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IN THE CIRCUIT COURT FOR THE STATE OF OREGON

FOR THE COUNTY OF CLACKAMAS

For her complaint, and on behalf of herself and all other similarly situated, plaintiff alleges:

PARTIES

CATHY BUCHAL is a resident of Clackamas County, Oregon, who files this complaint on behalf of herself and all others similarly situated.

Defendants fall generally within four categories, as alleged in more detail below: (1) Casino Defendants, being entities that operate websites which function to turn the personal computers of class members into gambling devices; (2) Gambling Software Defendants, being entities that provide software utilized by Casino Defendants; (3) Billing Alter Egos, entities through which Casino Defendants collect funds from class members; and (4) Credit Card Defendants, who transfer funds to Billing Alter Egos. As alleged below, these defendants, working in concert, form racketeering enterprises that prey upon class members in Oregon and elsewhere.

All defendants, except the Credit Card Defendants, attempt to conceal their geographic location and the identity of their owners. This is accomplished by doing business under multiple names, under assumed names, through websites that nowhere disclose the true identity of the defendant, providing telephone numbers that are answered by persons who claim ignorance of the identities of the entities whose business they are conducting, and maintaining offshore mailing addresses and contacts under different names. Such conduct is deliberate, and calculated to evade civil and criminal liability for business operations such defendants know to be illegal in most of the jurisdictions in which they do business.

Casino Defendants

Oregonians surfing the Internet through browsers access websites operated by defendants that transmit software to their computers that allows their personal computers to function as "gambling devices" within the meaning of ORS 167.117(8):

"any device, machine, paraphernalia or equipment that is used or usable in the playing phases of unlawful gambling, whether it consists of gambling between persons or gambling by a person involving the playing of a machine."

The entities Network Solutions (http://www.networksolutions.com) and Open SRS (http://www.opensrs.org), not parties to this action, maintain services through which defendants and others register their domain names so as to permit Oregonians and others to link to their computers, known as servers, through the World Wide Web. These two entities operate services called "whois" by which anyone on the Internet can look up the registered owner of such domain names, and obtain contact information. As a practical matter, these services form the only source of information available concerning the proprietors of websites that do not disclose such information within the pages visible to visitors.

Defendant ASTRA CASINO is an entity operating at all relevant times through http://www.astracasino.com. This website does not disclose the precise nature of the entity, other than to describe it as an "offshore gambler web site casino on net for online gambling". The "whois" lookup reports that the domain name is registered to defendant DOMAIN NAME SERVICES LIMITED, giving defendant PETER J. ASTELL-BURT, both with addresses on the Isle of Man, as contacts. ASTRA CASINO has employed defendant CYBER CAFÉ, INC., and/or its alter ego defendant IK2, INC. as a Billing Alter Ego. On or about March 16, 2001, ASTRA CASINO began to employ defendant SUREFIRE COMMERCE INC. as a Billing Alter Ego.

Defendant KING NEPTUNE'S CASINO is an entity operating at all relevant times through http://www.kingneptunecasino.com. This website does not disclose the precise nature of the entity, other than to describe it as an "offshore gambler web site casino on net for online gambling". The "whois" lookup reports that the domain name is registered to defendant DOMAIN NAME SERVICES LIMITED, giving defendant PETER J. ASTELL-BURT with an address on the Isle of Man as the contact. KING NEPTUNE'S CASINO has employed defendant CYBER FINANCE INVESTMENTS as a Billing Alter Ego.

Defendant LIBERTY CASINO is an entity operating at all relevant times through http://www.libertycasino.com. This website does not disclose the precise nature of the entity, other than to describe it as an "offshore gambler web site casino on net for online gambling". The "whois" lookup reports that the domain name is registered to defendant DOMAIN NAME SERVICES LIMITED, giving defendant PETER J. ASTELL-BURT with an address on the Isle of Man as the contact. LIBERTY CASINO has employed defendant MERCANTRADE (PTY) LTD as a Billing Alter Ego.

Defendant BOSS CASINOS LTD. is an entity operating at all relevant times as the "Gold Club Casino" through http://www.goldclubcasino.com. The "whois" lookup for that domain gives an address in St. John's, Antigua for defendant BOSS CASINOS LTD., as well as care of defendant BOSSMEDIA AB in Sweden. Upon information and belief, these two defendants are alter egos. BOSS CASINOS LTD has employed defendant WEBDOLLAR INC. as a Billing Alter Ego.

Defendant SUNSET TECHNOLOGY INC. is an entity operating at all relevant times as the "Grand Online Casino" at the URL http://www.grandonline.com. The "whois" lookup for that domain gives an address in St. John's, Antigua for defendant SUNSET TECHNOLOGY INC. SUNSET TECHNOLOGY INC. has employed defendant SULLIVAN BROWNSTONE LTD. as a Billing Alter Ego.

Both SUNSET TECHNOLOGY INC. and BOSS CASINOS LTD., have post office boxes in Woods Mall, also known as Woods Centre on Friar's Hill Road, St. John's, Antigua. They utilize common computer servers with defendant ALTER EGO INC., which also has an address in St. John's. Upon information and belief, these two defendants are alter egos of each other and defendant ALTER EGO INC.

Defendant INTERTAINET OVERSEAS LICENSING LTD., with an address in Cyprus, operates "Intercasino" through http://www.intercasino.com, and holds over fifty other domains for gambling purposes The "whois" lookup for that domain gives an address in Toronto of defendant CRYPTOLOGIC INC. as the technical contact. INTERTAINET OVERSEAS LICENSING LTD. has employed defendant CRYPTOLOGIC INC. as a Billing Alter Ego.

Defendant LASSETERS HOTEL CASINO is an entity operating at all relevant times at the URL http://www.lasseters.com.au. This website does not disclose the precise nature of the entity, other than to describe it as "licensed by the Northern Territory Government of Australia". LASSETERS HOTEL CASINO, unlike all other defendants, does not appear to employ a Billing Alter Ego.

Defendant ENGLISH HARBOUR ENTERTAINMENT LTD, is an entity doing as "English Harbour Online Casino" through http://www.englishharbour.com and http://www.englishharborcasino.com, as "Caribbean Gold Casino" through http://www.caribbeangold.com, and as “Silver Dollar Casino” through http://www.silverdollar.com. These websites do not disclose the precise nature of the entities, other than to describe them as "legally licensed in Antigua and Barbuda", and operating in St. John's, Antigua. The "whois" lookup contains no identification of any individual, giving defendant ENGLISH HARBOUR ENTERTAINMENT LTD., with an address in St. John, as the billing contact and defendant 3748472 CANADA INC., a federally-chartered Canadian corporation, with an address on Mowat Avenue in Toronto, as the technical contact. ENGLISH HARBOUR ENTERTAINMENT LTD. has employed defendant EC EXCHANGE INC. as its Billing Alter Ego.

