20. This Court has jurisdiction pursuant to 28 U.S.C. §1331 and §1367 because this action arises under 18 U.S.C. §§1961-1968. The Court also has diversity-based jurisdiction over the parties pursuant to 28 U.S.C. §1332(d)(2). The claims asserted by Plaintiffs and the Class members meet the statutory minimum concerning the amount in controversy and at least one class memberis a citizen of a state different from one or more of the Defendants. 21. Venue is proper in the United States District Court, District of Colorado, pursuant to 28 U.S.C. §1391, because a substantial part of Defendants’ acts or omissions giving rise to the injuries and damages sustained by the Plaintiffs and the Class members and giving rise to Plaintiffs’ claims and the Class members’ claims have occurred in the District of Colorado. Furthermore, Defendants transact business in Colorado, maintain registered agents in Colorado, and maintain multiple places of business in the District of Colorado. IV. GENERAL ALLEGATIONS A. Wal-Mart 22. Wal-Mart is the world’s largest company. In 2007, Wal-Mart had net sales of $374.5 billion, $12.7 billion in net income, and an aggregate market value of voting common stock of $108.8 billion. 23. According to Wal-Mart’s own website, Wal-Mart spent approximately $1.11 billion “in the state of Colorado” for merchandise and
Posted on: Sat, 27 Jul 2013 18:32:41 +0000