Lighting Defense Group v. SnapRays, dba SnapPower

In Calder v. Jones, this Court held that California courts could exercise personal jurisdiction over Florida defendants “because of their intentional conduct in Florida calculated to cause injury to [plaintiff] in California.” 465 U.S. 783, 787-91 (1984). This Court observed that the defendants “expressly aimed” their “intentional, and allegedly tortious” conduct at the forum and “knew that the brunt of that injury would be felt” there. Id. at 789- 90. This Court appeared to refine and cabin Calder in Walden v. Fiore, 571 U.S. 277 (2014). It explained that the forum connections in Calder largely turned on the “nature of the libel tort.” Id. at 286-88. Then, this Court held that a defendant does not have “sufficient contacts with [the forum] simply because he allegedly directed his conduct at plaintiffs whom he knew had [forum] connections.” Id. at 289-90. The question presented is: Whether a defendant subjects itself to personal jurisdiction anywhere a plaintiff operates simply because the defendant knows its out-of-forum conduct “would necessarily affect marketing, sales, and other activities” within the forum, Pet.App.11a—even though the defendant has no contacts with the plaintiff or the forum whatsoever.