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"), and Does 1 through 100, Defendants.


Jurisdiction:

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


Contents:


Coverage:

LA Times
LATimes
June 20, 2018
The Register
Register
July 18, 2018
Reddit
Reddit
97% upvoted
Zhihu
Zhihu
500,000+ views


Documents:

Full Complaint:
[ Dr-Iman-Sadeghi-v-Pinscreen-Inc-et-al.pdf ]

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

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

Timeline:

WHEN
WHAT
WHERE
June 11, 2018

I, Dr. Iman Sadeghi, filed a verified complaint 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. [view]

I allege that 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 LA Times that "All the Allegations Are 100% False." [view]

LA Times
July 9, 2018

I challenged 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. [view]

Facebook Twitter LinkedIn Google+ Instagram
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, and to other members of our community. It should be clear from the manner of those communications that those accusations would be uncharacteristic of Pinscreen, our team, and the reputation we've built with the community." [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 12, 2018
I challenged Li to identify a single communication within the complaint that he alleges to be fabricated. [view]
Facebook Twitter LinkedIn Google+ Instagram
TBA
Pinscreen's and Li's Official Court Answers
Superior Court of California
TBA
Court and Jury Trial
Superior Court of California

Causes of Action:

  1.   Fraud and Deceit
  2.   Assault and Battery
  3.   Violation of Cal. Labor Code § 1102.5 - Retaliation Against Whistleblowing
  4.   Breach of Contract
  5.   Breach of Implied Contract
  6.   Breach of Implied Covenant of Good Faith and Fair Dealing
  7.   Wrongful Termination in Violation of Cal. Public Policy
  8.   Intentional Interference with Contract
  9.   Negligent Hiring, Supervision or Retention
  10.   False Imprisonment
  11.   Invasion of Privacy
  12.   Conversion
  13.   Negligence
  14.   Intentional Infliction of Emotional Distress
  15.   Violation of Cal. Labor Code § 2802
  16.   Violation of Cal. Unfair Competition Law (UCL), Bus. & Prof. Code § 17200 et seq.
  17.   Declaratory Relief


Case Summary:

CASE SUMMARY

   1.    Sadeghi earned a doctorate in Computer Science/Computer Graphics from 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 data fabrication and academic misconduct. When confronted by Sadeghi, 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.

   5.    Li broke this promise on August 1, 2017, when Pinscreen and Li publicly mispresented fabricated avatars on the stage of SIGGRAPH 2017 Real-Time Live (“RTL”) to an audience of thousands. In retaliation for Sadeghi’s objections and whistleblowing regarding Li’s data fabrication, academic misconduct, labor 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.

   6.    On the day of the wrongful termination, Li and Pinscreen committed multiple other torts against Sadeghi, such as false imprisonment, assault and battery. As a result of the battery, Sadeghi has suffered severe physical, mental and emotional distress as well as physical injuries requiring medical treatments.

   7.    Following the wrongful termination, Pinscreen committed additional breaches of contract and engaged in other unlawful conduct, such as withholding business expense reimbursements, refusing to pay due penalties for late wage payments for nearly a year, damaging Sadeghi’s personal property, invasion of his privacy, and conversion of his personal data.

   8.    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, 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

   16.    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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   17.    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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   18.    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 SIGGRAPH conference, considered by many to be the most reputable conference in the field of Computer Graphics. Sadeghi also holds a patent on the framework together with Disney. The following figure features some of the results of the hair rendering framework: (Exhibits A2, A3, A4)

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

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   20.    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. Sadeghi and Li stayed in touch over the years and considered each other “good friends.” (Exhibits A7, A8)

   21.    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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   22.    Sadeghi joined Google as a Software Engineer, on August 15, 2011, and over the years, gained experience with Robust Software System Architectures, Reliable Scalable Distributed Systems, Deep Convolutional Neural Networks, and among other achievements holds multiple patents together with Google.

