purposeful direction requirement in California

2022(Yue v. Yang (2021) 62 Cal.App.5th 539 , 547–548 [purposeful availment 27 requirement met where nonresident defendant allegedly defamed and threatened the plaintiff, a California resident, in direct correspondence with the plaintiff in California and in website posts that “were directed to, and received by, a California audience” and were intended to cause harm in California]; Moncrief v. Clark (2015) 238 Cal.App.4th 1000 , 1006–1007 (Moncrief); [Arizona attorney misrepresented client’s ownership of equipment that was the subject of a single sales transaction in interstate communications with

2022(Yue v. Yang (2021) 62 Cal.App.5th 539 , 547–548 [purposeful availment 27 requirement met where nonresident defendant allegedly defamed and threatened the plaintiff, a California resident, in direct correspondence with the plaintiff in California and in website posts that “were directed to, and received by, a California audience” and were intended to cause harm in California]; Moncrief v. Clark (2015) 238 Cal.App.4th 1000 , 1006–1007 (Moncrief); [Arizona attorney misrepresented client’s ownership of equipment that was the subject of a single sales transaction in interstate communications with

2022(Yue v. Yang (2021) 62 Cal.App.5th 539 , 547–548 [purposeful availment 27 requirement met where nonresident defendant allegedly defamed and threatened the plaintiff, a California resident, in direct correspondence with the plaintiff in California and in website posts that “were directed to, and received by, a California audience” and were intended to cause harm in California]; Moncrief v. Clark (2015) 238 Cal.App.4th 1000 , 1006–1007 (Moncrief); [Arizona attorney misrepresented client’s ownership of equipment that was the subject of a single sales transaction in interstate communications with

2022(Yue v. Yang (2021) 62 Cal.App.5th 539 , 547–548 [purposeful availment 27 requirement met where nonresident defendant allegedly defamed and threatened the plaintiff, a California resident, in direct correspondence with the plaintiff in California and in website posts that “were directed to, and received by, a California audience” and were intended to cause harm in California]; Moncrief v. Clark (2015) 238 Cal.App.4th 1000 , 1006–1007 (Moncrief); [Arizona attorney misrepresented client’s ownership of equipment that was the subject of a single sales transaction in interstate communications with

2022(Yue v. Yang (2021) 62 Cal.App.5th 539 , 547–548 [purposeful availment 27 requirement met where nonresident defendant allegedly defamed and threatened the plaintiff, a California resident, in direct correspondence with the plaintiff in California and in website posts that “were directed to, and received by, a California audience” and were intended to cause harm in California]; Moncrief v. Clark (2015) 238 Cal.App.4th 1000 , 1006–1007 (Moncrief); [Arizona attorney misrepresented client’s ownership of equipment that was the subject of a single sales transaction in interstate communications with

2022(Yue v. Yang (2021) 62 Cal.App.5th 539 , 547–548 [purposeful availment 27 requirement met where nonresident defendant allegedly defamed and threatened the plaintiff, a California resident, in direct correspondence with the plaintiff in California and in website posts that “were directed to, and received by, a California audience” and were intended to cause harm in California]; Moncrief v. Clark (2015) 238 Cal.App.4th 1000 , 1006–1007 (Moncrief); [Arizona attorney misrepresented client’s ownership of equipment that was the subject of a single sales transaction in interstate communications with

2025(Casey v. Hill (2022) 79 Cal.App.5th 937 , 965.) As its name suggests, the purposeful direction test is met only if the nonresident defendant’s activity toward the forum state is “purposeful, deliberate, and intentional” (Jacqueline B., supra, 68 Cal.App.5th at p. 254); activity toward a forum state that is “random,” “fortuitous,” or “attenuated” will not suffice (Pavlovich, supra, 29 Cal.4th at p. 296 ).

2025(Vons, supra, 14 Cal.4th at p. 446 ; Jacqueline B., supra, 68 Cal.App.5th at p. 253.) None of these other avenues is at issue here. 9 (Walden, at pp. 285-286, italics added; Swenberg v. dmarcian, Inc. (2021) 68 Cal.App.5th 280 , 295; David L. v. Superior Court (2018) 29 Cal.App.5th 359, 362 (David L.) [“Specific jurisdiction must rest on [the defendant’s] own suit-related contacts with California, not merely a plaintiff who lives here”].) In light of this focus on the nonresident defendant’s connection with the forum (rather than with the plaintiff), the purposeful direction test is not met si

2025(Vons, supra, 14 Cal.4th at p. 446 ; Jacqueline B., supra, 68 Cal.App.5th at p. 253.) None of these other avenues is at issue here. 9 (Walden, at pp. 285-286, italics added; Swenberg v. dmarcian, Inc. (2021) 68 Cal.App.5th 280 , 295; David L. v. Superior Court (2018) 29 Cal.App.5th 359, 362 (David L.) [“Specific jurisdiction must rest on [the defendant’s] own suit-related contacts with California, not merely a plaintiff who lives here”].) In light of this focus on the nonresident defendant’s connection with the forum (rather than with the plaintiff), the purposeful direction test is not met si

2025Imputation of minimum contacts As a general rule, “[e]ach defendant’s contacts with [a] forum [s]tate must be assessed individually.” (Calder, supra, 465 U.S. at p. 790 ; Rush v. Savchuk (1980) 444 U.S. 320, 332 .) However, where two defendants are effectively the same entity, courts have sometimes imputed one defendant’s contacts with a forum state to the other defendant because, where such identity exists, the contacts of one are functionally the contacts of both, and both should reasonably anticipate being subject to suit in the forum state.

2025In assessing whether specific jurisdiction exists, “[t]he inquiry . . . ‘focuses on “the relationship among the defendant, the forum, and the litigation.”’” ( Walden, supra, 571 U.S. at pp. 283- 284, quoting Keeton v. Hustler Magazine, Inc. (1984) 465 U.S. 770, 775 ; Calder v. Jones (1984) 465 U.S. 783, 788 (Calder); Bristol-Myers, supra, 582 U.S. at p. 262 [“The primary focus of our personal jurisdiction inquiry is the defendant’s relationship to the forum [s]tate”].) Although “a defendant’s contacts with the forum [s]tate may be intertwined with [its] transactions or interactions with the pl

2025In assessing whether specific jurisdiction exists, “[t]he inquiry . . . ‘focuses on “the relationship among the defendant, the forum, and the litigation.”’” ( Walden, supra, 571 U.S. at pp. 283- 284, quoting Keeton v. Hustler Magazine, Inc. (1984) 465 U.S. 770, 775 ; Calder v. Jones (1984) 465 U.S. 783, 788 (Calder); Bristol-Myers, supra, 582 U.S. at p. 262 [“The primary focus of our personal jurisdiction inquiry is the defendant’s relationship to the forum [s]tate”].) Although “a defendant’s contacts with the forum [s]tate may be intertwined with [its] transactions or interactions with the pl