Specific personal jurisdiction requires an analysis of the relationship between the defendant, the forum, and the litigation, rather than focusing solely on the plaintiff's contacts with the forum.
A federal law enforcement officer seized cash from travelers at a Georgia airport and later drafted a false affidavit in Georgia to support a forfeiture action. The plaintiffs, who resided in Nevada, sued the officer in Nevada, alleging his conduct violated their Fourth Amendment rights. The court must determine whether the officer's conduct created sufficient minimum contacts with Nevada to support specific personal jurisdiction. Although the officer knew the plaintiffs had connections to Nevada, the court holds that the defendant's own conduct must connect him to the forum in a meaningful way. Because the officer's actions occurred entirely in Georgia, the plaintiffs' unilateral connections to the forum cannot be the sole basis for jurisdiction.
At page 286 Insufficient basis for jurisdiction based on third-party contacts358 citing casesTo be sure, a defendant’s contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties. But a defendant’s relationship with a plaintiff or third party, standing alone, is an insufficient basis for jurisdiction.
- Adams v. Best W. Int'l, Inc., No. 8:24-cv-00102 (D. Neb. Aug. 22, 2024). But see Walden v. Fiore, 571 U.S. 277, 284 (2014) (“Due process limits on the State’s adjudicative authority principally protect the liberty of the nonresident defendant—not the convenience of plaintiffs or third parties.”).
- Telemedicine Solutions LLC v. WoundRight Tech., LLC, 27 F. Supp. 3d 883 (N.D. Ill. 2014).published “a forum state's exercise of jurisdiction over an out-of-state intentional tortfeasor must be based on intentional conduct by the defendant that creates the necessary contacts with the forum.”
- Lillie, No. 4:25-cv-04239 (D.S.D. Sept. 15, 2026). See Pederson, 951 F.3d at 980 (finding “hundreds of phone calls and emails” to be insufficient without “allegation . . . that these communications were part of some broader effort by the defendants to create a connection with [the forum st…
- Herron, No. 4:26-cv-00003 (D. Ariz. Aug. 31, 2026). ([A] defendant’s relationship with a plaintiff or third party, 3 standing alone, is an insufficient basis for jurisdiction . . . Due process requires that a 4 defendant be haled into court in a forum State based on his…)
- Michaelidis, No. 2:26-cv-03005 (D. Ariz. Aug. 28, 2026).(But a defendant’s relationship with a plaintiff or third party, 18 standing alone, is an insufficient basis for jurisdiction.)
- Freight Innovation LLC v. Fellowship Warehousing & Logistics LLC, et al., No. 2:25-cv-02559 (E.D. Pa. Aug. 21, 2026). ([T]he plaintiff cannot be the only link between the defendant and the forum. Rather, it is the defendant’s conduct that must form the necessary connection with the forum State that is the basis for its jurisdiction ove…)
- Bradcliffe LLC & Donald A. McCloskey v. William Grant & Sons, Inc., William Grant & Sons Americas, LLC, William Grant & Sons US Distillers LLC, William Grant & Sons USA Corp., William Grant & Sons, Ltd., William Grant & Sons Holdings Ltd., William Grant & Sons (AME) Ltd., William Grant & Sons Brands Ltd., William Grant & Sons Global Brands Ltd., Red Tettemer, Inc., Modop, LLC, Quaker City Mercantile, Inc., & Does 1-10, No. 2:25-cv-06511 (E.D. Pa. July 22, 2026).([A] defendant’s relationship with a plaintiff or third party, standing alone, is an insufficient basis for jurisdiction.)
- Pitt v. Shefler, No. B338608 (Cal. Ct. App. June 24, 2026).published(Due process requires that a defendant be haled into court in a forum State based on his own affiliation with the State, not based on the ‘random, fortuitous, or attenuated’ contacts he makes by interacting with other p…)
- Morton, No. 7:25-cv-01812 (N.D. Ala. Apr. 29, 2026). ([A] defendant’s relationship with a plaintiff or third party, standing alone, is an insufficient basis for jurisdiction.)
- Almquist, No. 1:25-cv-00806 (E.D. Va. Mar. 4, 2026).(The requirements of International Shoe, however, must be met as to each defendant over whom a state court exercises jurisdiction.)
Show 242 more citing cases
- Mountain Meadows Pet Prods., Inc. v. NT Consulting, LLC; Nathan Thomas; & Seth Kaufman, No. 5:24-cv-05200 (W.D. Ark. Feb. 23, 2026). ([A] defendant’s contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties. But a defendant’s relationship with a plaintiff or third party, standing alone…)
- Stokinger v. Armslist, LLC, 166 F.4th 229 (1st Cir. 2026).published(To be sure, a defendant's contacts with the forum [s]tate may be intertwined with his transactions or interactions with the plaintiff or other parties.)
- Jane Doe (J.T.A.) v. Wyndham Hotels & Resorts, Inc., et al., No. 2:25-cv-00687, 2026 WL 73727 (D.N.J. Jan. 9, 2026).unpublished(To be sure, a defendant’s contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties. But a defendant’s relationship with a plaintiff or third party, stan…)
- Jane Doe (J.T.A.) v. Wyndham Hotels & Resorts, Inc., et al., No. 6:26-cv-00057 (M.D. Fla. Jan. 9, 2026).unpublished(To be sure, a defendant’s contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties. But a defendant’s relationship with a plaintiff or third party, stan…)
- Dosso, No. 3:25-cv-00190 (N.D. W. Va. Dec. 29, 2025). ([A] defendant’s relationship with a . . . third party, standing alone, is an insufficient basis for jurisdiction.)
- Dosso, No. 5:25-cv-00050 (W.D. Va. Dec. 29, 2025). ([A] defendant’s relationship with a . . . third party, standing alone, is an insufficient basis for jurisdiction.)
- Exotropin, No. 2:25-cv-00016 (D. Utah Dec. 4, 2025).(It is well-established that phone calls and letters are not necessarily sufficient in themselves to establish minimum contacts.)
- Fregoso, No. 1:24-cv-23308 (S.D. Fla. Oct. 22, 2025).([A] defendant’s relationship with a . . . third party, standing alone, is an insufficient basis for jurisdiction.)
- Fregoso, No. 1:24-cv-23308 (S.D. Fla. Oct. 21, 2025).([A] defendant’s relationship with a . . . third party, standing alone, is an insufficient basis for jurisdiction.)
- Doe "s.a.t." v. Wyndham Hotels & Resorts, Inc., No. 3:25-cv-02744 (N.D. Tex. Oct. 8, 2025).unpublished(To be sure, a defendant’s contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties. But a defendant’s relationship with a plaintiff or third party, stan…)
- Doe "s.a.t." v. Wyndham Hotels & Resorts, Inc., No. 2:24-cv-11511 (D.N.J. Oct. 8, 2025).unpublished(To be sure, a defendant’s contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties. But a defendant’s relationship with a plaintiff or third party, stan…)
- Rose v. Koch, No. 6:24-cv-00116 (E.D. Okla. Sept. 25, 2025). Newsome, 722 F.3d at 1268 ; see also Walden, 571 U.S. at 290 ("The proper question is not whether the plaintiff experienced a particular injury or effect but whether the defendant's conduct connects [her] to the forum in a meaningful way").
- Midamines Sprl Ltd. (Ill. Corp.) v. KBC Bank N.V., No. 1:16-cv-09429 (N.D. Ill. Dec. 15, 2017).
- Midamines Sprl Ltd. (Ill. Corp.) v. KBC Bank N.V., No. 1:16-cv-09429 (N.D. Ill. Jan. 16, 2018).
- Clearone, Inc. v. Revolabs, Inc., 2016 UT 16, 369 P.3d 1269.published
- Jason R. Searcy, as Tr. of the Exempt Assets Trust v. Parex Resources, Inc., No. 14-0293 (Tex. June 17, 2016).published
- Axiom Foods, Inc. v. Acerchem Int'l, Inc., 874 F.3d 1064 (9th Cir. 2017).published
- Old Repub. Ins. Co. v. Cont'l Motors, Inc., 877 F.3d 895 (10th Cir. 2017).published
- Let's Adopt! Global, Inc. v. Macey, 32 Mass. L. Rptr. 573 (Mass. Super. Ct. 2015).published
- Lehman Bros. Special Fin. Inc. v. Bank of Am. Nat'l Ass'n (In re Lehman Bros. Holdings Inc.), 535 B.R. 608 (Bankr. S.D.N.Y. 2015).published
- Axle Holding Co., LLC v. ARB Corp. LTD., No. 3:22-cv-01472 (S.D. Cal. Mar. 8, 2023).
- Burri Law Pa v. William Skurla, 35 F.4th 1207 (9th Cir. 2022).published
- Brandon Briskin v. Shopify, Inc., 135 F.4th 739 (9th Cir. 2025).published
- Welk Biology Co., Ltd. v. Hakumo LLC, No. 2:24-cv-01613 (D. Nev. Aug. 20, 2025).
- Seaboard Foods, LLC v. Cloverdale Foods Co., No. 2:25-cv-02160 (D. Kan. Feb. 3, 2026).
- Cox v. Gritman Med. Ctr., 170 F.4th 724 (9th Cir. 2026).published
- Akhmetshin v. Browder, 761 F. Supp. 3d 1 (D.D.C. 2024).published
- App-Order LLC v. Reynolds, No. 2:24-cv-01480 (D. Nev. Mar. 7, 2025).
- Little & Gorgeous, Inc. D/B/A Wild & Gorgeous Transfers & Amanda Fournier v. Wild Tribe Screen Prints, LLC, 717 S.W.3d 36 (Tex. App.—San Antonio 2025).published
- Driscoll, No. 3:25-cv-08054 (D. Ariz. Dec. 8, 2025).
- The Coll. of William & Mary in Virginia v. W M Symposia, Inc., No. 4:25-cv-00094 (E.D. Va. Feb. 26, 2026).
- Schmidt Bros. Farm LLC v. Eden Solutions LLC, SWJ Consulting LLC, No. 4:25-cv-04237 (D.S.D. Sept. 1, 2026).
- Mattson v. Basin Elec. Power Coop., No. 1:24-cv-00991 (E.D. Wis. Apr. 8, 2025).
- Hannah Dev., LLC v. Maverick Gen. Contractors, LLC, No. M2024-01592-COA-R3-CV (Tenn. Ct. App. July 21, 2025).published
- Rodriguez v. Netflix, No. B338932 (Cal. Ct. App. Aug. 28, 2025).unpublished
- Ross, No. 3:26-cv-03204 (N.D. Cal. July 8, 2026).
- Ross, No. 1:26-cv-05912 (S.D.N.Y. July 8, 2026).
- Mary Rawle v. Charles Bowman, No. 25A-PL-02715 (Ind. Ct. App. Aug. 31, 2026).published
- Reintegrative Therapy Ass'n, Inc. v. Kinitz, No. 3:21-cv-01297 (S.D. Cal. Sept. 26, 2022).
- Alhathloul v. DarkMatter Grp., No. 3:21-cv-01787, 2023 WL 2537761 (D. Or. Mar. 16, 2023).
- Matrix Warranty Solutions Inc v. The Staunton Grp. LLC, No. 3:21-cv-03111 (N.D. Tex. June 2, 2022).
- Suski, No. 3:25-cv-00860 (D. Conn. Apr. 13, 2026).“[A] defendant’s relationship with a plaintiff or third party, standing alone, is an insufficient basis for jurisdiction.”
- Vinmar Overseas Singapore PTE LTD v. PTT Int'l Trading PTE LTD, 538 S.W.3d 126 (Tex. App.—Houston [14th Dist.] 2017).published
At page 285 Determining jurisdiction based on defendant's contacts with forum state923 citing cases“looks to the defendant's contacts with the forum state itself, not the defendant's contacts with persons who reside there.”
- Gregory Langadinos v. City of Corona et al., No. 5:25-cv-01064 (C.D. Cal. Sept. 28, 2026).([O]ur ‘minimum contacts’ analysis looks to the 3 defendant’s contacts with the forum State itself, not the defendant’s contacts with 4 persons who reside there.)
- Anthony Shelton Graves, a.k.a. King Anthony v. Hillsborough Cnty. Sheriff’s Off., et al., No. 2:26-cv-10721 (C.D. Cal. Sept. 24, 2026).([T]he plaintiff cannot be the only link between the defendant and the forum. Rather, it is the defendant’s conduct that must form the necessary connection with the forum State that is the basis for its jurisdiction ove…)
- Lillie, No. 4:25-cv-04239 (D.S.D. Sept. 15, 2026). ([Tyhe plaintiff cannot be the only link between the defendant and the forum.)
- Tanner, No. 1:25-cv-00591 (S.D. Ind. Aug. 28, 2026). ('minimum contacts' analysis looks to the defendant's contacts with the forum State itself, not the defendant's contacts with persons who reside there.)
- Shane Patrick Skaar v. Meta Platforms, Inc., No. 3:26-cv-00015 (W.D. Wis. Aug. 3, 2026).([T]he plaintiff cannot be the only link between the defendant and the forum.)
- Abdullah Jones v. Alton Prilliman, Et. Al., No. 1:25-cv-00651 (M.D.N.C. July 29, 2026). ESAB Grp., Inc., v. Centricut, Inc., 126 F.3d 617 , 626 (4th Cir. 1997); see also Walden _v. Fiore, 571 U.S. 277, 290 (2014) (“The proper question is not where the plaintiff experienced a particular injury 6 Thus, the instant recommendatio…
- Curcio, No. 2:26-cv-01226 (W.D. Wash. July 22, 2026).(The plaintiff cannot be the only link between the Defendant 12 and the forum)
- Kalipeni v. Fam. Values at Work, No. 2025-3470 (D.D.C. July 6, 2026).published ([I]t is the defendant’s conduct that must form the necessary connection with the forum State.)
- Jones, No. 3:26-cv-00193 (N.D. Tex. June 10, 2026).([T]he plaintiff cannot be the only link between the defendant and the forum.)
- Ian Auckland v. Gilead Sciences, Inc., No. 25-1933 (4th Cir. June 9, 2026).unpublished ([The] ‘minimum contacts’ analysis looks to the defendant’s contacts with the forum State itself, not the defendant’s contacts with persons who reside there.)
Show 205 more citing cases
- McEntyre, No. 3:25-cv-10483 (N.D. Cal. June 9, 2026).(It is the defendant’s conduct that must form the necessary connection with the forum state)
- Morton, No. 7:25-cv-01812 (N.D. Ala. Apr. 29, 2026). And even though the policy was enforced against Ms. Morton, “a plaintiff cannot be the only link between the defendant and the forum.” Walden, 571 U.S. at 285 ; see also id. at 286 (“[A] defendant’s relationship with a plaintiff or third p…
- Pintas, No. 3:25-cv-01445 (D.P.R. Apr. 20, 2026). ([T]he plaintiff cannot be the only link between the defendant and the forum.)
- Deacon S. Labonte v. Wells Fargo Auto & Broadway Ford Hyundai, Inc., No. 1:25-cv-00753 (D. Colo. Mar. 30, 2026).([O]ur ‘minimum contacts analysis looks to the defendant’s contacts with the forum State itself, not the defendant’s contacts with persons who reside there.)
