This is a motion by defendant for an order under Fed.R.Civ.P. 12(b) dismissing the action (a) for lack of jurisdiction over the subject matter, (b) for lack of jurisdiction over the person of defendant, and (c) for improper venue, or in the alternative for an order under 28 U.S.C. § 1404(a) transferring the action to the Western District of Pennsylvania "for the convenience of parties and witnesses...
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