JURISDICTION AND VENUE
56. 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. 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.
57. 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.
58. 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. Sec. 1391(a), as well as, 28 U.S.C. Sec. 1350.
59. The Complaint also alleges violations of the following state unfair competition and consumer protection laws and seeks equitable relief as well as civil penalties based on these 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). In the alternative, the Court has supplemental jurisdiction over these state-law claims pursuant to 28 U.S.C. § 1367(a). The State-law claims are so related to the equitable and federal-law claims raised in this complaint that they form part of the same case or controversy under Article III of the United States Constitution. The issues raised by the State-law claims are no more novel or complex than the federal law claims, nor do they substantially predominate over the federal-law claims. Supplemental jurisdiction would avoid unnecessary duplication and multiplicity of actions, and should be exercised in the interests of judicial economy, convenience and fairness.
60. The Court has jurisdiction under 28 U.S.C. Sect. 1350, the Alien Torture Claims Act which provides, “the district courts shall have original jurisdiction of any civil action by an alien for a tort only, committed in violation of the laws of nations or a treaty of the United States
