MEMORANDUM AND ORDER Plaintiff Global Supplies NY, Inc. brings the instant action against Defendants Electrolux Home Products, Inc., (“Electrolux”) and Simple Wishes LLC (“Simple Wishes”) alleging tortious interference with existing and prospective business relationships.1 Electrolux moves pursuant to Rules 12(b)(2), 12(b)(5), and 12(b)(6) of the Federal Rules of Civil Procedure to dismiss the amended complaint in its entirety for lack of personal jurisdiction, improper venue, and failure to state a claim. In the alternative, Electrolux moves pursuant to Rule 21 of the Federal Rules of Civil Procedure to sever the action and pursuant to 28 U.S.C. §1404(a) to transfer the action to the Western District of North Carolina. Plaintiff cross-moves to transfer the action to the Western District of Washington. Simple Wishes likewise moves pursuant to Rule 12(b)(6) to dismiss the amended complaint in its entirety for failure to state a claim. In the alternative, Simple Wishes moves pursuant to Rule 12(f) to strike portions of the amended complaint.2 BACKGROUND3 Plaintiff is a business located in New York that buys products from manufacturers and sells them online (Am. Compl. 2, ECF No. 37.) Plaintiff became a third-party seller on Amazon in 2010. (Id. 3.) Electrolux is a U.S. subsidiary of a Swedish home-appliance manufacturer located in Delaware and headquartered in North Carolina. (Id.
18, 19.) Electrolux is the owner of U.S. Patent No. 9,901,852 — relating to a refrigerator that includes ice and water modules. (Id. 21.) Simple Wishes is a limited liability company located in Delaware and doing business in Texas and Connecticut. (Id. 30.) Simple Wishes is the owner of U.S. Patent No. 8,323,070 — relating to a garment worn while pumping breastmilk (Id. 31.) During the relevant period, Plaintiff listed approximately 1,000 name brand products on Amazon’s website. (Id. 5.) Plaintiff sold over 3,000,000 units to Amazon’s customers. (Id. 5.) According to Plaintiff, it reached $4.1 million in sales during its last six months with Amazon at a 12 percent net margin — or $492,000 in profits (i.e. monthly profits of $82,000). (Id. 5.) During the relevant period, Defendants and two other patent owners filed complaints with Amazon that Plaintiff had committed patent infringement by listing their patented products for sale (“IP Complaints”). (See id.
