answer and write in the same format from my last IRAC attached.

demanded that Katherine stop using the thermostat; however, Katherine continued and even left the windows open in her space. Further, Katherine demanded the directional sign out front be completed to show the salon was a tenant, instead Naman purposely had the landscaper not cut the bushes in front of the salon sign. The war of the Oranges continued to rage until both sides realized that this couldn't be resolved. Naman sues Katherine for breach of contract in local town court for an action of eviction hiring another friend from his MBA days Aarthi Manoharan, MBA, Esq. Katherine calls on her SU friend and attorney Jessie "the Silent Assassin" Siloahti, Esq, who works at the largest law firm in Syracuse (and commands the largest fee), and also countersues for breach of contract asking to terminate the contract and demands $30,000 in damages. What contractual issues do you need to consider in this fact pattern? Answer using the IRAC format.IRAC contracts The War of the Oranges Naman Bansal is a successful real estate mogul in Upstate New York. He owns a number of properties, both commercial and residential and all for rent. One property in particular on the East side of the City of Syracuse had underperformed compared to the rest of his portfolio. This property was a three-story building that overlooked the beautiful campus of Syracuse University, his alma mater. This commercially zoned piece of property was the corporate home to Naman''s empire, and his staff and he used most of the building; however, there was room for some commercial rental activity on part of the first floor. In an effort to improve the profitability of the property, Naman enlisted the assistance of his friend, and classmate from SU, Saeed Fadaeimanesh, a licensed real estate agent and real go getter. Saeed sold Naman on the fact that he would find a tenant for this property. Meanwhile, Katherine Sullivan was an entrepreneur who had opened a day salon in the city of Syracuse that was meeting with great success. Katherine had a nice business providing spa services to business professionals located in the heart of downtown Syracuse. Both men and women frequented the salon where they could get any number of pampering services. However, Katherine noted that the lack of parking and the lack of residential housing in the city of Syracuse limited her income potential. If she could find a place near the city but near people with money, and off-street parking she could increase her revenues and profits. At a chance meeting at the Inn Complete bar after an SU hockey game, Saeed (also an SU MBA alum), met his old classmate, Katherine who happens to be a hockey fan. The two conversed about the great time they had in school especially their favorite professor who taught them law and public policy and managerial accounting. During the conversation, they got caught up on what each other was doing and the lightbulb went off. Saeed realized that he might be able to get Katherine to lease the space that Naman had to offer. The location was perfect! After a few more refreshments and a cheeseburger, they agreed to meet the next day at the property. Katherine thought the location was perfect, but she needed the basement in addition to the first floor to execute her business plan. Saeed, in a hurry to make a sale, provided a sketch of the first floor and marked the map as \"Exhibit A\" and attached it to a lease document that he had made which outlined the terms of the agreement. The agreement (prepared by Saeed who is not a lawyer, but who thinks he is because of his one law class at SU) had the parties, the rent amount, and the term of the agreement which was for 5 years with 5-year options. Katherine insisted that she would be allowed to make some cosmetic changes and repairs to the space, including the basement to accommodate the look she wanted for her very particular and exclusive clientele. Saeed again, quickly agreed but only updated the Map on Katherine's copy of the lease agreement to include the basement. Naman had given Saeed his full authority to contract in this situation as he was very busy running his real estate empire and had no time for this small space on the first floor of the building. As such, Naman simply signed the agreement that Saeed gave him, however, Naman''s copy did not include the basement in the Exhibit A but simply the first-floor layout. There seemed to be an agreement and a signed document, so Katherine moved in and began construction of the remodeled space. The noise was quite the irritant to Naman, and his staff and he quickly became annoyed with his new tenant but did not say anything despite periodic inspections as to what all the noise was about. In addition, Naman noted that Katherine was using the basement space, but he did not recall the agreement including the basement. His copy of the agreement only showed a sketch of the first floor with no reference to the basement space. Again, too busy to worry about it, he let the construction finish, which included the installation of a washer, dryer and other equipment in the basement and attended the grand opening of the salon which was sparsely attended but tastefully done. Once the business began operations, it was clear that the basement was being used as a breakroom for the salon staff. They were eating their lunch in the basement, smoking cigarettes in the confined area and generally leaving a mess. Naman and his staff were also using the basement for storage and they would observe this behavior when accessing the basement. In addition, the only way for anyone to get to the basement was via a stairwell that was in the leased space by Katherine. The lease did not mention the landlord's right to enter the leased space or under what circumstances he or his staff could enter. As a few months went on, it was also clear that the entire building was heated and cooled from a thermostat in Katherine's portion of the building. Katherine's business used various equipment in the spa