With no explanation, chose the best option from "A", "B", "C" or "D". under Rule 60(b) is abuse of discretion, it is a per se abuse of discretion for a district court to refuse to vacate an invalid judgment. Id. at 1317. We cannot accept Trade Well’s contention that the district court lacked personal jurisdiction over it because Trade Well is a foreign corporation that did not have counsel at the time of the default judgments. By filing the original replevin action, Trade Well submitted itself to jurisdiction in Wisconsin for purposes of the replevin action and the counterclaim. In general, when a defendant interposes a permissive counterclaim, the plaintiff cannot object that the court lacks personal jurisdiction for purposes of adjudicating the claim. See Leman v. Krentler-Arnold Hinge Last Co., 284 U.S. 448, 451, 52 S.Ct. 238, 76 L.Ed. 389 (1932) (<HOLDING>); 6 ChaRles Alan Wright & Arthur R. Miller,

A: holding that the statute must specify the states intention to subject itself to suit in federal court in order to constitute a waiver
B: holding that the court had jurisdiction to hear the suit under the citizen suit provision of the caa
C: holding that a prior suit and a subsequent suit between the same parties did not involve the same claim because the evidence necessary to sustain the subsequent suit was insufficient to entitle the plaintiff to relief in the prior suit
D: holding in a patent case that when the plaintiff brought the suit in federal district court it submitted itself to the jurisdiction of the court with respect to all the issues embraced in the suit including those pertaining to the counterclaim of the defendants
D.