US Court of Appeals for the Fifth Circuit Opinions
Admar International, Inc. v. Eastrock, LLC
Opinion Date: November 19, 2021
Judge: James C. Ho
Areas of Law: Civil Procedure
Merely running a website that is accessible in all 50 states, but that does not specifically target the forum state, is not enough to create the "minimum contacts" necessary to establish personal jurisdiction in the forum state under International Shoe Co. v. Washington, 326 U.S. 310, 316 (1945). The defendant must take the additional step of targeting the forum state in a manner that reflects "purposeful availment" of the opportunity to do business in that state. Plaintiffs filed suit alleging that Eastrock committed copyright and trade dress infringement by displaying copies of their products on its website. The court affirmed the district court's dismissal of the complaint based on lack of personal jurisdiction, concluding that there is no evidence to support the conclusion that Eastrock's website specifically targets Louisiana.
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