Tuesday, May 03, 2022 4:50:02 PM
3. This court has subject matter jurisdiction under 28 USC § 1331 and
the U.S. Const., Art. III, because this case presents a federal question under the
Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962.
4. Plaintiff’s damages far exceed $75,000.
5. Plaintiff is informed and believes, and thereon alleges, that the pattern
of unlawful and fraudulent practices alleged in this Complaint was perpetrated and
committed in the County of Orange, State of California.
6. Plaintiff further alleges that the counterfeit goods were imported into
California by certain of the Defendants and from there were transported by said
same Defendants across state lines to the buyer.
7. Plaintiff further alleges that certain of the Defendants are residents of
and/or maintain business offices within Orange County, California.
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