Adventure Creative Group, Inc. v. Cvsl, Inc. et alMOTION to Dismiss/GeneralD. Minn.October 25, 2016IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA Adventure Creative Group, Inc., Plaintiff, v. CVSL, Inc. a Florida corporation doing business as JRJR Networks; Your Inspiration at Home Pty Ltd., an Australian proprietary limited company; Your Inspiration at Home, Ltd., a Nevada corporation; Inspired Portfolio Pty Ltd., an Australian proprietary limited company; CVSL YIAH Pty Ltd., an Australian proprietary limited company, Defendants. Civil Action No. 0:16-cv-02532-SRN-FLN DEFENDANTS’ MOTION TO DISMISS Defendants CVSL, Inc. d/b/a JRJR Networks, Your Inspiration at Home Pty Ltd., Your Inspiration at Home, Ltd., Inspired Portfolio Pty Ltd., and CVSL YIAH Pty Ltd. (collectively, “YIAH Defendants”)—which constitute all the defendants in this case— hereby move this Court to dismiss Plaintiff Adventure Creative Group, Inc.’s Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6) and on forum non conveniens grounds. The motion is based upon the accompanying memorandum and the complete files and records in this action, including Plaintiff’s Complaint, oral argument of counsel, and such other and further matters as this Court may consider. CASE 0:16-cv-02532-SRN-FLN Document 11 Filed 10/25/16 Page 1 of 2 2 Dated: October 25, 2016 Respectfully submitted, FISH & RICHARSON P.C. By: s/ Tasha Francis Tasha Francis (#0395360) Joseph A. Herriges (#390350) 3200 RBC Plaza 60 South Sixth Street Minneapolis, MN 55402 Telephone: (612) 335-5070 Facsimile: (612) 288-9696 tfrancis@fr.com; herriges@fr.com Taj Clayton (to be admitted pro hac vice) Texas Bar No.24050427 Rex Mann (to be admitted pro hac vice) Texas Bar No. 24075509 1717 Main Street, Suite 5000 Dallas, TX 75201 Telephone: (214) 747-5070 Facsimile: (214) 747-2091 clayton@fr.com; mann@fr.com COUNSEL FOR DEFENDANTS CVSL, INC. A FLORIDA CORPORATION DOING BUSINESS AS JRJR NETWORKS; YOUR INSPIRATION AT HOME PTY LTD., AN AUSTRALIAN PROPRIETARY LIMITED COMPANY; YOUR INSPIRATION AT HOME, LTD., A NEVADA CORPORATION; INSPIRED PORTFOLIO PTY LTD., AN AUSTRALIAN PROPRIETARY LIMITED COMPANY; CVSL YIAH PTY LTD., AN AUSTRALIAN PROPRIETARY LIMITED COMPANY. CASE 0:16-cv-02532-SRN-FLN Document 11 Filed 10/25/16 Page 2 of 2