ENGLISH HARBOUR ENTERTAINMENT LTD.'s website declares that "English Harbor Casino also recognizes issues concerning problem and underage gambling. We constantly monitor our games to identify behavior indicative of problem gambling." Defendant ENGLISH HARBOUR ENTERTAINMENT LTD never notified plaintiff that she displayed conduct indicative of problem gambling.

Defendant FORWARD SLASH INTERNET, INC., a New York corporation, upon information and belief does business as "The Gaming Club" through http://www.gamingclub.com, "River Belle Casino" through http://www.riverbelle.com, and "Lucky Nugget Online Casino" through http://www.luckynugget.com. These websites do not disclose the precise nature of these entities, other than to describe them as "online casinos". Defendant FORWARD SLASH INTERNET, INC. owns at least eleven domains named for gambling purposes. "Forward Slash" with an address in Waterfront, South Africa, is identified as a contact for these domains. Defendant FORWARD SLASH INTERNET INC. has employed defendant MERCANTRADE (PTY) LTD as its Billing Alter Ego.

Defendant IBC SA, a South African business, does business as "Fortune Lounge Casinos", under the additional names "7 Sultans Casino", "Vegas Palms Casino", "Royal Vegas Casino", and "Fortune Room Casino", operating at all relevant times through http://www.7sultans.com, http://www.vegaspalms.com, http://www.royalvegas.com, and http://www.fortuneroom.com. These websites do not disclose the precise nature of the entities, other than to describe them as "online casinos", legally licensed by the Kahnawake Gaming Commission, Mohawk Territory of Kahnawake, Canada. Defendant IBC SA owns at least 43 domains named for gambling purposes. In addition, IBC SA has, doing business as "Seven Sultans Casino", received funds directly from plaintiff's credit card company.

Defendant IBC SA also does business as "King Solomon's Casino" operating at all relevant times through http://www.kingsolomons.com and www.kingsolomonscasino.com. The website states that the Casino operates under a license granted by the Government of the Netherlands Antilles. Based upon the "whois" lookup for these domains, defendant NETAINMENT N.V., with an address in Vaduz, Liechtenstein, is an alter ego of IBC SA, as is defendant AQUA ONLINE (INT.) LTD., with an address on Gordon House Road in London, as is defendant VR SERVICES (PTY.) LTD., with an address in Durban, South Africa. Defendant AQUA ONLINE (INT.) LTD. is the registered owner of at least 2 other domains named for gambling purposes; defendant VR SERVICES (PTY.) LTD. is the registered owner of more than fifty such domains. IBC SA, doing business as "King Solomon's Casino", uses defendant "CYBER FINANCE INVESTMENTS" as a Billing Alter Ego.

Defendant UNIVERSAL SPHERES INC., doing business as "Golden Palace Online Casino" is an entity operating at all relevant times through http://www.goldenpalace.com. This website does not disclose the precise nature of the entity, other than to describe it as an "online casino", "legally licensed by the Kahnawake Gaming Commission, Mohawk Territory of Kahnawake, Canada, and by the governments of Antigua and Barbuda", with an address in St. John's, Antigua. UNIVERSAL SPHERES INC. has employed defendant SULLIVAN BROWNSTONE LTD. as its Billing Alter Ego.

Each of the Casino Defendants does business in the State of Oregon through the Internet, and has ongoing contacts with Oregon residents by controlling the screens of their personal computers, conducting gambling transactions between their servers and the computers of Oregon residents, conducting business through e-mails to Oregon residents, and, in some cases, causing gifts and enticements to gamble to be delivered to Oregon residents. Indeed, plaintiff first encountered the Casino Defendants through unsolicited e-mail advertising (also known as "spam") directed at her Oregon-based e-mail account, which offered free money to play. The Casino Defendants also transmit "web banner" advertising to the personal computers of Oregon residents viewing non-gambling websites.

Upon information and belief, each of the Casino Defendants knows the location of their customers, because, among other things, the credit card billing addresses are available in connection with the verification process. Many Casino Defendants post lists of winners identifying their geographic locations. These lists frequently identify Oregon as the location of a winner.

The Casino Defendants can easily implement procedures that would block transactions with customers with billing addresses where gambling is illegal.

Gambling Software Defendants

MICROGAMING SYSTEMS (UK) LTD., with an address in London, recruits individuals to operate casinos utilizing its software technology, and retains the ability to monitor and/or control casino operations through the linking of virtual slot machines into a "progressive" system called "Cash Splash", advertised through http://www.cashsplash.com, in which players in ostensibly separate casinos compete for a large jackpot funded by collections through all such machines.

Defendant MICROGAMING SYSTEMS (UK) LTD provides gambling software to defendant ASTRA CASINO, DOMAIN NAME SERVICES LIMITED, PETER J. ASTELL-BURT, ENGLISH HARBOUR ENTERTAINMENT LTD., FORWARD SLASH INTERNET, INC., IBC SA, NETAINMENT N.V., AQUA ONLINE (INT.) LTD., and VR SERVICES (PTY.) LTD. Defendant MICROGAMING SYSTEMS (UK) LTD. also offers software technology called "Cash Check", advertised through http://www.cashcheck.com "to allow players to view their complete financial transaction history at any casino powered by Microgaming Systems". Defendant VRSERVICES (PTY) LTD. with an address in South Africa is a contact reported by "whois" for http://www.cashcheck.com. MICROGAMING SYSTEMS (UK) LTD. also operates the site http://www.jackpotmadness.com to market its casinos.

Defendant WAGERLOGIC LIMITED, with an address in Cyprus, supplies gambling software to defendant INTERTAINMENT OVERSEAS LICENSING LTD. and other online casinos. Upon information and belief, WAGERLOGIC LIMITED is an alter ego of CRYPTOLOGIC INC.

Each of the Gaming Software Defendants does business in the State of Oregon through the Internet, and has ongoing contacts with Oregon residents by controlling the screens of their personal computers, and conducting gambling transactions between their servers and the computers of Oregon residents.

Billing Alter Egos

All but one of the Casino Defendants typically collects funds from class members through Billing Alter Egos, also known as "bank processors", who collect funds transmitted from class members by the Credit Card Defendants.

Each of the websites maintained by the Casino Defendants contains or links to a "bank" page or screen (or generates one through software transmitted to the class member), which when transmitted to the browser of a class member's personal computer makes the screen resemble an automated teller machine. The bank page or screen typically has buttons for pre-set amounts of cash to be withdrawn from an account previously identified by the class member. By pressing a button, the class member can, subject to immediate verification by the Credit Card Defendants, incur indebtedness on the credit cards and transfer cash to the Casino Defendant. The bank page or screen also informs the class member how the withdrawal will appear on their bill.

In most cases, in response to input from a class member, the Casino Defendant will transmit a payment request to the Billing Alter Ego; the Billing Alter Ego then transmits the request to the appropriate card system (typically MasterCard or VISA), the card system contacts the Credit Card Defendant (or its issuing bank) to request payment authorization; the Credit Card Defendant (or its issuing bank) approves the payment and transmits it to the Billing Alter Ego. In some cases, the payment is transmitted directly to the Casino Defendant.

