That's what the plaintiff says, all right. I expect at least one of the defendants will take issue with it. Especially this: "Each Individual Defendant has had substantial and continuous contacts with the Commonwealth of Massachusetts such that make the exercise of personal jurisdiction over them proper."
By the way, I wonder if Robin Bagai will be the second defendant released from the suit. The 10-K had already been signed and filed prior to his appointment to the Board. Unless there's another basis for his inclusion, I suspect he'll be dismissed.
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