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Li’s and Pinscreen’s Solicitation of Sadeghi

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   29.    In early October of 2016, during a scientific conference in Amsterdam, Netherlands, Li, as the Chief Executive Officer (“CEO”) and a co-founder of Pinscreen, approached Sadeghi and invited him to join the company, which Li followed up on in writing in November of 2016. 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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   30.    Li offered Sadeghi the “leadership role” of “VP of Engineering” and described it as “potentially having a more important role than CTO [Chief Technology Officer].” 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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   31.    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 with the other companies, not only in terms of impact but also financially.” (Exhibits B10, B12)

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   32.    After claiming that “for startup at our stage the biggest benefit is in stock options,” Li offered Sadeghi 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)

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Pinscreen’s Technology and Terminology

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

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

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   45.    Relevant terminology to this complaint includes the following:

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

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

   51.    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.

   52.    On January 22, 2017, before Sadeghi had signed the contract to join Pinscreen, Li sent him, in writing 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)

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   53.    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, such as by falsely representing manually prepared hair shapes as automatic.

   54.    For instance, Pinscreen falsely represented manually prepared hair shapes as automatic 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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   57.    Li also deceived Sadeghi by intentionally concealing that Li and Pinscreen were involved in data fabrication, academic misconduct, and unlawful practices that Sadeghi learned about only after resigning from Google and joining Pinscreen.

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   58.    On January 23, 2017, after relying on Li’s misrepresentations, 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 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. A strong justification for Sadeghi’s reasonable reliance on Li’s misrepresentations was that Li, on information and belief, was and is an assistant professor at USC. Li’s claims to have automated that which he had merely fabricated means that Li has committed academic misconduct which, if discovered, could be subject to draconian punishment. (Exhibits B11, G)

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Sadeghi’s Contributions

Hair Appearance

   59.    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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   60.    Pinscreen’s submission to SIGGRAPH Technical Papers, on January 16, 2017, prior to Sadeghi’s employment, was rejected. One of the reasons for the rejection, given by the conference reviewers, was the poor quality of Pinscreen’s avatars. One of the conference reviewers stated that the quality of Pinscreen avatars were “below the SIGGRAPH standard,” that “a lot of disturbing artifacts can be observed in almost all hair models” and that they “seriously doubt if the quality is good enough for games or VR applications.” (Exhibit D1)

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   61.    For the SIGGRAPH Asia Technical Papers submission, on May 23, 2017, Sadeghi implemented a variation of his published hair appearance framework which significantly improved the quality of Pinscreen’s avatars. This submission was consequently accepted. The quality improvement in the submission was so significant that the conference reviewers asked Pinscreen for an explanation on “why the quality is so improved comparing [sic] with previous submission?” Pinscreen’s official response stated that “in this submission, hair shading has been significantly improved using a variant of Sadeghi 2010 (used in Disney’s Tangled) and […].” (Exhibit D2)

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   62.    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

   70.    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)

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   71.    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.

   72.    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)

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

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SIGGRAPH 2017 Technical Papers Submission

   76.    Shortly after joining Pinscreen, Sadeghi realized that under Li’s leadership, Pinscreen included faked results in their SIGGRAPH Technical Papers submission, submitted on January 16, 2017, prior to Sadeghi’s employment. Sadeghi alleges, based on information and belief, that in that scientific research submission, among other misrepresentations, Pinscreen falsified 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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   77.    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, by publication time. 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)

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SIGGRAPH 2017 Real-Time Live Submission

   78.    In preparation for SIGGRAPH Real-Time Live (“RTL”) submission, due on April 4, 2017, Li wrote on a team thread, 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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   79.    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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SIGGRAPH Asia 2017 Technical Papers Submission

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

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

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

   84.    Li stated, on April 18, 2017, “then I have an artist create 100 hairs ahahahaha,” 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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   85.    Pinscreen also fabricated the process of estimating the eye color in the submission. Li stated that the eye color estimation process was, pardon the language, “total shit,” “completely random” and ordered Pinscreen employees to “manually fix all the eye colors” for the avatars. Pinscreen then 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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   86.    [May 15, 2017] Li: “Our eyes are wrong. The colors. We need to use a Deep Neural [Network] for that […] Or we just do it manually for SIGGRAPH Asia for now […] Let’s do it manually for now. I think it’s the only way.”

