Amended Complaint — Creation Entertainment, Inc. v. Small Business Administration (Dkt. 59, D.D.C.)

Summary

The second amended complaint in Creation Entertainment, Inc. v. Small Business Administration, Civil Action No. 22-684 (ABJ), in the U.S. District Court for the District of Columbia, filed January 15, 2026 as Document 59 against the SBA and Administrator Kelly Loeffler. It challenges the SBA's December 18, 2025 decision denying the company's April 28, 2021 Shuttered Venue Operators Grant application for $9,699,500.00. The complaint recounts earlier denials, rescissions on May 12, 2022 and July 7, 2025, and an August 2, 2022 response in which it says the SBA acknowledged the company appeared to qualify. It alleges the latest decision rests on whether live performances were the principal attraction of its events, a test not found in the statute. It pleads arbitrary and capricious action and unlawful withholding of agency action, and asks for the award or a remand.

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