- In the Matter of the Complaint of Crazy Pants LLC & the Est. of Gregory John Daiker for Exoneration from or Limitation of Liab. v. Scott Kottmann & Jane Doe Kottmann, Client Marine Servs., LLC, a Missouri Ltd. Liab. Co., Greg Kottmann & Jane Doe Kottmann, Devin Wozencraft & Jane Doe Wozencraft, Wozencraft Ins. Agency, Inc., a California Corp. dba Wozencraft Ins. & Fin., Randy Scism & Jane Doe Scism, Marine Tech., Inc., a Missouri Corp., Mercury Marine, a Div. of Brunswick Corp., No. 2:23-cv-00023 (D. Idaho Feb. 3, 2026). See generally Walden, 571 U.S. at 290 (“The proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant’s conduct connects him to the forum in a meaningful way.”) Because the first prong o…
- Kikuyama, No. 1:25-cv-00439 (D. Haw. Jan. 21, 2026). ([P]hysical entry into the State—either by the defendant in person or through an agent, goods, mail, or some other means—is certainly a relevant contact.)
- Leonite Fund I, LP v. Hawaii Brewery Dev. Co., Inc.; Waiakea Bottling Inc.; Waiakea Inc; & Marcus I Bender, No. 1:25-cv-01371 (D. Colo. Jan. 7, 2026). ([A] defendant's contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties. But a defendant's relationship with a plaintiff or third party, standing alone…)
- Sweat, No. 2:25-cv-01686 (D. Ariz. Jan. 5, 2026).(the plaintiff cannot be the only link between the 17 defendant and the forum)
- Rothschild, No. 2:25-cv-01658 (W.D. Wash. Oct. 17, 2025).(But the plaintiff cannot be the only link between the 12 defendant and the forum. Rather, it is the defendant’s conduct that must form the necessary 13 connection with the forum State that is the basis for its jurisdic…)
- United States of Am., for the use & benefit of Alameda Elec. Distributors, Inc. v. Eco Eng'g, Inc., No. 4:24-cv-06754 (N.D. Cal. Oct. 10, 2025).([I]t is the defendant’s 5 conduct that must form the necessary connection with the forum State that is the basis for its 6 jurisdiction over him.)
- Rose v. Koch, No. 6:24-cv-00116 (E.D. Okla. Sept. 25, 2025). Newsome, 722 F.3d at 1268 ; see also Walden, 571 U.S. at 290 ("The proper question is not whether the plaintiff experienced a particular injury or effect but whether the defendant's conduct connects [her] to the forum in a meaningful way").
- Ethridge v. Samsung SDI, 137 F.4th 309 (5th Cir. 2025).published
- Brandon Briskin v. Shopify, Inc., 135 F.4th 739 (9th Cir. 2025).published
- Harms v. Lillie, No. 1:23-cv-02616 (D. Colo. Mar. 9, 2025).
- Murphy v. Titlemax of Virginia, Inc., No. 1:22-cv-00971 (M.D.N.C. May 29, 2025).
- Waddell v. Titlemax of Virginia, Inc., No. 1:23-cv-00034 (M.D.N.C. May 29, 2025).
- Washington v. Titlemax of Virginia, Inc., No. 1:23-cv-00246 (M.D.N.C. May 29, 2025).
- Taylor v. Titlemax of Virginia, Inc., No. 1:23-cv-00408 (M.D.N.C. May 29, 2025).
- Powers v. Liberty Mut. Ins. Co., No. 3:24-cv-00794 (N.D. Ind. June 23, 2025).
- Janosky, No. 2:25-cv-00068 (E.D. Ky. Oct. 29, 2025).
- Mills, No. 3:25-cv-00203 (D. Conn. Jan. 5, 2026).
- Seaboard Foods, LLC v. Cloverdale Foods Co., No. 2:25-cv-02160 (D. Kan. Feb. 3, 2026).
- Mills, No. 3:26-cv-00052 (M.D. Tenn. Jan. 5, 2026).
- Cox v. Gritman Med. Ctr., 166 F.4th 1171 (9th Cir. 2026).published
- Cox v. Gritman Med. Ctr., 170 F.4th 724 (9th Cir. 2026).published
- Gulf Coast Pharm. Plus, LLC & Primary Pharm., Inc. v. RFT Consulting, Inc.; Brandon Reich; Richmont Capital LLC; LBR Mgmt. Grp. LLC; Tag Pres. Specialists, Corp.; Gonzalo Carranza; Ryan Wolf; Ryan Wolf, LLC; Wasatch RX LLC; Safe Chain Solutions LLC; Hutcheson Homecare Pharmacy, Inc.; XYZ Pharmacies & Suppliers 1-5; & John & Jane Does 1-10, No. 1:24-cv-00080 (S.D. Miss. July 31, 2026).
- Gulf Coast Pharm. Plus, LLC & Primary Pharm., Inc. v. RFT Consulting, Inc.; Brandon Reich; Tag Pres. Specialists, Corp.; Gonzalo Carranza; Ryan Wolf; Wasatch RX LLC; Safe Chain Solutions LLC; Hutcheson Homecare Pharmacy, Inc.; XYZ Pharmacies & Suppliers 1-5; & John & Jane Does 1-10, No. 1:24-cv-00080 (S.D. Miss. Aug. 28, 2026).
- Varsity Brands Holding Co. LLC v. Arch Ins. Companyl., No. N23C-10-283 MAA CCLD (Del. Super. Ct. Feb. 19, 2025).published
- Peters v. Qadhafi, No. 2021-0516 (D.D.C. Mar. 17, 2025).published
- Little & Gorgeous, Inc. D/B/A Wild & Gorgeous Transfers & Amanda Fournier v. Wild Tribe Screen Prints, LLC, 717 S.W.3d 36 (Tex. App.—San Antonio 2025).published
- Armstrong v. USA Auto. Partners, LLC, No. 3:24-cv-01281 (M.D. Tenn. May 27, 2025).
- Asbury v. Stout, No. 8:25-cv-00141 (M.D. Fla. July 10, 2025).
- Portillo v. Nebula Genomics, Inc., No. 1:24-cv-09894 (N.D. Ill. July 24, 2025).
- Brown v. Washington Univ. Sch. of Law, No. 8:24-cv-03198 (D. Md. Aug. 1, 2025).
- Asbury v. Stout, No. 3:25-cv-01386 (D. Or. July 10, 2025).
- SAE Int'l v. Int'l Aerospace Quality Grp. A.I.S.B.L., No. 2:25-cv-00268 (W.D. Pa. Aug. 26, 2025).
- Ex parte Tanner Med. Ctr., Inc. PETITION FOR WRIT OF MANDAMUS (In re: Richard Terry Cole v. Tanner Med. Ctr., Inc.) (Randolph Circuit Court: CV-24-900013)., No. SC-2025-0019 (Ala. Sept. 12, 2025).published
- Pete v. Facebook Data Breach, No. 1:25-cv-00245 (E.D. Tex. Sept. 15, 2025).
- Tate v. McCoy, No. 1:24-cv-00465 (D. Haw. Oct. 2, 2025).
- Duracarbon Latinamerica, LLC v. SIMEC USA Corp., et al., No. 7:24-cv-00331 (S.D. Tex. Dec. 5, 2025).
- Driscoll, No. 3:25-cv-08054 (D. Ariz. Dec. 8, 2025).
- The Coll. of William & Mary in Virginia v. W M Symposia, Inc., No. 4:25-cv-00094 (E.D. Va. Feb. 26, 2026).
- Melvin Morales v. Bah Logistics LLC Et Al., No. 3:25-cv-01106 (D.P.R. Mar. 4, 2026).
- Dunham Trust Co. v. Ruth Surrey, No. 4D2025-1889 (Fla. 4th DCA Apr. 29, 2026).published
- Linden, No. 2:25-cv-01491 (D. Nev. Aug. 28, 2026).
- Schmidt Bros. Farm LLC v. Eden Solutions LLC, SWJ Consulting LLC, No. 4:25-cv-04237 (D.S.D. Sept. 1, 2026).
- Nada v. United Arab Emirates, No. 2024-0206 (D.D.C. Sept. 15, 2026).published
- A&A Investments, Inc. v. A.S.A.P Logistics, Ltd., 2025 IL App (1st) 232289-U.unpublished
- Schultz v. Komori Am. Corp., No. 1:23-cv-03001 (D. Md. Feb. 28, 2025).
- Christman v. BE's Refreshments, No. 2:25-cv-00327 (E.D. Wis. Mar. 5, 2025).
- Christman v. BE's Refreshments, No. 2:24-cv-03189 (D. Ariz. Mar. 5, 2025).
- Moomaw v. Geosnapshot Pty Ltd, No. 3:23-cv-01321 (S.D. Ill. Mar. 6, 2025).
- City of Chicago v. Westforth Sports, Inc., 2025 IL App (1st) 231908, 258 N.E.3d 959.published
- STERN v. Ruzich, No. 2:24-cv-01222 (E.D. Pa. Mar. 21, 2025).
- Avataa USA, LLC v. Yaminsky, No. 3:24-cv-06314 (D.N.J. Mar. 24, 2025).unpublished
- Goldovsky v. Rauld, No. 6:24-cv-00159 (W.D. Tex. Feb. 28, 2025).
- Vines of Argentina LLC v. BBI Argentina, No. 2:22-cv-01619 (W.D. Wash. Mar. 31, 2025).
- Reynolds v. Air Line Pilots Ass'n, Int'l, No. 2:24-cv-01422 (S.D. Ohio Mar. 31, 2025).
- Chen Fang v. CMB Exp. Infrastructure Inv. Grp. 48 LP, 773 F. Supp. 3d 963 (E.D. Cal. 2025).published
- Reynolds v. Air Line Pilots Ass'n, Int'l, No. 1:25-cv-03553 (N.D. Ill. Mar. 31, 2025).
- Mattson v. Basin Elec. Power Coop., No. 1:24-cv-00991 (E.D. Wis. Apr. 8, 2025).
- Fregosa v. Mashable Inc., No. 3:25-cv-01094 (N.D. Cal. Apr. 10, 2025).
- Am. Guarantee & Liab. Ins. Co. v. Getfvp LLC, No. 3:24-cv-08922 (D.N.J. Apr. 14, 2025).unpublished
- Esgate v. Home Depot U.S.A., Inc., No. 6:24-cv-01806, 2025 WL 1207217 (D. Or. Apr. 24, 2025).
- Jovanovic v. The United States Olympic & Paralympic Comm., No. 3:22-cv-02098 (D.N.J. Apr. 28, 2025).unpublished
- Habbaba v. Gorilla Mind, LLC, No. 3:24-cv-00921 (S.D. Cal. Apr. 29, 2025).
- Johnson v. Allianz Global Risks US Ins. Co., No. 2:24-cv-00120 (E.D. Wis. May 1, 2025).
- S R P Env't L L C v. Cove House Condo. Ass'n, No. 5:23-cv-00776 (W.D. La. Apr. 29, 2025).
- Mueting v. Unified Sch. Dist. No. 443, No. 2:24-cv-02381 (D. Kan. May 6, 2025).
- BDO USA, P.C. v. Ankura Consulting Grp., LLC, No. 3:24-cv-00179 (E.D. Va. May 9, 2025).
- Foster v. Digit. Saf. Prods., LLC, No. 4:24-cv-00051 (W.D. Va. May 23, 2025).
- Media Matters for Am. v. Warren Paxton, Jr., 138 F.4th 563 (D.C. Cir. 2025).published
- Mosisa v. Perry, No. 8:24-cv-01445 (D. Md. June 2, 2025).
- M. W. Prince Hall Grand Lodge v. Anderson, No. 24-30517 (5th Cir. June 4, 2025).unpublished
- Brp-Rotax Gmbh & Co. Kg v. Sheema Shaik & Touseef Siddiqui, 716 S.W.3d 98 (Tex. 2025).published
- Measurement Specialties, Inc. v. Exergen Corp., No. 2:24-cv-08369 (D.N.J. June 20, 2025).
- Ipnav LLC v. Cbv Inc, No. 3:25-cv-00084 (N.D. Tex. June 25, 2025).
- Celsius Network Ltd. v. Tether Ltd., No. 24-04018 (Bankr. S.D.N.Y. June 30, 2025).published
- Holt Texas, Ltd v. Precision Power Source, LLC, No. 5:24-cv-00822 (W.D. Tex. June 2, 2025).
- PivotHealth Holdings LLC v. Horton, No. 2:24-cv-01786 (D. Ariz. July 7, 2025).
- Lisko v. Mid-South Agric. Equip. Inc, No. 4:23-cv-00757 (E.D. Ark. July 14, 2025).
- Century Bank v. Art Fin. Funding (IX), LLC, No. 1:24-cv-01027 (D.N.M. July 18, 2025).
- Hannah Dev., LLC v. Maverick Gen. Contractors, LLC, No. M2024-01592-COA-R3-CV (Tenn. Ct. App. July 21, 2025).published
- Ipnav LLC v. Cbv Inc, No. 1:25-cv-00895 (D. Del. June 25, 2025).
- CDC Real Est. v. La Biela, No. 24-50626 (5th Cir. Aug. 5, 2025).unpublished
- State of Texas v. Arity 875, LLC, No. 15-25-00082-CV (Tex. App.—15th Dist. Aug. 4, 2025).published
- Lane v. Baywood Hotels, Inc., No. 2:25-cv-00103 (E.D. La. Aug. 21, 2025).
- Rodriguez v. Netflix, No. B338932 (Cal. Ct. App. Aug. 28, 2025).unpublished
- Fogarty v. Liberty Mut. Holding Co., Inc., No. 3:24-cv-01998 (D. Or. Aug. 28, 2025).
- State v. Meta Platforms, Inc., 2025 VT 51, 346 A.3d 489.published
- Fight Sports LLC & Roberto De Abreu Filho A/K/A Roberto \Cyborg\" Abreu v. Mandy Schneider", No. 01-23-00897-CV (Tex. App.—Houston [1st Dist.] Aug. 29, 2025).published
- Triple G Ventures LLC & Robert D. Smith v. Thomas Wang, Aaron Boesky, Sharon So, & AT Gekko, LLC, No. 01-23-00634-CV (Tex. App.—Houston [1st Dist.] Aug. 28, 2025).published
- De Ciel v. Porter, No. 3:25-cv-03351 (N.D. Cal. Aug. 28, 2025).
- Yarbrough v. The United States Space Force, No. 4:23-cv-00876 (E.D. Tex. Sept. 9, 2025).
- Yarbrough v. Gen. B. Chance Saltzman, No. 4:25-cv-00990 (E.D. Tex. Sept. 9, 2025).
- Beauchamp v. Muise, No. 2:24-cv-00861 (D. Ariz. Sept. 11, 2025).
- Taylor v. Caplan, No. 4:24-cv-01303 (E.D. Mo. Sept. 22, 2025).
- Icpep, LLC v. Smc Specialty Fin., LLC, No. 1:24-cv-01819 (S.D. Ind. Sept. 23, 2025).
- Dalrada Fin. Corp. v. Bonar, No. 3:24-cv-02166 (S.D. Cal. Sept. 23, 2025).
- Hawkins v. Zenner, No. 2:24-cv-00788 (D. Ariz. Sept. 26, 2025).
- Parker v. Barclays Bank Delaware, No. 2:25-cv-02217 (E.D. Pa. Sept. 29, 2025).
- Sec. & Exch. Comm'n v. Lee, No. 1:24-cv-00296 (D. Md. Sept. 30, 2025).
- Beom Su Lee v. Kim Yonja, No. 2:23-cv-10677 (C.D. Cal. Sept. 22, 2025).
- Stone v. California Dep't of Just., No. 2:25-cv-02324 (D. Ariz. Oct. 8, 2025).
