purposeful availment inquiry in California

2026Pitt and Mondo Bongo presented evidence of purposeful availment “‘“The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs [its] activities toward the forum so that [it] should expect, by virtue of the benefit [it] receives, to be subject to the court’s jurisdiction based on” [its] contacts with the forum.’” ( Snowney, supra, 35 Cal.4th at pp. 1062-1063.) Thus, purposeful availment occurs where a nonresident defendant “(1) purposefully directs its activities at the forum s

2026Pitt and Mondo Bongo presented evidence of purposeful availment “‘“The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs [its] activities toward the forum so that [it] should expect, by virtue of the benefit [it] receives, to be subject to the court’s jurisdiction based on” [its] contacts with the forum.’” ( Snowney, supra, 35 Cal.4th at pp. 1062-1063.) Thus, purposeful availment occurs where a nonresident defendant “(1) purposefully directs its activities at the forum s

2025(See Burger King, supra, 471 U.S. at p. 475 [The purposeful availment requirement “ensures that a defendant will not be haled into a jurisdiction solely as a result of ‘random,’ ‘fortuitous,’ or ‘attenuated’ contacts [citations], or of the ‘unilateral activity of another party or a third person’ [citations]”].) Also, each of the contracts has a choice of law clause that selects a forum other than California as its governing law.

2023(See Khan v. Superior Court (1988) 204 Cal.App.3d 1168, 1178 [jurisdiction present where husband “intentionally established numerous contacts” and “diverse links with the state run[ning] the gamut from the personal to the professional to the commercial.”].) Even if we hesitated to exercise general jurisdiction over Robert, we could not but conclude he had sufficient contacts to justify specific jurisdiction over the marital dissolution. “‘The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully an

2026Dib alleged the defendants are “the alter-egos, co-conspirators, and agents of [Daher]” and that the conspirators have such a “unity of interest and ownership that separate personalities of these entities and the individuals no longer exist.” However, Dib provided no specific factual allegation, let alone evidence, Hamdan is an alter ego of K&A such that K&A’s property could also be Hamdan’s property. “‘[T]he defendant’s knowledge and intent in committing the tortious activity’ [is] the very focus of the purposeful availment requirement.” (Pavlovich, supra, 29 Cal.4th at p. 272 .) There is no

2025Purposeful Availment “ ‘The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs his activities toward the forum so that he should expect, by virtue of the benefit he receives, to be subject to the court’s jurisdiction based on’ his contacts with the forum. [Citation.] Thus, the ‘ “purposeful availment” requirement ensures that a defendant will not be haled into a jurisdiction solely as a result of “random,” “fortuitous,” or “attenuated” contacts [citations], or of the “uni

2025(See Ford, supra, 592 U.S. at p. 359 [a defendant purposefully avails itself of the forum’s benefits if it deliberately reaches out beyond its home by exploiting a market in the forum state]; Snowney, supra, 35 Cal.4th at p. 1062 [the purposeful availment requirement focuses on the defendant’s intentionality and is satisfied when the defendant purposefully and voluntarily directs its activities toward the forum so that it should expect, because of the benefit it receives, to be subject to the court’s jurisdiction based on its contacts with the forum]; World-Wide Volkswagen, supra, 444 U.S. at

2014Purposeful availment. “‘The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs his activities toward the forum so that he should expect, by virtue of the benefit he receives, to be subject to the court’s jurisdiction based on’ his contacts with the forum.” (Pavlovich, supra, 29 Cal.4th at p. 269 .) Purposeful availment asks whether the defendant’s “conduct and connection with the 14 forum State are such that he should reasonably anticipate being haled into court there.” (

2013(See Bridgestone Corp., supra, 99 Cal.App.4th at p. 776 [purposeful availment established where a nonresident defendant sold tires to "California distributors" and made "other efforts to market a product to customers in this state indirectly through an intermediary"].) (6) During the May 2002 meeting in San Diego, Sukumar discussed the status of certain "projects" between Sukumar and SRL.11 The trial court's order granting the motion to quash of SRL is silent regarding the research projects and their significance to the purposeful availment inquiry.

