RIPPLE, Circuit Judge.

In 2011, Timmermann’s Ranch and Saddle Shop (“Timmermann’s”) brought an action against its former employee, Jeanne Pace, for conversion, breach of fiduciary duty, fraud, and unjust enrichment. It alleged that Ms. Pace had stolen merchandise and money from the company. Ms. Pace filed her answer and a counterclaim in early 2011.

In 2013, Ms. Pace and Dan Pace, her husband, filed a separate action against Timmermann’s and four of its employees, Dale Timmermann, Carol Timmermann, Dawn Manley, and Tammy Rigsby (collectively “the individual defendants”). They alleged that these defendants had conspired to facilitate Ms. Pace’s false arrest. Ms. Pace alleged that, as a result of their actions, she had suffered severe and extreme emotional distress. Mr. Pace claimed a loss of consortium.

Ms. Pace filed a motion to consolidate these two actions. The court granted the motion with respect to discovery, but denied the motion with respect to trial and instructed Ms. Pace that she should request consolidation for trial after the close of discovery. In the midst of discovery, however, the district court dismissed Ms. Pace’s 2013 action after concluding that her claims were actually compulsory counterclaims that should have been filed with her answer to the company’s 2011 complaint. Ms. Pace appeals the dismissal of her 2013 action and the court’s denial of her motion to consolidate.

We hold that Ms. Pace’s claims against parties other than Timmermann’s were not compulsory counterclaims because Federal *750Rules of Civil Procedure 13 and 20, in combination, do not compel a litigant to join additional parties to bring what would otherwise be a compulsory counterclaim. We also hold that because Ms. Pace’s claim for abuse of process against Timmermann’s arose prior to the filing of her counterclaim, it was a mandatory counterclaim. We therefore affirm in part and reverse in part the judgment of the district court and remand the ease for further proceedings.

I

BACKGROUND

A.

The issues in this case present a somewhat complex procedural situation. For ease of reading, we first will set forth the substantive allegations of each party. Then, we will set forth the procedural history of this litigation in the district court.

1.

Timmermann’s boards, buys, and sells horses, as well as operates both a ranch and a “saddle shop,” in which it sells merchandise for owners and riders of horses. When this dispute arose, Carol and Dale Timmermann managed Timmermann’s. Dawn Manley and Tammy Rigsby were employees of Timmermann’s.

In its 2011 complaint, Timmermann’s alleged that, while employed as a bookkeeper at Timmermann’s, Ms. Pace had embezzled funds and stolen merchandise. According to the complaint, beginning at an unknown time, Ms. Pace regularly began removing merchandise from Timmer-mann’s without paying; she would then sell those articles on eBay for her personal benefit. Timmermann’s further alleged that it discovered that Ms. Pace was selling items on eBay through a private sting operation.

According to the complaint, in February 2011, a Timmermann’s employee discovered some of the company’s merchandise in Ms. Pace’s car. At this point, Timmer-mann’s fired Ms. Pace. Thereafter, during a review of its records, including the checking account maintained by Ms. Pace, Timmermann’s discovered that a check that Ms. Pace had represented as being payable to a hay vendor actually had been made payable to cash. Timmermann’s also discovered that, on at least eight occasions, Ms. Pace had utilized the company’s business credit card to make personal purchases.

2.

In her 2013 complaint, Ms. Pace alleged that her conduct while working at Timmer-mann’s was consistent with its usual course of business. She stated that Tim-mermann’s had a practice of allowing employees to use cash to purchase merchandise at cost or, alternatively, by deducting the merchandise’s value from the employee’s pay. She maintains that she had purchased the company’s merchandise under that established practice. She also alleged that Carol Timmermann, her supervisor, knew that she had sold the company’s merchandise at flea markets and never had objected.

Ms. Pace also maintained that she was instructed to write corporate checks out to cash and to note the payee in the check records. Pursuant to those instructions, Ms. Pace had written checks to cash and recorded the payee and purpose of the check in the check records. Ms. Pace further alleged that Carol Timmermann had instructed her to use Carol’s credit card, which was used as the corporate credit card, for personal purchases and to reimburse Carol, and not Timmermann’s, for those purchases.

*751According to Ms. Pace’s complaint, on February 14, 2011, Dale Timmermann called the Lake County, Illinois, Sheriffs Office and accused Ms. Pace of stealing over $100,000 in merchandise from Tim-mermann’s. On February 14 and 15, Dale Timmermann took affirmative steps to convince the Sheriffs Office to arrest Ms. Pace by stating that Ms. Pace had stolen approximately $100,000 in merchandise and that Ms. Pace had been changing inventory on the computer. Ms. Pace was taken into custody by the Lake County Sheriffs Office on February 15, 2011, and released on February 16.

Following her release from custody, the individual defendants continued to provide the Sherriffs Office with information about Ms. Pace’s allegedly unlawful conduct. On March 13, 2012, the State’s Attorney brought charges against Ms. Pace premised on the information provided by the company’s employees. Ms. Pace was charged with theft, forgery, and unlawful use of a credit card.

B.

We turn now to the procedural history of this litigation in the district court, a history that produced the situation before us today.

On March 3, 2011, Timmermann’s filed its civil complaint against Ms. Pace, alleging conversion, breach of fiduciary duty, fraud, and unjust enrichment. It sought to recover the value of the merchandise and money that Ms. Pace allegedly had stolen. Ms. Pace filed her answer and counterclaims on April 5, 2011.

On February 1, 2013, Ms. Pace and Mr. Pace (collectively “the Paces”) filed a complaint against Timmermann’s and the individual defendants, alleging that they had conspired to facilitate Ms. Pace’s false arrest. Ms. Pace alleged that she had suffered severe and extreme emotional distress; Mr. Pace claimed a loss of consortium. Specifically, the Paces’ complaint included seven counts: “false arrest/false imprisonment/in concert liability” (Count I); “abuse of process” (Count II); “intentional infliction of emotional distress” (Count III); “conspiracy to commit abuse of process and intentional infliction of emotional distress” (Count IV); “in concert activity” (Count V); “aiding and abetting abuse of process and intentional infliction of emotional distress” (Count VI); and “loss of consortium” (Count VII).1 Only four counts, Counts I — III and Count VII, listed Timmer-mann’s as a defendant. The remaining counts were directed at Dale and Carol Timmermann or the other individual defendants.

On March 15, 2013, Ms. Pace filed a motion to consolidate the two cases. On April 2, 2013, the district court Consolidated the cases for the purpose of discovery and pretrial practice. The court denied without prejudice the motion to consolidate the cases for trial; it stated that it would rule on a motion to consolidate for trial after discovery.

On May 2, 2013, Timmermann’s and the individual defendants moved to dismiss Ms. Pace’s action under Federal Rules of Civil Procedure 12(b)(6) and 13(a). They contended that her allegations should have been filed as compulsory counterclaims in the 2011 action. Thereafter, Ms. Pace moved to amend her 2011 counterclaim and to consolidate the cases for trial. The district court set a briefing schedule for the company’s motion to dismiss and held Ms. Pace’s motion to consolidate in abeyance.

In December 2013, the district court granted the company’s motion to dismiss. *752The court concluded that Ms. Pace’s separate claims were barred because they were compulsory counterclaims that should have been brought in the 2011 action because the claims arose out of the same transaction or occurrence. Noting that her 2013 complaint had indicated that the fear of being indicted caused her emotional distress, the court held that Ms. Pace’s claims were in existence when the 2011 action was filed; it therefore rejected Ms. Pace’s argument that her abuse-of-process claim was not in existence until she was charged. In the district court’s view, the absence of Mr. Pace and the individual defendants from the 2011 action did not preclude the court’s conclusion that Ms. Pace’s claims were compulsory counterclaims because Mr. Pace and the individual defendants could have been joined in the 2011 action under Federal Rule of Civil Procedure 20.2

II

DISCUSSION

The Paces now appeal the dismissal of the 2013 action. They concede that Ms. Pace’s false arrest and emotional distress claims against Timmermann’s were compulsory counterclaims and therefore properly dismissed. They contend, however, that Ms. Pace’s claims against the individual defendants and Mr. Pace’s claims for loss of consortium were not compulsory counterclaims. They also submit that Ms. Pace’s abuse of process claim against Tim-mermann’s did not “exist” when the 2011 action was filed and therefore could not have been a compulsory counterclaim.

