First Amended Complaint - 3
1965(a) and (d) because all Defendants have transacted and presently transact theiraffairs in this judicial district.5.
Defendants have previously consented to and waived objections tothis Court’s jurisdiction and to venue within this judicial district.
Plaintiff Asia Economic Institute is a limited liability company and, atall times relevant hereto, organized and existing pursuant to the laws of the State of California, and is authorized to do business in the State of California. Plaintiff AsiaEconomic Institute has its principal place of business at 11766 Wilshire Boulevard,Suite 260, Los Angeles, California 90025.7.
Plaintiff Mobrez is an individual and, at all times relevant hereto, aresident of Los Angeles, California, County of Los Angeles. Plaintiff Mobrez is aprincipal and manager of Asia Economic Institute, LLC. In addition, as aCalifornia-licensed broker, Mr. Mobrez derives a significant amount of revenuefrom brokering commercial real estate transactions.8.
Plaintiff Llaneras is an individual and, at all times relevant hereto, aresident of California, County of Los Angeles. Plaintiff Llaneras is a principal andmanager of Asia Economic Institute, LLC. In addition, as a California-licensedbroker, Ms. Llaneras derives a significant amount of revenue from brokeringcommercial real estate transactions.9.
Defendant Xcentric is a limited liability company organized andexisting pursuant to the laws of the State of Arizona with its purported domesticaddress as P.O. Box 470, Phoenix, Arizona 85280. Plaintiffs are informed andbelieve and thereon allege that Xcentric is owned by a single member, CreativeBusiness Investment Concepts, Inc., a Nevada corporation located at 2533 NorthCarson Street, Carson City, Nevada 89706. Defendant Xcentric transacts businessin interstate commerce as, inter alia, “Ripoff Report,” an enterprise, located in this
Case 2:10-cv-01360-SVW-PJW Document 96 Filed 07/27/10 Page 3 of 84 Page ID #:2324