VINCENT CREPY, PLAINTIFF, v. RECKITT BENCKISER, LLC, RECKITT GROUP PLC, RECKITT BENCKISER CORPORATE SERVICES, LTD., AND DOES 1-25, DEFENDANTS., 448 N.J. Super. 419

Summary

ISSUE: Whether to grant an LLC's motion to transfer venue from Essex County to Morris County, the location of its principal place of business. HOLDINGS: [1]-Under R. 4:3-2(b), venue for a suit against an LLC could be laid in the county where it was "actually doing business"; although R. 4:3-2(b) referred to corporations, not LLCs, there was no reason why a business entity that benefited from extensive and systemic business conduct in a county could not be sued there merely because it was unincorporated; [2]-Plaintiff did not meet his burden to prove venue was proper in Essex County, as the sales the LLC made there and the amount of contact its sales representatives had within the county were too minimal to satisfy the "actually doing business" requirement, and plaintiff failed to show how the LLC's advertising and marketing efforts were specifically targeted towards Essex County.