“We review de novo [a] district court’s grant of a motion to dismiss.” Thulin v. Shopko Stores Operating Co., LLC, 771 F.3d 994, 997 (7th Cir.2014); see also Transamerica Occidental Life Ins. Co. v. Aviation Office of Am., Inc., 292 F.3d 384, 389 (3d Cir.2002) (“[W]e review de novo the District Court’s determination that [the] suit should have been pursued as a compulsory counterclaim in the [prior] action.”).'

A.

Federal Rule of Civil Procedure 13 governs compulsory counterclaims. Rule 13(a)(1) provides:

In General. A pleading must state as a counterclaim any claim that — at the time of its service — the pleader has against an opposing party if the claim:

(A) arises out of the transaction or occurrence that is the subject matter of the opposing party’s claim; and

(B) does not require adding another party over whom the court cannot acquire jurisdiction.

The text of this subsection limits the definition of compulsory counterclaim to those claims that the pleader has against an opposing party; it does not provide for the joinder of parties. Instead, in a later subsection, it expressly incorporates the standards set out for the required joinder of parties under Rule 19 and the permissive joinder of parties under Rule 20. Specifically, subsection 13(h) provides: “Rules 19 and 20 govern the addition of a person as a party to a counterclaim or crossclaim.”

Rule 19 requires that a party be joined if, “in that person’s absence, the court cannot accord complete relief among existing parties,” or if proceeding in the party’s absence may “impair or impede the person’s ability to protect [his] interest” or “leave an existing party subject to a substantial risk of incurring double, multiple, or otherwise inconsistent obligations.” Fed.R.Civ.P. 19(a)(1). In contrast, Rule *75320 allows for parties to be joined if “any right to relief is asserted against them jointly, severally, or in the alternative with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences; and ... any question of law or fact common to all defendants will arise in the action.”3 Fed.R.Civ.P. 20(a)(2).

The district court did not hold, and Tim-mermann’s does not contend, that the individual defendants named in Ms. Pace’s complaint were opposing parties under Rule 13(a) in the 2011 action.4 Nor does the company’s claim that the individual defendants were required parties under Rule 19. Instead, Timmermann’s submits that, because the district court could have acquired jurisdiction over the individual defendants and could have joined them under Rule 20, it was appropriate to treat Ms. Pace’s claims as compulsory counterclaims. In essence, Timmermann’s combines the permissive joinder rule under Rule 20 with the compulsory counterclaim requirement in Rule 13 to create a rule for compulsory joinder.

The text of the rules, however, do not permit such an arrangement. Timmermann’s relies on the text of Rule 13(a)(1)(B), which provides that a claim is not a compulsory counterclaim if it “require[s] adding another party over whom the court cannot acquire jurisdiction.” Fed.R.Civ.P. 13(a)(1)(B). From this statement, Timmermann’s devises that, because the district court could have exercised jurisdiction over the individual defendants, the claims against them must be brought as compulsory counterclaims.5 Rule 13, *754however, does not require the joinder of parties. Its scope is limited to the filing of counterclaims. Although Rule 13(a)(1)(B), like Rule 19, encourages that all claims be resolved in one action with all the interested parties before the court,6 Rule 13 fulfills this objective by allowing, not mandating, that a defendant bring counterclaims that require additional parties.7 Whether a party must be joined in an action continues to be governed only by Rule 19. Rule 13(a)(1)(B) does not transform Rule 20 into a mandatory joinder rule.

The history of Rule 13 supports our conclusion that Rule 13 does not provide for compulsory joinder. Prior to 1966, Rule 13(h) read:

When the presence of parties other than those to the original action is required for the granting of complete relief in the determination of a counterclaim or cross-claim, the court shall order them to be brought in as defendants as provided in these rules, if jurisdiction of them can be obtained and their joinder will not deprive the court of jurisdiction of-the action.

As then written, Rule 13(h) was interpreted as an additional mandatory joinder rule, similar to Rule 19, which required that necessary parties be joined.8 To correct this use of Rule 13, subdivision (h) was amended in 1966 to provide: “Joinder of Additional Parties. Persons other than those made parties to the original action may be made parties to a counterclaim or cross-claim in accordance with the provisions of Rules 19 and 20.” In the note accompanying the amendment, the committee noted that Rule 13(h) had previously failed to reference that Rule 20 allows for the permissive joinder of parties. The committee continued:

The amendment of Rule 13(h) supplies the latter omission by expressly referring to Rule 20, as amended, and also incorporates by direct reference the revised criteria and procedures of Rule 19, as amended. Hereafter, for the purpose of determining who must or may be joined as additional parties to a counterclaim or cross-claim, ... amended Rules 19 and 20 are to be applied in the usual fashion.

Fed.R.Civ.P. 13 advisory committee’s note to 1966 amendment.9 The committee note thus highlights the limited nature of Rule 13, which operates only with regard to claims and does not mandate or otherwise influence the joinder of parties. The rule, supported by its accompanying note, di*755rects litigants to the framework under Rules 19 and 20, respectively, if they wish to join parties. To hold that Rule 13 compels the joinder of additional parties through the use of Rule 20 would read the term “opposing party” out of Rule 13(a).10

Requiring Ms. Pace to bring the claims against the individual defendants as a counterclaim in the initial action might well serve judicial economy, but the Federal Rules of Civil Procedure do not require such a result.11 The Rules strike a deli*756cate balance between (1) a plaintiffs interest in structuring litigation, (2) a defendant’s “wish to avoid multiple litigation, or inconsistent relief,” (3) an outsider’s interest in joining the litigation, and (4) “the interest of the courts and the public in complete, consistent, and efficient settlement of controversies.” Provident Tradesmens Bank & Tr. Co. v. Patterson, 390 U.S. 102, 109-11, 88 S.Ct. 733, 19 L.Ed.2d 936 (1968).12 The rules generally allow for a plaintiff to decide who to join in an action. See Applewhite v. Reichhold Chems., Inc., 67 F.3d 571, 574 (5th Cir.1995). A plaintiffs interest in structuring litigation is overridden only when the prejudice to the defendant or an absent party is substantial and cannot be avoided. See Fed.R.Civ.P. 19(b); see also Provident Tradesmens Bank & Tr. Co., 390 U.S. at 124-25, 88 S.Ct. 733. Otherwise, the threat of duplicative litigation generally is insufficient to override a plaintiffs interest in this regard.

Indeed, if Ms. Pace had brought her claim before Timmermann’s filed suit, she could have chosen to file separate actions against Timmermann’s and the individual defendants. See Temple v. Synthes Corp., 498 U.S. 5, 7, 111 S.Ct. 315, 112 L.Ed.2d 263 (1990) (per curiam) (noting that “[i]t has long been the rule that it is not necessary for all joint tortfeasors to be named as defendants in a single lawsuit”); see also Fed.R.Civ.P. 19 advisory committee’s note to 1966 amendment (stating that the rule “is not at variance with the settled authorities holding that a tortfeasor with the usual ‘joint-and-several’ liability is merely a permissive party to an action against another with like liability” and that the “[jjoinder of these tortfeasors continues to be regulated by Rule 20”).13 It *757makes little sense to require Ms. Pace to join the individual defendants under Rule 20 in order to bring all of her claims in the same action when, if she initially had been the plaintiff, she would not have been required to join those same parties.14

Timmermann’s recognizes that Rule 20 does not require a litigant to join additional parties.15 Therefore, because a party is not required to join additional parties under Rules 13 or 20, the district court erred by barring Ms. Pace’s claims against the individual defendants and Mr. Pace’s claims for failing to join them when she brought her counterclaim.

B.

We turn now to whether the district court appropriately characterized Ms. Pace’s claim against Timmermann’s for abuse of process as a compulsory counterclaim. Ms. Pace submits that her abuse of process claim did not exist until there was “process” in the form of an information or indictment. She contends that the facts alleged in the 2013 complaint that occurred before she was charged only demonstrated one element of the claim, the defendants’ mens rea. “In order to be a compulsory counterclaim, Rule 13(a) requires that a claim ... exist at the time of pleading_” Burlington N. R.R. Co. v. Strong, 907 F.2d 707, 710 (7th Cir.1990). Thus, “a party need not assert ... a compulsory counterclaim if it has not matured when the party serves his answer.” Id. at 712.

