arise under the laws of the State of Texas pursuant to 28 U.S.C. § 1367(a), because the state lawclaims are so related to the federal claims that they form a part of the same case or controversyand derive from a common nucleus of operative facts.9.
This Court has personal jurisdiction over Defendant because it has purposefullydirected its unlawful acts to this forum, committed torts in this District, breached a contractentered into in this District, and violated Texas statutory law in this district.10.
Upon information and belief, Defendant has purposefully availed itself to theforum by entering into one or more contracts with residents of the State of Texas, knowing that itwould receive commercial gain through such contracts.11.
Upon information and belief, Texas consumers interact with Defendant’sMySouthwestCheckIn.com website and have downloaded Defendant’s automatic flight check-insoftware.12.
Upon information and belief, Defendant collects personal and paymentinformation from Texas residents who purchase Defendant’s services.13.
Upon information and belief, Defendant directs its business activities to residentsof Texas knowing that it will receive commercial gain from selling its services to Texas residents.14.
Upon information and belief, Defendant knew that the injury from its unlawfulacts would be felt primarily by Southwest in this judicial district, where Southwest isincorporated and headquartered, and where it originates numerous flights every day for Texasresidents.15.
Moreover, in order to perpetrate the wrongful acts alleged in this complaint,
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