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   87.    [May 18, 2017] Li: “The eye color is total shit. It’s completely random […] I would say let’s do them manually for now.”

   88.    [May 18, 2017] Li: “Okay so I’m generating all the avatars. We need someone to manually fix all the eye colors.”

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   90.    On May 22, 2017, one day before the submission deadline, Li ordered the team, “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.”

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   91.    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:

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

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SIGGRAPH 2017 Real-Time Live Public Demo

   93.    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)

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   94.    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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   98.    While Sadeghi was away on his personal anniversary vacation, Li decided to misrepresent pre-cached avatars as real-time during Pinscreen’s RTL public demo, 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 a team 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 his earlier promise to Sadeghi. (Exhibit E26)

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   99.    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 a team 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)

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   100.    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)

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   101.    Later that evening, on July 22, 2017, Sadeghi met with Li in person. Li disclosed his plan to fabricate the webcam avatar generation and its speed by misrepresenting pre-cached manually prepared avatars as brand-new, automatic, and real-time. Sadeghi confronted Li and stated that Pinscreen should be truthful to the public and scientific community, that Li’s data fabrication could be considered “investment fraud,” and that everyone’s “academic reputation” at Pinscreen was at stake.

   102.    Li dismissed Sadeghi’s objections and claimed that the actual speed of Pinscreen’s avatar generation was “too slow,” and that it “won't be impressive”, and therefore Pinscreen could not present it. Li stated that one of his goals was to have “Loom.ai and ObEN to stop even trying to compete with us.” Li expressed concerns that Pinscreen’s actual automatic hair shape estimation could have poor quality and would “make us look bad” and claimed that “Loom.ai will laugh at us.” Li later made similar statements to the team until a few days before the RTL demo. (Exhibit E29)

   103.    Li claimed that Pinscreen “didn’t have any other choice at that point,” that the decision was made last week, that it was “final,” and that Sadeghi must follow the plan and focus on finalizing the RTL demo.

   104.    Subsequently, Sadeghi asked Li to promise that moving forward, Pinscreen would stay honest and avoid fabricating its results. Li dismissed Sadeghi’s request and stated, around midnight on July 22, 2017:

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

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

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   107.    On July 24, 2017, a Pinscreen officer 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)

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   108.    Li defined tasks such as “creating all avatars, hair models, tweak for perfect hair color” and “hair models/avatars” and assigned them to one of Pinscreen’s employees. The employee manually prepared the hair shapes for many of the avatars presented at RTL, including their own avatar. On July 28, 2017, another employee requested “for my hair if you can lower it down a bit if it’s not too hard, that would be nice. (I don’t think my forehead is that large).” The requested manual modification of the hair shape was done after around 2 days: (Exhibit E31)

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   109.    On August 1, 2017, during its SIGGRAPH RTL public demo, in front of thousands of attendees and online viewers, Pinscreen 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.

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Li’s Miscellaneous Data Fabrication and Academic Misconduct

   112.    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.” (Exhibit E33)

   113.    Li made public claims about having scientific contributions to the iPhone X until a Research Scientist from Apple Inc., the manufacturer of the iPhone X, posted on Li’s Facebook wall on October 25, 2017, suggesting Li “to avoid propagating fake information.” (Exhibit E34)

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   114.    Li’s data fabrication crossed over to business representations to 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. Li disrespected Softbank, the day the investment agreement between the parties was finalized, when he stated, pardon the language: (Exhibits E35, E36, E37)

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

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Li’s and Pinscreen’s Labor Law Violations

   116.    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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   117.    When Sadeghi questioned as to why there was a work-related event on Sunday, April 16, 2017, Li responded on a team thread, “we work every day.”

