KAS OW ITZ BE NS O N
TOR R ES LLP
A T T O R N E YS A T LAW
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the county of Los Angeles. At all relevant times, Plaintiff was and is the “loan-out” company
through which Scarlett Johansson provided her acting services in connection with the Picture.
17. Defendant The Walt Disney Company, on information and belief, is, and at all
relevant times was, a corporation organized under the laws of the State of Delaware doing
business throughout the United States, including at its offices in the State of California, County of
Los Angeles.
IV. FACTUAL BACKGROUND
A. Ms. Johansson is Cast in the Role of Natasha Romanoff/Black Widow
18. Ms. Johansson is an esteemed and versatile actress with over 25 years of
Hollywood acting experience. Her credits include lead roles in critically-acclaimed films such as
Lost in Translation, Match Point, The Prestige, The Other Boleyn Girl, Vicky Cristina Barcelona,
Her, Don Jon, Chef, Hail, Caesar!, The Jungle Book, Isle of Dogs, Marriage Story, and Jojo
Rabbit. She is a two-time Academy Award nominee, a five-time Golden Globe nominee, winner
of a BAFTA award, and winner of the 2010 Tony Award for Best Featured Actress in a Play. She
will be honored later this fall as the 35
th
recipient of the American Cinematheque Award.
19. In 2010, Ms. Johansson made her debut in the MCU in Iron Man 2, and she would
go on to star in six additional MCU films between 2012 and 2019. The MCU began as a
connected series of films about individual superheroes who would come together to form the
Avengers superhero team, which initially consisted of Marvel superheroes Iron Man, the
Incredible Hulk, Thor, Captain America, Hawkeye, and Black Widow, played by Ms. Johansson.
Over time, the MCU grew in scope, introducing other superheroes and teams from Marvel
Comics and culminating in two crossover films, Avengers: Infinity War and Avengers: Endgame,
which brought all of these characters together.
20. Black Widow, also known as Natasha Romanoff or Romanova, is an elite spy and
assassin. She is a notable member of the Avengers, not only for being the only woman in the
initial lineup, but also because she does not have superhuman abilities. Whereas, for example,
Captain America obtained extraordinary strength and athleticism from an experimental
“supersoldier” serum, and Thor is the god of thunder who fights with a hammer forged by