because the two companies hold themselves out to the world as a single entity. Siemens Germany has stated that “cross-group and cross-regional cooperation” between companies within the Siemens Group is “crucial for the success of [Siemens’s] Global Network of Innovation.” 2002 Siemens Germany Website, Ex. 18 to PI. Opp. Both companies use the name “Siemens” in their advertising. This Court, however, has previously rejected this theory of jurisdiction: These statements (use of common trade name “Sprint” on web page, reference to conglomerate as a collective entity, etc.), intended to be read by the consuming public, cannot create a single entity structure given the sophistication and complexity of today’s corporate world. Aerotel, 100 F.Supp.2d at 198. See also Jazini, 148 F.3d at 185 (<HOLDING>); J.L.B. Equities v. Ocwen Fin. Corp., 131
holding that a company registered with the new york department of state is found for purposes of rule b holding that statements by a foreign corporation to the effect that the company needs to become a truly global company and requests for worldwide cooperation from its subsidiaries does not show the pervasive control required to meet the prima facie test for mere department status holding in context of control person analysis that because defendant founded the company and was its largest shareholder he may be able to influence the company holding that the company administering a selfinsurance program for the department of transportation was an agent for the department and was therefore immune from suit holding that where company made statements constituting inability to pay orally at bargaining sessions company had duty to show its books to the union