purposeful availment requirement in Washington

2010The purposeful availment requirement “ensures that a defendant will not be haled into a jurisdiction solely as a result of‘random,’ ‘fortuitous,’ or ‘attenuated’ contacts.” Burger King, 471 U.S. at 475 (quoting Keeton, 465 U.S. at 774 ; World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 299 , 100 S. Ct. 559 , 62 L.

2010The purposeful availment requirement "ensures *150 that a defendant will not be hailed into a jurisdiction solely as a result of `random', `fortuitous', or `attenuated' contacts." Burger King Corp., 471 U.S. at 475 , 105 S.Ct. 2174 . ¶ 34 A plaintiff can establish purposeful availment by showing the initiation of a transaction outside the state "in contemplation that some phase of it will take place in the forum state." CTVC, 82 Wash.App. at 711 , 919 P.2d 1243 .

2016This ensures notice and fairness: "When a corporation 'purposefully avails itself of the privilege of conducting activities within the forum State,' it has clear notice that it is subject to 25 State v. LG Electronics, eta!., No. 91391-9 (Gordon McCloud, J., concurring in part/dissenting in part) suit there, and can act to alleviate the risk of burdensome litigation by procuring insurance, passing the expected costs on to customers, or, if the risks are too great, severing its connection with the State." Id. at 297 (citation omitted) (quoting Hanson, 357 U.S. at 253 ).

2016This ensures notice and fairness: “When a corporation ‘purposefully avails itself of the privilege of conducting activities within the forum State,’ it has clear notice that it is subject to suit there, and can act to alleviate the risk of burdensome litigation by procuring insurance, passing the expected costs on to customers, or, if the risks are too great, severing its connection with the State.” Id. at 297 (citation omitted) (quoting Hanson, 357 U.S. at 253 ). ¶68 The State’s complaint failed to allege such conduct by Defendants in Washington.

2015Holdings, Inc., 175 Wn.

2015Holdings, Inc., 175 Wn.

2010The purposeful availment requirement "ensures *150 that a defendant will not be hailed into a jurisdiction solely as a result of `random', `fortuitous', or `attenuated' contacts." Burger King Corp., 471 U.S. at 475 , 105 S.Ct. 2174 . ¶ 34 A plaintiff can establish purposeful availment by showing the initiation of a transaction outside the state "in contemplation that some phase of it will take place in the forum state." CTVC, 82 Wash.App. at 711 , 919 P.2d 1243 .

2010The purposeful availment requirement "ensures *150 that a defendant will not be hailed into a jurisdiction solely as a result of `random', `fortuitous', or `attenuated' contacts." Burger King Corp., 471 U.S. at 475 , 105 S.Ct. 2174 . ¶ 34 A plaintiff can establish purposeful availment by showing the initiation of a transaction outside the state "in contemplation that some phase of it will take place in the forum state." CTVC, 82 Wash.App. at 711 , 919 P.2d 1243 .

2017It noted 16 No. 74241-8-1/17 that the purposeful availment test is "most often used in suits sounding in contract," while the purposeful direction test is "most often used in suits sounding in tort." Id. (emphasis added).

2017Id.

2017Pruczinski v. Ashby, 185 Wn.

2010The purposeful availment requirement “ensures that a defendant will not be haled into a jurisdiction solely as a result of‘random,’ ‘fortuitous,’ or ‘attenuated’ contacts.” Burger King, 471 U.S. at 475 (quoting Keeton, 465 U.S. at 774 ; World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 299 , 100 S. Ct. 559 , 62 L.

2010The purposeful availment requirement “ensures that a defendant will not be haled into a jurisdiction solely as a result of‘random,’ ‘fortuitous,’ or ‘attenuated’ contacts.” Burger King, 471 U.S. at 475 (quoting Keeton, 465 U.S. at 774 ; World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 299 , 100 S. Ct. 559 , 62 L.

2010And a defendant may purposefully act in the forum state even though the defendant did not initiate contact, "'if a business relationship subsequently arises.'" CTVC, 82 Wash.App. at 711 , 919 P.2d 1243 (quoting Sorb Oil Corp. v. Batalla Corp., 32 Wash.App. 296, 299 , 647 P.2d 514 (1982)). ¶ 35 However, the mere execution of a contract with a resident does not establish purposeful availment.

2010And a defendant may purposefully act in the forum state even though the defendant did not initiate contact, "'if a business relationship subsequently arises.'" CTVC, 82 Wash.App. at 711 , 919 P.2d 1243 (quoting Sorb Oil Corp. v. Batalla Corp., 32 Wash.App. 296, 299 , 647 P.2d 514 (1982)). ¶ 35 However, the mere execution of a contract with a resident does not establish purposeful availment.

2010The purposeful availment requirement “ensures that a defendant will not be haled into a jurisdiction solely as a result of‘random,’ ‘fortuitous,’ or ‘attenuated’ contacts.” Burger King, 471 U.S. at 475 (quoting Keeton, 465 U.S. at 774 ; World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 299 , 100 S. Ct. 559 , 62 L.