Under Illinois law, “[t]he only elements necessary to plead a cause of action for abuse of process are: (1) the existence of an ulterior purpose or motive and (2) some act in the use of legal process not .proper in the regular prosecution of the proceedings.” Kumar v. Bornstein, 354 Ill.App.3d 159, 290 Ill.Dec. 100, 820 N.E.2d 1167, 1173 (2004) (emphasis in *758original). Although neither an indictment nor an arrest is a necessary element to bring an abuse of process’ claim' under Illinois law, a plaintiff is required to plead some improper use of legal process. See id. To satisfy this requirement, a plaintiff must plead facts that “show that the process was used to accomplish some result that is beyond the purview of the process.” Id. In most circumstances, this requirement is met through an arrest or physical seizure of property. See id. (noting that “the relevant case law generally views an actual arrest or seizure of property as a sufficient fact to state a claim of abuse of process” (emphasis in original)).

Ms. Pace was arrested on.February 15, 2011. The company’s 2011 complaint was filed on March 3, 2011, and Ms. Pace filed her answer and counterclaim on April 5, 2011. Consequently, the only fact not in Ms. Pace’s possession at the time she filed ,her answer was the March 13, 2012 information. Illinois courts are clear, however, that an arrest is sufficient to bring an abuse of process claim. See id. Ms. Pace’s abuse of process claim therefore matured when she was arrested, which occurred before she filed her responsive pleading. Her failure to raise the abuse of process claim as a counterclaim along with her answer therefore contravenes Rule 13.

Indeed, in alleging an abuse of process, Ms. Pace primarily relies on her 2011 arrest, and not on the fact that she was charged. The complaint alleges that the defendants intentionally injured and caused injury to Ms. Pace by giving “false information to law enforcement and explicitly or implicitly urgfing] the arrest and/or the indictment of [Ms. Pace].”16 The complaint makes it clear that Ms. Pace could have brought her claim following her 2011 arrest, and thus, her abuse of process claim matured at that time.

Because we conclude that the district court erred in dismissing both Ms. Pace’s claims against the individual defendants and Mr. Pace’s claims, we need not address the party’s arguments about Ms. Pace’s motion to consolidate. The district court will have the opportunity to consider the motion to consolidate on remand.

Conclusion

We conclude that the district court erred in dismissing the Paces’ 2013 complaint in its entirety. Because neither Rule 13 nor Rule 20 provide for compulsory joinder, Ms. Pace’s claims against the individual defendants and Mr. Pace’s claims for loss of consortium were not compulsory counterclaims. Ms. Pace’s abuse of process claim against Timmermann’s was in existence when Ms. Pace filed her 2011 answer and counterclaim, and therefore the district court was correct to bar her subsequent abuse of process claim against Tim-mermann’s. The judgment of the district court is therefore affirmed in part and reversed in part and the case is remanded for proceedings consistent with this opinion. Ms. Pace may recover her costs in this appeal.

AFFIRMED IN PART, REVERSED AND REMANDED IN PART.

*135 MEMORANDUM OPINION

Granting the Plaintiffs’ Motion to Amend the Complaint; Denying the Defendants’ Motion to Sever

URBINA, District Judge.

I. INTRODUCTION

Employees of the United States Central Intelligence Agency (“CIA”) brought this as-yet-uncertified class action against that agency, that agency’s director, George Tenet, and 30 unnamed “John and Jane Does” (collectively “the defendants”). In a four-count amended complaint, six plaintiffs allege that the CIA violated the Privacy Act of 1974, as amended, 5 U.S.C. § 552a (“Privacy Act”), and several of their constitutional rights. In a proposed second amended complaint, which is a subject of this memorandum opinion, 15 plaintiffs altogether1 allege that the CIA obstructs the plaintiffs’ efforts to obtain assistance of counsel, thereby causing an invasion of privacy among other alleged violations of the Constitution. Additionally, the proposed second amended complaint states that beginning in 1997, the defendants’ policy and practice associated with the alleged obstruction of counsel violates the Privacy Act. Furthermore, the plaintiffs claim that the defendants’ alleged practice of obstruction of counsel violates Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000 et seq (“Title VII”). Before the court is the plaintiffs’ motion to amend the complaint with their proposed second amended complaint pursuant to Federal Rule of Civil Procedure 15, and the defendants’ motion to sever the claims of the six existing plaintiffs pursuant to Federal Rule of Civil Procedure 21. After consideration of the parties’ submissions and the relevant law, the court grants the plaintiffs’ motion to amend the complaint and denies the defendants’ motion to sever.

II. BACKGROUND

A. Factual Background

On January 13, 1999, plaintiffs M.K. and Evelyn M. Conway filed the complaint initiating the present action. On April 12, 1999, the plaintiffs filed an amended complaint adding M.D.E., R.B., Grace Tilden, Vivian Green, and George D. Mitford as plaintiffs.2 By order dated August 4, 1999, the court approved the voluntary dismissal without prejudice of plaintiff Green’s claims. Order dated August 4, 1999. By order dated March 3, 2000, the court approved the voluntary dismissal without prejudice of plaintiff M.D.E.’s claims. Order dated March 3, 2000. On November 30, 2001, the plaintiffs filed a proposed second amended complaint adding *136J.T., J.B., C.B., P.C., P.C.I., C. Lynn, Nathan (P), Elaine Livingston (P), and Betty E. Ya-les (P) as nine new plaintiffs.3 Second Am. Compl. (“2d Am. Compl”) at 2 n. 2. The court identifies the six existing plaintiffs as M.K., Conway, Tilden, R.B., C.T., and Mitford. Beginning in 1997 and continuing to the present, the plaintiffs claim that the defendants’ acts and omissions in denying the plaintiffs access to effective assistance of counsel violate the plaintiffs’ rights under the First, Fourth, Fifth, and Ninth Amendments of the United States Constitution, the Privacy Act, and Title VII.2d Am. Compl. 1111 2-5, 444. Specifically, the nine new plaintiffs, in addition to the six existing plaintiffs, allege in the second amended complaint that the defendants’ September 4, 1998 notice entitled “Access to Agency Facilities, Information, and Personnel by Private Attorneys and Other Personal Representatives” deprives the plaintiffs’ counsel access to “official information” pertaining to the plaintiffs’ employment matters. Id. 1123. The defendants’ invocation of the September 4, 1998 notice has allegedly resulted in a denial of the plaintiffs’ access to CIA documents, policies, procedures, and regulations, thereby preventing counsel from effectively advising the plaintiffs of their rights. Id. The plaintiffs claim that the defendants have “willfully and intentionally failed to maintain accurate, timely, and complete records pertaining to the plaintiffs in their personnel, security, and medical files so as to ensure fairness to [the] plaintiffs, thus failing to comply with 5 U.S.C. § 552a(e)(5) [of the Privacy Act].” Am. Compl. 11116. What follows are the six existing plaintiffs’ factual allegations relating to the inaccuracy of the records in question.

Plaintiff M.K. complains of a letter of reprimand placed in her personnel file in April 1997, which concerns her responsibility for the loss of top-secret information contained on laptop computers sold at an auction. Id. 111115, 116a. Plaintiff Conway complains of a finding by the CIA Human Resources Staff or Personnel Evaluation Board concerning her ineligibility for foreign assignment. Id. HH23, 116b. Plaintiff Conway additionally avers that the CIA notified her of this finding in March 1997. Id. 1123.

Plaintiff C.T. complains of a Board of Inquiry determination that she was not qualified for the position she held with the CIA. Id. H1167, 116e. This Board of Inquiry convened after “early 1998.” Id. 111166-67. Plaintiff Mitford complains of receiving two negative Performance Appraisal Reports and two negative “spot reports” on unspecified dates in 1997, allegedly based on false information. Id. 111181, 116g. Plaintiff R.B. complains of inaccurate counter-intelligence and polygraph information contained in his file. Id. H 116f. Plaintiff R.B.’s last polygraph exam took place in February 1996. Id. H 76. Plaintiff Tilden makes no allegations relating to Count IV of the amended complaint (‘Violation of the Privacy Act”).

