OPINION AND ORDER Plaintiff Alcon Laboratories, Inc. (“Alcon”) brings this action alleging trademark infringement under 15 U.S.C. §1114 and New York common law; false designation of origin under 15 U.S.C. §1125(a); deceptive trade practices under New York General Business Law §349; false advertising under New York General Business Law §350; and unfair competition under New York common law. Defendant Lens.com, Inc. (“Lens.com”) is a corporation that operates websites selling contact lenses, including contact lenses produced by plaintiff Alcon. Alcon alleges that Lens.com’s sales of its products are “unauthorized” and consequently injurious to consumer safety and Alcon’s reputation. Lens.com maintains that it purchases genuine Alcon contact lenses in the United States and abroad and sells them to customers at discount prices in frustration of Alcon’s anticompetitive distribution scheme. The merits of the claims are not now under consideration. Before me is defendant’s motion to dismiss for lack of personal jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(2), or alternatively, to transfer venue to the District of Nevada pursuant to 28 U.S.C. §1404(a). For the reasons set forth below, Lens.com’s motion is denied.I. BACKGROUNDAlcon is a corporation organized under the laws of Delaware with its principal place of business in Texas. In 2017, Alcon sold nearly $15 million of Alcon contact lenses to New York eye care practitioners. Lens.com is a corporation organized under the laws of Nevada with its principal place of business in Nevada. Lens.com ships orders of contact lenses purchased from its websites from a warehouse and distribution center in Missouri.According to the Amended Complaint and declarations accompanying this motion, in Fall 2017, Alcon hired a private investigator to purchase its products from Lens.com. Between October and December 2017, the investigator placed orders for Alcon products “Dailies Aquacomfort Plus” and “02 Optix” from Lens.com. The orders arrived, containing the products, at an address in Queens, New York with shipping labels indicating shipment from Lens.com in Missouri. A second investigator, subcontracted by the first investigator, placed an order in November 2017 for “Dailies Aquacomfort Plus” from Lens.com and received the products at an address in Staten Island, New York apparently from Lens.com in Missouri.As it relates to jurisdiction, Alcon alleges that Lens.com is subject to specific jurisdiction in New York under New York’s long-arm statute, N.Y. C.P.L.R. §302, based on its actions as described in the First Amended Complaint. Those actions include:1. Operating multiple highly interactive internet sales websites through which consumers, including New York consumers, can order contact lenses shipped anywhere in the United States, including to New York (Am. Compl.