- Potts, No. 6:24-cv-01205 (D. Kan. Oct. 16, 2025).
- Trevor Hillstrom v. Best Egg, Inc., No. 3:25-cv-00019 (W.D. Wis. Oct. 22, 2025).
- Integrity Med. Prod. Solutions, LLC v. Seroclinix Corp., a Delaware Corp., et. al., No. 3:22-cv-00785 (S.D. Cal. Oct. 22, 2025).
- Barfell v. Freeman Health Sys. & Gulshan Uppal, M.D., 2025 OK 61, 579 P.3d 591.published
- ICPEP, LLC v. SMC Specialty Fin., LLC, Gary S. Raskin, & Alastair Burlingham, No. 2:25-cv-09747 (C.D. Cal. Sept. 23, 2025).
- Fennell, No. 8:25-cv-01062 (D. Md. Oct. 30, 2025).
- Folden, No. 3:25-cv-00271 (S.D. W. Va. Oct. 31, 2025).
- Marquis, No. 1:25-cv-10749 (D. Mass. Oct. 31, 2025).
- Printfly Corp. v. JWT Prods., Inc. d/b/a Thread Logic & ROI Revolution, Inc., No. 2:25-cv-00030 (E.D. Pa. Nov. 4, 2025).
- Ketan Mehta v. the State of Texas Ex Rel. Tarik Ahmed, 716 S.W.3d 186 (Tex. App.—15th Dist. 2025).published
- Barth, No. 1:25-cv-01883 (D. Colo. Nov. 14, 2025).
- Tsai, No. 8:25-cv-01774 (D. Md. Nov. 24, 2025).
- Landry's v. Chubb, No. 25-30566 (5th Cir. Dec. 8, 2025).unpublished
- Patel, No. 2:25-cv-00986 (D.N.J. Dec. 23, 2025).
- Rapport, No. 1:25-cv-02071 (N.D. Ohio Jan. 9, 2026).
- State of Iowa, Ex Rel. Attorney Gen. Brenna Bird v. Tiktok, Inc., Tiktok Ltd, Tiktok Pte. Ltd, Bytedance Ltd. & Bytedance, Inc., 30 N.W.3d 732 (Iowa 2026).published
- Rutherford v. Clements, No. 2025-2172 (D.D.C. Feb. 3, 2026).published
- Ross, No. 1:25-cv-00883 (D. Md. Feb. 5, 2026).
- Dyer, No. 1:25-cv-02189 (D. Or. Feb. 11, 2026).
- Cox, No. 3:24-cv-01122 (S.D. Cal. Jan. 16, 2026).
- Watkins, No. 3:25-cv-00032 (E.D. Tenn. Feb. 17, 2026).
- Barker, No. 1:25-cv-00212 (D. Md. Feb. 13, 2026).
- Gruhn, No. 2:24-cv-03195 (D. Ariz. Feb. 13, 2026).
- Hill, No. 5:25-cv-00275 (N.D.N.Y. Feb. 24, 2026).
- Jaimini Vyas v. Am. Van Lines, Inc., 430 So. 3d 135 (Fla. 4th DCA 2026).published
- Juselis v. Arlington Mgmt. Employees, No. 2023-0349 (D.D.C. Mar. 5, 2026).published
- Samuelson, No. 1:25-cv-01327 (D. Colo. Mar. 20, 2026).
- Riley, No. 3:25-cv-00036 (M.D. Tenn. Mar. 23, 2026).
- Morales, No. 1:25-cv-00271 (D. Idaho Mar. 31, 2026).
- Fruge, No. 1:25-cv-01298 (N.D. Ga. Mar. 31, 2026).
- Ledbetter, No. 1:24-cv-00538 (N.D. Ga. Mar. 31, 2026).
- Baldwin, No. 3:26-cv-00145 (E.D. Tenn. Mar. 26, 2026).
- Bellamy, No. 3:26-cv-01283 (D.S.C. Mar. 25, 2026).
- Bellamy, No. 4:25-cv-00775 (N.D. Ohio Mar. 25, 2026).
- Fuller, No. 1:25-cv-11565 (D. Mass. Mar. 31, 2026).
- Watson, No. 1:25-cv-01623 (S.D. Ind. Apr. 17, 2026).
- Keyway Pride Ltd. v. Reuben, No. B340135 (Cal. Ct. App. May 1, 2026).unpublished
- Bryant, No. 1:24-cv-00071 (D. Md. Mar. 30, 2026).
- Ronald Milor, Jr., et al. v. Oasis Hotels & Resorts, S.A. de C.V., et al., No. 1:24-cv-00792 (D. Md. Mar. 30, 2026).
- Chappie, No. 2:25-cv-00235 (E.D. Ky. May 4, 2026).
- A.B., No. 1:25-cv-02475 (D. Md. Mar. 31, 2026).
- Rye, No. 2:25-cv-02903 (D. Ariz. Mar. 31, 2026).
- Lincoln Benefit Life Co. v. Wilmington Trust, N.A., as Sec. Intermediary, & Gregory Baydiuk, No. 2:25-cv-02728 (D.N.J. Mar. 5, 2026).
- Juselis, No. 8:26-cv-01222 (D. Md. Mar. 5, 2026).
- Atzili v. Islamic Repub. of Iran, No. 2024-3365 (D.D.C. May 29, 2026).published
- Davis, No. 2:26-cv-00099 (E.D. Tenn. June 8, 2026).
- Solo, No. 3:25-cv-00452 (S.D. W. Va. May 20, 2026).
- Marshall, No. 3:25-cv-00805 (M.D. La. June 26, 2026).
- Marshall, No. 3:26-cv-02181 (N.D. Tex. June 26, 2026).
- Hauck, No. 2:25-cv-01656 (W.D. Wash. June 18, 2026).
- Kitsch LLC v. Blonde Comet L.L.C., No. 2:25-cv-11595 (C.D. Cal. June 16, 2026).
- Ross, No. 3:26-cv-03204 (N.D. Cal. July 8, 2026).
- Aloisio, No. 1:25-cv-07997 (S.D.N.Y. June 17, 2026).
- Christian, No. 3:25-cv-00993 (W.D.N.C. July 9, 2026).
- Burning Glass Int'l, Inc. v. Burning Glass Inst., No. 3:25-cv-00142 (D. Idaho July 10, 2026).
- ERC Specialists v. Schoolmates, No. 25-4116 (10th Cir. July 13, 2026).unpublished
- Northwell Health, Inc. v. Grp. Hospitalization & Med. Servs., Inc., No. 25-192, 2026 WL 2035965 (2d Cir. July 15, 2026).published
- Drink Lmnt, Inc. v. Elmnt, LLC, No. 2:25-cv-01018 (M.D. Fla. July 11, 2026).
- Burmeister v. Peterson, No. 25-3926 (9th Cir. Aug. 4, 2026).unpublished
- Afiniti, Ltd. v. Chishti, No. 2023-0303 (D.D.C. Aug. 11, 2026).published
- The Sherwin-Williams Co. v. Power Engineers, Inc. et al., No. 1:25-cv-02100 (N.D. Ohio July 31, 2026).
- Castillo, No. 2:25-cv-02238 (D. Ariz. Aug. 12, 2026).
- Christina Combs v. Dig Creative Solutions, Et Al., No. 5:25-cv-02044 (W.D. La. Aug. 14, 2026).
- Tufano, No. 3:26-cv-01016 (M.D. Pa. July 9, 2026).
- E.T. v. the Boys & Girls Club of Hudson Cnty., No. A-69-24 (N.J. Aug. 19, 2026).published
- Wang, No. 1:24-cv-04844 (N.D. Ill. Aug. 26, 2026).
- Cox, No. 3:24-cv-01122 (S.D. Cal. Aug. 26, 2026).
- Ross, No. 1:26-cv-05912 (S.D.N.Y. July 8, 2026).
- Mary Rawle v. Charles Bowman, No. 25A-PL-02715 (Ind. Ct. App. Aug. 31, 2026).published
- The Sherwin-Williams Co. v. Power Engineers, Inc. et al., No. 3:26-cv-02845 (N.D. Tex. July 31, 2026).
- Monique Kennedy v. Maersk Line, Ltd., No. 1:26-cv-00234 (S.D. Ala. Aug. 31, 2026).
- Crile, No. 4:26-cv-00762 (E.D. Mo. Aug. 31, 2026).
- Monique Kennedy v. Maersk Line, Ltd., No. 2:26-cv-00916 (E.D. Va. Aug. 31, 2026).
- Malherbe, No. 1:21-cv-10903 (S.D.N.Y. Aug. 3, 2026).
- Novakhova, No. 2:26-cv-00585 (E.D. Pa. Sept. 11, 2026).
- In Re: Kia Hyundai Veh. Theft Mktg., Sales Practices, & Prods. Liab. Litig.: Insu, No. 24-5219 (9th Cir. Sept. 14, 2026).published
- Melendez, No. 3:25-cv-01398 (D.P.R. Sept. 24, 2026).
- Lacey, No. 2:25-cv-02847 (E.D. Cal. Sept. 25, 2026).
- Tracy Dinkmeyer v. Shawn Force, 22 N.W.3d 244 (Wis. Ct. App. 2025).unpublished
- Garnier, No. 3:25-cv-01649 (S.D. Ill. Dec. 19, 2025).
- Garnier, No. 3:25-cv-01478 (M.D. Tenn. Dec. 19, 2025).
- Parker v. Freiberger, No. B342580 (Cal. Ct. App. Jan. 12, 2026).unpublished
- Brown, No. 1:25-cv-05629 (N.D. Ill. Sept. 18, 2026).
- Thalasila v. Lo, No. 5:23-cv-06116 (N.D. Cal. Apr. 8, 2024).“[T]he plaintiff cannot be the only link between the defendant and the forum.”
- Walls v. VRE Chi. Eleven, LLC, 344 F. Supp. 3d 932 (E.D. Ill. 2018).published“[I]t is the defendant's conduct that must form the necessary connection with the forum *945 State that is the basis for its jurisdiction over him.”
- Sec. Inv. Prot. Corp. v. Bernard L. Madoff Inv. Sec. LLC, 594 B.R. 167 (Bankr. S.D.N.Y. 2018).published“although physical presence in the forum is not a prerequisite to jurisdiction ... physical entry into the State - either by the defendant in person or through an agent, goods, mail, or some other means - is certainly a…”
- Day v. Datta, No. 3:21-cv-00409 (N.D. Ind. May 2, 2022).“[I]t is the defendant's conduct that must form the necessary connection with the forum State that is the basis for its jurisdiction over him.”
- Philos Tech., Inc. v. Philos & D, Inc., 802 F.3d 905 (7th Cir. 2015).published“[T]he plaintiff cannot be the only link between the defendant and the forum.”
- Lions Gate Ent. Inc. v. TD Ameritrade Servs. Co., 170 F. Supp. 3d 1249 (C.D. Cal. 2016).published“[T]he plaintiff cannot be the only link between the defendant and the forum. Rather, it is the defendant’s conduct that must form the necessary connection with the forum State that is the basis for its jurisdiction ove…”
- Perrigo Co. v. Merial Ltd., 215 F. Supp. 3d 1329 (N.D. Ga. 2016).published“[T]he plaintiff cannot be the only link between the defendant and the forum. Rather, it is the defendant’s conduct that must form the necessary connection with the forum State that is the basis for its jurisdiction ove…”
- Ahkeo Labs LLC v. Plurimi Inv. Managers, LLP., 293 F. Supp. 3d 741 (N.D. Ohio 2018).published“[O]ur 'minimum contacts' analysis looks to the defendant's contacts with the forum State itself, not the defendant's contacts with persons who reside there.”
- Dennis v. JPMorgan Chase & Co., 343 F. Supp. 3d 122 (S.D. Ill. 2018).published“[T]he plaintiff cannot be the only link between the defendant and the forum. Rather, it is the defendant's conduct that must form the necessary connection with the forum State that is the basis for its jurisdiction ove…”
- Vinmar Overseas Singapore PTE LTD v. PTT Int'l Trading PTE LTD, 538 S.W.3d 126 (Tex. App.—Houston [14th Dist.] 2017).published“[t]he plaintiff cannot be the only link between the defendant and the forum. Rather, it is the defendant’s conduct that must form the necessary connection with the forum State that is the basis for its jurisdiction ove…”
- Palladino v. Leavitt, No. 1:22-cv-06756, 2023 WL 6366095 (D.N.J. Sept. 29, 2023).“physical entry into the State—either by the defendant in person or through an agent, goods, mail, or some other means—is certainly a relevant contact.”
- Nuevos Destinos, LLC v. Peck, No. 2015-1846, 2019 WL 78780 (D.D.C. Jan. 2, 2019).published“But the plaintiff cannot be the only link between the defendant and the forum. Rather, it is the defendant’s conduct that must form the necessary connection . . . .”
- Maverick Whiskey, LLC v. Brewery on Half Moon Bay, Inc., No. 5:19-cv-00136 (W.D. Tex. June 23, 2020).“[I]t is the defendant’s conduct that must form the necessary connection with the forum State that is the basis for its jurisdiction over him,” and that connection must be “substantial.”
- Offray v. Harkavy,goldman,goldman,& gerstein,p.A., No. 2019-3739 (D.D.C. June 23, 2020).published“[T]he plaintiff cannot be the only link between the defendant and the forum.”
- Yangtze Memory Tech., Inc. v. Strand Consult, No. 5:24-cv-03454 (N.D. Cal. Sept. 12, 2025).“the plaintiff cannot be the only link between the defendant and the forum”
- Donald Little v. SKF Sverige AB, 594 F. App'x 810 (5th Cir. 2014).unpublished“[Ojur ‘minimum contacts’ analysis looks to the defendant’s contacts with the forum State itself, not the defendant’s contacts with persons who reside there.”
- Wong v. Fed. Trade Comm'n, No. 6:24-cv-01410 (W.D. La. Mar. 25, 2025).
- Suski, No. 3:25-cv-00860 (D. Conn. Apr. 13, 2026).
At page 290 Determining meaningful connection to forum for jurisdiction228 citing casesThe proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant's conduct connects [it] to the forum in a meaningful way.
- Adams v. Best W. Int'l, Inc., No. 8:24-cv-00102 (D. Neb. Aug. 22, 2024). But see Walden v. Fiore, 571 U.S. 277, 284 (2014) (“Due process limits on the State’s adjudicative authority principally protect the liberty of the nonresident defendant—not the convenience of plaintiffs or third parties.”).
- Abdullah Jones v. Alton Prilliman, Et. Al., No. 1:25-cv-00651 (M.D.N.C. July 29, 2026). (The proper question is not where the plaintiff experienced a particular injury 6 Thus, the instant recommendation obviates the need for resolution of issues beyond personal jurisdiction raised in the Motions. See Iannu…)
- Kalipeni v. Fam. Values at Work, No. 2025-3470 (D.D.C. July 6, 2026).published Addressing that issue “[t]hirty years after Calder, the Supreme Court emphasized that ‘an injury is jurisdictionally relevant only insofar as it shows that the defendant has formed a contact with the forum state.’” Akhmetshin v. Browder, 7…
- Covert, No. 3:25-cv-00506 (D. Idaho Apr. 24, 2026). (The proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant’s conduct connects [it] to the forum in a meaningful way.)
- Fucich, No. 1:25-cv-00160 (S.D. Miss. Mar. 31, 2026). (Petitioner’s actions in Georgia did not create sufficient contacts with Nevada simply because he allegedly directed his conduct at plaintiffs whom he knew had Nevada connections.)