B. Procedural History

On March 24, 1999, the defendants filed a motion to dismiss pursuant to Federal Rules of Civil Procedure 12(b)(1), (2), (3), and (6). On March 23, 2000, this court issued a Memorandum Opinion and supplemental order granting in part and denying in part the defendants’ motion to dismiss. M.K v. Tenet, 99 F.Supp.2d 12 (D.D.C.2000); Order dated Mar. 23, 2000. On April 20, 2001, the defendants filed a “motion for reconsideration” of that ruling pursuant to Federal Rule of Civil Procedure 54(b), seeking to dismiss the plaintiffs’ remaining due process and Privacy Act claims. On November 30, 2001, the plaintiffs filed a motion for leave to file the second amended complaint along with the proposed second amended complaint. On December 3, 2001, this court issued a Memorandum Opinion and supplemental order granting in part and denying in part the defendants’ motion for reconsideration under Rule 54(b). M.K v. Tenet, 196 F.Supp.2d 8 (D.D.C.2001); Order dated Dec. 3, 2001. On December 4, 2001, this court set out the parties’ filing deadlines in its “Initial Scheduling and Procedures Order.” Order dated Dec. 4, 2001. On January 2, 2002, the defendants filed their instant motion to sever the claims of the six existing plaintiffs pursuant to Federal Rule of Civil Procedure 21. On *137March 6, 2002, the plaintiffs filed a certificate of notification informing the CIA and the court of the 30 Doe defendants’ identities. For the reasons that follow, the court grants the plaintiffs’ motion to amend the complaint and denies the defendants’ motion to sever.

III. ANALYSIS

A. Legal Standard for a Motion to Amend

Federal Rule of Civil Procedure 15(a) provides that a “party may amend the party’s pleading once as a matter of course at any time before a responsive pleading is served____” Fed. R. Civ. P. 15(a). Once a responsive pleading is filed, “a party may amend the party’s pleading only by leave of the court or by written consent of the adverse party; and leave shall be freely given when justice so requires.” Id.; see also Foman v. Davis, 371 U.S. 178, 182, 83 S.Ct. 227, 9 L.Ed.2d 222 (1962). The D.C. Circuit has held that for a trial court to deny leave to amend is an abuse of discretion unless the court provides a sufficiently compelling reason, such as “undue delay, bad faith, or dilatory motivef,] ... repeated failure to cure deficiencies by [previous] amendments [or] futility of amendment.” Firestone v. Firestone, 76 F.3d 1205, 1208 (D.C.Cir.1996) (quoting Foman, 371 U.S. at 182, 83 S.Ct. 227). The court may also deny leave to amend the complaint if it would cause undue prejudice to the opposing party. Foman, 371 U.S. at 182, 83 S.Ct. 227. In sum, a district court has wide discretion in granting leave to amend the complaint.

A court may deny a motion to amend the complaint as futile when the proposed complaint would not survive a Federal Rule of Civil Procedure 12(b)(6) motion to dismiss. James Madison Ltd. v. Ludwig, 82 F.3d 1085, 1099 (D.C.Cir.1996) (internal citations omitted). When a court denies a motion to amend a complaint, the court must base its ruling on a valid ground and provide an explanation. Id. “An amendment is futile if it merely restates the same facts as the original complaint in different terms, reasserts a claim on which the court previously ruled, fails to state a legal theory, or could not withstand a motion to dismiss.” 3 Moore’s Federal Practice § 15.15[3] (3d ed.2000).

B. Legal Standard for Severance

Claims against different parties can be severed for trial or other proceedings under Federal Rules of Civil Procedure 20(b), 21, and 42(b). In re Vitamins Antitrust Litig., 2000 WL 1475705, at 16-17, 2000 U.S. Dist. LEXIS 7397, at * 74 (D.D.C.2000) (Hogan, J.). Specifically, Federal Rule of Civil Procedure 21 governs the misjoinder of claims. Brereton v. Communications Satellite Corp., 116 F.R.D. 162 (D.D.C.1987) (Richey, J.) (holding that an appropriate remedy for mis-joinder is severance of claims brought by the improperly joined party). Rule 21 provides, in relevant part:

Misjoinder of parties is not ground for dismissal of an action. Parties may be dropped or added by order of the court on motion of any party or of its own initiative at any stage of the action and on such terms as are just. Any claim against a party may be severed and proceeded with separately.

Fed. R. Crv. P. 21. In determining whether the parties are misjoined, the joinder standard of Federal Rule of Civil Procedure 20(a) applies. Rule 20(a) provides, in relevant part:

All persons may join in one action as plaintiffs if they assert any right to relief jointly, severally, or in the alternative in ■ respect of or arising out of the same transaction, occurrence or series of transactions or occurrences and if any question of law or fact common to all these persons will arise in the action.

The purpose of Rule 20 is to promote trial convenience and expedite the final resolution of disputes, thereby preventing multiple lawsuits, extra expense to the parties, and loss of time to the court as well as the litigants appearing before it. Anderson v. Francis I. duPont & Co., 291 F.Supp. 705, 711 (D.Minn.1968). The determination of a motion to sever is within the discretion of the trial court. In re Nat’l Student Marketing Litig., 1981 WL 1617, at *10 (D.D.C.1981) *138(Parker, J.); Bolling v. Mississippi Paper Co., 86 F.R.D. 6, 7 (N.D.Miss.1979).

There are two prerequisites for joinder under Rule 20(a): (1) a right to relief must be asserted by, or against, each plaintiff or defendant relating to or arising out of the same transaction or occurrence or series of transactions or occurrences, and (2) a question of law or fact common to all of the parties must arise in the action. Mosley v. Gen. Motors Corp., 497 F.2d 1330, 1333 (8th Cir.1974). “In ascertaining whether a particular factual situation constitutes a single transaction or occurrence for purposes of Rule 20, a case by case approach is generally pursued.” Id.

Additionally, “the court should consider whether an order under Rule 21 would prejudice any party, or would result in undue delay.” Id.; see also Brereton, 116 F.R.D. at 163 (stating that Rule 21 must be read in conjunction with Rule 42(b), which allows the court to sever claims in order to avoid prejudice to any party). The court may also consider whether severance will result in less jury confusion. Henderson v. AT & T Corp., 918 F.Supp. 1059, 1063 (S.D.Tex.1996) (directing in part that the claims of former employees from separate offices, which alleged various combinations of race, age, and national origin discrimination be severed because the claims were “highly individualized” and would be “extraordinarily confusing for the jury”); but see In re Vitamins Antitrust Litig., 2000 WL 1475705, at 17, 2000 U.S. Dist. LEXIS 7397, at *75-76 (stating that courts “consistently deny motions to sever where [the] plaintiffs allege that [the] defendants have engaged in a common scheme or pattern of behavior” (citing Brereton, 116 F.R.D. at 164)).

C. The Court Grants the Plaintiffs’ Motion to Amend the Complaint

The plaintiffs ask this court for leave to file their second amended complaint in order “to address deficiencies found by the [c]ourt and to avail themselves of favorable intervening precedent,” referring to the D.C. Circuit’s decision in Jacobs v. Schiffer, 204 F.3d 259 (D.C.Cir.2000).4 Pis.’ Mot. at 2, 5. The plaintiffs state that the D.C. Circuit’s decision in Jacobs supports the plaintiffs’ claim that the defendants have violated the plaintiffs’ First Amendment rights by not allowing the plaintiffs to disclose to their attorneys government documents that are available to the plaintiffs.5 Jacobs, 204 F.3d *139at 261; Pis.’ Mot. at 5. Additionally, the plaintiffs seek to “address subsequent arguments raised by [the][d]efendants in their [m]otion for [reconsideration filed on April 20, 2001, and to add additional claims and [plaintiffs, all related through [the][d]efen-dants’ pattern and practice of obstruction of counsel.” Pis.’ Mot. at 2. Also, the plaintiffs seek to expand their allegations of the defendants’ violations of their right to effective assistance of counsel under the First Amendment to a “wide range of wrongful conduct,” as compared to the “plaintiffs’ initial allegations that the defendants merely refused to provide access to government documents.” Id. at 5.

The defendants challenge the plaintiffs’ proposed amendment asserting that the plaintiffs’ “factually diverse” claims are unrelated to each other. Defs.’ Opp’n at 1-2. Specifically, the defendants argue that “neither the existing six plaintiffs nor the proposed nine plaintiffs have alleged claims factually in common with one another.” Id. According to the defendants, the “wide range of wrongful conduct” that the plaintiffs allege in their proposed second amended complaint arises out of “unique sets of facts and circumstances, involving completely different types of [a]gency actions, proceedings or personnel matters, such as employment terminations, revocations of security clearances, forced resignations, disciplinary proceedings, failure to obtain promotions ... and retaliation.” Id. The plaintiffs’ proposed second amended complaint, however, cites to numerous obstruction-of-counsel situations, including denying counsel access to requested CIA policies, procedures, and documents upon request. 2d Am. Compl. 111124-27, 36-37, 64. Additionally, the plaintiffs allege that when they requested the presence of counsel, the defendants failed to accommodate that request and attempted to restrict the plaintiffs’ access to counsel. Id. HH59, 62, 65.

