5.1     This suit is brought, in part, pursuant to TEX. BUS. & COM. CODE §17.41, et seq., commonly known as the Texas Deceptive Trade Practices - Consumer Protection Act and pursuant to TEX. BUS. & COM. CODE §2.313(a).

5.2     Venue of this action is proper in Orange County, Texas. Specifically, venue is permissive pursuant to TEX. CIV. PRAC. & REM. CODE §15.033 because it is the county in which the Plaintiffs resided at the time the acts or omissions giving rise to Plaintiffs’ cause of action occurred, as the causes of action accrued, it is the county in which the Plaintiffs purchased Defendants’ products, and the county in which the Defendants’ products failed to kill lice infestation.

5.3     Defendants regularly and systematically do business within the State of Texas, and have, therefore, subjected themselves to specific and general jurisdiction of this court. Plaintiffs’ damages exceed the minimum jurisdictional limits of this court.