Supra Floors, Inc. (“Supra Floors”) is a Canadian corporation with a principal place of business at 35 Woodbine Downs Blvd., Rexdale, Ontario, Canada M9W6N5. SupraFloors promotes, markets, sells, and provides technical support and training for OSBE’sElastilon products, throughout the United States.4.
Supra Floors, Inc. is the exclusive licensee from OSBE Parket B.V. under the‘251 Patent for the right to sell, offer to sell, and market OSBE’s Elastilon products at least in theUnited States.5.
According to Georgia’s Secretary of State, Foam Products is a Georgiacorporation with a principal place of business at 350 Beamer Road, SW, Calhoun, Georgia30701.6.
On information and belief, Jerry G. Arnold is the CEO of Foam Products, with anaddress of 350 Beamer Road, SW, Calhoun, Georgia 30701.7.
On information and belief, Mr. Arnold personally participates in the decisionmaking process of Foam Products concerning all aspects of manufacturing, marketing and promoting flooring products and installation services to its customers.
JURISDICTION AND VENUE
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.§§ 1331 (federal question), 1332 (diversity), and/or 1338 (patents), because it is a civil actionarising under the laws of the United States, namely, 35 U.S.C. § 271.9.
This Court has personal jurisdiction over Foam Products pursuant to the IllinoisLong Arm Statute, 735 ILCS 5/2-209(a)(1)-(2) and (c) because, among other things, FoamProducts transacts business in this judicial district, at least by offering to sell, selling and/or advertising floor surfacing products and/or services at least through the Internet in such a way as