Beyond the details we heard in the LA Times report from earlier today, Joystiq has obtained the entire 23 page complaint this afternoon (filed against former Infinity Ward co-heads Jason West and Vince Zampella by Activision), which details the publisher's claims about the duo's insubordination during employment. The claims detailed therein range from refusing to meet with Activision executives, to "engaging in a campaign to portray Activision and its management in a negative light to IW employees in an effort to solicit those employees," to slowing pre-production of Modern Warfare 3 as leverage in ongoing discussions with Activision. The suit even says that West and Zampella "refused to sign standard exit documents representing that they had returned all Activision property, including computer code, and would honor the confidentiality obligations that they have to Activision."
Further, Activision claims that "on numerous occasions and during critical final stages of game development," West and Zampella threatened to stop production on last year's Modern Warfare 2 "in a bad faith effort to gain further leverage in their contractual relations with Activision." And during all this, the publisher claims that the studio heads were engaging in secret conversations "with Activision's direct competitor" (presumably Electronic Arts, though an EA representative refused to confirm that earlier today).
As a result of these alleged actions, Activision's complaint seeks to "recapture certain equity from West and Zampella, and to recover, as a measure of damages, all compensation and benefits in addition to equity received by them during the period of their disloyalty." In English, that means that Activision is seeking an undisclosed fortune from the defendants, left up to the court to determine, but consisting of money the two earned during their amorphous "period of disloyalty." And there's a ton more in the complaint that we couldn't fit into this measly post, so we'd strongly suggest clicking through its 23 pages in the gallery below. We'll gather up some of the most notable bits and share them after the break.
Regarding who owns the Modern Warfare-branded Call of Duty games:
"Activision owns and/or controls the rights to Call of Duty and Modern Warfare and continues to oversee the development and production of games under the Call of Duty and Modern Warfare brands."
Regarding West and Zampella's alleged insubordination:
"Threatening, on numerous occasions and during critical final stages of game development, to halt production of Modern Warfare 2 in a bad faith effort to gain further leverage in their contractual relations with Activision in an attempt to wrest control of the Call of Duty franchise and the IW studio away from Activision and its shareholders."
On the subject of negotiations with other publishers:
"Knowing of the wrongfulness of their actions, West and Zampella took steps to keep their actions hidden. West and Zampella sent and received the following messages in an apparent effort to covertly copy certain materials, reading in part: 'Dunno how to scan secretely [sic]. . . . [IW Employee's] computer down. . . . [IW Employee] did it for me last time. .. . Really. No paranoia about it being in [IW employee] user folder? Her comp down anyway now. . . . She had a secret area it scanned into. . . . Probably better to just photocopy and fedex. .. .Can scan or photo - your call. . . . Boom boom pow. Away.'
Assisted by their designated agent, West and Zampella secretly contacted the CEO and other senior executives of Activision's largest competitor. One of those executives emailed West's assistant, cc'ing West, that he was "glad to have super secret way into Jason," and was looking forward to meeting with West. Just three days after that email, the competitor flew West and Zampella on a corporate jet to a meeting of its top executives."
Regarding claims of insulting Activision executives:
"Acting insubordinately by, for example, repeatedly refusing to follow the directions of senior Activision management to whom West and Zampella reported and publicly and privately insulting Activision's executives and other Activision employees, including, for example, by creating fictitious and unwarranted accusations of 'incompetence' on the part of Activision employees in order to poison the relationship between IW and Activision."