"In addition to general jurisdiction, you must also show that the court you selected has personal jurisdiction over the respondent in your case. Even if you live in California and a lawsuit would be more convenient for you file in California, if you cannot show that the responding party has substantial contacts with California, you may have to go elsewhere to file your lawsuit. The test for establishing personal jurisdiction is very fact-based, depending on the parties and the controversy. The more factors you can demonstrate that connect a defendant to a particular jurisdiction, the more success you're likely to have with petition to challenge the jurisdiction."

My ideal scenario is the case gets thrown out on the Venue issue, and then Sullivan initiates a counter-suit immediately so Rosen has to start focusing on a defense rather than looking for another venue.
I sure wish Seeking Alpha could be forced to reveal Mako's identity. Maybe an SEC investigation of Seeking Alpha could make them give up the goods. SA's refusal to remove that article, once proven false and malicious, certainly seems to point to foul play!