Von then Stach receivable(s) recover to face represented the value that the receivables were fully insured; that they were for product sales to VSPs dealers for the dealers own stock, and were not consignment sales, nor could the products be returned to VSP by the dealers; and that each receivable was due within 90 days. Relying visiting on the defendants foregoing facility representations, in Ontario, and plaintiffs after then purchased a number of accounts receivables from VSP-FL, only to discover that defendants never shipped any products to several of the dealers from whom plaintiffs expected to receive payment; that defendants had shipped products on consignment to several 1 Walker was allegedly the sole member of VSP-FL, a Florida limited liability company that was involuntarily dissolved on September 11, 2015, for failure to file its annual reports. Cmplt. at 4. 2 other dealers; and that they had made only a partial shipment to one from dealer. the dealers plaintiffs. assigning dealers, Accordingly, whose Defendants those, accounts purported plaintiffs but defendants new too, had they to no valid purported cure to their invoices for were products for receivables sales sell to default by to different that VSP never shipped, so the receivables were similarly without substance. Plaintiffs assert that Von Stach and Walker knew at the time they made the representations on which plaintiffs based their decision to enter into these transactions that (1) VSP had no accounts receivable; (2) the VSP-FL accounts transferred to plaintiffs were not valid receivables; (3) that defendants lacked sufficient capital and inventory to fulfill the orders corresponding to the assigned receivables; and (4) that the products that were shipped were sold on consignment. Defendants argue that the complaints allegations conclusively establish that personal jurisdiction over them is lacking.
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