In many cases, the Billing Alter Egos exercise apparent control over the Casino Defendants. For example, if a class member wishes to raise a weekly betting limit, and contacts the Casino in an attempt to do so, the Casino Defendant will typically refer him or her to the associated Billing Alter Ego. If a class member contacts a Casino Defendant in an attempt to change the credit card to be charged, the Casino Defendant will typically refer him or her to the associated Billing Alter Ego.

Defendant IK2, INC., is a Maryland corporation and Billing Alter Ego doing business through http://www.tekcash.com as "Cyber Café". The website represents that "Cyber Café deposits are held at an FDIC or CDIC insured North American Bank". Upon information and belief, defendant IK2, INC. is the alter ego of defendant CYBER CAFÉ, INC., a name that has appeared on credit card transfers conducted in connection with the business name "Cyber Café". Upon information and belief, defendant BOBBY GARG, identified as the registered agent for defendant IK2, INC., is its alter ego. The "whois" lookup provides Leo Friday of Caribbean Cyber Café, St. Maarten, Netherlands Antilles, as an administrative contact. IK2, INC. collects funds from the Credit Card Defendants for gambling in connection with defendant ASTRA CASINO.

Defendant EC EXCHANGE INC. is a Billing Alter Ego doing business through http://www.ecexchange.com. Upon information and belief, defendant 3748472 CANADA INC. is an alter ego of defendant EC EXCHANGE INC.; the "whois" lookup gives the same address for both defendants in Toronto, Ontario. Upon information and belief, defendant PAUL SUDOLSKI, the sole director of defendant 3748472 CANADA INC., is the alter ego of both entities. Defendant EC EXCHANGE INC. collects funds from the Credit Card Defendants for gambling in connection with defendants ENGLISH HARBOUR ENTERTAINMENT LTD.

Defendant EHCL INC. is a Billing Alter Ego doing business through http://www.ehcl.com. The website does not disclose the nature of the entity, except to describe it as an "electronic eCash system" and to state that "all deposits are held at an FDIC insured North American Bank". The "whois" lookup gives an address for defendant in Boulder City, Nevada. EHCL INC. collects funds from the Credit Card Defendants for gambling in connection with defendants ENGLISH HARBOUR ENTERTAINMENT LTD.

Defendant WEBDOLLAR INC. is a Billing Alter Ego doing business through the URL http://www.webdollar.com. The website does not disclose the nature of the entity, except to describe it as an "electronic cash system" with deposits "held at a European bank". The "whois" lookup gives an address for defendant on Wells Road in Boulder City, Nevada (the same address as EHCL INC.). WEBDOLLAR INC. collects funds from the Credit Card Defendants for gambling in connection with defendants BOSS CASINOS LTD. and BOSSMEDIA AB. Defendant WEBDOLLAR INC. acts through defendant WEBDOLLAR LTD of P.O. Box W1627, Woods Centre, St. John's Antigua, West Indies; upon information and belief, these two entities are alter egos.

Defendant CYBER FINANCE INVESTMENTS, with an address in London, is a Billing Alter Ego doing business as "Cyber Finance Investments" through http://www.cf-investments.com. CYBER FINANCE INVESTMENTS collects funds from the Credit Card Defendants for gambling in connection with defendants IBC SA. The "whois" lookup identifies an employee of defendant AQUA ONLINE (INT.) LTD., with an address in London, as the administrative contact.

Defendant MERCANTRADE (PTY) LTD, with an address in Capetown, South Africa, is a Billing Alter Ego doing business as "Proc Cyber Services" through http://www.proc-cyber-services.com and http://www.proccyber.com. The "whois" lookup gives an address for defendant MERCANTRADE (PTY) LTD. in Capetown, South Africa. MERCANTRADE collects funds from the Credit Card Defendants for gambling in connection with defendant FORWARD SLASH INTERNET, INC. MERCANTRADE has acted through defendant MERVYN KAPLAN of 7 Richview Ct, Thornhill, ON L3T7S9 Canada who has paid funds to plaintiff and is, upon information and belief, an alter ego of defendant MERCANTRADE (PTY) LTD.

Defendant CRYPTOLOGIC INC., with an address in Toronto, is a Billing Alter Ego doing business as "Cryptologic" through http://www.cryptologic.com. Defendant CRYPTOLOGIC INC. supplies gambling software to defendant INTERTAINMENT OVERSEAS LICENSING LTD. and other online casinos.

Defendant SULLIVAN BROWNSTONE LTD., with an address on Old Parham Road in St John's, Antigua, is a Billing Alter Ego doing business as "E Cash World" through http://www.ecashworld.com. SULLIVAN BROWNSTONE LTD. collects funds from the Credit Card Defendants for gambling in connection with defendants SUNSET TECHNOLOGY INC. and UNIVERSAL SPHERES INC. Defendant SULLIVAN BROWNSTONE LTD. recently began processing transactions through SUREFIRE COMMERCE INC.

Defendant SUREFIRE COMMERCE INC. represents the latest structural innovation of the online gambling racketeers. SUREFIRE COMMERCE INC. is a Canadian company doing business as "Firecash" through http://www.firecash.com (its more traditional website is http://sfcommerce.com), and also operates under the alter ego defendant FIRECASH LTD. with an address in Montreal. SUREFIRE COMMERCE undertakes to become a billing alter ego to the Billing Alter Egos.

Plaintiff did not engage directly in any transactions involving defendant SUREFIRE COMMERCE INC., but upon information and belief, defendant SUREFIRE COMMERCE INC. became a member of the Racketeering Enterprises as alleged below at times when those Enterprises were preying upon plaintiff and other class members.

Each of the Billing Alter Egos knows that it is collecting funds for the benefit of the Casino Defendants, such funds being derived from unlawful activity as alleged herein. Each of the Billing Alter Egos extracts financial benefit from processing payments for the Casino Defendants.

Each of the Billing Alter Egos does business in the State of Oregon through the Internet, and has ongoing contacts with Oregon residents by controlling the screens of their personal computers, conducting gambling transactions between their servers and the computers of Oregon residents, conducting business through e-mails to Oregon residents, receiving telephone calls from, and making telephone calls to Oregon residents, and placing "web banner" advertising on websites frequently accessed by Oregon residents.

Credit Card Defendants

Defendant ADVANTA BANK CORPORATION, a foreign corporation, is a credit card issuer doing business in the State of Oregon. It issued plaintiff a MasterCard Executive Business Card.

Defendant CAPITAL ONE FINANCIAL CORPORATION, a foreign corporation, is a credit card issuer doing business in the State of Oregon. It issued plaintiff a Cash Rebate Program VISA card.

