, other Pinscreen employees, and Pinscreen’s investors and stakeholders.

   297.    Sadeghi was harmed and Pinscreen is liable because Pinscreen negligently hired and retained an unfit, incompetent, and ineligible CEO, did not properly train him, did not properly supervise him, and did not properly verify his eligibility.

The End



Truth Challenge:

USC v. Dr. Hao Li Truth Challenge


I, Dr. Iman Sadeghi, filed a verified complaint on June 11, 2018, and the verified amended complaint on October 5, 2018, in the Superior Court of California against Pinscreen Inc. and its CEO Dr. Hao Li who is an assistant professor at University of Southern California (USC).

I allege and support by conclusive evidence that Li perpetrated Fraud and Deceit, Data Fabrication, and Academic Misconduct.

Li responded on his social media on July 19, 2018 and alleged that I fabricated communications and evidence for the lawsuit.

I appealed to the scientific community on October 8, 2018 to challenge Li to identify any communication or item of evidence within the verified amended complaint that he alleges to be “fabricated.”

USC Annenberg Media reported on October 30, 2018 that “Li doesn't refute the existence of the screenshotted messages [where he admits data fabrication], but said in a recent email to Annenberg Media that they are easy to misinterpret.” Li also stated that “the messages and screenshots are presented in a manner that allows them to be taken out of context quite easily.”

Since Li claimed to USC Annenberg Media that context gives the screenshots a meaning other than the obvious, I appeal to UCS, USC Viterbi School of Engineering, USC Viterbi Department of Computer Science, USC Graphics, USC Institute for Creative Technologies (ICT), USC ICT Vision and Graphics Lab, USC News, and USC Annenberg Media as well as USC students, alumni, faculties, and affiliates to challenge Li to explain the context for his use of the word “cheating,” which he used to characterize Pinscreen’s conduct:


USC v. Dr. Hao Li Truth Challenge:
[ USC-v-Dr-Hao-Li-Truth-Challenge.pdf ]
USC v. Dr. Hao Li Truth Challenge


Scientific Integrity v. Pinscreen Truth Challenge


I, Dr. Iman Sadeghi, filed a verified complaint on June 11, 2018, and the verified amended complaint on October 5, 2018, in the Superior Court of California against Pinscreen Inc. et al.

I allege that Pinscreen, perpetrated Fraud and Deceit, Data Fabrication, and Academic Misconduct supported by conclusive evidence

Pinscreen, through its CEO, Dr. Hao Li, has publicly alleged that some of the communications and evidence within the lawsuit are “fabricated.”

I appeal to my coauthors, collaborators, and colleagues; my fellow scientists, academics, researchers, and engineers; Computer Science, Computer Graphics, and SIGGRAPH communities; ACM, ETH Zürich, USC, USC ICT, and USC Viterbi School of Engineering; friends, family, and individuals who value #science, #integrity, and the #truth to demand and challenge Pinscreen and its affiliates to identify any communication or item of evidence within the verified amended complaint that they allege to be “fabricated.” #truthchallenge

Pinscreen’s relevant affiliates to the lawsuit:

  • Dr. Hao Li, CEO, co-founder, and board member
  • Yen-Chun (Frances) Chen, CFO, co-founder, and board member
  • Stanley Kim, co-founder, and board member
  • Jens Fursund, CTO
  • Dr. Jaewoo Seo
  • Dr. Koki Nagano
  • Dr. Lingwei (Cosimo) Wei
  • Shunsuke Saito
  • Liwen Hu
  • Carrie Sun
  • Stephen Chen
  • Ronald Yu
  • Sitao Xiang
  • Yi Zhou
  • Han-wei Kung
  • Dr. Jun Xing
  • Kyle Morgenroth
  • Bilal Zuberi


Scientific Integrity v. Pinscreen Truth Challenge:
[ Scientific-Integrity-v-Pinscreen-Truth-Challenge.pdf ]
Scientific Integrity v. Pinscreen Truth Challenge

Dr. Iman Sadeghi v. Dr. Hao Li Truth Challenge


I, Dr. Iman Sadeghi, filed a verified complaint on June 11, 2018 in the Superior Court of California against Pinscreen Inc. and its Chief Executive Officer, Dr. Hao Li, who is an assistant professor at University of Southern California.

I allege that Li perpetrated Fraud and Deceit, Data Fabrication, and Academic Misconduct supported by conclusive evidence.

Li responded in the LA Times on June 20, 2018 that "All the allegations are 100% False."

I challenge Li to confirm his position on a small subset of community relevant allegations, under penalty of perjury, by signing the attached form and sharing it publicly on his social media.

I appeal to my coauthors, collaborators, and colleagues; my fellow scientists, academics, researchers, and engineers; Computer Science, Computer Graphics, and SIGGRAPH communities; friends, family, and individuals who value #science, #integrity, and the #truth to invite Li to accept the challenge. #truthchallenge

Dr. Iman Sadeghi v. Dr. Hao Li Truth Challenge:
[ Dr-Iman-Sadeghi-v-Dr-Hao-Li-Truth-Challenge.pdf ]
Dr. Iman Sadeghi v. Dr. Hao Li Truth Challenge

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Reach:

Reach of the #truthchallenge within the first week of anouncement:
dr-iman-sadeghi-v-pinscreen-inc-et-al-reach

Discussion:


Text Reference:

Dr. Iman Sadeghi v. Pinscreen Inc., et al., Verified ComplaintSuperior Court of the State of California, County of Los Angeles, Central District., June 11, 2018.

Dr. Iman Sadeghi v. Pinscreen Inc., et al., Verified Amended ComplaintSuperior Court of the State of California, County of Los Angeles, Central District., October 5, 2018.


BibTex Reference:


	@article{Dr-Iman-Sadeghi-v-Pinscreen-Inc-et-al-verified-complaint,
		title = {Dr. Iman Sadeghi v. Pinscreen Inc., et al. Verified Complaint},
		publisher = {Superior Court of the State of California, County of Los Angeles, Central District.},
		pages = {1--160},
		month = {June},
		day = {11},
		year = {2018},
	}

	@article{Dr-Iman-Sadeghi-v-Pinscreen-Inc-et-al-verified-amended-complaint,
		title = {Dr. Iman Sadeghi v. Pinscreen Inc., et al. Verified Amended Complaint},
		publisher = {Superior Court of the State of California, County of Los Angeles, Central District.},
		pages = {1--274},
		month = {October},
		day = {5},
		year = {2018},
	}
				

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