Cindy filed a complaint in the United States District Court in New Jersey, alleging in substance the following:

Cindy resides in New Jersey, near the New York border. She read an advertisement in a local New Jersey newspaper for an electrical device called "Burglar-Be-Gone," which was designed to sound an alarm bell if an intruder entered the premises. "Burglar-Be-Gone" is manufactured by BBG Corporation, which is incorporated and has corporate headquarters in Massachusetts. BBG Corporation sells the "Burglar-Be- Gone" device only in Massachusetts and New York. Because Cindy was impressed with the features of the device listed in the advertisement, she purchased a "Burglar-Be-Gone" device for $1,000 from Deborah while shopping in New York. Deborah also personally guaranteed that "Burglar-Be-Gone" would prevent any theft from Cindy's home. Deborah is an authorized "Burglar-Be-Gone" retailer who lives and works exclusively in New York. While "Burglar-Be-Gone" was installed and Cindy was asleep in her home, intruders entered her home and stole $15,000 worth of her personal property. The device failed to function. Cindy claims damages of $15,000 for the stolen property and $100,000 for mental anguish resulting from its loss.

Deborah was personally served in New Jersey while she was attending her mother's funeral.

Your firm is retained by BBG Corporation and Deborah. Your initial research into New Jersey law establishes that a New Jersey appellate court has recently held that there can be no recovery of damages for mental anguish for unintentional conduct unless the plaintiff was physically injured. Moreover, you discover that the New Jersey long arm statute authorizes all jurisdiction allowed by the federal Constitution.

 

Analyzing whether a motion to dismiss for lack of subject matter jurisdiction and personal jurisdiction would be successful. Fully analyze how you anticipate a court would rule on each aspect of the motion with respect to each defendant, including all plausible arguments.