Can you draft a jurisdictional complaint under Fed. R. Civ. P. 8(a) based on the facts given below ?

Your client, Plotkin, Inc., manufactures a substance called carbonium that is an important component of high technology products. Plotkin is incorporated in Delaware and has its headquarters in Davenport, Iowa. The manufacturing process for carbonium is a closely held secret at Plotkin and is central to its carbonium sales business, which earns over $100 million a year. If its process were to get out, it would reduce Plotkin's profits to no more than $10 million a year.

Recently, Plotkin's internal security team discovered that one of its employees, Dristol Kastol, had copied key files relating to the carbonium manufacturing process onto a USB drive. The security team examined the contents of Kastol's work email account and discovered an email from an account at a competitor named Educom, Inc. that offered to pay Kastol $500,000 for detailed information about Plotkin's carbonium manufacturing process. Data on the email indicates that it originated from Educom's Indianapolis headquarters.

Plotkin is preparing to file an action against Kastol and Educom for trade secret misappropriation under the federal Defend Trade Secrets Act, codified at 18 U.S.C. 1836. The elements of a trade secret misappropriation claim are (1) the existence of a trade secret, and (2) that the defendant misappropriated the secret, a concept that encompasses both breach of a duty of confidentiality as well as using improper means to obtain the trade secret of another (such as bribery). Plotkin would like to file in the Southern District of Iowa (which encompasses Davenport).

You have been asked to draft the jurisdictional sections of the complaint. Your research has uncovered that Kastol's residence is in Moline, Illinois, where he has lived for the past five years. You have also determined that Educom is incorporated in Delaware and has its corporate headquarters in Indianapolis, Indiana.

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Answer In the United States District Court for the Southern District of Iowa Plotkin Inc Plaintiff v ... View the full answer