2

Nature of Action

4. USADA has notified Mr. Armstrong that unless he initiates an arbitration proceeding with USADA under USADA’s rules by 5:00 p.m. on Saturday, July, 14, 2012, USADA will strip Armstrong of his seven Tour de France titles and all other cycling victories and accomplishments and impose a lifetime ban on further competition, including banning Mr. Armstrong from competing in ce rtain triathlon competitions in which he now earns a living. Mr. Armstrong contends USADA does not have the right to charge and sanction him and strip him of his titles. Armstrong also contends USADA does not have the right to force him to arbitrate those charges without a valid, enforceable legal agreement to do so. Mr. Armstrong contends USADA ’s activity also violates his constitutional rights and tortiously interferes with his contract with Union Cycliste Internationale (“UCI”), the governing body wit h which he has an agreement. Mr. Armstrong is asking this Court for temporary, preliminary and permanent relief from USADA’s actions against him, declaratory relief, and damages against USADA with respect to his claim for tortious interference with c ontract.

Jurisdiction and Venue

5.

This court has subject matter jurisdiction over this matter pursuant to 28 U.S.C. § 1331 because it is a matter that arises under the Constitution and laws of the United States. 6.

This Court also has subject matter jurisdiction pursuant to 28 U.S.C. § 1332(a)(1) because it is an action between citizens of different states and the matter in controversy exceeds the sum or value of $75,000. The damage already caused and t he value of the continuing threat to Mr. Armstrong’s property, reputation, and livelihood, as