Defendant CHASE MANHATTAN BANK USA, N.A., a foreign corporation, is a credit card issuer doing business in the State of Oregon. It issued plaintiff a Platinum MasterCard.

Defendant FIRST USA BANK, N.A., a foreign corporation, is a credit card issuer doing business in Oregon. It issued plaintiff a First Card Platinum VISA card.

Defendant FLEET BANK, a foreign corporation, is a credit card issuer doing business in Oregon. It issued plaintiff a Fleet Platinum MasterCard.

Defendant GREENWOOD TRUST COMPANY, a foreign corporation, is a credit card issuer doing business in the State of Oregon. It issued plaintiff a Discover Platinum Card.

Defendant OREGON TELCO CREDIT UNION, an Oregon corporation, is a credit card issuer doing business in the State of Oregon. It issued plaintiff a VISA card and "KWIK" line of credit, which plaintiff utilized to pay debt incurred on the VISA card.

Defendant PROVIDIAN NATIONAL BANK, a national banking association organized and existing under the laws of the United States of America, is a credit card issuer doing business in Oregon. It issued plaintiff a VISA Platinum card.

Defendant WELLS FARGO, a foreign corporation, is a credit card issuer doing business in Oregon. It issued plaintiff a Wells Fargo Platinum MasterCard.

Each of the Credit Card Defendants advanced credit to plaintiff with reckless disregard of plaintiff's ability to repay funds advanced.

Each of the Credit Card Defendants, with the exception of OREGON TELCO, made unsolicited offers of credit to plaintiff, in most if not all cases through the mail and through direct telephone solicitations.

Upon information and belief, each of the Credit Card Defendants maintains ongoing financial relationships with one or more of the Billing Alter Egos, and will continue to do so unless enjoined by the Court.

Each of the Credit Card Defendants knows or has reason to know that such Billing Alter Egos have collected, and continue to collect, funds for the Casino Defendants with which they are associated, as pleaded below. Indeed, some of the Credit Card Defendants treat transactions involving Internet gambling as cash advances rather than purchases, based on such knowledge. Others, such as defendant WELLS FARGO, have purported to require their customers, as a matter of contract, not to use their cards "for any unlawful purpose[; f]or example, funding any account set up to facilitate online gambling" (effective December 1, 2000).

Upon information and belief, the Credit Card Defendants refuse to transfer funds to Billing Alter Egos in connection with players from certain parts of South East Asia, Eastern Europe and Southern Africa. At all relevant times, the Credit Card defendants have been technologically capable of refusing to enable Internet gambling transactions for their clients who reside in locations where such gambling is illegal.

RACKETEERING ENTERPRISES

This complaint alleges conduct that is the very object of the Oregon Racketeer Influenced and Corrupt Organization Act (ORICO) 's anti-racketeering laws, because the Casino Defendants, Gambling Software Defendants, and Billing Alter Egos have formed racketeering "enterprises" that prey upon Oregon citizens by a "pattern of racketeering activity" within the meaning of ORS Chapter 166. In the alternative, the Credit Card Defendants also constitute members of such racketeering "enterprises". These "enterprises" constitute the vehicle through which the unlawful pattern of racketeering activity, alleged more specifically below, has been committed, and continues to be committed, against class members.

The Oregon statutes against gambling aim broadly for an enterprise approach to remedying the evil of gambling. In particular, they call for a broad reading of what it means to "promote unlawful gambling":

"'Promote unlawful gambling" means that a person, acting other than solely as a player, engages in conduct that materially aids any form of unlawful gambling. Conduct of this nature includes, but is not limited to, conduct directed toward the creation or establishment of the particular game, contest, scheme, device or activity involved, toward the acquisition of premises, paraphernalia, equipment or apparatus therefore, toward the solicitation or inducement of persons to participate therein, toward the conduct of the playing phases thereof, toward the arrangement of any of its financial or recording phases or toward any other phase of its operation." ORS 167.117(17)

Predicate Acts of Racketeering (Oregon Law)

All defendants have engaged in conduct which constitutes "unlawful gambling in the first degree" within the meaning of ORS 167.127, a Class C Felony: "A person commits the crime of unlawful gambling in the first degree if the person knowingly promotes or profits from unlawful gambling."

All defendants other than the Credit Card Defendants have engaged in conduct which constitutes "possession of a gambling device" within the meaning of ORS 167.147(1), a Class A misdemeanor, because each defendant "conducts or negotiates a transaction affecting or designed to affect . . . use of . . . any other gambling device, believing that the device is to be used in promoting unlawful gambling activity", when such defendant electronically and intentionally controls the screens of the personal computers owned by class members to transform them into gaming devices, or processes transactions initiated by such devices.

All of the defendants have engaged in conduct which constitutes the collection of an "unlawful debt" within the meaning of ORS 166.715(7), in that the gambling losses alleged below produced debt that was legally unenforceable in Oregon in whole or in part because the debt was incurred in violation of ORS 167.117 to 167.164, relating to gambling, and incurred in gambling activity in violation of federal law, and defendants sought to collect such debt.

All defendants have engaged in the crime of "laundering a monetary instrument", a class B felony under Oregon law, in that they have knowingly conducted financial transactions that involve the proceeds of unlawful activity, as alleged herein, knowing that the transactions were designed, in part, to conceal or disguise the nature, location, ownership or control of the proceeds of unlawful activity, as alleged below.

Upon information and belief, each of the Casino Defendants has engaged in "cheating", within the meaning of ORS 167.167, a Class C felony, by arbitrary adjustments to the ostensibly random plays of the games they control, interrupting the play of their clients, and/or refusing to pay winnings.

Predicate Acts of Racketeering (Federal Law)

Pursuant to ORS 166.715(6)(b), conduct defined as "racketeering activity" within the meaning of 18 U.S.C. § 1961(B)-(E) is "racketeering activity" for purposes of ORICO. Violations of each of the federal statutes pleaded herein are defined as "racketeering activity" for purposes of 18 U.S.C. § 1961(B)-(E).

The Casino Defendants have engaged in conduct which violates the Interstate Wire Act, 18 U.S.C. § 1081-84, as amended in the Interstate Gaming Prohibition Act, in that they are "engaged in the business of betting or wagering . . . [and using] a wire communication facility for the transmission in interstate or foreign commerce" of communications "which entitled the recipient to receive money or credit as a result of bets or wagers". The losses alleged herein are all comprised of bets transmitted over wires in interstate and/or foreign commerce.

The Casino Defendants have engaged in conduct that violates the Interstate Transportation of Wagering Paraphernalia Act, 18 U.S.C. 1953, which prohibits distributing materials for illegal gambling activity in interstate or foreign commerce. The software and data packets transmitted to Class Members to control the screens of their personal computers constitute wagering paraphernalia within the meaning of the Act.

The Credit Card Defendants and Billing Alter Egos have engaged in conduct which violates the Interstate Wire Act, 18 U.S.C. § 1081-84, as amended in the Interstate Gaming Prohibition Act, in that they have used wire communication facilities to transmit money or credit as a result of bets or wagers.

