Digital Chocolate is informed and believes, and based thereon alleges thatDefendant Zynga Game Network Inc. is a Delaware corporation having its principal place of business at 365 Vermont Street, San Francisco, California 94103.
This Court has jurisdiction of this action under 15 U.S.C. §§ 1119, 1121, and1125, and 28 U.S.C. §§ 1331, 1338, and 1367. This action is filed,
, under the UnitedStates Trademark Act of July 5, 1946, as amended, 15 U.S.C. § 1501
(the “Lanham Act”).
This Court has personal jurisdiction over Defendant because,
, Defendantmaintains its principal place of business in California.
Venue is proper in this District pursuant to 28 U.S.C. § 1391, as both partiesmaintain their principal place of business in this District and a substantial part of the eventsgiving rise to the claims alleged herein occurred in this District.
This is an Intellectual Property Action within the meaning of Civil Local Rule 3-2(c), and is to be assigned on a District-wide basis accordingly.
Digital Chocolate is a developer and publisher of popular mass market games andsocial networking applications which are made available to consumers through a variety of platforms, including mobile phones, the Internet, social networking services, and game consoles.Founded in 2003, Digital Chocolate rapidly developed a reputation as a producer of high-qualityand popular multi-platform games. Via partnerships with leading distributors, DigitalChocolate’s products are available throughout the United States and around the world. DigitalChocolate has engaged in strategic acquisitions to expand its distribution and product offeringsand, in June 2004, acquired Sumea Interactive Ltd. (“Sumea”), a premier game developer basedin Finland. That acquisition expanded Digital Chocolate’s reach to 110 distribution partners inmore than 53 countries on 5 continents. ///