The defendants counter that they would suffer “undue prejudice” if the court grants the plaintiffs’ motion to amend. Defs.’ Opp’n at 6 (citing Atchinson v. District of Columbia, 73 F.3d 418, 425 (D.C.Cir.1996) (quoting Foman, 371 U.S. at 182, 83 S.Ct. 227)). The defendants further assert that the burden on the defendants “against fifteen substantially different sets of facts and legal arguments in one case far outweighs any practical benefit that might accrue from considering” the eases of the six existing plaintiffs and the nine new plaintiffs. Id.

1. The Plaintiffs Have Not Repeatedly Failed to Cure Deficiencies by Previous Amendments

The plaintiffs seek leave to amend their complaint to address prior deficiencies6 named by the court in its March 2000 Memorandum Opinion and to avail themselves of intervening legal precedent. Pis.’ Mot. at 5. As such, the court deems these justifications reasonable and concludes that the deficiencies that the plaintiffs seek to address are not “repeated failure[s] to cure deficiencies by amendments previously allowed.” Foman, 371 U.S. at 182, 83 S.Ct. 227.

In determining whether undue prejudice will result, however, the D.C. Circuit has suggested that the court consider whether amendment of a complaint would require additional discovery. Atchinson, 73 F.3d at 426 (citing Alley v. Resolution Trust Corp., 984 F.2d 1201, 1208 (D.C.Cir.1993) (remanding the case for the district court to allow amendment where the plaintiffs assured the court of appeals that additional discovery would be unnecessary)). If additional discovery will result, then this factor may weigh negatively on the plaintiffs’ instant motion to *140amend the complaint. Id. The plaintiffs point out that the ease at bar has yet to enter the discovery stage. Pis.’ Reply at 1-2. The defendants, however, fear the potential burdens associated with excessive discovery and argue that the “myriad claims presented by each plaintiff and the number of defendants” in the second amended complaint would make it “incredibly burdensome to prepare an answer, conduct discovery, or file a dis-positive motion.” Defs.’ Opp’n at 26. Furthermore, the defendants argue that “discovery in a case that essentially challenges and finds fault with nearly every [ajgency proceeding and practice would be unmanageable, particularly where the business of the defendant is national security and intelligence gathering.” Id. at 28. But the defendants misconstrue the additional discovery factor as one that discourages discovery altogether. In a ease such as this in which discovery has yet to occur, it would defy logic to deny the plaintiffs an opportunity to amend the complaint on the basis that additional discovery will result. While it is conceivable that a great deal of discovery may result from the addition of new claims, 30 defendants, and nine plaintiffs in the proposed second amended complaint, this does not constitute evidence of undue prejudice to deny the plaintiffs’ instant motion. Teachers Retirement Bd. v. Fluor Corp., 654 F.2d 843, 856 (2d Cir.1981) (stating that the plaintiffs did not unduly prejudice the defendants because the plaintiffs requested leave to amend when no trial date was set by the court and the defendants had not filed a motion for summary judgment).

2. The Plaintiffs’ Proposed Second Amended Complaint Satisfies Rule 8’s Requirements

The defendants challenge the plaintiffs’ proposed second amended complaint under Federal Rule of Civil Procedure Rule 8, stating that the plaintiffs’ pleading “is not a pleading [that] [the] defendants can reasonably answer or that can reasonably be expected to control discovery.” Defs.’ Opp’n at 26. In Atchinson, the D.C. Circuit stated that Rule 8(a)(2) requires that a complaint include “a short and plain statement of the claim showing that the pleader is entitled to relief.” 73 F.3d at 421. Additionally, Rule 8(e) states that “each averment of a pleading shall be simple, concise, and direct” and further instructs courts to construe “all pleadings ... to do substantive justice.” Fed. R. Civ. P. 8(e); Atchinson, 73 F.3d at 421. Accordingly, “under the Federal Rules, the purpose of pleading is simply to ‘give the defendant fair notice of what the plaintiffs claim is and the grounds upon which it rests,’ not to state in detail the facts underlying the complaint.” Id. (citing Conley v. Gibson, 355 U.S. 41, 47, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957); Sinclair v. Kleindienst, 711 F.2d 291, 293 (D.C.Cir.1983)).

In this case, the plaintiffs’ first amended complaint was 44 pages in length compared to the plaintiffs’ proposed 219-page second amended complaint. Compare Am. Compl. to 2d Am. Compl. Although the defendants insist that the court should strike the plaintiffs’ proposed second amended complaint, the defendants fail to point out any specific Rule 8 violations. Defs.’ Opp’n at 27. Stating only that the second amended complaint is a “detailed and lengthy pleading,” the defendants also cite to several cases where courts have denied amendment on a variety of distinguishable grounds. Id. at 26-27 (citations omitted).7

The court concludes that the length of the plaintiffs’ proposed second amended complaint is reasonable, considering that the plaintiffs have added new claims, new plaintiffs, and new defendants. In the plaintiffs’ second amended complaint, each of the 15 plaintiffs’ individual averments are approximately 12 pages in length, while the remainder of the second amended complaint requests several forms of relief and alleges common questions of law and fact. 2d Am.

*141Compl. til 14-555. While the plaintiffs certainly could “state [in less] detail the facts underlying” their claims, the court notes that most of the individual paragraphs of then-proposed second amended complaint are “simple, concise, and direct.” Fed. R. Civ. P. 8(e); Atchinson, 73 F.3d at 421. For example, in stating facts to construe her privacy act claim, plaintiff Tilden states in the second amended complaint that:

[o]n or about August 8, 2000, [p]laintiff Tilden reviewed her CIA Office of Medical Services (“OMS”) file and first learned that it omit[t]ed a favorable psychological evaluation performed on her in 1993, which determined [that] she was fit for overseas assignment. Upon inquiry, OMS advised her to examine her medical file to locate the psychological evaluation.

2d Am. Compl. H157. Moreover, the court follows Rule 8(e)’s mandate that courts must construe “all pleadings ... to do substantive justice.” Fed. R. Civ. P. 8(e); Atchinson, 73 F.3d at 421. In doing so, the court determines that there is no basis for the defendants’ Rule 8 challenge.

Indeed, to bar the plaintiffs from amending their complaint would contravene Rule 15(a)’s underlying policy of granting leave to amend freely as justice requires. Foman, 371 U.S. at 182, 83 S.Ct. 227. This is not to say that in every instance, the court must allow the requested amendment, but to conclude otherwise in this case would positively bar the plaintiffs from asserting claims that may prove meritorious. Besides, as stated earlier, the case has yet to enter the discovery phase, which distinguishes this case from other cases where amendment is sought after discovery has started or closed. Atchinson, 73 F.3d at 426 (citing Williamsburg Wax Museum v. Historic Figures, Inc., 810 F.2d 243, 247-48 (D.C.Cir.1987) (affirming a district court’s denial of leave to amend more than seven years after the filing of the initial complaint because new discovery was necessary)); Alley, 984 F.2d at 1208.

D. The Court Denies the Defendants’ Motion to Sever the Claims of the Six Existing Plaintiffs

The court now addresses the defendants’ instant motion to sever. In the defendants’ view, the plaintiffs’ obstruction-of-counsel claim consists of “a series of unrelated, isolated grievances, unique to each plaintiff, each of which would have to be decided on its own set of law and facts, and each potentially presenting a ‘novel’ constitutional claim.” Defs.’ Reply at 1 (quoting M.K., 99 F.Supp.2d at 30). Thus, the defendants ask this court to sever the claims of the six existing plaintiffs8 under Federal Rule of Civil Procedure 21. Defs.’ Mot. at 5, 8. By the same token, the defendants ask the court to deny the plaintiffs’ proposed Rule 20 join-der of the nine new plaintiffs and the 30 new “Doe” defendants. Defs.’ Mot. at 3.

The plaintiffs, however, argue that the court should not sever the six existing plaintiffs because both prongs of Rule 20(a)’s join-der requirement are satisfied. The court need not extensively address the joinder of the six existing plaintiffs’ new claims because the court is convinced that under the unrestricted joinder provision of Federal Rule of Civil Procedure 18, such joinder of new claims is possible. 3 Moore’s Federal Practice § 21.02[1] (3d ed.2000). To wit, it suffices to state that “Rule 18 permits the claimant to join all claims the claimant may have against the defendant regardless of transactional relatedness.” Id. As such, the court focuses its analysis on the Rule 20 joinder issue raised by the defendants.