process that caused the temperature in the leased space to raise so high that Katherine or her staff, had to turn on the air conditioning during the winter in Syracuse, New York. Naman''s staff was constantly in his office complaining that they couldn't work in these conditions. Naman, too was wearing three sweaters to work to keep warm in his own office. As such, Naman would regularly go down after hours into the leased space and adjust the temperature via the thermostat in the leased space. Katherine and her staff would come to work each day in their shorts and T-shirts because the heat was too much. Katherine kept yelling at her staff to stop playing with the thermostat. Of course, the staff continue to claim they had nothing to do with the temperature adjustment. One of her staff, a hair stylist named Swan Nguyen decided to borrow her nanny camera (used to watch her baby while she was away) from home and aim it at the thermostat to see who was changing the temperature. The camera caught Naman on a number of occasions adjusting the thermostat and muttering, \"That'll fix em-. Finally, having enough of the mess, cigarette's and temperature wars, Naman called Saeed and yelled \"you got me into this mess with this space, you get me out\"! Naman looked at his copy of the lease and told Saeed that he never agreed to rent the basement, his copy of the lease doesn't include the basement, he never agreed to lease the space and he wanted Katherine out. Katherine after 6 months in the new location was similarly disenchanted. She lost most of her downtown business customers. Katherine failed to take into account the convenience of her previous location to the businesspeople of the City of Syracuse. They were unable to drive out to the new location during their lunch and make it back in time for their work schedule. Business was bad, she had invested $20,000 in improvements, which was her life savings after she finished paying her student loans. She was looking for a way out of the lease but didn't know how to do it since she had 4 plus years remaining. Saeed, being stuck in the middle, tried to negotiate between both sides. Pursuant to Naman''s instructions, Saeed (with dreams of being able to lease all of Tyler's properties) went to Katherine and demanded that she stop using the basement. Katherine refused; pulling out her copy of the agreement with a different map than the one Saeed had provided to Naman. (It appears that Saeed, in his haste to make the deal had attached different copies of the space to the two parties' agreements). Saeed Isabella Odjourian 2/18/24 IRAC 1 - Jurisdiction Issue: This case raises the issue of whether or not the state court of California has personal jurisdiction, under the Long Arm Statute, over Shiva Incorporated, since it is based in New York. Rule of Law: In California, personal jurisdiction can be established through the long arm statute if three specific criteria are met regarding the defendant's actions: \"(1) purposefully availed himself of the laws of California whereby the nonresident did some act or consummated some transaction which invoked the benefits and protections of California; (2) the claim must arise out of or result from the defendant's acts in California and (3) the exercise of jurisdiction must be reasonable, meaning that jurisdiction can't offend constitutional due process requirements\" (Petosa 2024). In this case, courts may then employ the effect doctrine, a constitutional principle allowing regulation of activities impacting interstate commerce by Congress within a state. Consequently, courts have the authority to grant personal jurisdiction based on the defendant's conduct. Application: Gilbert Films Inc., a prominent film production firm based in California, is suing Shiva Inc. for trademark infringement. The goal is to prove personal jurisdiction by meticulously implementing the three-part test given in the prompt. Initially, Gilbert Films Inc. attempted to create a website on December 11th, 2011, only to learn that Shiva Inc. had already claimed ownership of the domain name "Gilbert.com." Despite Gilbert Films Inc.'s legitimate ownership of registered trademarks such as "Gilbertyision" and "Gilbertflex" for their film equipment, Shiva Inc. not only refused to give up the domain name, but also proposed a blatant financial settlement offer. This conduct reflects a disturbing pattern in Shiva Inc.'s history of registering and benefiting from domain names, similar to earlier examples involving well-known firms such as Neiman Marcus and Under Armour. Furthermore, Shiva Inc. escalated the matter by changing the website, replacing Syracuse photographs with videos insulting Gilbert for possession of the domain name, despite conversations with Gilbert's lawyer. Shiva Inc.'s intentional acts clearly reflect a planned purpose to exploit Gilbert Films Inc.'s trademark rights for financial advantage. Abiding by the fact that these occurrences took place online, establishing personal jurisdiction over Shiva Inc. would be difficult. As stated in the lawsuit, Network Solutions Inc. does not decide the authenticity of an individual's entitlement to register a domain name. Regardless of this technicality, the clear reality remains that Shiva Inc. consistently registers domain names only for financial gain, as evidenced by the lawsuit. Given that Gilbert's company is based in California and Shiva's headquarters are in New York, Shiva's acts have an undeniable influence on a California-based organization, warranting the exercise of personal jurisdiction. This application of the effect of doctrine emphasizes the need to establish personal jurisdiction in this case. The thorough examination of the facts is consistent with the three-step process established by the federal court system, resulting in a strong case for the court's involvement. Conclusion: Upon examining the case's facts and applying the three-part test for personal jurisdiction, it becomes evident that a federal court in California can establish personal jurisdiction over this