- In the Matter of the Complaint of Crazy Pants LLC & the Est. of Gregory John Daiker for Exoneration from or Limitation of Liab. v. Scott Kottmann & Jane Doe Kottmann, Client Marine Servs., LLC, a Missouri Ltd. Liab. Co., Greg Kottmann & Jane Doe Kottmann, Devin Wozencraft & Jane Doe Wozencraft, Wozencraft Ins. Agency, Inc., a California Corp. dba Wozencraft Ins. & Fin., Randy Scism & Jane Doe Scism, Marine Tech., Inc., a Missouri Corp., Mercury Marine, a Div. of Brunswick Corp., No. 2:23-cv-00023 (D. Idaho Feb. 3, 2026). (The proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant’s conduct connects him to the forum in a meaningful way.)
- Leonite Fund I, LP v. Hawaii Brewery Dev. Co., Inc.; Waiakea Bottling Inc.; Waiakea Inc; & Marcus I Bender, No. 1:25-cv-01371 (D. Colo. Jan. 7, 2026). Walden, 571 U.S. at 285-86 (“[A] defendant's contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties.
- Doe v. Deutsche Lufthansa Aktiengesellschaft, 157 F.4th 1103 (9th Cir. 2025).published (The proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant’s conduct connects him to the forum in a meaningful way.)
- Rose v. Koch, No. 6:24-cv-00116 (E.D. Okla. Sept. 25, 2025). (The proper question is not whether the plaintiff experienced a particular injury or effect but whether the defendant's conduct connects [her] to the forum in a meaningful way)
- Indus. Turnaround Corp. v. Captura Corp., No. 3:24-cv-00595 (E.D. Va. Sept. 25, 2025).([Mlere injury to a forum resident is not a sufficient connection to the forum.)
Show 203 more citing cases
- Bertec v. Sparta Software Corp., No. 2:19-cv-04623, 2020 WL 2112162 (S.D. Ohio May 4, 2020).
- Tara Blessing v. Sujana Chandrasekhar, 988 F.3d 889 (6th Cir. 2021).published
- Eighteen Seventy v. Jayson, 32 F.4th 956 (10th Cir. 2022).published
- Brandon Briskin v. Shopify, Inc., 87 F.4th 404 (9th Cir. 2023).published
- Brana v. Moravcik, No. 1:19-cv-02802 (N.D. Ohio Oct. 6, 2020).
- Christine Seward v. Charles Richards & a., 265 A.3d 9 (N.H. 2021).published
- Alexander Ross v. Robinson, Hoover & Fudge, PLLC, 173 F.4th 745 (6th Cir. 2026).published
- Rogers v. City of Hobart, Indiana, 491 F. Supp. 3d 351 (N.D. Ill. 2020).published
- Savu v. Purolite Co., No. 8:22-cv-01149 (D. Md. Feb. 21, 2023).
- Winston v. Zaehringer (JRG3), No. 1:19-cv-00216, 2020 WL 3259531 (E.D. Tenn. June 16, 2020).
- Brandon Briskin v. Shopify, Inc., 135 F.4th 739 (9th Cir. 2025).published
- Dimante v. Schnayderman, No. 1:23-cv-15110 (N.D. Ill. Nov. 22, 2024).
- Cascade Aircraft Mgmt., LLC v. Geoffrey Antenor Velazco, 913 S.E.2d 4 (Ga. Ct. App. 2025).published
- Hanover v. One Commc'ns (Guyana) Inc, No. 1:24-cv-06637 (E.D.N.Y. Mar. 28, 2025).
- M. W. Prince Hall Grand Lodge v. Anderson, No. 24-30517 (5th Cir. June 4, 2025).unpublished
- State of Texas v. Arity 875, LLC, No. 15-25-00082-CV (Tex. App.—15th Dist. Aug. 4, 2025).published
- Matrix Warranty Solutions Inc v. The Staunton Grp. LLC, No. 3:21-cv-03111 (N.D. Tex. June 2, 2022).
- Christie v. Nat'l Inst. for Newman Studies, 258 F. Supp. 3d 494 (D.N.J. 2017).published“Calder made clear that mere injury to a forum resident is not a sufficient connection to the forum.”
- Offray v. Harkavy,goldman,goldman,& gerstein,p.A., No. 2019-3739 (D.D.C. June 23, 2020).published
At page 284 Determining jurisdiction through defendant's minimum contacts1,264 citing cases“for a state to exercise jurisdiction consistent with due process, the defendant's suit-related conduct must create a substantial connection with the forum state.”
- Adams v. Best W. Int'l, Inc., No. 8:24-cv-00102 (D. Neb. Aug. 22, 2024). (Due process limits on the State’s adjudicative authority principally protect the liberty of the nonresident defendant—not the convenience of plaintiffs or third parties.)
- Ellis, No. 2:24-cv-08213 (D.N.J. Sept. 25, 2026).(there must be evidence that the defendant ‘purposefully availed’ itself of conducting activity in the forum state, by directly targeting its web site to the state, knowingly interacting with residents of the forum stat…)
- Lillie, No. 4:25-cv-04239 (D.S.D. Sept. 15, 2026). See Pederson, 951 F.3d at 980 (finding “hundreds of phone calls and emails” to be insufficient without “allegation . . . that these communications were part of some broader effort by the defendants to create a connection with [the forum st…
- Tanner, No. 1:25-cv-00591 (S.D. Ind. Aug. 28, 2026). Walden, 571 U.S. at 285 ("'minimum contacts' analysis looks to the defendant's contacts with the forum State itself, not the defendant's contacts with persons who reside there.").
- Curry, No. 3:26-cv-01788 (M.D. Pa. July 29, 2026). First, the Court considers whether a statutory basis for jurisdiction exists under the forum state’s long-arm statute.2 See Walden v. Fiore, 571 U.S. 277, 283 (2014) (“Federal courts ordinarily follow state law in determining the bounds of…
- Covert, No. 3:25-cv-00506 (D. Idaho Apr. 24, 2026). Schwarzenegger, 374 F.3d at 803 (applying the Calder effects test); Walden, 571 U.S. at 290 (“The proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant’s conduct connects [it] to the…
- Daimer Truck Fin. Servs. v. Vanguard Nat'l Trailer Corp., 2026 Tex. Bus. 16 (Tex. Bus. Ct. 2026).published([T]he defendant’s suit-related conduct must create a substantial connection with the forum State.)
- Mountain Meadows Pet Prods., Inc. v. NT Consulting, LLC; Nathan Thomas; & Seth Kaufman, No. 5:24-cv-05200 (W.D. Ark. Feb. 23, 2026). “The unilateral activity of those who claim some relationship with a nonresident defendant cannot satisfy the requirement of contact with the forum State.” Mountaire Feeds, Inc., 677 F.2d at 654 (quoting Hanson v. Denckla, 357 U.S. 235, 25…
- In the Matter of the Complaint of Crazy Pants LLC & the Est. of Gregory John Daiker for Exoneration from or Limitation of Liab. v. Scott Kottmann & Jane Doe Kottmann, Client Marine Servs., LLC, a Missouri Ltd. Liab. Co., Greg Kottmann & Jane Doe Kottmann, Devin Wozencraft & Jane Doe Wozencraft, Wozencraft Ins. Agency, Inc., a California Corp. dba Wozencraft Ins. & Fin., Randy Scism & Jane Doe Scism, Marine Tech., Inc., a Missouri Corp., Mercury Marine, a Div. of Brunswick Corp., No. 2:23-cv-00023 (D. Idaho Feb. 3, 2026). See generally Walden, 571 U.S. at 290 (“The proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant’s conduct connects him to the forum in a meaningful way.”) Because the first prong o…
- Dosso, No. 3:25-cv-00190 (N.D. W. Va. Dec. 29, 2025). See Bristol-Myers Squibb Co., 582 U.S. at 268 (“The bare fact that [the defendant] contracted with a California distributor is not enough to establish personal jurisdiction in the State.”); Walden, 571 U.S. at 286 (“[A] defendant’s relatio…
Show 200 more citing cases
- Dosso, No. 5:25-cv-00050 (W.D. Va. Dec. 29, 2025). See Bristol-Myers Squibb Co., 582 U.S. at 268 (“The bare fact that [the defendant] contracted with a California distributor is not enough to establish personal jurisdiction in the State.”); Walden, 571 U.S. at 286 (“[A] defendant’s relatio…
- Warfield, No. 2:25-cv-00037 (E.D. Tenn. Nov. 6, 2025). ([T]he relationship must arise out of contacts that the defendant himself creates with the forum State.)
- Doe v. Deutsche Lufthansa Aktiengesellschaft, 157 F.4th 1103 (9th Cir. 2025).published Although the tortious conduct primarily occurred in Saudi Arabia, we “evaluate all of a defendant’s contacts with the forum state, whether or not those contacts involve wrongful activity by the defendant.” See Yahoo!, 433 F.3d at 1207 ; se…
- Sw. v. 19th Jud. Dist., 2024 MT 320.published
- Ethridge v. Samsung SDI, 137 F.4th 309 (5th Cir. 2025).published
- Sage Global Servs. Ltd. v. 4th Paradigm (Beijing) Tech. Co., Ltd., No. 5:23-cv-04534 (N.D. Cal. July 30, 2025).
- Brandon Briskin v. Shopify, Inc., 135 F.4th 739 (9th Cir. 2025).published
- Reed v. Ascension Health, No. 4:24-cv-00419 (N.D. Okla. May 9, 2025).
- Unnikrishnan v. IOT.nxt Americas USA, Inc., No. 4:22-cv-00870 (E.D. Tex. July 28, 2025).
- Hufft, No. 4:25-cv-00057 (N.D. Okla. Sept. 29, 2025).
- Manchester United Football Club Ltd. v. The Partnerships & Unincorporated Associations Identified on Schedule A, No. 1:24-cv-05692 (N.D. Ill. Dec. 23, 2024).
- Cascade Aircraft Mgmt., LLC v. Geoffrey Antenor Velazco, 913 S.E.2d 4 (Ga. Ct. App. 2025).published
- Hurricane Express Inc. v. Red Chamber Co., No. 4:24-cv-00393 (N.D. Okla. Feb. 21, 2025).
- Huffman v. RC3 Innovations, LLC, No. 7:24-cv-01037 (E.D.N.C. Feb. 24, 2025).
- Healthcare Dev. Partners, LLC v. Signet Health Corp., No. 1:24-cv-12343 (N.D. Ill. Mar. 25, 2025).
- Scott Crabtree v. Aon Ins. Managers (Bermuda) Ltd., No. 23-1959 (4th Cir. Mar. 28, 2025).unpublished
- Abraham v. Kwauk, No. 3:24-cv-01630 (D. Or. Apr. 28, 2025).
- Andrew Harrington v. Cracker Barrel Old Country Store, Inc., 142 F.4th 678 (9th Cir. 2025).published
- Welk Biology Co., Ltd. v. Hakumo LLC, No. 2:24-cv-01613 (D. Nev. Aug. 20, 2025).
- Banet v. The Cooper Companies, Inc., No. 4:24-cv-00029 (W.D. Ky. Sept. 30, 2025).
- Menge, No. 2:25-cv-11964 (E.D. Mich. Nov. 3, 2025).
- Servpro Indus., LLC v. Reed Gaskin & Brittany Gaskin, No. 15-25-00193-CV (Tex. App.—15th Dist. Nov. 17, 2025).published
- Mills, No. 3:25-cv-00203 (D. Conn. Jan. 5, 2026).
- Baker, No. 3:25-cv-00070 (W.D. Ky. Jan. 16, 2026).
- Seaboard Foods, LLC v. Cloverdale Foods Co., No. 2:25-cv-02160 (D. Kan. Feb. 3, 2026).
- Mills, No. 3:26-cv-00052 (M.D. Tenn. Jan. 5, 2026).
- Cox v. Gritman Med. Ctr., 166 F.4th 1171 (9th Cir. 2026).published
- Cox v. Gritman Med. Ctr., 170 F.4th 724 (9th Cir. 2026).published
- Reed, No. 4:24-cv-00419 (N.D. Okla. Mar. 25, 2026).
- Victory Energy Operations, LLC v. Collins & Collins Mech., Inc., No. 4:25-cv-00445 (N.D. Okla. July 24, 2026).
- Curry, No. 3:26-cv-01606 (M.D. Pa. July 22, 2026).
- Pike v. Littlejohn Fin. Servs., Inc., No. 6:24-cv-00707 (D. Or. Dec. 17, 2024).
- Fairfield Sentry Ltd. (In Liquidation) v. Citco Global Custody N.V., No. 19-01122 (Bankr. S.D.N.Y. Dec. 20, 2024).
- Akhmetshin v. Browder, 761 F. Supp. 3d 1 (D.D.C. 2024).published
- Sabbagh v. Ins. Auto Auctions, Inc., No. 2:24-cv-06742 (D.N.J. Dec. 26, 2024).unpublished
- Click Go & Buy Inc. v. It Assets, Inc., No. 2:24-cv-00744 (D.N.J. Dec. 31, 2024).
- Crear v. Am. Airlines Grp. Inc., No. 2023-3812 (D.D.C. Jan. 6, 2025).published
- King Cnty. v. Express Scripts Inc, No. 2:24-cv-00049 (W.D. Wash. Jan. 7, 2025).
- L.W. v. Audi AG, 108 Cal. App. 5th 95 (Cal. Ct. App. 2025).published
- Elmer v. Kohli, No. 1:22-cv-02303 (D.N.J. Jan. 14, 2025).
- Taylor v. FedEx Corp., No. 4:24-cv-00460 (D. Ariz. Jan. 15, 2025).
- Parke v. Delta Air Lines Inc., No. 6:23-cv-02221 (M.D. Fla. Jan. 23, 2025).
- Byron v. Stiiizy, Inc., No. 3:24-cv-01082 (S.D. Ill. Jan. 29, 2025).
- EBET, Inc. v. Aspire Global Int'l Ltd., No. 2:23-cv-01830 (D. Nev. Jan. 31, 2025).
- SmarterSwipe, Inc. v. Navarrete, No. 2:24-cv-00299 (D. Nev. Feb. 3, 2025).
- Regeneron Pharm., Inc. v. Mylan Pharm. Inc., 127 F.4th 896 (Fed. Cir. 2025).published
- Sessa v. Ancestry.com Operations Inc., No. 2:20-cv-02292 (D. Nev. Feb. 12, 2025).
- Woods v. Cortland Capital Mkt. Servs., LLC, No. 1:23-cv-03892 (N.D. Ill. Feb. 18, 2025).
- Varsity Brands Holding Co. LLC v. Arch Ins. Companyl., No. N23C-10-283 MAA CCLD (Del. Super. Ct. Feb. 19, 2025).published
- Strobl v. Croft, No. 1:24-cv-00140 (E.D. Tenn. Feb. 20, 2025).
- Jambulingham v. 1, No. 3:24-cv-05792 (N.D. Cal. Feb. 20, 2025).
- Hakimyar v. Habib Bank Ltd., No. 1:24-cv-00993 (S.D.N.Y. Feb. 25, 2025).
- Norman v. Webster, No. 2:24-cv-00240 (E.D. La. Feb. 27, 2025).
- Nash v. Near North Am., Inc., No. 3:24-cv-06623, 2025 WL 654051 (D.N.J. Feb. 28, 2025).unpublished
- App-Order LLC v. Reynolds, No. 2:24-cv-01480 (D. Nev. Mar. 7, 2025).
- Weveel, LLC v. Evaco LLC, No. 1:24-cv-01008 (D.N.J. Mar. 11, 2025).