All defendants have engaged in conduct that violates the Travel Act, 18 U.S.C. § 1952, which makes it illegal to use "any facility in interstate or foreign commerce with the intent to perform an unlawful activity, which includes any business enterprise involving gambling".

Identification of Racketeering Enterprises

For purposes of this complaint, the enterprises alleged herein are identified as "Racketeering Enterprises" and following associations of defendants constitute racketeering "enterprises" for ORICO purposes:

(a) The "EHCL" Enterprise, consisting of defendants 3748472 CANADA INC., PAUL SUDOLSKI, EHCL INC., ENGLISH HARBOUR ENTERTAINMENT LTD., EC EXCHANGE INC., WEBDOLLAR INC., BOSS CASINOS LTD., and BOSSMEDIA AB, who are associated in fact as alleged above and, upon information and belief, constitute alter egos of each other and act in concert and conspire to commit the predicate acts of racketeering alleged herein. Credit card transactions associated with the operations of this enterprise are identified as "ECHL, Boulder City", "EHCL, Alpharetta, GA", "EC Exchange/EHCL", "MPACT_ECX", and "SFC_ECX". Credit card transactions associated with the operations of this enterprise as conducted under the "Webdollar" name are identified as "Gold Club Web dol", "GCC Webdollar", and "Web D".

(b) The "Proc Cyber" Enterprise, consisting of defendants MERVYN KAPLAN and MERCANTRADE (PTY) LTD., who are associated in fact as alleged above and, upon information and belief, constitute alter egos of each other and act in concert and conspire to commit the predicate acts of racketeering alleged herein. Credit card transactions associated with the operations of this enterprise are identified as "Proc Cyber Services", "MPACT_PCS", "SFC_PCS", "PCS, LTD", "Proc", and "www.proccy / Montreal"

(c) The "Cyber Café" Enterprise, consisting of defendants BOBBY GARG, IK2, INC., and CYBER CAFÉ, INC., who are associated in fact as alleged above and, upon information and belief, constitute alter egos of each other and act in concert and conspire to commit the predicate acts of racketeering alleged herein. Credit card transactions associated with the operations of this enterprise are identified as "Cyber Café, Inc.", "MPACT_C3I", "SFC_C3I".

(d) The "ECash World" Enterprise, consisting of defendant SULLIVAN BROWNSTONE LTD., UNIVERSAL SPHERES INC., ALTER EGO INC., SUNSET TECHNOLOGY INC., who are associated in fact as alleged above and, upon information and belief, constitute alter egos of each other and act in concert and conspire to commit the predicate acts of racketeering alleged herein. Credit card transactions associated with the operations of this enterprise are identified as "ECash World", "MPACT_ECash World", and "SFC_ECash World".

(e) The "CFI" Enterprise, consisting of defendants CYBER FINANCE INVESTMENTS, IBC SA, AQUA ONLINE (INT.) LTD., FORWARD SLASH INTERNET, INC., NETAINMENT, N.V., and VR SERVICES (PTY.) LTD. who are associated in fact as alleged above and, upon information and belief, constitute alter egos of each other and act in concert and conspire to commit the predicate acts of racketeering alleged herein. For example, "whois" lists an employee of VR SERVICES (PTY.) LTD with an e-mail address operated by FORWARD SLASH INTERNET, INC. as a contact for http://www.nolimitscasino.com, with an address that is also used by IBC SA. Credit card transactions associated with the operations of this enterprise are identified as "CFI" and "MPACT Cyber - Fin - Invest".

(f) The “Astell-Burt” Enterprise, consisting of defendants PETER J. ASTELL-BURT, DOMAIN NAME SERVICES LIMITED, ASTRA CASINO, KING NEPTUNE’S CASINO, and LIBERTY CASINO who are associated in fact as alleged above, and, upon information and belief, constitute alter egos of each other and act in concert and conspire to commit the predicate acts of racketeering alleged herein.

(g) The “Cryptologic” Enterprise, consisting of defendants INTERTAINMENT OVERSEAS LICENSING INC. and WAGERLOGIC LIMITED and CRYPTOLOGIC INC. who are associated in fact as alleged above, and, upon information and belief, constitute alter egos of each other and act in concert and conspire to commit the predicate act of racketeering alleged herein.

Defendant SUREFIRE COMMERCE INC. is also a member of the Astell-Burt Enterprise, insofar as it provides services to transfer funds to members of the enterprise knowing of the nature and source of the funds. Upon information and belief, defendant SUREFIRE COMMERCE INC. is a member of other of the Racketeering Enterprises alleged herein.

Defendant MICROGAMING SYSTEMS (UK) LTD. is also a member of the Astell-Burt and EHCL Enterprises, insofar as it supplies the gambling software to those Enterprises. Upon information and belief, defendant MICROGAMING SYSTEMS (UK) LTD. is also a member of other Racketeering Enterprises as alleged herein.

Potential ORICO Liability of Credit Card Defendants

Upon information and belief, each of the Credit Card Defendants may also be considered additional members of one or more of the foregoing Racketeering enterprises within the meaning of ORICO, because but for their participation, the Racketeering Enterprises could not succeed, and the Credit Card Defendants knew or had reason to know of the unlawful nature of the Racketeering Enterprises. Specifically, the Credit Card Defendants knew or had reason to know the nature of the business of the Billing Alter Egos, and the role they play in enabling the Casino Defendants to profit.

Moreover, each of the Credit Card Defendants has contractual relations with MasterCard International, Inc., VISA International Service Association, and/or Discover Financial Services, a business unit of Morgan Stanley Dean Witter & Co. These companies operate computer systems that have provided authorization, transaction processing, and/or settlement services for businesses around the world, including the Billing Alter Egos. MasterCard International, Inc. and VISA International Service Association processed most of the transactions submitted by plaintiff and class members. They have detailed procedural rules and application requirements that put them on notice of the illegal nature of the transactions they are handling.

On October 2, 2000, MasterCard issued a new policy to all cardholders advising that it now prohibited "Internet casino merchants from applying credits to MasterCard card accounts for winnings or unspent electronic chips". Each of the Credit Card Defendants issuing MasterCards has access to information possessed by their agent MasterCard International, Inc. concerning Internet gambling. Each could prevent holders of the cards they issue from engaging in transactions with the Casino Defendants, but does not do so, preferring knowingly to profit from such transactions.

VISA has at times maintained an "Internet gambling advisory" on its website http://www.visa.com. Each of the Credit Card Defendants issuing VISA cards has access to information possessed by their agent VISA International Service Association concerning Internet gambling. Each could prevent holders of the cards they issue from engaging in transactions with the Casino Defendants, but does not do so, preferring knowingly to profit from such transactions.

ORICO Violations

Each of these defendants has, through the participation in Racketeering Enterprises as alleged above, engaged in unlawful racketeering activity within the meaning of ORS 166.720(3).

