SDF Funding LLC v. Fry
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The Court of Chancery granted Defendants' motion to dismiss the amended complaint against them under Court of Chancery Rule 12(b)(2) for lack of personal jurisdiction, holding that this Court lacked personal jurisdiction.
To establish personal jurisdiction, Plaintiffs relied on sections 3104(c)(1) and 3014(c)(3) of Delaware's Long-Arm Statute and the conspiracy theory of jurisdiction. The Court of Chancery dismissed the claims without prejudice, holding (1) both theories of jurisdiction required a forum-related act or omission; (2) Plaintiffs did not adequately allege a forum-related act or omission; and (3) Plaintiffs' interpretation of section 3014(c)(3) was unsupported by caselaw.
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