Case 1:20-cv-01637-RMB-KMW Document 1 Filed 02 / 14 / 20 Page 3 of 10 PageID : 3
Quartz Master distributes its infringing products within this judicial district . Finally , Cambria ’ s claims arise out of or relate to Quartz Master ’ s activities in New Jersey .
6 . This Court has personal jurisdiction over Raphael Stone . Upon information and belief , Raphael Stone has a physical place of business in this judicial district located at 6-9 Park Place , Lodi , NJ 07644 , USA . Raphael Stone has also committed the tortious acts complained of herein in New Jersey , including , but not limited to using , selling , or offering for sale the infringing products accused herein , and directs its infringing products at the residents in the State of New Jersey and in this judicial district . Raphael Stone distributes its infringing products within this judicial district . Finally , Cambria ’ s claims arise out of or relate to Raphael Stone ’ s activities in New Jersey .
7 . Joinder of Quartz Master and Raphael Stone in this same action is appropriate pursuant to 35 U . S . C . § 299 because the ( 1 ) the infringement described below arises from the same series of transactions or occurrences relating to using , importing into the United States , offering for sale , or selling of the same Accused Products ; and ( 2 ) the infringement described below involves questions of fact common to both Quartz Master and Raphael Stone .
8 . Venue is proper in this judicial district pursuant to 28 U . S . C . §§ 1391 and 1400 ( b ) because Defendants have committed acts of infringement in this judicial district where the infringing product can be found , and have regular and established physical places of business in this judicial district . Defendants also do business in this judicial district through a permanent and continuous presence here .
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