The plaintiffs cite to the first prong of Rule 20(a), also known as the “transactional test,” and argue that the defendants’ acts and omissions pertaining to the plaintiffs’ obstruction-of-counsel claims are “logically related” events that the court can regard as “arising out of the same transaction, occurrence or series of transactions or occurrences.” Fed. R. Civ. P. 20(a); Pls.’ Reply at 10 (quoting Mosley, 497 F.2d at 1333). In *142citing to Mosley, the plaintiffs assert that “all ‘logically related’ events entitling a person to institute a legal action against another generally are regarded as comprising a transaction or occurrence.” Mosley, 497 F.2d at 1330 (citing 7 C. Wright, Federal Practice & Procedure § 1653 at 270 (1972 ed.)); Pis.’ Reply at 15.

The court agrees with the plaintiffs’ assertion that “logically related” events may consist of an alleged “consistent pattern of ... obstruction of security-cleared counsel by [the] [defendants.” 2d Am. Compl. 11 430. Specifically, each of the existing plaintiffs allege that they were injured by the defendants through employment-related matters, such as retaliation, discrimination, and the denial of promotions and overseas assignments. 2d Am. Compl. ITU 36-37, 64-65, 129-30, 132-33, 140, 142,148-49, 154,156, 176-77, 190, 200, 209-12, 221, 224, 229-30, 232. After each employment dispute began, each of the plaintiffs or the plaintiffs’ counsel sought access to employee and agency records. Id. The defendants, however, denied and continue to deny the plaintiffs and/or their counsel access to the plaintiffs’ requested information. Id. As such, without this relevant information, the plaintiffs cannot effectively prepare or submit administrative complaints to the defendants or attempt to seek legal recourse through the applicable Title VII discrimination, Privacy Act, or First, Fifth, and Seventh Amendment claims. Id. The court concludes that the alleged repeated pattern of obstruction of counsel by the defendants against the plaintiffs is “logically related” as “a series of transactions or occurrences” that establishes an overall pattern of policies and practices aimed at denying effective assistance of counsel to the plaintiffs. Mosley, 497 F.2d at 1331,1333; Pis.’ Reply at 16. In this case, each plaintiff alleges that the defendants’ policy and practice of obstruction of counsel has damaged the plaintiffs. Id. Further, each plaintiff requests declaratory and injunctive relief. 2d Am. Compl. 11465. Thus, the court determines that each plaintiff in this case has satisfied the first prong of Rule 20(a). Fed. R. Civ. P. 20(a); see also Mosley, 497 F.2d at 1331, 1333.

Turning to the second prong of Rule 20(a), the plaintiffs aver that each of their claims are related by a common question of law or fact. FED. R. CIV. P. 20(a); Pis.’ Reply at 15. Specifically, one question of law or fact that is common to each of the six existing plaintiffs is whether the defendants’ September 4, 1998 notice restricting the plaintiffs’ counsel from accessing records intruded on the plaintiffs’ substantial interest in freely discussing their legal rights with their attorneys. Jacobs, 204 F.3d at 265 (quoting Martin, 686 F.2d at 32); 2d Am. Compl. ¶ 23. Indeed, the question of law or fact that is common to all may be whether the “defendants have engaged in a common scheme or pattern of behavior” that effectively denies the plaintiffs’ legal right to discuss their claims with their counsel. Fed. R. Civ. P. 20(a); In re Vitamins Antitrust Litig., 2000 WL 1475705, at 17, 2000 U.S. Dist. LEXIS 7397, at *75-76; Brereton, 116 F.R.D. at 164. The plaintiffs also allege that the defendants’ policy or practice of obstruction of counsel “is implemented through [a] concert of action among CIA management and the Doe Defendants,” who are now named in the second amended complaint. Pis.’ Reply at 16; 2d Am. Compl. 1111547-52. In light of the aforementioned common questions of law and fact, the court concludes that the plaintiffs meet the second prong of Rule 20(a). Fed. R. Civ. P. 20(a).

The court need not stop here in its Rule 20(a) analysis. Indeed, it appears that there exists a further basis supporting the plaintiffs’ position challenging severance; Each plaintiff alleges common claims under the Privacy Act. Pis.’ Reply at 22. Specifically, the plaintiffs’ second amended complaint alleges that the defendants “maintained records about the plaintiffs in unauthorized systems of records in violation of § 552a(e)(4) of the Privacy Act” and that the defendants “failed to employ proper physical safeguards for records in violation of § 552a(e)(10) of the Privacy Act.” Id.; 2d Am. Compl. HH 472, 477. The plaintiffs also allege that the defendants wrongfully denied the plaintiffs and plaintiffs’ counsel access to records in violation of § 552a(d)(l) of the Privacy Act and “illegally maintained specific records describing their First Amendment activities in violation of § 552a(e)(7) of the Privacy Act.” 2d Am. *143Compl. 1111444, 489, 508-17; Pis.’ Reply at 22. Furthermore, the plaintiffs’ first amended complaint contains similar allegations. Through their alleged Privacy Act violations, the plaintiffs are united by yet another “question of law or fact” that is common to each of them. FED. R. CIV. P. 20(a). Accordingly, the court concludes that the plaintiffs satisfy the second prong of Rule 20(a) and, thus, the court denies the defendants’ motion to sever.

On a final note, in denying the defendants’ motion to sever, the court defers to the policy underlying Rule 20, which is to promote trial convenience, expedite the final determination of disputes, and prevent multiple lawsuits. Mosley, 497 F.2d at 1332. Indeed, the Supreme Court addressed this important policy in United Mine Workers of America v. Gibbs, 383 U.S. 715, 86 S.Ct. 1130, 16 L.Ed.2d 218 (1966), stating that “[ujnder the rules, the impulse is toward entertaining the broadest possible scope of action consistent with fairness to the parties; joinder of claims, parties, and remedies is strongly encouraged.” Id. at 724, 86 S.Ct. 1130. In accordance with Gibbs, the court believes that the joinder or non-severance of the six existing plaintiffs and their new claims under Rule 20(a) will promote trial convenience, expedite the final resolution of disputes, and act to prevent multiple lawsuits, extra expense to the parties, and loss of time to the court and the litigants in this case. Gibbs, 383 U.S. at 715, 86 S.Ct. 1130; Anderson, 291 F.Supp. at 711. For this added reason, the court denies the defendants’ motion to sever.

IV. CONCLUSION

For all of the foregoing reasons, the court grants the plaintiffs’ motion to amend and denies the defendants’ motion to sever. An order directing the parties in a manner consistent with this Memorandum Opinion is separately and contemporaneously issued this 30th day of July 2002.

ORDER

Granting the Plaintiffs’ Motion to Amend the Complaint; Denying the Defendants’ Motion to Sever

For the reasons stated in this court’s Memorandum Opinion separately and eon-temporaneously issued this 30th day of July 2002, it is

ORDERED that the plaintiffs’ motion for leave to file the second amended complaint is GRANTED; and it is

FURTHER ORDERED that the defendants’ motion to sever is DENIED; and it is

ORDERED that the defendants file a response to the plaintiffs’ second amended complaint within 60 days from the date of this order.

SO ORDERED.

DECISION AND ORDER

SMITH, United States District Judge.

I. Introduction

Central Tools, Inc. (“Central”), a Rhode Island corporation, brought this action seeking a declaratory judgment for, among other things, noninfringement and invalidity of patent, U.S. Patent No. 4,743,902 (the “902 Patent”),1 against: C.E. Johansson AB (“CEJ”), the owner of the 902 Patent; Mitutoyo Corporation (“Mitutoyo”), a Japanese corporation and the exclusive licensee of that portion of the 902 Patent covering length measuring devices; 2 and Mitutoyo American Corpora*73tion (“MAC”), a subsidiary of Mitutoyo serving as Mitutoyo’s American distributor (collectively, “Defendants”). Defendants have moved to dismiss this action for lack of personal jurisdiction under Rule 12(b)(2) of the Federal Rules of Civil Procedure. For the reasons set forth below, the Defendants’ motion is granted.

II. Background

The Court takes Plaintiffs well-pleaded allegations as true for purposes of this motion. See Electronics for Imaging, Inc. v. Coyle, 340 F.3d 1344, 1349 (Fed.Cir.2003) (“In the procedural posture of a motion to dismiss, a district court must accept the uncontroverted allegations in the plaintiffs complaint as true and resolve any factual conflicts in the affidavits in the plaintiffs favor.”). Furthermore, the Court “may consider public records without transforming the motion into one for summary judgment.” Greene v. Rhode Island, 289 F.Supp.2d 5, 8 (D.R.I.2003). And finally, when “a complaint’s factual allegations are expressly linked to — and admittedly dependent upon — a document (the authenticity of which is not challenged), that document effectively merges into the pleadings and [this Court] can review it in deciding a motion to dismiss.” Beddall v. State Street Bank and Trust Co., 137 F.3d 12, 17 (1st Cir.1998).

