Plaintiffs request judgment against Defendants as follows:
1. That the Court enter judgment against Defendants that Defendants have:
a. Violated the Computer Fraud and Abuse Act, in violation of 18 U.S.C. § 1030;
b. Violated the California Comprehensive Computer Data Access and Fraud Act, in violation California Penal Code § 502;
c. Breached their contracts with WhatsApp in violation of California law;
d. Wrongfully trespassed on Plaintiffs’ property in violation of California law.
2. That the Court enter a permanent injunction enjoining and restraining Defendants and their agents, servants, employees, successors, and assigns, and all other persons acting in concert with or conspiracy with any of them or who are affiliated with Defendants from:
a. Accessing or attempting to access WhatsApp’s and Facebook’s service, platform, and computer systems;
b. Creating or maintaining any WhatsApp or Facebook account;
c. Engaging in any activity that disrupts, diminishes the quality of, interferes with the performance of, or impairs the functionality of Plaintiffs’ service, platform, and computer systems; and
d. Engaging in any activity, or facilitating others to do the same, that violates WhatsApp’s or Facebook’s Terms
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