Kendall Hunt Publishing Company v. The Learning Tree Publishing Corporation, No. 22-1885 (8th Cir. 2023)
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Kendall Hunt Publishing Company (Kendall Hunt) filed suit against The Learning Tree Publishing Corporation (Learning Tree) in district court in Iowa, where Kendall Hunt is located. The complaint alleged, as relevant here, claims of copyright infringement, tortious interference with contract, and unfair competition. The district court1 granted Learning Tree’s motion to dismiss for lack of personal jurisdiction, concluding that the California corporation lacked minimum contacts with Iowa.
The Eighth Circuit affirmed. The court wrote that Learning Tree’s contacts with Iowa were as follows: it maintains a nationally available website through which an Iowa resident purchased the allegedly infringing work. This conduct was not “uniquely or expressly aimed at” Iowa, however, particularly in light of the fact that Learning Tree did not advertise in Iowa and its litigation-anticipated sale to a Kendall Hunt employee occurred in Iowa. Although Kendall Hunt argued in its brief that this online sale was sufficient to create jurisdiction in Iowa, our court subsequently decided on similar facts that a single online sale did not establish personal jurisdiction over Defendant. The remaining specific-jurisdiction analysis factors do not tip the balance in Kendall Hunt’s favor. The court concluded that because Learning Tree’s connections with Iowa were not such that it would reasonably have anticipated being haled into court there, the district court lacked personal jurisdiction over the corporation.
Court Description: [Wollman, Author, with Smith, Chief Judge, and Loken, Circuit Judge] Civil case - Civil Procedure. The district court dismissed this copyright and tortious interference case for lack of personal jurisdiction, concluding that the California defendant lacked minimum contacts with Iowa; a single online sale of a book in Iowa was not sufficient to establish personal jurisdiction over defendant; further defendant's alleged wrongful conduct took place in California, and the remaining specific-jurisdiction factors do not weigh in plaintiff's favor; the district court did not err in dismissing the matter for lack of personal jurisdiction.
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