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James C. Hann, Esq. # 215778 LAW OFFICES OF TAK S. CHANG 1530 The Alameda, Suite 305 San Jose, CA 95126 (408) 975-9000 voice (408) 975-9100 fax Attorneys for Cross-Complainants

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA DIGITALL WORLD CO., LTD.; AND DLT ) Case No.: 1-07-CV-083621 ELECTRONICS, ) ) CROSS-COMPLAINT OF XXXX FOR ) ) Plaintiffs, ) ) vs. ) KTVNNC, CORP.; KOREA TELEVISION ) NETWORKS OF SAN FRANCISCO, INC.; ) ) NORTHERN CALIFORNIA KOREAN COMMUNITY CENTER OF EDUCATION ) AND CULTURE; KTVN, INC.; KUMCHA ) CHANG; KEE AHNG SUNG individually and) doing business as KTN-TV and DOES 1-20, ) ) Inclusive, ) ) Defendants. ) ) ) XXXXXXXX, ) ) Cross-Complainants, ) ) vs. ) DIGITALL WORLD CO., LTD.; AND DLT ) ELECTRONICS, and ROES 1-20, Inclusive, ) ) ) Cross-Defendants. ) ) ) ) GENERAL ALLEGATIONS CROSS-COMPLAINANT XXXXX (XXXXX), complains and alleges as follows:

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CROSS-COMPLAINT OF XXXX FOR

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1.

CROSS-COMPLAINANT XXXXX is, and at all times herein mentioned was, an

individual, over the age of 18, and a resident of the County of Santa Clara, California. 2. CROSS-COMPLAINANT is informed and believes and thereon alleges that

CROSS-DEFENDANT DIGITAL WORLD CO., LTD, (hereinafter "Digitall") is, and at all times herein mentioned was, a corporation duly organized and existing in the Republic of Korea. 3. CROSS-COMPLAINANT is informed and believes and thereon alleges that

CROSS-DEFENDANT DIGITAL WORLD CO., LTD, (hereinafter "Digitall") is, and at all times herein mentioned was, a corporation duly organized and existing in the Republic of Korea. 4. CROSS-COMPLAINANT is ignorant of the true names and capacities of

CROSS-DEFENDANTS sued herein as ROES 1 through 10, INCLUSIVE, and therefore sues these CROSS-DEFENDANTS by such fictitious names, CROSS-COMPLAINANT prays leave to amend this CROSS-COMPLAINT to allege their true names and capacities when the same have been ascertained. 5. CROSS-COMPLAINANT is informed and believes and thereon alleges that at all

times herein mentioned each of the CROSS-DEFENDANTS sued herein was the agent, employee, and/or joint venturer of each of the remaining CROSS-DEFENDANTS, and were, at all times, acting within the purpose and scope of such agency, employment and/or joint venture.

FIRST CAUSE OF ACTION

WHEREFORE, CROSS-COMPLAINANT prays for judgment against CROSS-DEFENDANT, and each of them, as hereinafter set forth: 1. 2. 3. 4. For damages in the sum of at least $xxxx or sum to be prove at trial; For attorneys fees and costs incurred herein; For costs of suit incurred; and For such other and further relief as the court may deem just and proper.

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CROSS-COMPLAINT OF XXXX FOR

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DATED:

Law Offices of Tak S. Chang

BY:

___________________________ JAMES C. HANN, ESQ. Attorneys for Cross-Complainants

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CROSS-COMPLAINT OF XXXX FOR