Verisign-Cnic-Lawsuit
Case 1:15-cv-01028-LO-IDD Document 1-1 Filed 08/13/15 Page 1 of 123 PageID# 5 VIRGINIA: IN THE CIRCUIT COURT OF FAIRFAX COUNTY VERISIGN, INC., Plaintiff, V. Civil Action No. CL 2015-3519 CENTRALNIC LIMITED, XYZ.COM LLC Serve; Paracorp Incorporated, Reg. Agt. 318 N. Carson Street, Suite 208 Carson City, NV 89701 -and- DANIEL NEGARI, 205 South Camden Drive Beverly Hills, CA 90212 Defendants. FIRST AMENDED COMPLAINT COMES NOW the plaintiff, VeriSign, Inc. ("Verisign"), bycounsel, and for its first amended complaintstates the following: Parties 1. Verisign is a corporation organized and existing under the laws of the State of Delaware, having its principal place of business in the Commonwealth of Virginia. EXHIBIT /I Case 1:15-cv-01028-LO-IDD Document 1-1 Filed 08/13/15 Page 2 of 123 PageID# 6 2. Defendant CentralNic Limited ("CentralNic") is a corporation organized and existing under the laws of the United Kingdom, having its principal place of business in London, England. 3. Defendant XYZ.COM LLC ("XYZ") is a limited liability company organized and existing under the laws of the State of Nevada, having its principal place ofbusiness in the State ofNevada. 4. Defendant Daniel Negari is a natural person who, upon information and belief, is a resident of the State of California. Upon information and belief, Negari owns and/or controls XYZ. Jurisdiction and Venue 5. This Court has subject matterjurisdiction over this action pursuant to Virginia Code § 17.1-513. 6. CentralNic, XYZ and Negari are subject to personal jurisdiction in this Court pursuant to Virginia Code § 8.01-328.1(3 & 4) in that, as set forth herein, CentralNic, XYZ and Negari have caused tortious injury by acts in this Commonwealth; and have caused tortious injury in this Commonwealth by acts and omissions outside this Commonwealth and regularly do or solicit business, orengage in other persistent course ofconduct in this Commonwealth.
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