PARTIES, JURISDICTION, AND VENUE
ERICO is an Ohio corporation, with its principal place of business located at31700 Solon Road, Solon, Ohio 44139.3.
Upon information and belief, Defendant Bruce G. Phillips is an individual and aresident of the State of Arizona, residing at 108 West Laurel Court, Gilbert, Arizona 85233.4.
Upon information and belief, Defendant Electrical Prefab Systems, LLC is anArizona limited liability company, with its principal place of business located at 6607 WestBoston Street # 3, Chandler, Arizona 85226.5.
Upon information and belief, Defendant Phillips is the co-founder and a member of Defendant Electrical Prefab Systems, LLC.6.
Upon information and belief, either directly or indirectly, Defendantsmanufacture, distribute, supply, and/or sell goods or services into and/or from the State of Ohio.Defendants derive a financial benefit from the commercial activities they conduct, either directlyor indirectly, in the State of Ohio.7.
This Complaint seeks declaratory relief under the Declaratory Judgment Act, 28U.S.C. §§ 2201 and 2202. This Court has subject matter jurisdiction over the claims in thisaction pursuant to 35 U.S.C. § 271 and 28 U.S.C. §§ 1331, 1338, and 1367, because it arises, in part, pursuant to 35 U.S.C. § 271.8.
This Court also has subject matter jurisdiction over the claims in this action pursuant to 28 U.S.C. § 1332(a), because the amount in controversy exceeds $75,000, exclusiveof interest and costs, and the controversy is between citizens of different States9.
Defendants are subject to this Court’s personal jurisdiction in that they: (1)transact business within the State of Ohio and this District; (2) contract to supply goods or