- NSC Partners, LLC v. Eli Lilly & Co., 770 F. Supp. 3d 1118 (N.D. Ill. 2025).published
- Peters v. Qadhafi, No. 2021-0516 (D.D.C. Mar. 17, 2025).published
- Little & Gorgeous, Inc. D/B/A Wild & Gorgeous Transfers & Amanda Fournier v. Wild Tribe Screen Prints, LLC, 717 S.W.3d 36 (Tex. App.—San Antonio 2025).published
- House of Raeford Farms of Louisiana L L C v. Gulf States Cold Storage Co, No. 5:24-cv-00471 (W.D. La. Mar. 17, 2025).
- Moore v. Med. Mgmt. Int'l, Inc., No. 2:23-cv-00152 (E.D. Tenn. Mar. 18, 2025).
- Odegaard v. TK Global, Inc., No. 1:24-cv-01121 (N.D. Ill. Mar. 24, 2025).
- Hanover v. One Commc'ns (Guyana) Inc, No. 1:24-cv-06637 (E.D.N.Y. Mar. 28, 2025).
- Armstrong v. USA Auto. Partners, LLC, No. 3:24-cv-01281 (M.D. Tenn. May 27, 2025).
- Asbury v. Stout, No. 8:25-cv-00141 (M.D. Fla. July 10, 2025).
- Portillo v. Nebula Genomics, Inc., No. 1:24-cv-09894 (N.D. Ill. July 24, 2025).
- Brown v. Washington Univ. Sch. of Law, No. 8:24-cv-03198 (D. Md. Aug. 1, 2025).
- Asbury v. Stout, No. 3:25-cv-01386 (D. Or. July 10, 2025).
- SAE Int'l v. Int'l Aerospace Quality Grp. A.I.S.B.L., No. 2:25-cv-00268 (W.D. Pa. Aug. 26, 2025).
- Ex parte Tanner Med. Ctr., Inc. PETITION FOR WRIT OF MANDAMUS (In re: Richard Terry Cole v. Tanner Med. Ctr., Inc.) (Randolph Circuit Court: CV-24-900013)., No. SC-2025-0019 (Ala. Sept. 12, 2025).published
- Pete v. Facebook Data Breach, No. 1:25-cv-00245 (E.D. Tex. Sept. 15, 2025).
- Tate v. McCoy, No. 1:24-cv-00465 (D. Haw. Oct. 2, 2025).
- Duracarbon Latinamerica, LLC v. SIMEC USA Corp., et al., No. 7:24-cv-00331 (S.D. Tex. Dec. 5, 2025).
- Driscoll, No. 3:25-cv-08054 (D. Ariz. Dec. 8, 2025).
- The Coll. of William & Mary in Virginia v. W M Symposia, Inc., No. 4:25-cv-00094 (E.D. Va. Feb. 26, 2026).
- Melvin Morales v. Bah Logistics LLC Et Al., No. 3:25-cv-01106 (D.P.R. Mar. 4, 2026).
- Dunham Trust Co. v. Ruth Surrey, No. 4D2025-1889 (Fla. 4th DCA Apr. 29, 2026).published
- Linden, No. 2:25-cv-01491 (D. Nev. Aug. 28, 2026).
- Schmidt Bros. Farm LLC v. Eden Solutions LLC, SWJ Consulting LLC, No. 4:25-cv-04237 (D.S.D. Sept. 1, 2026).
- Nada v. United Arab Emirates, No. 2024-0206 (D.D.C. Sept. 15, 2026).published
- Suski, No. 3:25-cv-00860 (D. Conn. Apr. 13, 2026).
At page 283 Determining personal jurisdiction under due process and minimum contacts604 citing casesexplaining that the “‘minimum contacts’ analysis looks to the defendant’s contacts with the forum State itself, not the defendant’s contacts with persons who reside there
- Curry, No. 3:26-cv-01788 (M.D. Pa. July 29, 2026). (Federal courts ordinarily follow state law in determining the bounds of their jurisdiction over persons.)
- Covert, No. 3:25-cv-00506 (D. Idaho Apr. 24, 2026). Schwarzenegger, 374 F.3d at 803 (applying the Calder effects test); Walden, 571 U.S. at 290 (“The proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant’s conduct connects [it] to the…
- Fucich, No. 1:25-cv-00160 (S.D. Miss. Mar. 31, 2026). His mere knowledge that compliance with the order could6 have an effect in Mississippi does not “connect[] him to the forum in a meaningful way.” Walden, 571 U.S. at 290 (“Petitioner’s actions in Georgia did not create sufficient contacts…
- Sage Global Servs. Ltd. v. 4th Paradigm (Beijing) Tech. Co., Ltd., No. 5:23-cv-04534 (N.D. Cal. July 30, 2025).
- Fitzgerald v. Little, No. 2:24-cv-00898 (D. Vt. June 17, 2025).
- Fitzgerald v. Little, No. 2:25-cv-11906 (D.N.J. June 17, 2025).
- Alexander Ross v. Robinson, Hoover & Fudge, PLLC, 173 F.4th 745 (6th Cir. 2026).published
- Brandon Briskin v. Shopify, Inc., 135 F.4th 739 (9th Cir. 2025).published
- Reed v. Ascension Health, No. 4:24-cv-00419 (N.D. Okla. May 9, 2025).
- Jane Doe v. Webgroup Czech Repub., A.S., 93 F.4th 442 (9th Cir. 2024).published
Show 190 more citing cases
- Old Repub. Home Prot. Co., Inc. v. Frank Winston Crum Ins. Co., No. 3:23-cv-05315 (N.D. Cal. May 14, 2024).
- Thalasila v. Lo, No. 5:23-cv-06116 (N.D. Cal. May 23, 2024).
- This, LLC v. HolaBelle, Inc., No. 3:23-cv-01579 (D. Conn. June 12, 2024).
- Duran v. Joekel, No. 2:23-cv-00558, 2024 WL 2384963 (M.D. Fla. May 23, 2024).
- Manchester United Football Club Ltd. v. The Partnerships & Unincorporated Associations Identified on Schedule A, No. 1:24-cv-05692 (N.D. Ill. Dec. 23, 2024).
- Red Box Energy Servs. Pte. Ltd. & RBES B v. v. William Buck, No. 09-23-00386-CV (Tex. App.—Beaumont Jan. 23, 2025).published
- Cascade Aircraft Mgmt., LLC v. Geoffrey Antenor Velazco, 913 S.E.2d 4 (Ga. Ct. App. 2025).published
- Hurricane Express Inc. v. Red Chamber Co., No. 4:24-cv-00393 (N.D. Okla. Feb. 21, 2025).
- Huffman v. RC3 Innovations, LLC, No. 7:24-cv-01037 (E.D.N.C. Feb. 24, 2025).
- Harms v. Lillie, No. 1:23-cv-02616 (D. Colo. Mar. 9, 2025).
- Healthcare Dev. Partners, LLC v. Signet Health Corp., No. 1:24-cv-12343 (N.D. Ill. Mar. 25, 2025).
- Scott Crabtree v. Aon Ins. Managers (Bermuda) Ltd., No. 23-1959 (4th Cir. Mar. 28, 2025).unpublished
- Abraham v. Kwauk, No. 3:24-cv-01630 (D. Or. Apr. 28, 2025).
- Daughtry v. Silver Fern Chem., 138 F.4th 210 (5th Cir. 2025).published
- Murphy v. Titlemax of Virginia, Inc., No. 1:22-cv-00971 (M.D.N.C. May 29, 2025).
- Waddell v. Titlemax of Virginia, Inc., No. 1:23-cv-00034 (M.D.N.C. May 29, 2025).
- Washington v. Titlemax of Virginia, Inc., No. 1:23-cv-00246 (M.D.N.C. May 29, 2025).
- Taylor v. Titlemax of Virginia, Inc., No. 1:23-cv-00408 (M.D.N.C. May 29, 2025).
- Powers v. Liberty Mut. Ins. Co., No. 3:24-cv-00794 (N.D. Ind. June 23, 2025).
- Andrew Harrington v. Cracker Barrel Old Country Store, Inc., 142 F.4th 678 (9th Cir. 2025).published
- Welk Biology Co., Ltd. v. Hakumo LLC, No. 2:24-cv-01613 (D. Nev. Aug. 20, 2025).
- Banet v. The Cooper Companies, Inc., No. 4:24-cv-00029 (W.D. Ky. Sept. 30, 2025).
- Janosky, No. 2:25-cv-00068 (E.D. Ky. Oct. 29, 2025).
- Menge, No. 2:25-cv-11964 (E.D. Mich. Nov. 3, 2025).
- Servpro Indus., LLC v. Reed Gaskin & Brittany Gaskin, No. 15-25-00193-CV (Tex. App.—15th Dist. Nov. 17, 2025).published
- Mills, No. 3:25-cv-00203 (D. Conn. Jan. 5, 2026).
- Baker, No. 3:25-cv-00070 (W.D. Ky. Jan. 16, 2026).
- Seaboard Foods, LLC v. Cloverdale Foods Co., No. 2:25-cv-02160 (D. Kan. Feb. 3, 2026).
- Mills, No. 3:26-cv-00052 (M.D. Tenn. Jan. 5, 2026).
- Cox v. Gritman Med. Ctr., 166 F.4th 1171 (9th Cir. 2026).published
- Cox v. Gritman Med. Ctr., 170 F.4th 724 (9th Cir. 2026).published
- Reed, No. 4:24-cv-00419 (N.D. Okla. Mar. 25, 2026).
- Victory Energy Operations, LLC v. Collins & Collins Mech., Inc., No. 4:25-cv-00445 (N.D. Okla. July 24, 2026).
- Gulf Coast Pharm. Plus, LLC & Primary Pharm., Inc. v. RFT Consulting, Inc.; Brandon Reich; Richmont Capital LLC; LBR Mgmt. Grp. LLC; Tag Pres. Specialists, Corp.; Gonzalo Carranza; Ryan Wolf; Ryan Wolf, LLC; Wasatch RX LLC; Safe Chain Solutions LLC; Hutcheson Homecare Pharmacy, Inc.; XYZ Pharmacies & Suppliers 1-5; & John & Jane Does 1-10, No. 1:24-cv-00080 (S.D. Miss. July 31, 2026).
- Curry, No. 3:26-cv-01606 (M.D. Pa. July 22, 2026).
- Gulf Coast Pharm. Plus, LLC & Primary Pharm., Inc. v. RFT Consulting, Inc.; Brandon Reich; Tag Pres. Specialists, Corp.; Gonzalo Carranza; Ryan Wolf; Wasatch RX LLC; Safe Chain Solutions LLC; Hutcheson Homecare Pharmacy, Inc.; XYZ Pharmacies & Suppliers 1-5; & John & Jane Does 1-10, No. 1:24-cv-00080 (S.D. Miss. Aug. 28, 2026).
At page 289 Analyzing minimum contacts through defendant's actions156 citing casesThe proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant's conduct connects him to the forum in a meaningful way.
- Leonite Fund I, LP v. Hawaii Brewery Dev. Co., Inc.; Waiakea Bottling Inc.; Waiakea Inc; & Marcus I Bender, No. 1:25-cv-01371 (D. Colo. Jan. 7, 2026). Walden, 571 U.S. at 285-86 (“[A] defendant's contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties.
- Old Repub. Ins. Co. v. Cont'l Motors, Inc., 877 F.3d 895 (10th Cir. 2017).published
- Lehman Bros. Special Fin. Inc. v. Bank of Am. Nat'l Ass'n (In re Lehman Bros. Holdings Inc.), 535 B.R. 608 (Bankr. S.D.N.Y. 2015).published
- Burdick v. Superior Court, 233 Cal. App. 4th 8 (Cal. Ct. App. 2015).published
- Dennis Boyer & Richard Smith v. Ernest Smith, Suzanne Cassidy, & In-Plas, Inc., 24 N.E.3d 435 (Ind. Ct. App. 2014).published
- Est. of Esther Klieman v. Palestinian Auth., 82 F. Supp. 3d 237 (D.D.C. 2015).published
- Maxitrate Tratamento Termico e Controles v. Super Sys., Inc., 617 F. App'x 406 (6th Cir. 2015).unpublished
- Francesca Munne Nordness v. Paige Faucheux, 170 So. 3d 454 (Miss. 2015).published
- Intego Software, LLC d/b/a Critical Alert v. Concept Dev., Inc., 198 So. 3d 887 (Fla. 1st DCA 2016).published
- Gramercy Advisor LLC, Gramercy Asset Mgmt. LLC, Gramercy Local Markets Recovery Fund LLC & Gramercy Fin. Servs. LLC v. R. K. Lowery, Jr. L-Falling Creek LLC, Russell A. Chabaud, R-Rac Wimbledon, LLC, John P. Moffitt, J-Jason LLC, Russell A. Chabaud, Tr. of the Russell G. Chabaud 1999 Inv. Trust, R- Russell Wimbledon, LLC, No. 01-14-00904-CV (Tex. App.—Houston [1st Dist.] Feb. 2, 2015).published
Show 146 more citing cases
- Gramercy Advisor LLC, Gramercy Asset Mgmt. LLC, Gramercy Local Markets Recovery Fund LLC & Gramercy Fin. Servs. LLC v. R. K. Lowery, Jr. L-Falling Creek LLC, Russell A. Chabaud, R-Rac Wimbledon, LLC, John P. Moffitt, J-Jason LLC, Russell A. Chabaud, Tr. of the Russell G. Chabaud 1999 Inv. Trust, R- Russell Wimbledon, LLC, No. 01-14-00904-CV (Tex. App.—Houston [1st Dist.] Feb. 13, 2015).published
- Drobny v. Lanham, 680 F. App'x 486 (7th Cir. 2017).unpublished
- Wesly v. The Nat'l Hemophilia Found., 2017 IL App (3d) 160382.published
- N. Frac Proppants, II, LLC, Lamstex Material Handling, LLC, Jeffries Alston, J & P Capital LLC, Patrick A. Tesson, & Badger Mining Corp. v. 2011 NF Holdings, LLC F/K/A NF Holdings, LLC & N. Frac Proppants, LLC, Series 1, No. 05-16-00319-CV, 2017 WL 3275896 (Tex. App.—Dallas July 27, 2017).published
- Jackson v. Euphoria Wellness, LLC, No. 3:20-cv-03297, 2020 WL 5366419 (N.D. Cal. Sept. 8, 2020).
- Jackson v. Euphoria Wellness, LLC, No. 2:20-cv-01661 (D. Nev. Sept. 8, 2020).
- Ethridge v. Samsung SDI, 137 F.4th 309 (5th Cir. 2025).published
- Sage Global Servs. Ltd. v. 4th Paradigm (Beijing) Tech. Co., Ltd., No. 5:23-cv-04534 (N.D. Cal. July 30, 2025).
- Learning Evolution, LLC v. CPG Catnet Inc., No. 3:20-cv-02153 (S.D. Cal. Feb. 16, 2022).
- Tara Blessing v. Sujana Chandrasekhar, 988 F.3d 889 (6th Cir. 2021).published
- Tricarichi Vs. CoÖperatieve Rabobank, U.A., 135 Nev. 87 (2019).published
- Eighteen Seventy v. Jayson, 32 F.4th 956 (10th Cir. 2022).published
- Brandon Briskin v. Shopify, Inc., 87 F.4th 404 (9th Cir. 2023).published
- Johnson v. Griffin, No. 3:22-cv-00295 (M.D. Tenn. Mar. 3, 2023).
