Zawitz

I. BACKGROUND

19 A. Parties Tangle is a California corporation and the exclusive master licensee for the manufacture and marketing of the Tangle Sculpture, a unique sculptural design used for play, therapy, and educational purposes. Compl. ¶¶ 2, 6; id., Ex. 2. Zawitz is the founder of Tangle and the creator and owner of the Tangle Sculpture. Id. ¶ 1. Star Magic is a business entity with its principal place of business in New York. MTD at 1. Ayal is the President of Star Magic and in charge of Star Magic’s business operations. Id. Star Magic has purchased Tangle Sculptures from Tangle since the 1980s. Compl. ¶ 8. Star brick-and-mortar retail stores in the early 2000s and began selling Tangle products exclusively online, including on Amazon. Id. Ayal asserts that neither he nor other Star Magic representatives have ever traveled to California for purposes related to Star Magic’s business. [Docket No. 16-1, Declaration of Shlomo Ayal (“Ayal Decl.”) ¶ 6.] All meetings between Plaintiffs and Defendants have taken place in New York. Id. Additionally, no Star Magic entity has been incorporated…