2013(See Bridgestone Corp., supra, 99 Cal.App.4th at p. 776 [purposeful availment established where a nonresident defendant sold tires to "California distributors" and made "other efforts to market a product to customers in this state indirectly through an intermediary"].) 19 (6) During the May 2002 meeting in San Diego, Sukumar discussed the status of certain "projects" between Sukumar and SRL.11 The trial court's order granting the motion to quash of SRL is silent regarding the research projects and their significance to the purposeful availment inquiry.

2021As we have said, specific jurisdiction depends on three factors: whether the defendant “ ‘purposefully availed himself or herself of forum benefits,’ ” whether the controversy ‘ “is related to or ‘arises out of’ [the] defendant’s contacts with the forum” ’ and whether the assertion of personal jurisdiction ‘ “would comport with ‘fair play and substantial justice.’ ” ’ ” (Pavlovich, supra, 29 Cal.4th at p. 269 .) “ ‘ “The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs

2021As we have said, specific jurisdiction depends on three factors: whether the defendant “ ‘purposefully availed himself or herself of forum benefits,’ ” whether the controversy ‘ “is related to or ‘arises out of’ [the] defendant’s contacts with the forum” ’ and whether the assertion of personal jurisdiction ‘ “would comport with ‘fair play and substantial justice.’ ” ’ ” (Pavlovich, supra, 29 Cal.4th at p. 269 .) “ ‘ “The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs

2026Pitt and Mondo Bongo presented evidence of purposeful availment “‘“The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs [its] activities toward the forum so that [it] should expect, by virtue of the benefit [it] receives, to be subject to the court’s jurisdiction based on” [its] contacts with the forum.’” ( Snowney, supra, 35 Cal.4th at pp. 1062-1063.) Thus, purposeful availment occurs where a nonresident defendant “(1) purposefully directs its activities at the forum s

2022The specific jurisdiction inquiry must consider “ ‘ “the relationship among the defendant, the forum, and the litigation.” ’ ” ( Walden, supra, 571 U.S. at pp. 283–284.) Indeed, when specific jurisdiction is based on an alleged tort, “ ‘the defendant’s knowledge and intent in committing the tortious activity’ ” is “the very focus of the purposeful availment requirement.” (Pavlovich, supra, 29 Cal.4th at p. 272 .) Yet the trial court, in focusing on Defendants’ non-litigation-related contacts with Missouri, excluded from its analysis any consideration of the communications that were at issue in

2022That constitutional question does not turn on the specific state law requirements of alter ego or agency, although the inquiry may be similar in some circumstances.” (Id. at p. 983; see also Empire Steel Corp. v. Superior Court (1961) 56 Cal.2d 823, 835 [trial court need not decide whether the parent was the alter ego of its subsidiary where “jurisdiction over [parent] has been established on the basis of the acts of the parent itself”].) As the trial court correctly reasoned, under Anglo Irish, it is sufficient, for purposes of the purposeful availment inquiry, that SK Trading directed SK Ene

2022That constitutional question does not turn on the specific state law requirements of alter ego or agency, although the inquiry may be similar in some circumstances.” (Id. at p. 983; see also Empire Steel Corp. v. Superior Court (1961) 56 Cal.2d 823, 835 [trial court need not decide whether the parent was the alter ego of its subsidiary where “jurisdiction over [parent] has been established on the basis of the acts of the parent itself”].) As the trial court correctly reasoned, under Anglo Irish, it is sufficient, for purposes of the purposeful availment inquiry, that SK Trading directed SK Ene

2024We begin with the purposeful availment prong of the test. “ ‘The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs [its] activities toward the forum so that [it] should expect, by virtue of the benefit [it] receives, to be subject to the court’s jurisdiction based on’ [its] contacts with the forum.” (Pavlovich v. Superior Court (2002) 29 Cal.4th 262, 269 .) “[T]he underlying rationale of all the purposeful availment tests is that ‘it is fair to subject defendants to spec

2023We begin with the purposeful availment prong of the test. “ ‘The purposeful availment inquiry . . . focuses on defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs [its] activities toward the forum so that [it] should expect, by virtue of the benefit [it] receives, to be subject to the court’s jurisdiction based on’ [its] contacts with the forum.” (Pavlovich v. Superior Court (2002) 29 Cal.4th 262, 269 .) “[T]he underlying rationale of all the purposeful availment tests is that ‘it is fair to subject defendants to specific

