4
15.
On information and belief, at all times material herein, the Campaign is and was the
agent of Defendant Trump, and acting within the scope of such agency.
16.
On information and belief, Defendant Margo Mcatee Martin is Deputy
Communications Chief of the Campaign, and resides in Texas.
17.
On information and belief, at all times material herein, Defendant Martin is and was
the agent and/or employee of Defendant Trump and/or the Campaign, and acting within the scope
of such agency and/or employment.
JURISDICTION AND VENUE
18. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338
because this case involves federal claims arising under the Copyright Act, 17 U.S.C. § 101 et seq.
19. This Court has personal jurisdiction over each of the Defendants. Defendants,
acting alone or in concert with each other, and/or Defendants’ other agents or personal
representatives (a) maintain a principal place of business or otherwise have a substantial presence
in the State of New York; (b) regularly engage in fundraising and other campaign-related activities
in the State of New York or with entities and individuals in the State of New York and in this
District; and/or (c) enter into contracts in and/or perform contracts in the State of New York.
C.P.L.R. 301.
20. This Court also has personal jurisdiction over Defendants pursuant to Section 302 of
New York’s Civil Practice Law and Rules. Defendants, acting alone or in concert with each other
Defendants, and/or Defendants other agents and/or personal representatives transact business in the
State of New York, and/or supply goods or services in the State of New York, including, for
example, by attending and/or hosting events in the State of New York, and/or by inviting
individuals or entities located in the State of New York to such events, including, among others, a
Case 1:24-cv-06811 Document 1 Filed 09/09/24 Page 4 of 13