Central sells measuring devices such as the length measurement device which is covered by the 902 patent. Since 1995, Central has been in direct communication with Mitutoyo regarding a disagreement about the 902 Patent. Mitutoyo initiated the correspondence by sending a letter to Central accusing Central of infringing on Mitutoyo’s exclusive right to control the sale of the length measuring devices covered by the 902 Patent by selling similar devices made in China. The parties engaged in correspondence on the matter throughout 1995. (Compl. at ¶¶ 17-23.)

On September 15, 1995, Mitutoyo wrote to Central with an offer: If Central stopped selling the length measuring devices made in China, Mitutoyo would not hold Central liable for past infringements. (Letter of 9/15/1995 from Mitutoyo to Central.) Central responded to this proposal on September 27, 1995. Without admitting liability or the validity of the patent, Central agreed not to sell or place future orders for the allegedly infringing goods. (Letter of 9/27/1995 from Central to Mitu-toyo.) The parties then entered into an agreement (the “Agreement”) whereby Central would cease marketing the allegedly infringing goods and Mitutoyo would not pursue any claims regarding past sales.

Following the Agreement, Central found itself at an economic disadvantage because other competitors continued to sell the allegedly infringing goods. Central concluded from this that either there was no infringement or that Mitutoyo was selectively enforcing the patent, rendering it unenforceable. As a result, Central terminated the Agreement. (Letter of 11/7/1995 from Central to Mitutoyo.) In response, Mitutoyo wrote to Central objecting to the termination of the Agreement. (Letter of 12/8/1995 from Mitutoyo to Central.) The two companies exchanged correspondence for seven years with no resolution, ultimately leading to the filing of this action.

III. Discussion

Claims concerning personal jurisdiction over a party in a declaratory judgment action involving patent invalidity are governed by Federal Circuit law. Electronics for Imaging, 340 F.3d at 1348. Federal Circuit law also governs personal jurisdiction issues involved in state law *74claims that go “hand-in-hand” with patent infringement claims, such as Central’s claim here regarding the validity/breach of the Agreement.3 3D Sys., Inc. v. Aarotech Labs., Inc., 160 F.3d 1373, 1377 (Fed.Cir.1998) (concluding that state law libel and unfair competition claims should be analyzed under Federal Circuit law “because the resolution of the patent infringement issue will be a significant factor in determining whether or not 3D libeled the defendants”). Finally, procedural issues that may be critical to analysis of the Motion to Dismiss (such as whether CEJ is an indispensable party under Rule 19 of the Federal Rules of Civil Procedure) are resolved under this Court’s regional circuit law. Bayer AG v. Housey Pharms., Inc., 340 F.3d 1367, 1371 (Fed.Cir.2003) (“We review the grant of a motion to dismiss under Rule 12(b)(6) by applying the procedural law of the regional circuit.”); Dainippon Screen Mfg. Co., Ltd. v. CFMT, Inc., 142 F.3d 1266, 1269 (Fed.Cir.1998) (“[wjhether a party is indispensable under Rule 19(b) is a matter of regional circuit law”).

In this case, Defendants argue, among other things, that CEJ, as the owner of the patent,4 is an indispensable party not subject to personal jurisdiction, and thus this action cannot proceed here. Central, meanwhile, argues CEJ is not beyond the jurisdictional reach of this Court, and even if it is, it is not an indispensable party.

A. Is CEJ Subject to the Personal Jurisdiction of this Court?

“Determining whether personal jurisdiction exists over an out-of-state defendant involves two inquiries: whether a forum state’s long-arm statute permits service of process and whether assertion of personal jurisdiction would violate due process.” Id. at 1270. Where, as here, the state’s long arm statute is co-extensive with the limits of due process, see KVH Indus., Inc. v. Moore, 789 F.Supp. 69, 70 (D.R.I.1992), “the two inquiries collapse into a single inquiry: whether jurisdiction comports with due process,” Inamed Corp. v. Kuzmak, 249 F.3d 1356, 1360 (Fed.Cir.2001). Thus, the ultimate inquiry turns on whether there are sufficient contacts between the defendant and the State of Rhode Island. Viam Corp. v. Iowa Export-Import Trading Co., 84 F.3d 424, 427 (Fed.Cir.1996).

Personal jurisdiction over a defendant may be based on either specific or general jurisdiction. Specific jurisdiction refers “to a situation in which the cause of action arises directly from the defendant’s contacts with the forum State.” Id. General jurisdiction, of course, looks more broadly “to the situation in which the defendant’s contacts [with the forum state] have no necessary relationship to the cause of action.” Id.

As noted above, Central argues that CEJ is either not an indispensable party to this action, in which case the Court’s lack of personal jurisdiction over CEJ is no bar to this action proceeding, or is an indispensable party and thereby becomes subject to the Court’s jurisdiction via Mitu-toyo’s agency. As to the latter argument, *75Central cites Burger King Corp. v. Rudzewicz, 471 U.S. 462, 105 S.Ct. 2174, 85 L.Ed.2d 528 (1985) wherein the Supreme Court stated that in analyzing issues of personal jurisdiction, “when commercial activities are ‘carried on in behalf of an out-of-state party those activities may sometimes be ascribed to the party.” 471 U.S. at 480 n. 22, 105 S.Ct. 2174. Central argues that if CEJ is indeed an indispensable party to an action involving the 902 Patent because it retained substantial rights in that patent, then all of Mitutoyo’s threats of litigation in defense of the 902 Patent must have been made by Mitutoyo on behalf of CEJ because Mitutoyo lacks the power to bring such an infringement action on its own. (See Pl.’s Obj. at 19 (citing Abbott Labs. v. Diamedix Corp., 47 F.3d 1128, 1132 (Fed.Cir.1995) (holding that where patent owner licensor retained substantial rights under license agreement, licensee did “not have an independent right to sue for infringement”)).) But see Intellectual Prop. Dev., Inc. v. TCI Cablevision of Cal., Inc., 248 F.3d 1333, 1346-47 (Fed.Cir.2001) (noting that “the Supreme Court has stated that a patent owner that grants ‘the exclusive right to make, use, or vend [a patented invention], which does not constitute a statutory assignment ... must allow the use of his name as plaintiff in any action brought by the licensee ... to obtain damages for the injury to his exclusive right’ ”) (quoting Indep. Wireless Tel. Co. v. Radio Corp. of Am., 269 U.S. 459, 469, 46 S.Ct. 166, 70 L.Ed. 357 (1926)) (emphasis in original). In support of its argument that CEJ is subject to the personal jurisdiction of this Court by way of some type of Burger King agency theory, which is Central’s only argument for finding personal jurisdiction over CEJ, Central relies on Akro Corp. v. Luker, 45 F.3d 1541 (Fed.Cir.1995).

For purposes of analyzing Plaintiffs argument, the Court will assume it has personal jurisdiction over Mitutoyo (which it must in order to conclude Mitutoyo subjected CEJ to the jurisdiction of this Court via its actions as CEJ’s “agent”) as a consequence of Mitutoyo’s enforcement activities in defense of its exclusive license. See id. (concluding combination of letters directed at alleged infringer and license agreement with in-state company subjected out-of-state patent owner to personal jurisdiction). Central relies on Akro to press the point that “[t]o reject the argument that there is jurisdiction over CEJ if there is jurisdiction over Mitutoyo, would both ‘ignore basic principles of agency law and exalt form over substance in an area where the Supreme Court generally has cautioned against such an approach.’ ” (Pl.’s Obj. at 20 (quoting Akro, 45 F.3d at 1546) (internal citation omitted).) Akro, however, is not on point. To begin with, while the Federal Circuit in that case did rely in part on the relationship between the patent owner and its exclusive licensee to find personal jurisdiction over the out-of-state patent owner, the significance of that relationship was that the licensee was a resident of the state in which jurisdiction was sought (in that case, Ohio). Akro, 45 F.3d at 1546. Here, Mitutoyo is incorporated in Japan, not Rhode Island. Furthermore, the Akro court relied on agency principles simply to allow the letters sent by the patent owner’s counsel to the alleged infringer’s counsel in North Carolina to be deemed to have been directed to the alleged infringer in Ohio. Id. Agency principles were not used, as Central seeks to use them here, to ascribe activities on the part of the licensee to the patent owner. In fact, Central directs the Court to no case where the actions of a licensee, taken to protect its rights under an exclusive license agreement, were ascribed to the patent owner for the pur*76poses of establishing personal jurisdiction. (See PL’s Obj. at 18-21.)

