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43. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §1332(a) since the amount in controversy exceeds $75,000 per plaintiff exclusive of interests and costs and there is diversity of citizenship.

44. Jurisdiction may also be predicated upon 28 U.S.C. § 1331 due to the claims made within this complaint based on the Civil Rights Act of 1866, codified as 42.U.S.C.§ 1982.

45. The Court has personal jurisdiction over the parties in that the defendants conduct systematic and continuous business within the various states and districts in which the original and/or underlying complaints were filed.

46. Venue is proper in this Court since the defendants do business and may be found in the District within the meaning of 28 U.S.C. §1391(a), as well as, 28 U.S.C. §1350.

47. The Court also has supplemental jurisdiction over the following state-law claims pursuant to 28 U.S.C. § 1367(a)claims: California's Unfair Competition Act, Cal. Bus. & Prof. Code §§ 17200 et seq.; Illinois' Consumer Fraud and Deceptive Business Practices Act, 815 ILCS §505/1 et seq.; Louisiana's Unfair Trade Practices and Consumer Protection Law, La R.S. 51:1401 et seq.; New Jersey's Unfair Trade Practice Law, N.J. Stat. § 56:8-1; New York's Consumer Protection From Deceptive Acts and Practices Laws, NY CLS Gen Bus § 349 and § 350; and Texas' Deceptive Trade Practices and Consumer Protection Act, Tex.Bus. and Com. Code § 17.41. This Court has jurisdiction over these claims pursuant to diversity jurisdiction, 28 USC §1332(a).


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