- V.Z.Z.R. v. Tallcastle, No. 2:22-cv-00154 (D. Utah May 12, 2023).
- Flint v. Armstrong, No. 1:22-cv-00123 (D. Utah July 7, 2023).
- Christine Seward v. Charles Richards & a., 265 A.3d 9 (N.H. 2021).published
- Alexander Ross v. Robinson, Hoover & Fudge, PLLC, 173 F.4th 745 (6th Cir. 2026).published
- M. C. v. Quest Global, Inc., 537 P.3d 571 (Or. Ct. App. 2023).published
- Rogers v. City of Hobart, Indiana, 491 F. Supp. 3d 351 (N.D. Ill. 2020).published
- Winston v. Zaehringer (JRG3), No. 1:19-cv-00216, 2020 WL 3259531 (E.D. Tenn. June 16, 2020).
- Brandon Briskin v. Shopify, Inc., 135 F.4th 739 (9th Cir. 2025).published
- Shanika K. Lewis v. Conagra Brands, Inc. f/k/a & Successor in Interest to Conagra Foods/ Shanika K. Lewis v. DS Containers, Inc. & PSMT, LLC d/b/a Pricesmart, 2023 VI Super 30P (2023).published
- Asbury v. Stout, No. 8:25-cv-00141 (M.D. Fla. July 10, 2025).
- Asbury v. Stout, No. 3:25-cv-01386 (D. Or. July 10, 2025).
- State of Texas v. Arity 875, LLC, No. 15-25-00082-CV (Tex. App.—15th Dist. Aug. 4, 2025).published
- Dalrada Fin. Corp. v. Bonar, No. 3:24-cv-02166 (S.D. Cal. Sept. 23, 2025).
- Cox, No. 3:24-cv-01122 (S.D. Cal. Aug. 26, 2026).
- Novakhova, No. 2:26-cv-00585 (E.D. Pa. Sept. 11, 2026).
- Matrix Warranty Solutions Inc v. The Staunton Grp. LLC, No. 3:21-cv-03111 (N.D. Tex. June 2, 2022).
- Raser Tech. v. Morgan Stanley, 2019 UT 44.published
- Garnier, No. 3:25-cv-01649 (S.D. Ill. Dec. 19, 2025).
- Garnier, No. 3:25-cv-01478 (M.D. Tenn. Dec. 19, 2025).
- Philos Tech., Inc. v. Philos & D, Inc., 802 F.3d 905 (7th Cir. 2015).published
- Christie v. Nat'l Inst. for Newman Studies, 258 F. Supp. 3d 494 (D.N.J. 2017).published
- Ahkeo Labs LLC v. Plurimi Inv. Managers, LLP., 293 F. Supp. 3d 741 (N.D. Ohio 2018).published
- Nuevos Destinos, LLC v. Peck, No. 2015-1846, 2019 WL 78780 (D.D.C. Jan. 2, 2019).published
At page 291 Establishing personal jurisdiction through defendant's contacts102 citing cases[I]t is the defendant, not the plaintiff or third parties, who must create contacts with the forum State.
- Marc Vinson v. Carlo Civelli & Aster Capital S.A. (LTD) Panama, No. 09-24-00182-CV (Feb. 12, 2026).published([I]t is the defendant, not the plaintiff or third parties, who must create contacts with the forum State.)
- K. Morrill v. Scott Fin. Corp., 873 F.3d 1136 (9th Cir. 2017).published
- Jason R. Searcy, as Tr. of the Exempt Assets Trust v. Parex Resources, Inc., No. 14-0293 (Tex. June 17, 2016).published
- Jackson v. Euphoria Wellness, LLC, No. 3:20-cv-03297, 2020 WL 5366419 (N.D. Cal. Sept. 8, 2020).
- Jackson v. Euphoria Wellness, LLC, No. 2:20-cv-01661 (D. Nev. Sept. 8, 2020).
- Green Light Nat'l, LLC v. Kent, No. 1:17-cv-06370, 2018 WL 4384298 (N.D. Ill. Sept. 14, 2018).
- Harriman v. Compton, No. 2:21-cv-01102 (D.S.C. June 29, 2021).
- Vesi Inc. v. Vera Bradley Designs Inc., No. 1:19-cv-00696 (S.D. Ohio Sept. 2, 2020).
- Flint v. Armstrong, No. 1:22-cv-00123 (D. Utah July 7, 2023).
- Red Box Energy Servs. Pte. Ltd. & RBES B v. v. William Buck, No. 09-23-00386-CV (Tex. App.—Beaumont Jan. 23, 2025).published
Show 92 more citing cases
- Varsity Brands Holding Co. LLC v. Arch Ins. Companyl., No. N23C-10-283 MAA CCLD (Del. Super. Ct. Feb. 19, 2025).published
- Hanover v. One Commc'ns (Guyana) Inc, No. 1:24-cv-06637 (E.D.N.Y. Mar. 28, 2025).
- Icpep, LLC v. Smc Specialty Fin., LLC, No. 1:24-cv-01819 (S.D. Ind. Sept. 23, 2025).
- ICPEP, LLC v. SMC Specialty Fin., LLC, Gary S. Raskin, & Alastair Burlingham, No. 2:25-cv-09747 (C.D. Cal. Sept. 23, 2025).
At page 287 Examining contacts for specific personal jurisdiction based on tort effects88 citing casesThe crux of Calder was that the reputation-based ‘effects’ of the alleged libel connected the defendants to California, not just to the plaintiff.
- Triple Up Ltd. v. Youku Tudou Inc., 235 F. Supp. 3d 15 (D.D.C. 2017).published (reversing the Ninth Circuit’s application of the effects test on the grounds that the Ninth Circuit improperly “shift[ed] the analytical focus from [the defendant's] contacts with the forum to his contacts with [the pla…)
- Herron, No. 4:26-cv-00003 (D. Ariz. Aug. 31, 2026). Ariz. Oct. 1, 2024); see 2 also Walden, 571 U.S. at 286 (“[A] defendant’s relationship with a plaintiff or third party, 3 standing alone, is an insufficient basis for jurisdiction . . .
- Pintas, No. 3:25-cv-01445 (D.P.R. Apr. 20, 2026). Contra Walden, 571 U.S. at 285 (“[T]he plaintiff cannot be the only link between the defendant and the forum.”).
- Jason R. Searcy, as Tr. of the Exempt Assets Trust v. Parex Resources, Inc., 496 S.W.3d 58 (Tex. 2016).published
- United Airlines, Inc. v. Zaman, 152 F. Supp. 3d 1041 (N.D. Ill. 2015).published
- Clearone, Inc. v. Revolabs, Inc., 2016 UT 16, 369 P.3d 1269.published
- Axiom Foods, Inc. v. Acerchem Int'l, Inc., 874 F.3d 1064 (9th Cir. 2017).published
- Let's Adopt! Global, Inc. v. Macey, 32 Mass. L. Rptr. 573 (Mass. Super. Ct. 2015).published
- Burdick v. Superior Court, 233 Cal. App. 4th 8 (Cal. Ct. App. 2015).published
- Acorda Therapeutics Inc. v. Mylan Pharm. Inc., 817 F.3d 755 (Fed. Cir. 2016).published
Show 78 more citing cases
- Fletcher Fixed Income Alpha Fund, Ltd. v. Grant Thornton LLP, 54 N.E.3d 570 (Mass. App. Ct. 2016).published
- AlixPartners v. Charles Brewington, 836 F.3d 543 (6th Cir. 2016).unpublished
- Jennifer Deuel Stanton as Co-Indep. of the Est. of Ardyce Deuel-Nash, & Individually v. Brittany Gloerson, No. 05-16-00214-CV, 2016 WL 7166550 (Tex. App.—Dallas Nov. 30, 2016).published
- Burri Law Pa v. William Skurla, 35 F.4th 1207 (9th Cir. 2022).published
- Daughtry v. Silver Fern Chem., 138 F.4th 210 (5th Cir. 2025).published
- Akhmetshin v. Browder, 761 F. Supp. 3d 1 (D.D.C. 2024).published
- Media Matters for Am. v. Warren Paxton, Jr., 138 F.4th 563 (D.C. Cir. 2025).published
- Novakhova, No. 2:26-cv-00585 (E.D. Pa. Sept. 11, 2026).
- Matrix Warranty Solutions Inc v. The Staunton Grp. LLC, No. 3:21-cv-03111 (N.D. Tex. June 2, 2022).
- Raser Tech. v. Morgan Stanley, 2019 UT 44.published
- Johnson v. TheHuffingtonpost.com, 21 F.4th 314 (5th Cir. 2021).published
- Vinmar Overseas Singapore PTE LTD v. PTT Int'l Trading PTE LTD, 538 S.W.3d 126 (Tex. App.—Houston [14th Dist.] 2017).published
At page 288 Analyzing minimal contacts for personal jurisdiction39 citing casesholding that a nonresident defendant corporation’s three-year-long business relationship with Virginia limited liability company was sufficient for personal jurisdiction
- Tricarichi Vs. CoÖperatieve Rabobank, U.A., 135 Nev. 87 (2019).published
- V.Z.Z.R. v. Tallcastle, No. 2:22-cv-00154 (D. Utah May 12, 2023).
- Harrison, No. 1:25-cv-00355 (W.D. Tex. Oct. 6, 2025).
- Alexander Ross v. Robinson, Hoover & Fudge, PLLC, 173 F.4th 745 (6th Cir. 2026).published
- Burri Law Pa v. William Skurla, 35 F.4th 1207 (9th Cir. 2022).published
- Rogers v. City of Hobart, Indiana, 491 F. Supp. 3d 351 (N.D. Ill. 2020).published
- Daughtry v. Silver Fern Chem., 138 F.4th 210 (5th Cir. 2025).published
- Mueting v. Unified Sch. Dist. No. 443, No. 2:24-cv-02381 (D. Kan. May 6, 2025).
- Dyer, No. 1:25-cv-02189 (D. Or. Feb. 11, 2026).
- Reintegrative Therapy Ass'n, Inc. v. Kinitz, No. 3:21-cv-01297 (S.D. Cal. Sept. 26, 2022).
Show 29 more citing cases
- Alhathloul v. DarkMatter Grp., No. 3:21-cv-01787, 2023 WL 2537761 (D. Or. Mar. 16, 2023).
- Matrix Warranty Solutions Inc v. The Staunton Grp. LLC, No. 3:21-cv-03111 (N.D. Tex. June 2, 2022).
- Raser Tech. v. Morgan Stanley, 2019 UT 44.published
- Johnson v. TheHuffingtonpost.com, 21 F.4th 314 (5th Cir. 2021).published
- Day v. Datta, No. 3:21-cv-00409 (N.D. Ind. May 2, 2022).
At page 277 Determining personal jurisdiction based on defendant's contacts24 citing casesThe plaintiff cannot be the only link between the defendant and the forum.
- Jason R. Searcy, as Tr. of the Exempt Assets Trust v. Parex Resources, Inc., 496 S.W.3d 58 (Tex. 2016).published
- Erie Ins. Exch. v. Larose, 202 So. 3d 148 (Fla. 2d DCA 2016).published
- K. Morrill v. Scott Fin. Corp., 873 F.3d 1136 (9th Cir. 2017).published
- Stisser v. SP Bancorp, Inc., 174 A.3d 405 (Md. Ct. Spec. App. 2017).published
- United Airlines, Inc. v. Zaman, 152 F. Supp. 3d 1041 (N.D. Ill. 2015).published
- Humphries v. Allstate Ins. Co., No. 2:18-cv-11006 (E.D. Mich. June 16, 2020).
- Buckley v. Bushell, No. 4:25-cv-00012 (D. Ariz. May 2, 2025).
- Pratt v. Higgins, No. 4:22-cv-04228, 2023 WL 4564551 (N.D. Cal. July 17, 2023).
- Pratt v. Higgins, No. 4:22-cv-04228 (N.D. Cal. Feb. 14, 2024).
- Learning Evolution, LLC v. CPG Catnet Inc., No. 3:20-cv-02153 (S.D. Cal. Feb. 16, 2022).
Show 14 more citing cases
- Vora v. C4 Therapeutics, Inc, No. 1:22-cv-00640 (D. Colo. Aug. 1, 2023).
- McEwen v. Strickland, No. 2:19-cv-00880 (M.D. Fla. Jan. 30, 2020).
- Green Light Nat'l, LLC v. Kent, No. 1:17-cv-06370, 2018 WL 4384298 (N.D. Ill. Sept. 14, 2018).
- Rosenthal v. Bloomingdale's Inc., 686 F. Supp. 3d 36 (D. Mass. 2023).published
- Bertec v. Sparta Software Corp., No. 2:19-cv-04623, 2020 WL 2112162 (S.D. Ohio May 4, 2020).
- Harriman v. Compton, No. 2:21-cv-01102 (D.S.C. June 29, 2021).
At page 279 Determining personal jurisdiction based on contacts20 citing cases“[Hjowever significant the plaintiffs contacts with the forum may be, those contacts cannot be decisive in determining whether the defendant’s due process rights are violated.”
- Tara Blessing v. Sujana Chandrasekhar, 988 F.3d 889 (6th Cir. 2021).published
- Tricarichi Vs. CoÖperatieve Rabobank, U.A., 135 Nev. 87 (2019).published
- Eighteen Seventy v. Jayson, 32 F.4th 956 (10th Cir. 2022).published
- Brandon Briskin v. Shopify, Inc., 87 F.4th 404 (9th Cir. 2023).published
- Rincon Etal Investments Inc. v. Coughran, No. 4:21-cv-00426 (D. Ariz. July 12, 2022).
- Axle Holding Co., LLC v. ARB Corp. LTD., No. 3:22-cv-01472 (S.D. Cal. Mar. 8, 2023).
- Int'l Constr. Prods. LLC v. Caterpillar Inc., No. 1:15-cv-00108 (D. Del. Aug. 10, 2020).
- Brana v. Moravcik, No. 1:19-cv-02802 (N.D. Ohio Oct. 6, 2020).
- Fusion Indus. LLC v. Whalen, No. 5:19-cv-00691 (W.D. Okla. Nov. 6, 2019).
- Johnson v. Griffin, No. 3:22-cv-00295 (M.D. Tenn. Mar. 3, 2023).
Show 10 more citing cases
- V.Z.Z.R. v. Tallcastle, No. 2:22-cv-00154 (D. Utah May 12, 2023).
- Flint v. Armstrong, No. 1:22-cv-00123 (D. Utah July 7, 2023).
- Christine Seward v. Charles Richards & a., 265 A.3d 9 (N.H. 2021).published
- Kinzie Advanced Polymers, LLC v. Calyx Containers, LLC, No. 1:24-cv-01887, 2025 WL 2418908 (N.D. Ohio Aug. 21, 2025).
- Harrison, No. 1:25-cv-00355 (W.D. Tex. Oct. 6, 2025).
- Alexander Ross v. Robinson, Hoover & Fudge, PLLC, 173 F.4th 745 (6th Cir. 2026).published
At page 280 Seizing cash after airport search and subsequent forfeiture proceedings17 citing casesand their carry-on bags at the San Juan airport in Puerto Rico. They found almost $97,000 in cash. Fiore explained to DEA agents in San Juan that she and…
- Tricarichi Vs. CoÖperatieve Rabobank, U.A., 135 Nev. 87 (2019).published
- Eighteen Seventy v. Jayson, 32 F.4th 956 (10th Cir. 2022).published
- Flint v. Armstrong, No. 1:22-cv-00123 (D. Utah July 7, 2023).