(a) Each of the defendants is associated with one or more of the Racketeering Enterprises as alleged herein;

(b) Each of the defendants has conducted and/or participated, directly or indirectly, in such Racketeering Enterprises through a pattern of racketeering activity as alleged herein.

(c) Each of the defendants has conducted and/or participated, directly or indirectly, in such Racketeering Enterprises by the collection of unlawful debts as alleged herein.

Upon information and belief, each of the defendants has also conspired and/or endeavored to violate ORS 166.720(3) and the underlying predicate statutes, in violation of ORS 166.720(4).

INDIVIDUAL ALLEGATIONS AND CLAIMS

First Cause Of Action —ORS 30.740

All of these losses alleged herein occurred when plaintiff played "contests of chance" for credits of monetary value on websites controlled by the Casino Defendants and/or Racketeering Enterprises pleaded herein, conduct constituting "gambling" within the meaning of ORS 167.117(7).

All of the losses alleged herein occurred when plaintiff purchased "credits" for use with the relevant Casino Defendant, gambled such credits until exhausted, then replenished the credit supply by transmitting additional funds from the relevant Credit Card Defendant to the relevant Billing Alter Ego or Casino Defendant. The losses alleged below represent the total funds transfers from plaintiff's credit or debit card accounts to the relevant Billing Alter Ego or Casino Defendant. Total gross losses, as calculated on a game-by-game basis, would be much larger. The losses alleged are not net losses, however, in that plaintiff occasionally had winnings transmitted from the relevant Billing Alter Ego or Casino Defendant back to her.

Each of the Enterprises pleaded maintains transaction records that would permit allocation of such losses as among particular Casino Defendants; such records are not available to plaintiff. When plaintiff attempted to access such records through the websites maintained by the Casino Defendants, plaintiff discovered that only recent transactions were available, so that plaintiff could not obtain any relevant information.

All of the losses alleged herein occurred in or after June, 1999.

Count I: Against the EHCL Enterprise

Plaintiff lost $151,200 to defendants constituting the EHCL Enterprise, as alleged above.

The defendants comprising the EHCL Enterprise, individually and collectively constituted the "proprietor whose benefit the game was played" within the meaning of ORS 30.740.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of $302,400 from defendants constituting the EHCL Enterprise, who are jointly and severally liable to plaintiff for such damages.

Count II: Against the Proc Cyber Enterprise

Plaintiff lost $120,470 to defendants constituting the Proc Cyber Enterprise, as alleged above.

Defendants constituting the Proc Cyber Enterprise individually and collectively constituted the "proprietor whose benefit the game was played" within the meaning of ORS 30.740.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of $280,940 from defendants constituting the Proc Cyber Enterprise, who are jointly and severally liable to plaintiff for such damages.

Count III: Against the Cyber Café Enterprise

Plaintiff lost $71,475 to defendants constituting the Cyber Café Enterprise.

Defendants constituting the Cyber Café Enterprise individually and collectively constituted the "proprietor whose benefit the game was played" within the meaning of ORS 30.740.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of $142,950 from defendants constituting the Cyber Café Enterprise, who are jointly and severally liable to plaintiff for such damages.

Count IV: Against the E Cash World Enterprise

Plaintiff lost at least $12,699.50 to defendants constituting the E Cash World Enterprise.

Defendants constituting the E Cash World Enterprise individually and collectively constitute the "proprietor whose benefit the game was played" within the meaning of ORS 30.740.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of at least $25,399 from defendants constituting the E Cash World Enterprise, who are jointly and severally liable to plaintiff for such damages.

Count V: Against the CFI Enterprise

Plaintiff lost at least $5,550 to defendants constituting the CFI Enterprise.

Defendants constituting the CFI Enterprise individually and collectively constitute the "proprietor whose benefit the game was played" within the meaning of ORS 30.740.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of $11,000 from defendants constituting the CFI Enterprise, who are jointly and severally liable to plaintiff for such damages.

Count VI: Against the Cryptologic Enterprise

Plaintiff lost at least $160 to defendants constituting the Cryptologic Enterprise.

Defendants constituting the Cryptologic Enterprise individually and collectively constitute the "proprietor whose benefit the game was played" within the meaning of ORS 30.740.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of $320 from defendants constituting the Cryptologic Enterprise, who are jointly and severally liable to plaintiff for such damages.

Count VII: Against Lasseters Hotel Casino

Plaintiff lost at least $1,035.64 to defendant LASSETERS HOTEL CASINO.

Defendant LASSETERS HOTEL CASINO and the defendant members of its enterprise as alleged above constituted the "proprietor whose benefit the game was played" within the meaning of ORS 30.740.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of at least $2,071.68 from LASSETERS HOTEL CASINO.

Second Cause of Action: Individual ORICO Claim

Plaintiff's losses as alleged herein constitute racketeering injury within the meaning of Oregon law, in that the conduct alleged above has injured the business and/or property interests of plaintiff.

The total damages alleged in Counts I-V below have been trebled pursuant to ORS 166.725(7)(a).

Pursuant to ORS 166.725(14), plaintiff is also entitled to attorney fees in connection with Counts I-VI.

Count I: Against the EHCL Enterprise

Plaintiff is entitled to at least $453,600 in ORICO damages from defendants constituting the EHCL Enterprise, who are jointly and severally liable for such damages.

Count II: Against the Proc Cyber Enterprise

Plaintiff is entitled to at least $361,410 in ORICO damages from defendants constituting the Proc Cyber Enterprise, who are jointly and severally liable for such damages.

Count III: Against the Cyber Café Enterprise

Plaintiff is entitled to at least $214,425 in ORICO damages from defendants constituting the Cyber Café Enterprise, who are jointly and severally liable for such damages.

Count IV: Against the E Cash World Enterprise

Plaintiff is entitled to at least $38,098.50 in ORICO damages from defendants constituting the CFI Enterprise, who are jointly and severally liable for such damages.

Count V: Against the CFI Enterprise

Plaintiff is entitled to at least $16,650 in ORICO damages from defendants constituting the E Cash World Enterprise, who are jointly and severally liable for such damages.

Count VI: Against the Cryptologic Enterprise

Plaintiff is entitled to at least $480 in ORICO damages from defendants constituting the Cryptologic Enterprise, who are jointly and severally liable for such damages.

Third (and Alternative) Cause of Action: Piercing Corporate Veil

Count I: Against Defendant PETER J. ASTELL-BURT

Upon information and belief defendant PETER J. ASTELL-BURT has employed the entities ASTRA CASINO, DOMAIN NAMES SERVICES LTD. and KING NEPTUNE'S CASINO as part and parcel of a unlawful scheme that has injured plaintiff, such entities are grossly undercapitalized, and he is the real party in interest behind these entities.