   118.    On June 28, 2017, Sadeghi told Li that some of Pinscreen’s non-exempt employees were working an excessive amount of overtime and should be properly compensated. Li dismissed Sadeghi’s proposal, telling him that “the students are used to working this many hours” and that “the employees are salary based and are being paid enough already.”

   119.    Li told Sadeghi, in the same meeting, that “deadlines are a tool to push the students to work more. Without deadlines they won’t work on the weekends and nights.” Li also suggested Sadeghi to push Pinscreen employees to work more “as long as they don’t die from Karōshi.” Karōshi is a Japanese term literally meaning “overwork death.” Another related Japanese term used by Li was Salaryman which refers to employees who “are expected to work long hours, additional overtime, […] and to value work over all else.” (Exhibits F2, F3)

   120.    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 a Pinscreen employee as “Salariman [sic]” multiple times. Li also publicly paid tribute to death from overwork, on his Facebook, by posting “Karoshi! Let me tell you! Sleep is for the weak.” (Exhibits F4, F5, F6)

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   121.    Sadeghi dined with two Pinscreen employees, 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. One of the employees further stated that they “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 RTL 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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   122.    Additionally, Li harassed and discriminated against a Pinscreen employee whom Li, on information and belief, suspected to have 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 used demeaning language such as, pardon the language, “are you fucking shitting me???” and “we are not fucking paying you 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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   123.    Furthermore, Li discussed firing Pinscreen’s CTO, while he was expecting a newborn. Li claimed that if Li and Sadeghi do not check on the CTO, “he is just doing nothing,” and that the CTO “is sick at every deadline we have.” Li stated that the CTO, “out of a sudden [sic] had a child” and attributed CTO’s alleged lack of performance to having a baby. Sadeghi alleges, on information and belief, that the CTO’s performance was indeed satisfactory and Li’s resentment toward the CTO was because the CTO prioritized his family over work during the weekends. Li told Sadeghi that the CTO was a “bad hombre” because “he doesn’t work on the weekends.” Li later claimed, on May 23, 2017, that “[the CTO]’s baby has cost Pinscreen a shit ton of money.” In order to clarify the CTO’s performance, Sadeghi suggested that Li ask the CTO to share detailed progress reports with Li and Sadeghi. Furthermore, Sadeghi suggested that Li “make sure he [the CTO] doesn't feel micromanaged or disrespected.” (Exhibits F10, F11)

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

   124.    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 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.:

   125.    [August 6, 2017] Sadeghi: “I would like to have a 1:1 meeting to talk about multiple important topics. Are you free Monday or Tuesday night to talk over dinner?”

   126.    [August 6, 2017] Li: “Let’s meet at 5 p.m. in the office, we can discuss in the conference meeting room.”

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

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

   132.    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.

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

   134.    Neither Sadeghi’s termination letter nor his employment personnel file contain any reasons for the termination nor do they indicate any concerns with Sadeghi’s performance.

   135.    Sadeghi alleges, on information and belief, that his 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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   143.    [August 7, 2017] Sadeghi to Li: “Don’t touch me. Don’t touch me.”

   144.    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.

   145.    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

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   150.    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 that such reimbursement would be “subject to execution of a mutually agreeable MNDA” between Pinscreen and Sadeghi.

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The End



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


Li responded on his social media on July 19, 2018 and alleged that "… that individual has taken aggressive actions to defame us publicly with false accusations, and has fabricated communications and other evidences to portray us negatively to our peers, and to other members of our community. It should be clear from the manner of those communications that those accusations would be uncharacteristic of Pinscreen, our team, and the reputation we've built with the community."

2018-07-19-li-facebook

I challenge Li to identify a single communication within the complaint that he alleges to be fabricated.

All communications and evidence presented in the complaint are authentic and verifiable by third parties (e.g. through a subpoena to Skype and/or Facebook).


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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., Superior Court of the State of California, County of Los Angeles, Central District., June 11, 2018.


BibTex Reference:


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

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