Archive | Personal Jurisdiction

Specific Personal Jurisdiction from NPE Enforcement Effort

Many people think that efforts to enforce a patent in a particular forum, without more, cannot give rise to personal jurisdiction over the patent owner in that forum.  If you so thought, you thought wrong.  In Xilinx, Inc., v. Papst Licensing GmbH & Co., KG, No. 2015-1919 (Fed. Cir. Feb 15, 2017), the court held […]

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Website Doesn’t Create Personal Jurisdiction in Patent Case

An Ohio court has transferred a patent case to the Eastern District of Washington after finding that the defendant’s website was insufficient to create specific personal jurisdiction.  Zen Indus., Inc. v. Hoffman Mfg., Inc., No. 1:16 CV 2352 (N.D. Ohio, Feb. 9, 2016).  Applying Federal Circuit law to consider personal jurisdiction with respect to the […]

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When Does Internet Use Create Personal Jurisdiction?

A defendant’s use of computers in Canada to access servers in Connecticut was sufficient to give rise to personal jurisdiction in Connecticut, the Second Circuit Court of Appeals has held. MacDermid, Inc. v. Deiter, No. 11-5388-cv (2nd Cir. Dec. 26, 2012). A district court had held that the defendant’s conduct was not covered under Connecticut’s […]

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No Personal Jurisdiction Based on “Location” of Patent

A patent owner’s residence in Washington state did not confer personal jurisdiction over defendants in a dispute over the defendants’ rights to license and sub-license the patent.  VSIM Patent Co., LLC v. Benson, No. C12-102RSL (W.D. Wash. 2012).  The action that the patent owner brought did, however, end up conferring a right to fees and […]

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E.D. Va. Asserts Personal Jurisdiction Over Foreign Web Site Providers

Courts sometimes assert personal jurisdiction over foreign defendants who did not specifically target the jurisdiction when establishing a website accessible from within it, and who may have conducted only a relatively miniscule amount of business in the jurisdiction.  In a recent example, a Virginia court held that it had personal jurisdiction over two European corporations […]

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