2022That constitutional question does not turn on the specific state law requirements of alter ego or agency, although the inquiry may be similar in some circumstances.” (Id. at p. 983; see also Empire Steel Corp. v. Superior Court (1961) 56 Cal.2d 823, 835 [trial court need not decide whether the parent was the alter ego of its subsidiary where “jurisdiction over [parent] has been established on the basis of the acts of the parent itself”].) As the trial court correctly reasoned, under Anglo Irish, it is sufficient, for purposes of the purposeful availment inquiry, that SK Trading directed SK Ene

2022That constitutional question does not turn on the specific state law requirements of alter ego or agency, although the inquiry may be similar in some circumstances.” (Id. at p. 983; see also Empire Steel Corp. v. Superior Court (1961) 56 Cal.2d 823, 835 [trial court need not decide whether the parent was the alter ego of its subsidiary where “jurisdiction over [parent] has been established on the basis of the acts of the parent itself”].) As the trial court correctly reasoned, under Anglo Irish, it is sufficient, for purposes of the purposeful availment inquiry, that SK Trading directed SK Ene

2022Analysis of Specific Jurisdiction Applying the three-part test, the trial court found that (1) SK Trading purposefully directed its activities at California residents by and through SK Energy, whose employees made trades on the California spot market and engaged in business in California on behalf of SK Trading; (2) the People’s “claims for collusion, market manipulation, and unfair competition are 8 sufficiently related to [SK Trading’s] contacts with California to warrant the exercise of specific jurisdiction”; and (3) the assertion of jurisdiction in this case would comport with fair play a

2022Analysis of Specific Jurisdiction Applying the three-part test, the trial court found that (1) SK Trading purposefully directed its activities at California residents by and through SK Energy, whose employees made trades on the California spot market and engaged in business in California on behalf of SK Trading; (2) the People’s “claims for collusion, market manipulation, and unfair competition are 8 sufficiently related to [SK Trading’s] contacts with California to warrant the exercise of specific jurisdiction”; and (3) the assertion of jurisdiction in this case would comport with fair play a

2014(Vons, supra, 14 Cal.4th at p. 450 ; see Pavlovich, supra, 29 Cal.4th at p. 268 .) Indeed, because California’s lóng-arm statute “ ‘manifests an intent to exercise the broadest possible jurisdiction’ ” (Magnecomp Corp. v. Athene Co. (1989) 209 Cal.App.3d 526, 535 [ 257 Cal.Rptr. 278 ]), its courts may apply the purposeful availment test most conducive to establishing specific jurisdiction over a defendant in a particular case, consistent with due process.

2007(World-Wide Volkswagen Corp. v. Woodson (1980) 444 U.S. 286, 297 [ 62 L.Ed.2d 490 , 100 S.Ct. 559 ]; Vans Companies, Inc. v. Seabest Foods, Inc. (1996) 14 Cal.4th 434, 446 [ 58 Cal.Rptr.2d 899 , 926 P.2d 1085 ]; see also Hanson v. Denckla (1958) 357 U.S. 235, 253 [ 72 L.Ed.2d 1283 , 8 S.Ct. 1228 ].) “The fact that many companies have established virtual beachheads on the Internet and the fact that the Internet is now accessible from almost any point on the globe have created complex, new considerations in counting minimum contacts for purposes of determining personal jurisdiction.” (Butler v.

2022By limiting the scope of a forum’s jurisdiction in this manner, the “ ‘purposeful availment’ requirement ensures 5 that a defendant will not be haled into a jurisdiction solely as a result of ‘random,’ ‘fortuitous,’ or ‘attenuated’ contacts....” [Citation.] Instead, the defendant will be subject to personal jurisdiction only if “ ‘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.’ ” ’ ” (Health

2013(Burger King, [supra, 471 U.S.] at pp. 478–479, 486, fn. 29 [105 S.Ct. at pp. 2185–2186, 2189–2190]; Kulko v. California Superior Court (1978) 436 U.S. 84, 89, 92 [ 56 L.Ed.2d 132 , 98 S.Ct. 1690, 1695 , 1696–1697]; Vons[, supra, 14 Cal.4th] at p. 450.)‟ (Bridgestone Corp. v. Superior Court (2002) 99 Cal.App.4th 767, 774 [ 121 Cal.Rptr.2d 673 ].)” (HealthMarkets, Inc. v. Superior Court (2009) 171 Cal.App.4th 1160, 1166-1167 (HealthMarkets).) “ „ “The purposeful availment inquiry . . . focuses on the defendant‟s intentionality. [Citation.] This prong is only satisfied when the defendant purpose

