FILED: NEW YORK COUNTY CLERK 05/09/2011

ad faith negotiation tactic. She had deliberately interrupted the financing, believing that if she
put it into jeopardy, Gate Five would have no alternative but to give in to her new demands.
10. Ms. Carter’s scheme outraged Alcon, which pulled its financing because of her
erratic behavior. BDJ’s members, however, were desperate to avoid the collapse of a business
venture they had devoted years of their lives and millions of dollars to, and that was on the brink
of great success. So, Gate Five accepted her new compensation demands, and one of BDJ’s
members offered to provide bridge financing the very next day if she would re-commit to the
project. Ms. Carter, in breach of the Agreement, refused.
11. Ms. Carter evidently did decide to resume the project, but without Gate Five.
While she was abandoning Gate Five, her choreographer and creative advisor (who had been
intimately involved with the project) was sending text messages to the art director of Starpower:
Beyoncé, telling him that Ms. Carter still wanted to do a game and wished to hire the people who
had worked on Starpower: Beyoncé when she “found her new company.” He forewarned that
those involved in her new project would have to “give her what she wants” because she is such a
“big star.”
12. With no Beyoncé, no financing, and millions of dollars in debt from creating a
Beyoncé-specific game, Gate Five was forced to abandon the project the week before Christmas.
While Ms. Carter walked away unscathed (in fact, she bought her husband a $2 million car that
month), Gate Five was out of business, and the 70 person development team she had agreed to
hire was left unemployed.
13. Now, through the filing of this action, Gate Five seeks an injunction barring Ms.
Carter from associating with any other video game, and monetary damages consisting of the
hundreds of millions of dollars in profits that Gate Five would have realized if she had honored
PC Law # 15232 5