The actions Mitutoyo took to defend its rights to manufacture, market and sell the length measuring devices at issue here were on its own behalf. The license agreement between CEJ and Mitutoyo gives Mitutoyo “the sole right at its cost to take legal actions against and collect damages for any infringement of [CEJ]’s Patent Rights to the extent that such infringement is invading the exclusive rights of [Mitutoyo].” (Defs.’ Ex. 4 at 16.) “In such cases [CEJ] shall assist [Mitutoyo] and, upon request of [Mitutoyo], furnish [Mitutoyo] with any information or evidence which is available and material to the proper defense or prosecution of such actions.” (Id.) Were Mitutoyo defending the rights granted to it under the license agreement on behalf of CEJ, one would expect the preceding provision to be very different. At the very least, the Court will not read the parties’ agreement as precluding Mitutoyo from bringing an infringement action on its own behalf. In light of the foregoing, the Court concludes that CEJ is not subject to the personal jurisdiction of this Court under Plaintiffs agency theory.

B. Is CEJ an Indispensable Party?5

Having concluded that CEJ is not subject to the personal jurisdiction of this Court, the next question becomes whether CEJ is an indispensable party. If it is, the case must be dismissed. The Court will analyze the indispensability of CEJ under Rule 19 of the Federal Rules of Civil Procedure.6 Rule 19(a) provides, in relevant part, the basis for finding a party necessary:

A person who is subject to service of process and whose joinder will not deprive the court of jurisdiction over the subject matter of the action shall be joined as a party in the action if ... the person claims an interest relating to the *77subject of the action and is so situated that the disposition of the action in the person’s absence may ... as a practical matter impair or impede the person’s ability to protect that interest....

Fed.R.Civ.P. 19(a). Here, CEJ is a necessary party because it retains substantial rights in the 902 Patent and those rights would be impaired were this Court to conclude the 902 Patent was invalid.

The conclusion that CEJ retains substantial rights in the 902 Patent is based on the fact that the 902 Patent covers both length measuring devices as well as rotational displacement measuring devices (Defs.’ Reply at 2), and Mitutoyo has received an exclusive license only as to the length measuring devices (see Pl.’s Ex. 4 at 15 (Amendment No. 2 to Patent Sub-license Agreement of September 1, 1983, between CEJ and Mitutoyo)). Because both the length measuring and rotational displacement measuring devices are covered under the same claim of the 902 Patent,7 the validity of both either stand or fall together. In other words, while this Court can invalidate particular claims within a patent without invalidating the entire patent, the Plaintiff has cited no authority for the proposition that the Court can invalidate a particular claim as to only a particular device created thereunder without invalidating the entire claim. Cf. Maloney-Crawford Tank Corp. v. Sauder Tank Co., Inc., 465 F.2d 1356, 1365 (10th Cir.1972) (stating that, while finding a particular claim within a patent invalid does not invalidate the entire patent, individual claims “stand or fall alone”). Thus, while it may be somewhat of a close call, the Court concludes that it may not *78parse the claim so finely as Plaintiff would like, so as to excise those parts of the claim to which CEJ retains an interest. Furthermore, the substantial rights in the 902 Patent retained by CEJ would be impaired were this Court to invalidate the 902 Patent because, at the very least, “such a judgment would have a prejudicial effect on the licensors’ interests even if not absolutely binding.” Messerschmitt-Boelkow-Blohm GmbH v. Hughes Aircraft Co., 483 F.Supp. 49, 53 (S.D.N.Y.1979).8 Thus, the Court concludes that CEJ retains substantial rights in the 902 Patent, and that CEJ’s ability to protect those rights would be impaired by a declaration of invalidity by this Court, making CEJ a necessary party to this action. See Zenith Elecs. Corp. v. ExZec, Inc., 876 F.Supp. 175, 179 (N.D.Ill.1995) (concluding licensee was necessary party to patent infringement action under Rule 19(a) because the license agreement “transfers all substantial ownership rights” to the licensee).

Having concluded that CEJ is a necessary party not subject to the personal jurisdiction of this Court, the analysis turns to “whether in equity and good conscience the action should proceed among the parties before it, or should be dismissed, the absent person being thus regarded as indispensable.” Fed.R.Civ.P. *7919(b). Rule 19(b) sets out four factors this Court must consider:

[F]irst, to what extent a judgment rendered in the person’s absence might be prejudicial to the person or those already parties; second, the extent to which, by protective provisions in the judgment, by the shaping of relief, or other measures, the prejudice can be lessened or avoided; third, whether a judgment rendered in the person’s absence will be adequate; fourth, whether the plaintiff will have an adequate remedy if the action is dismissed for nonjoin-der.

Id.

The question of prejudice has already been addressed, at least in part, in the preceding 19(a) analysis.9 See Gonzalez v. Cruz, 926 F.2d 1, 6 (1st Cir.1991) (“In this case, the first factor under Rule 19(b) seems to weigh in favor of dismissal. Although the insurer would not be bound by the judgment in federal court, an adverse ruling could, as a practical matter, impair its probability of success in a future proceeding and reduce its ability to reach a favorable settlement.”). In addition, CEJ would be prejudiced because its interests would not be adequately defended by Mitutoyo. See Pujol v. Shearson/American Express, Inc., 877 F.2d 132, 135 (1st Cir.1989) (asking whether absent party’s interests would be adequately protected as part of 19(b) analysis). Mitutoyo does not have as expansive an interest in the 902 Patent as CEJ, which retained its rights as to “dimensional measuring instruments.” (Defs.’ Reply Ex. 4 at 15 (“Licensor shall grant to Licensee ... the non-exclusive, non-transferable, fully paid-up, worldwide right to use Licensor’s Patent Rights for manufacture, market, sales and use of Products for any application within the field of dimensional measuring instruments.”) (emphasis added).) Therefore, Mitutoyo may advance a construction of the 902 Patent claim at issue here that is narrower than CEJ would. For these reasons, the Court concludes a judgment rendered in CEJ’s absence could be prejudicial to CEJ.10

*80The second factor, the Court’s ability to shape relief to avoid prejudice, also favors finding CEJ to be an indispensable party because, as noted above, the relevant claim of the 902 Patent cannot be subdivided into one claim covering length measuring devices and another claim covering rotational displacement measuring. But see Dainippon, 142 F.3d at 1272-73 (“The second factor, the court’s ability to shape relief to avoid prejudice, is of little relevance in the context of a patent declaratory judgment suit because the relief sought in such a suit does not depend upon the patentee’s presence in court.”).

“The third factor, adequacy of the judgment, favors maintenance of the suit in [CEJj’s absence because a declaration of invalidity or noninfringement would fully serve [Centrales interest in ensuring that it is free from claims of patent infringement irrespective of [CE J]’s absence.” Id. at 1273; see also Dickson, 141 F.2d at 6.

Finally, the fourth factor, whether Central will have an adequate remedy if the case is dismissed favors dismissal because, as Defendants concede (Tr. at 7, 20) and Central does not contest, this action can be brought in the District of Columbia pursuant to 35 U.S.C. § 293. See Chisum, § 21.02[3][d] (“Section 293 operates as a special ‘long-arm’ statute, providing jurisdiction over a United States patentee who does not reside within the United States and who has not made a designation of a resident agent on whom process may be served. Its primary purpose is to provide at least one available forum where persons charged with infringement of a United States patent held by a person residing abroad may file an action for a declaratory judgment of invalidity and/or noninfringement. The jurisdiction is only in the United States District Court for the District of Columbia.”); see also H.D. Corp. of Puerto Rico v. Ford Motor Co., 791 F.2d 987, 993 (1st Cir.1986) (“Fourth and finally, it follows from what we have said that plaintiffs have an adequate remedy in the commonwealth courts to vindicate their claims against both Ford and Ford Caribbean.”). In sum, the evaluation of these factors support finding CEJ to be an indispensable party to these proceedings.11

IV. Conclusion

In light of the foregoing, the Court concludes CEJ is an indispensable party not subject to the personal jurisdiction of this Court, and therefore GRANTS Defendants’ Motion to Dismiss.

IT IS SO ORDERED.