Plaintiffs complain and allege as follows:
PARTIES, JURISDICTION AND VENUE
Turbo Style Products, LLC is a Utah corporation having a principal place of business at 2402 Lake View Ct., Park City, Utah 84060.2.
Upon information and belief, Luigia’s Lashes, LLC is a Alabama limited liabilitycompany with its principal place of business at 6097 County Rd 33, Hollywood, Alabama 35752.3.
Upon information and belief, Carlo Mark Bone is an individual residing in theUnited Kingdom at 23 Seymour Road, Luton, LU1 3NL, United Kingdom.4.
Upon information and belief, Carlo Mark Bone does business under the namesEyelashes For Cars and Transglobal Distribution Network.5.
Turbo Style brings this action under U.S. patent laws, 35 U.S.C. §§ 1
.,under the Lanham Trademark Act, Title 15, United States Code §1051,
, and under variousother Utah state law and common law provisions.
This Court has subject matter jurisdiction over this action under 28 U.S.C. §§1331 and 1338.
This Court has supplemental jurisdiction over any state law statutory and commonlaw claims pursuant to 28 U.S.C. § 1367.
Upon information and belief, this Court has specific personal jurisdiction over Defendants as Defendants have purposefully directed their activities toward the state of Utah.
Upon information and belief, this Court has general personal jurisdiction over Defendants since Defendants’ contacts with Utah are substantial, continuous, and systematic and this action is based upon activities that arise out of or are related to those contacts.
Venue is proper in this judicial district pursuant to 28 U.S.C. §1391 becauseDefendants’ conduct business directly related to the patents and trade dress at issue in this case,thereby harming Plaintiffs in this judicial district.