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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELA WARE
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`FISHER-PRICE, INC. and
`MATTEL, INC.,
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`Plaintiffs,
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`vs.
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`C.A. No. 17-0051-LPS-CJB
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`DYNACRAFT BSC, INC.,
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`Defendant.
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`Declaration of David Castrucci in Support of Defendant
`Dynacraft BSC, Inc.'s Motion to Dismiss for Improper Venue
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`I, David Castrucci, am the Managing Director at Dynacraft BSC, Inc. ("Dynacraft") and I
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`have personal knowledge of the facts attested to herein. I declare under penalty of perjury that the
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`content of this declaration is true and correct.
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`1.
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`Dynacraft is a corporation organized and existing under the laws of the State of
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`Massachusetts but has no regular and established business there. Dynacraft has no employed and
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`does not have any physical facilities in Massachusetts.
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`2.
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`Dynacraft is headquartered at 89 S. Kelly Road, American Canyon, California.
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`Dynacraft employs about 40 employees at its headquarters, including its corporate officers and
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`product design staff. At its headquarters, Dynacraft's operations include management, personnel,
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`customer service, shipping, traffic, IT, and creative.
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`3.
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`4.
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`Dynacraft is""~ot incorporated in the State of Delaware.
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`Dynacraft does not have any regular and established business in the District of
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`Delaware. Dynacraft has no employees and does not have any physical facilities in Delaware.
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`Dated: June J_, 2017
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