Even crediting the references to personal jurisdiction within Defendants’ analysis in their special motion to strike, the purported motion to quash is without merit. Plaintiff does not claim that there is general jurisdiction over Defendants, who are Illinois and Oklahoma residents, and Plaintiff has met his burden to show that exercising specific jurisdiction over these Defendants comports with due process.
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Here, Plaintiff has come forward with evidence to satisfy this showing. To the extent that he relies on allegations in his unverified complaint, he has not presented admissible evidence. An “unverified complaint has no evidentiary value in determination of personal jurisdiction.” (Mihlon v. Superior Court (1985) 169 Cal.App.3d 703, 710.) Plaintiff has submitted evidence, however, that Plaintiff has felt the brunt of the harm in California, where he resides and works. (Declaration of Christopher Avellone ¶¶ 27-29.) Plaintiff also presents evidence that Defendants knew that Plaintiff would suffer the brunt of the harm in California and specifically aimed conduct at California, by directing tweets at one of Plaintiff’s former employers, Electronic Arts, Inc. (Avellone Decl. ¶ 26 & Exhs. 12, 13.) In addition, as noted above, Defendants’ tweets referred to Plaintiff by name, knowing that he resides in California, suggesting that they would know he would suffer the brunt of the harm there. (Avellone Decl. ¶¶ 25, 26.)