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12345678910111213141516171819202122232425262728Plaintiff, Quest Nutrition, LLC (“Quest Nutrition”), files this Complaintagainst the above-named defendants, Board of Supervisors of LSU Agricultural andMechanical College (“Board”), LSU Agricultural Center (“Agricultural Center”),William Richardson, Robert Yarborough, Ann Duplessis, Garret Danos, ScottBallard, Stanley Jacobs, Ann Duplessis, J. Stephen Perry, Scott Angelle, JohnGeorge, Raymond Lasseigne, R. Blake Chatelain, James Moore, Jr., RonaldAnderson, Rolfe McCollister, Jr., Jack Lawton, Jr., Lee Mallett (collectively,“Defendants”), and demanding a trial by jury, alleges as follows:
JURISDICTION AND VENUE
1. The Court has diversity jurisdiction over this action pursuant to 28U.S.C. § 1332, as well as subject matter jurisdiction over this action as it arisesunder the patent laws of United States Code, Title 35 and under the DeclaratoryJudgment Act, 28 U.S.C. § 2201. The Court also has pendent jurisdiction for thecommon law claims.2. This Court has jurisdiction over Defendants due to Defendant’s purposeful direction of activities to residents of California. In addition to thecontractual relationships created by Defendants and California corporations such asQuest Nutrition, on information and belief, Defendants Board and AgriculturalCenter have participated in conferences within the State of California, solicitedresearch contracts, funds, and volunteers within the State of California, and targetedadvertising to residents of the State of California and within this District.3. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b)(2) because a substantial part of the events or omissions giving rise to this dispute between the parties occurred and continue to occur in this judicial district.
4. Plaintiff Quest Nutrition is a California corporation with its principal place of business at 2233 East El Segundo Boulevard, El Segundo, California92045.