Upon information and belief, as a result of defendant PETER J. ASTELL-BURT's improper conduct in exercising control over ASTRA CASINO, DOMAIN NAME SERVICES LTD., and KING NEPTUNE'S CASINO, it is unlikely that plaintiff and class members will be able to recover any damages awarded against those defendants in this action, and therefore defendant PETER J. ASTELL-BURT should be held individually and personally liable for the acts and omissions of those entities.

Plaintiff lost an amount to PETER J. ASTELL-BURT that shall be proved at trial.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of such amount.

Pursuant to ORS 166.725(7)(a), plaintiff is entitled to treble damages of such amount, and pursuant to ORS 166.725(14), plaintiff is also entitled to attorney fees.

Count II: Against Defendant MERVYN KAPLAN

Upon information and belief defendant MERVYN KAPLAN has employed the entity MERCANTRADE (PTY) LTD. as part and parcel of a scheme to defraud plaintiff, such entities are grossly undercapitalized, and and is the real party in interest behind these entities.

Upon information and belief, as a result of defendant MERVYN KAPLAN'S improper conduct in exercising control over MERCANTRADE (PTY.) LTD., it is unlikely that plaintiff and class members will be able to recover any damages awarded against those defendants in this action, and therefore defendant MERVYN KAPLAN should be held individually and personally liable for the acts and omissions of those entities.

Plaintiff lost an amount to defendant MERVYN KAPLAN that shall be proved at trial.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of such amount.

Pursuant to ORS 166.725(7)(a), plaintiff is entitled to treble damages of such amount, and pursuant to ORS 166.725(14), plaintiff is also entitled to attorney fees.

Count III: Against Defendant PAUL SUDOLSKI

Upon information and belief defendant PAUL SUDOLSKI has employed the entities 3748472 CANADA INC., EHCL INC., EC EXCHANGE INC., and WEBDOLLAR, INC. as part and parcel of a scheme to defraud plaintiff, such entities are grossly undercapitalized, and and is the real party in interest behind these entities.

Upon information and belief, as a result of defendant PAUL SUDOLSKI'S improper conduct in exercising control over 3748472 CANADA INC., EHCL INC., EC EXCHANGE INC., and WEBDOLLAR, INC., it is unlikely that plaintiff and class members will be able to recover any damages awarded against those defendants in this action, and therefore defendant PAUL SUDOLSKI should be held individually and personally liable for the acts and omissions of those entities.

Plaintiff lost an amount to defendant PAUL SUDOLSKI that shall be proved at trial.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of such amount.

Pursuant to ORS 166.725(7)(a), plaintiff is entitled to treble damages of such amount, and pursuant to ORS 166.725(14), plaintiff is also entitled to attorney fees.

Count IV: Against Defendant BOBBY GARG

Upon information and belief defendant BOBBY GARG has employed the entities IK2, INC. and CYBER CAFÉ, INC. as part and parcel of a scheme to defraud plaintiff, such entities are grossly undercapitalized, and and is the real party in interest behind these entities.

Upon information and belief, as a result of defendant BOBBY GARG'S improper conduct in exercising control over IK2, INC. and CYBER CAFÉ, INC., it is unlikely that plaintiff and class members will be able to recover any damages awarded against those defendants in this action, and therefore defendant BOBBY GARG should be held individually and personally liable for the acts and omissions of those entities.

Plaintiff lost an amount to defendant BOBBY GARG that shall be proved at trial.

Pursuant to ORS 30.740, plaintiff is entitled to recover double damages of such amount.

Pursuant to ORS 166.725(7)(a), plaintiff is entitled to treble damages of such amount, and pursuant to ORS 166.725(14), plaintiff is also entitled to attorney fees.

Fourth Cause of Action: Declaratory Judgment (Contract)

Plaintiff's losses as alleged above have given rise to the following debts to the following Credit Card Defendants:

Credit Card Defendant Debt

(a) ADVANTA BANK CORP. $8,348.23

(b) CAPITAL ONE FINANCIAL CORPORATION $2,788.81

(d) FIRST USA BANK, N.A. $12,293.22

(e) FLEET BANK $12,134.26

(f) GREENWOOD TRUST COMPANY $16,484.14

(g) OREGON TELCO CREDIT UNION $10,828.24

(h) PROVIDIAN NATIONAL BANK $10,042.50

(i) WELLS FARGO BANK $9,505.56

Each of the Credit Card Defendants knew, or had reason to know, that such debt was incurred through gambling activity in violation of Oregon and federal law. All but three of the defendants processed large numbers of transactions associated with the foregoing Racketeering Enterprises, and plaintiff's debt arose from such transactions.

Defendants FLEET BANK and GREENWOOD TRUST COMPANY did not process transactions with members of the Racketeering Enterprises alleged herein in connection with plaintiff's accounts. Plaintiff's debt to these defendants arose from balance transfers from other Credit Card Defendants.

Plaintiff's debt to defendant CAPITAL ONE FINANCIAL CORPORATION arose from balance transfers with other Credit Card Defendants, but defendant CAPITAL ONE FINANCIAL CORPORATION subsequently processed transactions with respect to plaintiff's account that were associated with the Proc Cyber Enterprise.

Upon information and belief, defendant CAPITAL ONE FINANCIAL CORPORATION processed transactions with members of the Racketeering Enterprises alleged herein in connection with accounts of other class members.

Upon information and belief, FLEET BANK processed transactions with members of the Racketeering Enterprises alleged herein in connection with accounts of other class members.

Representatives of defendants FLEET BANK, GREENWOOD TRUST COMPANY and CAPITAL ONE FINANCIAL CORPORATION contacted plaintiff by telephone, indicating an awareness of her outstanding debt to other credit card defendants, including the amounts outstanding, and solicited the balance transfers giving rise to the debts alleged above. Each had reason to know from the extraordinary size of the debts and the identities of the other creditors that such debts arose from gambling; upon information and belief each had and has access to databases from which they could have, and perhaps did, ascertain the nature of the debt.

There is a present and actual dispute between each of the Credit Card Defendants and plaintiff in that plaintiff contends, and the Credit Card Defendants deny, that the Credit Card Defendants may not collect these debts. Indeed, each of the Credit Card defendants is engaged in active efforts to collect the debts. On or about March 23, 2001, defendant PROVIDIAN NATIONAL BANK initiated an action to collect the debt in the Circuit Court of Marion County, Oregon.

Plaintiff is entitled to a declaration that these debts are void and not collectable pursuant to the public policy of the State of Oregon.

CLASS ALLEGATIONS AND CLAIMS

It has been estimated that over 80,000 Oregonians have developed problems with controlling gambling. Upon information and belief, thousands of Oregonians have engaged in Internet gambling.

News media accounts report suggest that Internet gambling sites will cause all U.S. citizens to lose anywhere between $1.5 billion and $3 billion this year.

