IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF MISSOURIWESTERN DIVISION
DANIEL R. KLOSTER, )an individual, ))Plaintiff, ) Case No.)v. ))PETZL AMERICA, INC., ) JURY TRIAL DEMANDEDa Utah corporation, ))and ))PETZL INTERNATIONAL SAS, )a France limited liability company, ))Defendants. )
Plaintiff, Daniel R. Kloster (“Kloster” or “Plaintiff”), for its Complaint againstdefendants, Petzl America, Inc. and Petzl International SAS (collectively “Petzl” or“Defendants”) states and alleges as follows:
1.Daniel R. Kloster is an individual having a primary residence at 4021Brookridge Drive, Fairway, Kansas 66205.2.Upon information and belief, defendant Petzl America, Inc. is a Utahcorporation having its principal place of business at Building M7, Freeport Center,Clearfield, Utah 84016. Petzl can be served with process by serving its registered agent,Cass C. Butler, 10 East South Temple, Suite 900, Salt Lake City, Utah 84133.