- Alexander Ross v. Robinson, Hoover & Fudge, PLLC, 173 F.4th 745 (6th Cir. 2026).published
- Burri Law Pa v. William Skurla, 35 F.4th 1207 (9th Cir. 2022).published
- M. C. v. Quest Global, Inc., 537 P.3d 571 (Or. Ct. App. 2023).published
- Rogers v. City of Hobart, Indiana, 491 F. Supp. 3d 351 (N.D. Ill. 2020).published
- Elzeftawy v. Pernix Grp. Inc., No. 1:18-cv-06971 (N.D. Ill. Sept. 20, 2021).
- Savu v. Purolite Co., No. 8:22-cv-01149 (D. Md. Feb. 21, 2023).
- Freeman v. HSBC Holdings PLC, 413 F. Supp. 3d 67 (E.D.N.Y. 2019).published
Show 6 more citing cases
- Winston v. Zaehringer (JRG3), No. 1:19-cv-00216, 2020 WL 3259531 (E.D. Tenn. June 16, 2020).
- Sarafin v. Bridgestone HosePower LLC, No. 2:23-cv-00203 (N.D. Tex. Mar. 1, 2024).
- Pierce v. Aircraft Fin. Corp., LLC, 512 F. Supp. 3d 753 (S.D. Tex. 2021).published
- AVT California v. Arrow Recycling Solutions, No. 2:19-cv-00939 (D. Utah Sept. 18, 2020).
- Brandon Briskin v. Shopify, Inc., 135 F.4th 739 (9th Cir. 2025).published
At page 282 Ninth circuit's finding on personal jurisdiction in nevada15 citing casesBecause we resolve the case on jurisdictional grounds, we do not decide whether venue was proper in Nevada.
- Vora v. C4 Therapeutics, Inc, No. 1:22-cv-00640 (D. Colo. Aug. 1, 2023).
- Harrison, No. 1:25-cv-00355 (W.D. Tex. Oct. 6, 2025).
- M. C. v. Quest Global, Inc., 537 P.3d 571 (Or. Ct. App. 2023).published
- Dental Dynamics v. Jolly Dental Grp., 946 F.3d 1223 (10th Cir. 2020).published
- Shanika K. Lewis v. Conagra Brands, Inc. f/k/a & Successor in Interest to Conagra Foods/ Shanika K. Lewis v. DS Containers, Inc. & PSMT, LLC d/b/a Pricesmart, 2023 VI Super 30P (2023).published
- Page v. Response Mktg. Grp., LLC, No. 4:22-cv-06194 (N.D. Cal. Jan. 4, 2023).
- Vora v. Dionne, No. 1:22-cv-00572, 2023 WL 1784227 (D. Colo. Feb. 6, 2023).
- White Buffalo Env't, Inc. v. Hungry Horse, LLC, No. 1:21-cv-00175 (D.N.M. Feb. 25, 2021).
- White Buffalo Env't, Inc. v. Hungry Horse, LLC, No. 4:20-cv-00461 (N.D. Okla. Feb. 25, 2021).
- Dennis v. Good Deal Charlie, Inc., No. 4:20-cv-00295, 2021 WL 815841 (N.D. Okla. Mar. 3, 2021).
Show 4 more citing cases
- Dimante v. Schnayderman, No. 1:23-cv-15110 (N.D. Ill. Nov. 22, 2024).
- Reed v. Ascension Health, No. 4:24-cv-00419 (N.D. Okla. May 9, 2025).
- Unnikrishnan v. IOT.nxt Americas USA, Inc., No. 4:22-cv-00870 (E.D. Tex. July 28, 2025).
- Hufft, No. 4:25-cv-00057 (N.D. Okla. Sept. 29, 2025).
At page 278 Determining sufficient connection to forum for jurisdiction10 citing casesmere injury to a forum resident” is insufficient
- Thornton v. Takata Corp., No. 2:16-cv-01986 (N.D. Ala. Feb. 13, 2020).
- Castel S.A. v. Christopher A. Wilson, No. 2:19-cv-09336 (C.D. Cal. July 15, 2020).
- Guzman v. Cruise Yacht Op Co. Ltd., No. 1:22-cv-21123 (S.D. Fla. Mar. 20, 2023).
- Revelation Yogurt, LLC v. Kline Law Grp., P.C., No. 2:20-cv-11195 (E.D. Mich. May 6, 2021).
- Vesi Inc. v. Vera Bradley Designs Inc., No. 1:19-cv-00696 (S.D. Ohio Sept. 2, 2020).
- McCarty v. Doe, No. 1:22-cv-12091 (D. Mass. Aug. 15, 2024).
- Fifteen Twenty-One Second Avenue Condo. Ass'n v. Viracon LLC, No. 2:23-cv-01999 (W.D. Wash. June 25, 2024).
- Fifteen Twenty-One Second Avenue Condo. Ass'n v. Viracon LLC, No. 2:23-cv-01999 (W.D. Wash. Sept. 24, 2024).
- Fitzgerald v. Little, No. 2:24-cv-00898 (D. Vt. June 17, 2025).
- Fitzgerald v. Little, No. 2:25-cv-11906 (D.N.J. June 17, 2025).
134 S. Ct. at 1118 Examining relationship for personal jurisdiction over defendant6 citing cases
- Livingston v. Hoffmann-La Roche Inc., 293 F. Supp. 3d 760 (E.D. Ill. 2018).published
- Midamines Sprl Ltd. (Ill. Corp.) v. KBC Bank N.V., No. 1:16-cv-09429 (N.D. Ill. Dec. 15, 2017).
- Midamines Sprl Ltd. (Ill. Corp.) v. KBC Bank N.V., No. 1:16-cv-09429 (N.D. Ill. Jan. 16, 2018).
- Livingston v. Hoffmann-La Roche, Inc, No. 1:17-cv-07650 (N.D. Ill. Mar. 7, 2018).
- Brennan v. 42 Tech. LTD., No. 1:17-cv-12475 (D. Mass. Apr. 17, 2018).
- Sw. v. 19th Jud. Dist., 2024 MT 320.published
At page 281 Lack of personal jurisdiction based on interstate actions6 citing casesdescribing the court of appeals’ rationale
- in Re Fed. Corp., No. 13-16-00219-CV (Tex. App.—Corpus Christi Sept. 1, 2016).published
- in Re Fed. Corp., No. 13-16-00219-CV (Tex. App.—Corpus Christi Nov. 1, 2016).published
- Ariel Investments, LLC v. Ariel Capital Advisors LLC, 881 F.3d 520 (7th Cir. 2018).published
- M. C. v. Quest Global, Inc., 537 P.3d 571 (Or. Ct. App. 2023).published
- Health & Hosp. Corp. of Marion Cty. v. Talevski, 599 U.S. 166 (2023).published
- Christie v. Nat'l Inst. for Newman Studies, 258 F. Supp. 3d 494 (D.N.J. 2017).published
At page 294 Reiterating minimum contacts inquiry protecting nonresident defendant5 citing cases
- Ncontracts, LLC v. Holmberg, No. 1:22-cv-01608 (E.D. Cal. Dec. 15, 2022).
- JRS Partners, GP v. Leech Tishman Fuscaldo & Lampl, LLC, No. 3:19-cv-00469, 2020 WL 5877131 (M.D. Tenn. Oct. 2, 2020).
- Shelter Mut. Ins. Co. v. Bissell Homecare, Inc., No. 3:20-cv-00813 (M.D. Tenn. Apr. 28, 2021).
- Ever-Seal, Inc. v. DuraSeal, Inc., No. 3:22-cv-00365 (M.D. Tenn. Aug. 23, 2022).
- Ncontracts, LLC v. Holmberg, No. 3:22-cv-00868, 2022 WL 17724148 (M.D. Tenn. Dec. 15, 2022).
188 L. Ed. 2d at 74 cited at this page1 citing case
- Hickman v. TL Transp., LLC, 317 F. Supp. 3d 890 (E.D. Pa. 2018).published
v.
Gina FIORE Et Al.
[*279] This case asks us to decide whether a court in Nevada may exercise personal jurisdiction over a defendant on the basis that he knew his allegedly tortious conduct in Georgia would delay the return of funds to plaintiffs with connections to Nevada. Because the defendant had no other contacts with Nevada, and because a plaintiff's contacts with the forum State cannot be "decisive in determining whether the defendant's due process rights are violated," Rush v. Savchuk, 444 U.S. 320 , 332, 100 S.Ct. 571 , 62 L.Ed.2d 516 (1980), we hold that the court in Nevada may not exercise personal jurisdiction under these circumstances.
I
Petitioner Anthony Walden serves as a police officer for the city of Covington, Georgia. In August 2006, petitioner was working at the Atlanta Hartsfield-Jackson Airport as a deputized agent of the Drug Enforcement Administration (DEA). As part of a task force, petitioner conducted investigative stops and other law enforcement functions in support of the DEA's airport drug interdiction program.
On August 8, 2006, Transportation Security Administration agents searched respondents Gina Fiore and Keith Gipson[*280] and their carry-on bags at the San Juan airport in Puerto Rico. They found almost $97,000 in cash. Fiore explained to DEA agents in San Juan that she and Gipson had been gambling at a casino known as the El San Juan, and that they had residences in both California and Nevada (though they provided only California identification). After respondents were cleared for departure, a law enforcement official at the San Juan airport notified petitioner's task force in Atlanta that respondents had boarded a plane for Atlanta, where they planned to catch a connecting flight to Las Vegas, Nevada.
When respondents arrived in Atlanta, petitioner and another DEA agent approached them at the departure gate for their flight to Las Vegas. In response to petitioner's questioning, Fiore explained that she and Gipson were professional gamblers. Respondents maintained that the cash they were carrying was their gambling " 'bank' " and winnings. App. 15, 24. After using a drug-sniffing dog to perform a sniff test, petitioner seized the cash. [1] Petitioner advised respondents that their funds would be returned if they later proved a legitimate source for the cash. Respondents then boarded their plane.
After respondents departed, petitioner moved the cash to a secure location and the matter was forwarded to DEA headquarters. The next day, petitioner received a phone call from respondents' attorney in Nevada seeking return of the funds. On two occasions over the next month, petitioner also received documentation from the attorney regarding the legitimacy of the funds.
At some point after petitioner seized the cash, he helped draft an affidavit to show probable cause for forfeiture of the funds and forwarded that affidavit to a United States[*281] Attorney's Office in Georgia. [2] According[*1120] to respondents, the affidavit was false and misleading because petitioner misrepresented the encounter at the airport and omitted exculpatory information regarding the lack of drug evidence and the legitimate source of the funds. In the end, no forfeiture complaint was filed, and the DEA returned the funds to respondents in March 2007.
Respondents filed suit against petitioner in the United States District Court for the District of Nevada, seeking money damages under Bivens v. Six Unknown Fed. Narcotics Agents, 403 U.S. 388 , 91 S.Ct. 1999 , 29 L.Ed.2d 619 (1971). Respondents alleged that petitioner violated their Fourth Amendment rights by (1) seizing the cash without probable cause; (2) keeping the money after concluding it did not come from drug-related activity; (3) drafting and forwarding a probable cause affidavit to support a forfeiture action while knowing the affidavit contained false statements; (4) willfully seeking forfeiture while withholding exculpatory information; and (5) withholding that exculpatory information from the United States Attorney's Office.
The District Court granted petitioner's motion to dismiss. Relying on this Court's decision in Calder v. Jones, 465 U.S. 783 , 104 S.Ct. 1482 , 79 L.Ed.2d 804 (1984), the court determined that petitioner's search of respondents and his seizure of the cash in Georgia did not establish a basis to exercise personal jurisdiction in Nevada. The court concluded that even if petitioner caused harm to respondents in Nevada while knowing they lived in Nevada, that fact alone did not confer jurisdiction. Because the court dismissed the complaint for lack of personal jurisdiction, it did not determine whether venue was proper.
[*282] On appeal, a divided panel of the United States Court of Appeals for the Ninth Circuit reversed. The Court of Appeals assumed the District Court had correctly determined that petitioner's search and seizure in Georgia could not support exercise of jurisdiction in Nevada. The court held, however, that the District Court could properly exercise jurisdiction over "the false probable cause affidavit aspect of the case." 688 F.3d 558 , 577 (2011). According to the Court of Appeals, petitioner "expressly aimed" his submission of the allegedly false affidavit at Nevada by submitting the affidavit with knowledge that it would affect persons with a "significant connection" to Nevada. [3] Id., at 581 . After determining that the delay in returning the funds to respondents caused them "foreseeable harm" in Nevada and that the exercise of personal jurisdiction over petitioner was otherwise reasonable, the court found the District Court's exercise of personal jurisdiction to be proper. [4] Id., at 582, 585 . The Ninth Circuit denied rehearing en banc, with eight judges, in[*1121] two separate opinions, dissenting. Id., at 562, 568 .
We granted certiorari to decide whether due process permits a Nevada court to exercise jurisdiction over petitioner. 568 U.S. ----, 133 S.Ct. 1493 , 185 L.Ed.2d 547 (2013). We hold that it does not and therefore reverse. [5]
[*283] II
A
"Federal courts ordinarily follow state law in determining the bounds of their jurisdiction over persons." Daimler AG v. Bauman, 571 U.S. ----, ----, 134 S.Ct. 746 , 753, 187 L.Ed.2d 624 (2014). This is because a federal district court's authority to assert personal jurisdiction in most cases is linked to service of process on a defendant "who is subject to the jurisdiction of a court of general jurisdiction in the state where the district court is located." Fed. Rule of Civ. Proc. 4(k)(1)(A). Here, Nevada has authorized its courts to exercise jurisdiction over persons "on any basis not inconsistent with ... the Constitution of the United States." Nev.Rev.Stat. § 14.065 (2011). Thus, in order to determine whether the Federal District Court in this case was authorized to exercise jurisdiction over petitioner, we ask whether the exercise of jurisdiction "comports with the limits imposed by federal due process" on the State of Nevada. Daimler, supra, at ----, 134 S.Ct., at 753 .
B
1
The Due Process Clause of the Fourteenth Amendment constrains a State's authority to bind a nonresident defendant to a judgment of its courts. World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 , 291, 100 S.Ct. 559 , 62 L.Ed.2d 490 (1980). Although a nonresident's physical presence within the territorial jurisdiction of the court is not required, the nonresident generally must have "certain minimum contacts ... such that the maintenance of the suit does not offend 'traditional notions of fair play and substantial justice.' " International Shoe Co. v. Washington, 326 U.S. 310 , 316, 66 S.Ct. 154 , 90 L.Ed. 95 (1945) (quoting Milliken v. Meyer, 311 U.S. 457 , 463, 61 S.Ct. 339 , 85 L.Ed. 278 (1940) ).
This case addresses the "minimum contacts" necessary to create specific jurisdiction. [6] The inquiry whether a forum[*284] State may assert specific jurisdiction over a nonresident defendant " focuses on 'the relationship among the defendant, the forum, and the litigation.' " Keeton v. Hustler Magazine, Inc., 465 U.S. 770 , 775, 104 S.Ct. 1473 , 79 L.Ed.2d 790 (1984) (quoting Shaffer v. Heitner, 433 U.S. 186 , 204, 97 S.Ct. 2569 , 53 L.Ed.2d 683 (1977) ). For a State to exercise jurisdiction consistent with due process, the defendant's suit-related conduct must create a substantial connection with the forum State. Two related[*1122] aspects of this necessary relationship are relevant in this case.
