On information and belief, Defendant Spotify Technology SARL is a businessentity incorporated in Luxembourg, having its principal place of business at Avenue Marie-Therese 22, 2132 Luxembourg, Luxembourg.7.
On information and belief, Defendant Spotify Limited is a Private LimitedCompany organized under the laws of the United Kingdom, having its principal place of business at Golden House, 30 Great Pulteney Street, London W1F 9NN, United Kingdom. Oninformation and belief, Spotify Limited is a wholly owned subsidiary of Spotify TechnologySARL.8.
On information and belief, Defendant Spotify USA Inc. is a DelawareCorporation having its principal place of business at 76 9th Avenue, Suite 1110, 11th Floor, NewYork, NY 10011, USA. On information and belief, Spotify USA Inc. is a wholly ownedsubsidiary of Spotify Limited.
JURISDICTION AND VENUE
This action arises under the patent laws of the United States, Title 35 of theUnited States Code. This Court has original subject matter jurisdiction over this action pursuantto 28 U.S.C. §§ 1331 and 1338.10.
Venue is proper in the district under 28 U.S.C. §§ 1391 and 1400(b). Oninformation and belief, Spotify USA Inc. is a Delaware corporation and all four Defendants havetransacted business in this district and have committed and induced acts of patent infringement inthis district either directly, or through intermediaries.11.
On information and belief, Defendants are subject to the Court’s personal jurisdiction due, at least, to Spotify USA Inc.’s incorporation in the state and Spotify Limited’s,Spotify Technology SARL’s, and Spotify AB’s substantial business in the district, directly, orthrough intermediaries, including Spotify USA Inc., their wholly owned subsidiary.
Paragraphs 1-11 are incorporated by reference as if stated fully herein.