Plastic2Oil Inc (PTOI)

[scion]

The minimum contacts analysis requires a review of any contacts by Mr. Bordynuik with the state of Florida. See Consolidated Energy, Inc. v. Strumor, 920 So. 2d 829, 832 (Fla. 4th DCA 2006). A review of the Complaint establishes that Plaintiff has alleged no facts to establish any contacts between Mr. Bordynuik and Florida.

The Complaint clearly states that Mr. Bordynuik is a resident of Ontario, Canada and that he is the CEO and President of JBI, a Nevada corporation with a principal place of business in Cambridge, Massachusetts.3 (Complaint, irs 3,4) However, the Plaintiffs Complaint contains no allegation of acts committed by Mr. Bordynuik in Florida. Further, the Plaintiff has not alleged the existence of activities or conduct that Mr. Bordynuik purposefully directed to the state of Florida. Given the absence of such allegations, the Plaintiff has failed to establish that Mr. Bordynuik has purposefully availed himself of the jurisdiction of the courts of Florida or that Mr. Bordynuik should reasonably have anticipated being hailed into court in Florida. Therefore, the Plaintiff has failed to meet its burden that Mr. Bordynuik maintains sufficient minimum contacts with the state of Florida.

Doc 10 PDF file, p5
http://viewer.zoho.com/docs/gccRod

Florida Limited Liability Company

PAK-IT, LLC

Title MGR
BORDYNUIK, JOHN
311 PARK PLACE, #190
CLEARWATER FL 33759

http://tinyurl.com/2feqqe4

Domain Name: HEATHERBORDYNUIK.COM

Registrant:
John Bordynuik
1901 60th Place
Suite L9181
Bradenton, Florida 34203
United States

Domain Name: HEATHERBORDYNUIK.COM

Created on: 09-Dec-04
Expires on: 09-Dec-18
Last Updated on: 10-Dec-08

Administrative Contact:
Bordynuik, John
1901 60th Place
Suite L9181
Bradenton, Florida 34203
United States
7163046711 Fax -- 7163041904

Technical Contact:
Bordynuik, John
1901 60th Place
Suite L9181
Bradenton, Florida 34203
United States
7163046711 Fax -- 7163041904

Domain servers in listed order:
NS05.DOMAINCONTROL.COM
NS06.DOMAINCONTROL.COM

http://whois.domaintools.com/heatherbordynuik.com