Gem & Jewelry Design, Inc. ("LA Gem") by and through itsundersigned attorneys, sues Alex and Ani, LLC ("Alex"), and alleges:
is a California corporation having a place
Los Angeles, California.
GEM also conducts business under its
Upon information and belief, Defendant Alex is a Rhode Island limited
liability company. Alex conducts business and sells merchandise across the country,
including California and this District. Indeed, Alex boasts on its website
<www.alexandani.com/blog/alex-and-ani-conquered-los-angeles/> that "Alex And Ani
Conquered Los Angeles!" at its "Bangle Bar Party" sales and marketing event in Los
Angeles, California. Further, Alex operates an e-commerce website located at
<www alexandani.com>, which distributes products throughout the United States,
including California and this District.
JURISDICTION AND VENUE
The Court has jurisdiction over the subject matter
this action pursuant to
1331, 1338(a), 35 U.S.C. § 292, the Lanham Act,
U.S.C. §§ 1125 and
et seq., and pursuant to 28 U.S.C.
and 2202. The Court also has
supplemental jurisdiction pursuant to 28 U.S.C. § 1367(a).
4. This Court has personal jurisdiction over Defendant Alex because, by
engaging in at least the conduct itemized above, it has purposely directed its activities to
California and this District and purposely availed itself
the benefits and protections
California, including this District. Further,
contacts with the State
California and this District are significant and pervasive, including hosting marketing and
sales events in Los Angeles, and having sales representatives, dealers, and distributors
located in California and this District, and selling products directly to consumers in