First, the relationship must arise out of contacts that the "defendant himself " creates with the forum State. Burger King Corp. v. Rudzewicz, 471 U.S. 462 , 475, 105 S.Ct. 2174 , 85 L.Ed.2d 528 (1985). Due process limits on the State's adjudicative authority principally protect the liberty of the nonresident defendant-not the convenience of plaintiffs or third parties. See World-Wide Volkswagen Corp., supra, at 291-292, 100 S.Ct. 559 . We have consistently rejected attempts to satisfy the defendant-focused "minimum contacts" inquiry by demonstrating contacts between the plaintiff (or third parties) and the forum State. See Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 , 417, 104 S.Ct. 1868 , 80 L.Ed.2d 404 (1984) ("[The] unilateral activity of another party or a third person is not an appropriate consideration when determining whether a defendant has sufficient contacts with a forum State to justify an assertion of jurisdiction"). We have thus rejected a plaintiff's argument that a Florida court could exercise personal jurisdiction over a trustee in Delaware based solely on the contacts of the trust's settlor, who was domiciled in Florida and had executed powers of appointment there. Hanson v. Denckla, 357 U.S. 235 , 253-254, 78 S.Ct. 1228 , 2 L.Ed.2d 1283 (1958). We have likewise held that Oklahoma courts could not exercise personal jurisdiction[*285] over an automobile distributor that supplies New York, New Jersey, and Connecticut dealers based only on an automobile purchaser's act of driving it on Oklahoma highways. World-Wide Volkswagen Corp., supra, at 298, 100 S.Ct. 559 . Put simply, however significant the plaintiff's contacts with the forum may be, those contacts cannot be "decisive in determining whether the defendant ' s due process rights are violated." Rush, 444 U.S., at 332 , 100 S.Ct. 571 .
Second, our "minimum contacts" analysis looks to the defendant's contacts with the forum State itself, not the defendant's contacts with persons who reside there. See, e.g., International Shoe, supra, at 319, 66 S.Ct. 154 (Due process "does not contemplate that a state may make binding a judgment in personam against an individual ... with which the state has no contacts, ties, or relations"); Hanson, supra, at 251 , 78 S.Ct. 1228 ("However minimal the burden of defending in a foreign tribunal, a defendant may not be called upon to do so unless he has had the 'minimal contacts' with that State that are a prerequisite to its exercise of power over him"). Accordingly, we have upheld the assertion of jurisdiction over defendants who have purposefully "reach[ed] out beyond" their State and into another by, for example, entering a contractual relationship that "envisioned continuing and wide-reaching contacts" in the forum State, Burger King, supra, at 479-480, 105 S.Ct. 2174 , or by circulating magazines to "deliberately exploi[t]" a market in the forum State, Keeton, supra, at 781 , 104 S.Ct. 1473 . And although physical presence in the forum is not a prerequisite to jurisdiction, Burger King,supra, at 476, 105 S.Ct. 2174 , physical entry into the State-either by the defendant in person or through an agent, goods, mail, or some other means-is certainly a relevant contact. See, e.g., Keeton, supra, at 773-774 , 104 S.Ct. 1473 .
But the plaintiff cannot be the only link between the defendant and the forum. Rather, it is the defendant's conduct that must form the necessary connection with the forum State that is the basis for its jurisdiction over him. See[*286] Burger King, supra, at 478, 105 S.Ct. 2174 ("If the question is whether an individual's contract[*1123] with an out-of-state party alone can automatically establish sufficient minimum contacts in the other party's home forum, we believe the answer clearly is that it cannot"); Kulko v. Superior Court of Cal., City and County of San Francisco, 436 U.S. 84 , 93, 98 S.Ct. 1690 , 56 L.Ed.2d 132 (1978) (declining to "find personal jurisdiction in a State ... merely because [the plaintiff in a child support action] was residing there"). To be sure, a defendant's contacts with the forum State may be intertwined with his transactions or interactions with the plaintiff or other parties. But a defendant's relationship with a plaintiff or third party, standing alone, is an insufficient basis for jurisdiction. See Rush, supra, at 332 , 100 S.Ct. 571 ("Naturally, the parties' relationships with each other may be significant in evaluating their ties to the forum. The requirements of International Shoe, however, must be met as to each defendant over whom a state court exercises jurisdiction"). Due process requires that a defendant be haled into court in a forum State based on his own affiliation with the State, not based on the "random, fortuitous, or attenuated" contacts he makes by interacting with other persons affiliated with the State. Burger King, 471 U.S., at 475 , 105 S.Ct. 2174 (internal quotation marks omitted).
2
These same principles apply when intentional torts are involved. In that context, it is likewise insufficient to rely on a defendant's "random, fortuitous, or attenuated contacts" or on the "unilateral activity" of a plaintiff. Ibid. (same). A forum State's exercise of jurisdiction over an out-of-state intentional tortfeasor must be based on intentional conduct by the defendant that creates the necessary contacts with the forum.
Calder v. Jones, 465 U.S. 783 , 104 S.Ct. 1482 , 79 L.Ed.2d 804 , illustrates the application of these principles. In Calder, a California actress brought a libel suit in California state court against a reporter and an editor, both of whom worked for the National Enquirer at[*287] its headquarters in Florida. The plaintiff's libel claims were based on an article written and edited by the defendants in Florida for publication in the National Enquirer, a national weekly newspaper with a California circulation of roughly 600,000.
We held that California's assertion of jurisdiction over the defendants was consistent with due process. Although we recognized that the defendants' activities "focus[ed]" on the plaintiff, our jurisdictional inquiry "focuse[d] on 'the relationship among the defendant, the forum, and the litigation.' " Id., at 788 , 104 S.Ct. 1482 (quoting Shaffer, 433 U.S., at 204 , 97 S.Ct. 2569 ). Specifically, we examined the various contacts the defendants had created with California (and not just with the plaintiff) by writing the allegedly libelous story.
We found those forum contacts to be ample: The defendants relied on phone calls to "California sources" for the information in their article; they wrote the story about the plaintiff's activities in California; they caused reputational injury in California by writing an allegedly libelous article that was widely circulated in the State; and the "brunt" of that injury was suffered by the plaintiff in that State. 465 U.S., at 788-789, 104 S.Ct. 1482 ."In sum, California [wa]s the focal point both of the story and of the harm suffered." Id., at 789 , 104 S.Ct. 1482 . Jurisdiction over the defendants was "therefore proper in California based on the 'effects' of their Florida conduct in California." Ibid.
The crux of Calder was that the reputation-based "effects" of the alleged libel[*1124] connected the defendants to California, not just to the plaintiff. The strength of that connection was largely a function of the nature of the libel tort. However scandalous a newspaper article might be, it can lead to a loss of reputation only if communicated to (and read and understood by) third persons. See Restatement (Second) of Torts § 577, Comment b (1976); see also ibid. ("[R]eputation is the estimation in which one's character is held by his neighbors or associates"). Accordingly, the reputational injury[*288] caused by the defendants' story would not have occurred but for the fact that the defendants wrote an article for publication in California that was read by a large number of California citizens. Indeed, because publication to third persons is a necessary element of libel, see id ., § 558, the defendants' intentional tort actually occurred in california. keeton, 465 U.S., at 777, 104 S.ct. 1473 ("the tort of libel is generally held to occur wherever the offending material is circulated"). In this way, the "effects" caused by the defendants' article- i.e., the injury to the plaintiff's reputation in the estimation of the California public-connected the defendants' conduct to California, not just to a plaintiff who lived there. That connection, combined with the various facts that gave the article a California focus, sufficed to authorize the California court's exercise of jurisdiction. [7]
III
Applying the foregoing principles, we conclude that petitioner lacks the "minimal contacts" with Nevada that are a prerequisite to the exercise of jurisdiction over him. Hanson, 357 U.S., at 251 , 78 S.Ct. 1228 . It is undisputed that no part of petitioner's course of conduct occurred in Nevada. Petitioner approached, questioned, and searched respondents, and seized the cash at issue, in the Atlanta airport. It is alleged that petitioner later helped draft a "false probable cause affidavit" in Georgia and forwarded that affidavit to a United States Attorney's Office in Georgia to support a potential action for forfeiture of the seized funds. 688 F.3d, at 563 .
[*289] Petitioner never traveled to, conducted activities within, contacted anyone in, or sent anything or anyone to Nevada. In short, when viewed through the proper lens-whether the defendant ' s actions connect him to the forum -petitioner formed no jurisdictionally relevant contacts with Nevada.
The Court of Appeals reached a contrary conclusion by shifting the analytical focus from petitioner's contacts with the forum to his contacts with respondents. See Rush, 444 U.S., at 332 , 100 S.Ct. 571 . Rather than assessing petitioner's own contacts with Nevada, the Court of Appeals looked to petitioner's knowledge of respondents' "strong forum connections." 688 F.3d, at 577-579, 581 . In the court's view, that knowledge, combined with its conclusion that respondents suffered foreseeable harm in Nevada, satisfied the "minimum contacts" inquiry. [8] Id., at 582 .
[*1125] This approach to the "minimum contacts" analysis impermissibly allows a plaintiff's contacts with the defendant and forum to drive the jurisdictional analysis. Petitioner's actions in Georgia did not create sufficient contacts with Nevada simply because he allegedly directed his conduct at plaintiffs whom he knew had Nevada connections. Such reasoning improperly attributes a plaintiff's forum connections to the defendant and makes those connections "decisive" in the jurisdictional analysis. See Rush, supra, at 332 , 100 S.Ct. 571 . It also obscures the reality that none of petitioner's challenged conduct had anything to do with Nevada itself.
Relying on Calder, respondents emphasize that they suffered the "injury" caused by petitioner's allegedly tortious conduct ( i.e., the delayed return of their gambling funds) while they were residing in the forum. Brief for Respondents 14. This emphasis is likewise misplaced. As previously[*290] noted, Calder made clear that mere injury to a forum resident is not a sufficient connection to the forum. Regardless of where a plaintiff lives or works, an injury is jurisdictionally relevant only insofar as it shows that the defendant has formed a contact with the forum State. The proper question is not where the plaintiff experienced a particular injury or effect but whether the defendant's conduct connects him to the forum in a meaningful way.
Respondents' claimed injury does not evince a connection between petitioner and Nevada. Even if we consider the continuation of the seizure in Georgia to be a distinct injury, it is not the sort of effect that is tethered to Nevada in any meaningful way. Respondents (and only respondents) lacked access to their funds in Nevada not because anything independently occurred there, but because Nevada is where respondents chose to be at a time when they desired to use the funds seized by petitioner. Respondents would have experienced this same lack of access in California, Mississippi, or wherever else they might have traveled and found themselves wanting more money than they had. Unlike the broad publication of the forum-focused story in Calder, the effects of petitioner's conduct on respondents are not connected to the forum State in a way that makes those effects a proper basis for jurisdiction. [9]
[*291] The Court of Appeals pointed to other possible contacts with Nevada, each ultimately unavailing. Respondents' Nevada attorney contacted petitioner in Georgia, but that is precisely the sort of "unilateral activity" of a third party that "cannot satisfy the requirement of contact with the forum State." Hanson, 357 U.S., at 253 , 78 S.Ct. 1228 . Respondents allege that[*1126] some of the cash seized in Georgia "originated" in Nevada, but that attenuated connection was not created by petitioner, and the cash was in Georgia, not Nevada, when petitioner seized it. Finally, the funds were eventually returned to respondents in Nevada, but petitioner had nothing to do with that return (indeed, it seems likely that it was respondents' unilateral decision to have their funds sent to Nevada).
* * *
Well-established principles of personal jurisdiction are sufficient to decide this case. The proper focus of the "minimum contacts" inquiry in intentional-tort cases is " 'the relationship among the defendant, the forum, and the litigation.' " Calder, 465 U.S., at 788 , 104 S.Ct. 1482 . And it is the defendant, not the plaintiff or third parties, who must create contacts with the forum State. In this case, the application of those principles is clear: Petitioner's relevant conduct occurred entirely in Georgia, and the mere fact that his conduct affected plaintiffs with connections to the forum State does not suffice to authorize jurisdiction. We therefore reverse the judgment of the Court of Appeals.
It is so ordered.
Respondents allege that the sniff test was "at best, inconclusive," and there is no indication in the pleadings that drugs or drug residue were ever found on or with the cash. App. 21.
The alleged affidavit is not in the record. Because this case comes to us at the motion-to-dismiss stage, we take respondents' factual allegations as true, including their allegations regarding the existence and content of the affidavit.
The allegations in the complaint suggested to the Court of Appeals that petitioner "definitely knew, at some point after the seizure but before providing the alleged false probable cause affidavit, that [respondents] had a significant connection to Nevada." 688 F.3d, at 578 .
Judge Ikuta dissented. In her view, the "false affidavit/forfeiture proceeding aspect" over which the majority found jurisdiction proper was not raised as a separate claim in the complaint, and she found it "doubtful that such a constitutional tort even exists." Id. , at 593. After the court denied rehearing en banc, the majority explained in a postscript that it viewed the filing of the false affidavit, which effected a "continued seizure" of the funds, as a separate Fourth Amendment violation. Id., at 588-589 . Petitioner does not dispute that reading here.
We also granted certiorari on the question whether Nevada is a proper venue for the suit under 28 U.S.C. § 1391 (b)(2). Because we resolve the case on jurisdictional grounds, we do not decide whether venue was proper in Nevada.
"Specific" or "case-linked" jurisdiction "depends on an 'affiliatio[n] between the forum and the underlying controversy' " ( i.e., an "activity or an occurrence that takes place in the forum State and is therefore subject to the State's regulation"). Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. ----, ----, 131 S.Ct. 2846 , 2851, 180 L.Ed.2d 796 (2011). This is in contrast to "general" or "all purpose" jurisdiction, which permits a court to assert jurisdiction over a defendant based on a forum connection unrelated to the underlying suit ( e.g., domicile). Respondents rely on specific jurisdiction only.
The defendants in Calder argued that no contacts they had with California were sufficiently purposeful because their employer was responsible for circulation of the article. See Calder v. Jones, 465 U.S. 783 , 789, 104 S.Ct. 1482 , 79 L.Ed.2d 804 (1984). We rejected that argument. Even though the defendants did not circulate the article themselves, they "expressly aimed" "their intentional, and allegedly tortious, actions" at California because they knew the National Enquirer "ha[d] its largest circulation" in California, and that the article would "have a potentially devastating impact" there. Id., at 789-790 , 104 S.Ct. 1482 .
Respondents propose a substantially similar analysis. They suggest that "a defendant creates sufficient minimum contacts with a forum when he (1) intentionally targets (2) a known resident of the forum (3) for imposition of an injury (4) to be suffered by the plaintiff while she is residing in the forum state." Brief for Respondents 26-27.
Respondents warn that if we decide petitioner lacks minimum contacts in this case, it will bring about unfairness in cases where intentional torts are committed via the Internet or other electronic means ( e.g., fraudulent access of financial accounts or "phishing" schemes). As an initial matter, we reiterate that the "minimum contacts" inquiry principally protects the liberty of the nonresident defendant, not the interests of the plaintiff. World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 , 291-292, 100 S.Ct. 559 , 62 L.Ed.2d 490 (1980). In any event, this case does not present the very different questions whether and how a defendant's virtual "presence" and conduct translate into "contacts" with a particular State. To the contrary, there is no question where the conduct giving rise to this litigation took place: Petitioner seized physical cash from respondents in the Atlanta airport, and he later drafted and forwarded an affidavit in Georgia. We leave questions about virtual contacts for another day.