Plaintiffs bring this suit as a class action pursuant to Rule 32 of the Oregon Rules of Civil Procedure on behalf of a class consisting of Oregonians suffering losses from Internet gambling to any of the foregoing defendants or enterprises within the applicable statute of limitations, and such additional defendants or enterprises as may be identified through amendment of the pleadings, and a subclass consisting of those who have outstanding debt to any of the foregoing Credit Card Defendants, or such additional defendants as may be identified through amendment of the pleadings.

This case is properly maintainable as a class action for the following reasons:

(a) The members of the Class are so numerous that joinder of all members is impracticable. While the exact number of class members is unknown to plaintiffs at this time, and can only be ascertained through appropriate discovery, plaintiffs believe that there are thousands of members of the Class.

(b) Common questions of law and fact exist as to all members of the Class and predominate over any questions affecting solely individual members. Among the questions of law and fact common to the Class are:

(i) Whether the Casino Defendants are in violation of Oregon laws concerning gambling, and whether they constitute the "proprietors for whose benefit the game was played" within the meaning of ORS 30.740.

(ii) Whether the Casino Defendants, Gaming Software Defendants and Billing Alter Egos collectively constitute Racketeering Enterprises as alleged above.

(iii) Whether the law of Oregon bars the Credit Card defendants from attempting to collect debts arising from Internet gambling; and

(iv) Whether the Credit Card defendants, by virtue of their participation in Internet gambling, constitute members of the Racketeering Enterprises as alleged above.

(c) Plaintiff's claims are typical of the claims of the members of the Class in that plaintiffs and the other members of the Class sustained damages arising out of the same course of conduct alleged above. Plaintiff does not have any interests that are adverse or antagonistic to those of the Class, and is an ideal class representative because of her large losses from many Casino Defendants and/or Racketeering Enterprises.

(d) Plaintiff will fairly and adequately protect the interests of the members of the Class. Plaintiff is committed to the vigorous prosecution of this action and has retained counsel competent to prosecute this action.

A class action is superior to other available methods for the fair and efficient adjudication of this controversy. Because the damages suffered by individual class members may be relatively small, the expense and burden of individual litigation, exacerbated in this case by the extraordinary conduct by the Billing Alter Egos and Casino Defendants to hide their identities, as alleged above, make it impracticable for the class members to individually seek redress for the wrongs done to them. Plaintiff envisions no difficulty in the management of this case as a class action.

FIRST CAUSE OF ACTION: DECLARATORY JUDGMENT

There is a present and actual controversy between the parties in that plaintiff and Class members contend, and the Casino Defendants, Gambling Software Defendants, and Billing Alter Egos deny, that they are members of Racketeering Enterprises, as alleged above, are jointly and severally liable to return double the losses of class members pursuant to ORS 30.740, and are jointly and severally liable for treble damages pursuant to ORICO.

There is a present and actual controversy between the parties in that plaintiff and Class members contend, and the Credit Card defendants deny that, the Credit Card defendants may not lawfully collect debts arising from Internet gambling as alleged herein.

Plaintiff and the Class are entitled to declaratory relief setting forth the rights of the parties as alleged below.

SECOND CAUSE OF ACTION: INJUNCTION

The conduct alleged herein by all defendants is ongoing, and threatens irreparable injury to large numbers of Oregonians, who lack an adequate remedy at law.

The class members are entitled to an injunction forbidding all defendants from engaging in the conduct alleged herein.

CATHY BUCHAL, on behalf of herself and all others similarly situated,

Plaintiff,

v.

3748472 CANADA INC.; ALTER EGO INC.; AQUA ONLINE (INT.) LTD; ASTRA CASINO; ADVANTA BANK CORPORATION; BOBBY GARG; BOSS CASINOS LTD.; BOSSMEDIA AB; CAPITAL ONE FINANCIAL CORPORATION; CHASE MANHATTAN BANK USA, N.A.; CRYPTOLOGIC INC.; CYBER CAFÉ, INC.; CYBER FINANCE INVESTMENTS; DOMAIN NAME SERVICES LTD.; EC EXCHANGE INC.; EHCL INC.; ENGLISH HARBOUR ENTERTAINMENT LTD; FIRECASH LTD.; FIRST USA BANK, N.A.; FLEET BANK; FORWARD SLASH INTERNET INC.; GREENWOOD TRUST COMPANY; IBC SA; IK2 INC.; INTERTAINET OVERSEAS LICENSING LTD; KING NEPTUNE'S CASINO; LASSETERS HOTEL CASINO; LIBERTY CASINO; MERCANTRADE (PTY.) LTD.; MERVYN KAPLAN; MICROGAMING SYSTEMS (UK) LTD.; NETAINMENT N.V.; OREGON TELCO CREDIT UNION; PAUL SUDOLSKI; PETER J. ASTELL-BURT; PROVIDIAN NATIONAL BANK; SULLIVAN BROWNSTONE LTD.; SUNSET TECHNOLOGY INC.; SUREFIRE COMMERCE INC.; UNIVERSAL SPHERES INC.; VR SERVICES (PTY.) LTD; WAGERLOGIC LIMITED; WEBDOLLAR INC.; WEBDOLLAR LTD. and WELLS FARGO BANK,

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Case No.

COMPLAINT

ORS 30.750

ORS 166.725 (ORICO)

Declaratory Judgment (Contract)

WHEREFORE, plaintiffs demand judgment against defendants as follows:

A. For plaintiff, individually, an award of at least $763,009 in damages on her First Cause of Action as alleged above; at least $1,084,663.50 on her Second Cause of Action as alleged above; in the alternative, for an award of damages on her Third Cause of action in an amount to be proved at trial; and a judgment declaring that the debts alleged in Fourth Cause of Action are void as against public policy.

B. For an order determining that the case is properly maintainable as a class action pursuant to Rule 32 of the Oregon Rules of Civil Procedure;

C. Awarding plaintiffs and the class a declaration that

1. The Casino Defendants, Gaming Software Defendants and Billing Alter Egos are members of Racketeering Enterprises, as alleged above, and are jointly and severally liable to return double the losses of class members pursuant to ORS 30.740, and jointly and severally liable for triple the losses of class members pursuant to ORICO.

2. The Credit Card defendants may not lawfully collect any debts arising from gambling activity conducted by the Racketeering Enterprises.

D. Awarding plaintiffs and the class an injunction that forbids the Casino Defendants, Gaming Software Defendants and Billing Alter Egos from doing business with customers residing in Oregon, and that requires the Credit Card Defendants to adopt standards and procedures designed to prevent them from processing transactions associated with the Casino Defendants, Gaming Software Defendants and Billing Alter Egos.

E. Awarding plaintiff the costs and disbursements of this action, including reasonable attorney and experts' fees; and

F. Awarding plaintiff and the other members of the Class such other and further relief as the Court may deem just and proper.

Dated: April 3, 2001.

James L. Buchal, OSB #92161

MURPHY & BUCHAL LLP 1500 SW First Avenue, Suite 1135

Portland, OR 97201

Of Attorneys for Plaintiff