Downshire is a Quebec, Canada corporation headquartered in Montreal.
purports to be a private investment banking group.
holds the license to use the trade mark"PennyStockChaser" in the United States and Canada, whose stated services include providing awebsite featuring stock market information.
Meadow Vista is a Wyoming corporation which purports to be an investmentbank headquartered in Cheyenne, Wyoming.
III. JURISDICTION AND
11. The Court has jurisdiction over this action pursuant to Sections 20(b), 20(d), and22(a)
the Securities Act
U.S.C. §§77t(b), 77t(d), and 77(v)(a)]; and Sections 21(d), 21(e),and 27
the Exchange Act
U.S.C. §§78u(d), 78u(e), and 78aa].
The Court has personal jurisdiction over the Defendants, and venue is appropriatein the Southern District
Florida. As described below, many
transactions, acts, practicesand courses
c o n s t ~ t u t i n g
the Securities Act and Exchange Act occurredin the Southern District
Florida as well as in the United States.
For example, Meadow Vista maintains brokerage accounts at a firm in BocaRaton, Florida, where the Defendants receive, purchase, and sell shares
the companies toutedon PennyStockChaser. McKeown signed the account opening forms for these accounts, and islisted as corporation owner on them. McKeown and Ryan control and manage these brokerageaccounts, including by regularly sending e-mails to brokers at the Boca Raton
directingtrading in these accounts. Downshire and Meadow Vista also maintain accounts at no fewer thanthree other brokerage firms in the United States, where McKeown has also signed accountopening forms.