Multi-way modeling has become an important tool in the analysis of large scale multi-modal data. When turned on, an incandescent lamp draws a large inrush current of about ten times the steady-state current; as the filament heats up, its resistance rises and the current decreases to a steady-state value. You only need to train your core two to three times per week and make sure to get adequate rest. Following submission of proposals, agencies make SBIR awards based on small business qualification, degree of innovation, technical merit, and future market potential. 29. The Board of Directors of MTN Group can, and did, specifically direct MTN subsidiary companies to undertake actions or make expenditures. Indeed, MTN Group and its downpipe roll former Board (including the Chairman Cyril Ramaphosa, CEO Phuthuma Nhleko, COO Sifiso Dabengwa, and Commercial Director Irene Charnley) were direct participants in the matters at issue in this case. MTN Group was directly involved in, and had direct decisional authority over, the matters alleged in this Complaint. 28. All management decisions at issue here executed by MTN Mauritius were made and directed by MTN Group, or MTN Group had the final authority over any subsidiary-made management decisions. 30. Because ownership and ultimate unfettered management authority lie with MTN Group, it dominates and controls each of its subsidiaries.

32. MTN Group exercised its control over its subsidiaries, including MTN Holdings, MTN International, MTN South Africa, MTN Mauritius, MTN-Irancell, and MTN Management Services, among others, to compose and execute its staggeringly brazen orchestra of corruption. A common use is control of lighting, where multiple switches may be wired into one circuit to allow convenient control of light fixtures. 33. Because the MTN companies (collectively "MTN") have unity of ownership and interest, MTN Group is able to dominate and control each marionette-subsidiary; they are all but alter-egos of one another. 27. MTN Group has a unity of ownership and interest with each of it subsidiaries. With the sole exception of MTN-Irancell, the entity formed as a result of MTN's bad acts for which Turkcell complains, MTN Group maintains a controlling, majority ownership interest in each of its subsidiaries. 40. Because of the services that MTN makes available in the United States through its roaming arrangements, a significant percentage of MTN's call volume originates in the United States, and a significant percentage of calls on the MTN network are directed toward the United States. 41. Unlike many typical international cellular telephone service providers that provide roaming services in the United States, MTN's business dealings and contacts with the United States are far more extensive.

48. MTN also transacts significant amounts of business with United States entities. Rather, it expressly and intentionally targets and advertises to people in the United States. MTN expressly targets U.S. 38. MTN South Africa lists its U.S. 37. For example, the MTN's subsidiary at issue here, Irancell, publicly lists its U.S. Specific personal jurisdiction also arises out of MTN's knowing and intentional defamatory statements that were published in the District of Columbia falsely accusing Turkcell of criminal acts and attacking Turkcell's reputation. Each subsidiary had a role to play, and each of their actions in MTN's scheme was controlled from the top - MTN Group. 23. Because Turkcell is an alien, this Court has subject matter jurisdiction over its claims against MTN Group involving torts committed in violation of the law of nations or treaties of the United States pursuant to 28 U.S.C. 26. As set forth below, this Court may also exercise personal jurisdiction over MTN and its named subsidiary pursuant to Federal Rule of Civil Procedure 4(k)(1)(A) and D.C. Alternatively, this Court may exercise personal jurisdiction over MTN based on its aggregate contacts with the United States as a whole pursuant to Federal Rule of Civil Procedure 4(k)(2) because exercising personal jurisdiction would be consistent with the United States Constitution and laws.

§ 1350. This Court has supplemental subject matter jurisdiction over claims arising under District of Columbia law pursuant to 28 U.S.C. 25. This Court may exercise specific personal jurisdiction over MTN because it breached the Confidentiality Agreement it entered with Turkcell in the District of Columbia by publishing confidential information in the District of Columbia. Code § 13-334(a) because its contacts with the District of Columbia are sufficiently continuous and systematic so as to render it at home here. 34. The jurisdictional contacts of each MTN company should be attributed to MTN Group and the MTN organization as a whole. § 1391(d) because MTN Group is an alien. 31. MTN Group has abused its corporate form to perpetuate egregious wrongs. But during cell division, DNA is in its compact chromosome form to enable transfer to new cells. § 1367(a) because such claims form part of the same case or controversy giving rise to the federal claims. Proper part and mold design are equally critical to MIM success. All downspouts that are disconnected from the combined sewer through this program must conform to the disconnection methods or systems approved by the Director.