3. Venue is proper in the Southern District of Texas, Corpus Christi Divisionin that a substantial part of the events or omissions giving rise to the claim occurred ortook place in this District.
4. Plaintiff, Sylvia Pena, is a resident of Corpus Christi, Nueces County,Texas.5. Plaintiff, Albert A. Pena, III, is a resident of Corpus Christi, NuecesCounty, Texas.6. Defendant, TOYOTA MOTOR CORPORATION (“TMC”), is, and at allrelevant times was, a Japanese corporation with its headquarters in Toyota City, AichiPrefecture, Japan. Defendant TMC may be served with Citation in accordance with theFederal Rules of Civil Procedure and the Hague Convention on the Service Abroad ofJudicial and Extra-Judicial Documents in Civil or Commercial Matters, TIAS # 10072(U.S. Treaties & other International Acts) and 20 UST 361 (U.S. Treaties & otherInternational Agreements), by servicing the Citation upon the Office of the Ministry ofForeign Affairs of Japan, which shall then served the agent or officers of Defendant withCitation at its offices at 1 Toyota-Cho, Toyota City, Aichi Prefecture 471-8571, Japan,Phone: (0565) 28-2121, or otherwise, pursuant to the laws of Japan.7. Defendant, TOYOTA MOTOR SALES, U.S.A., INC. (“TMS”), is, and at allrelevant times was, a California corporation with its principal place of business in LosAngeles County, California. Defendant TMS conducts business in the state of Texas,derives substantial profits from its business in the state of Texas, and may be servedwith process in this action by delivering summons and copy of this complaint to its