2026(Their passport numbers and addresses are, however, listed in a “Currency Transaction Report” prepared by the title company.) In any case, there is no indication these documents factored into 19 (Seagate, supra, 219 Cal.App.3d at 704 [“no personal contact would result from doing nothing more than ratifying an act taken by the corporation or by another corporate officer”].) And contrary to plaintiff’s reading, Seagate does not stand for the proposition that a corporate entity’s contacts are necessarily attributable to its owners in the context of a purposeful availment analysis.

2026Co. Ltd. v. Superior Court (2022) 77 Cal.App.5th 378 , 388 (SK Trading).) However, “activities that are undertaken on behalf of a defendant may be attributed to the defendant for purposes of personal jurisdiction if the defendant purposefully directed those activities toward the forum state.” (Anglo Irish Bank Corp., PLC v. Superior Court (2008) 165 Cal.App.4th 969, 981-982 ; see Burger King Corp. v. Rudzewicz, supra, 471 U.S. at p. 479, fn. 22 [“We 18 have previously noted that when commercial activities are ‘carried on in behalf of’ an out-of-state party those activities may sometimes be asc

2025(See Ford, supra, 592 U.S. at p. 359 [a defendant purposefully avails itself of the forum’s benefits if it deliberately reaches out beyond its home by exploiting a market in the forum state]; Snowney, supra, 35 Cal.4th at p. 1062 [the purposeful availment requirement focuses on the defendant’s intentionality and is satisfied when the defendant purposefully and voluntarily directs its activities toward the forum so that it should expect, because of the benefit it receives, to be subject to the court’s jurisdiction based on its contacts with the forum]; World-Wide Volkswagen, supra, 444 U.S. at

2023(See Khan v. Superior Court (1988) 204 Cal.App.3d 1168, 1178 [jurisdiction present where husband “intentionally established numerous contacts” and “diverse links with the state run[ning] the gamut from the personal to the professional to the commercial.”].) Even if we hesitated to exercise general jurisdiction over Robert, we could not but conclude he had sufficient contacts to justify specific jurisdiction over the marital dissolution. “‘The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully an

2022(Doe v. Roman Catholic Archbishop of Cashel & Emly (2009) 177 Cal.App.4th 209, 218 [appellant waived substantial evidence challenge to order quashing service of summons by failing to discuss challenged findings]; Shenouda v. Veterinary Medical Bd. (2018) 27 Cal.App.5th 500, 515 [appellant waived substantial evidence challenge by failing to address trial court’s findings or explain why the evidence did not support the findings].) Further, we need not address the argument because John Jr.’s evidence, standing alone, was insufficient to satisfy the purposeful availment requirement. 13

2022(Ibid.) “ ‘ “ ‘The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs its activities toward the forum so that it should expect, by virtue of the benefit it receives, to be subject to the court’s jurisdiction based on’ its contacts with the forum.” [Citation.] Thus, purposeful availment occurs where a nonresident defendant “ ‘purposefully directs’ its activities at residents of the forum, purposefully derives benefits from its activities in the forum” [citation], “creates

2022(Doe v. Roman Catholic Archbishop of Cashel & Emly (2009) 177 Cal.App.4th 209, 218 [appellant waived substantial evidence challenge to order quashing service of summons by failing to discuss challenged findings]; Shenouda v. Veterinary Medical Bd. (2018) 27 Cal.App.5th 500, 515 [appellant waived substantial evidence challenge by failing to address trial court’s findings or explain why the evidence did not support the findings].) Further, we need not address the argument because John Jr.’s evidence, standing alone, was insufficient to satisfy the purposeful availment requirement. 13

2016The Purposeful Availment Requirement “‘“The purposeful availment inquiry . . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs [its] activities toward the forum so that [it] should expect, by virtue of the benefit [it] receives, to be subject to the court’s jurisdiction based on” [its] contacts with the forum.’” ( Snowney, supra, 35 Cal.4th at pp. 1062-1063.) “‘“‘Purposeful availment’ requires that the defendant ‘have performed some type of affirmative conduct which allows or promotes the transaction of