On information and belief, Prudential is a wholly owned subsidiary of PrudentialFinancial, Inc., a New Jersey corporation with headquarters located at 751 Broad Street, Newark, New Jersey 07102.
JURISDICTION AND VENUE
This action arises under the patent laws of the United States, 35 U.S.C. § 1
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.§§ 1331, 1332, 1338 and 2201.8.
Venue is proper in this federal district pursuant to 28 U.S.C. §§1391(b)-(c) and 1400(b) in that defendant resides in this district, a substantial part of the events giving rise to theclaims occurred in this district, and/or defendant has a regular and established practice of business in this district and has committed acts of infringement in this district.9.
This Court has general and specific personal jurisdiction over defendant, becausedefendant has substantial contacts with the forum as a result of conducting significant business inthe State of Texas and within this district. On information and belief, defendant regularly doesand solicits business in the State of Texas and this district; derives revenue from products and/or services provided to individuals residing in the State of Texas and this district; conducts businessutilizing the claimed systems and methods with and for customers residing in the State of Texasand this district; and provides and/or markets products and services directly to consumers in theState of Texas and this district. On information and belief, Defendant Prudential Investmentsconducts business in this district via an office located at 3616 Rosedale Avenue, Dallas, Texas75205. On information and belief, Prudential Financial, Inc. and its subsidiaries conduct business in this district via multiple offices, at least at: 2200 Ross Avenue, Dallas, Texas 75201;9304 Forest Lane, Dallas, Texas 75243; and 4100 Alpha Road #400, Dallas, Texas 75244.