Washington Shoe Co. v. A-Z Sporting Goods Inc., No. 11-35166 (9th Cir. 2012)
Annotate this CaseWashington Shoe brought suit against A-Z for, among other things, copyright infringement. At issue was whether A-Z, an Arkansas retailer, was subject to personal jurisdiction in Washington. The district court dismissed the action for lack of personal jurisdiction. The court held that Washington Shoe presented evidence that A-Z engaged in intentional acts that willfully infringed its copyright, knowing that it would adversely impact Washington Shoe in the state of Washington, and knew or should have known both about the existence of the copyright and the forum. Thus, A-Z's intentional acts were expressly aimed at Washington Shoe in Washington and the harm was felt in Washington. The district court therefore erred in dismissing the action. Accordingly, the court reversed and remanded.
Court Description: Copyright / Personal Jurisdiction. The panel reversed the dismissal of a copyright infringement action for lack of personal jurisdiction. Applying the State of Washington’s long-arm statute, which extends jurisdiction over a defendant to the fullest extent permitted by the Due Process Clause, the panel held that an Arkansas retailer was subject to personal jurisdiction in Washington even though its only relevant contact with the state was a claim that it willfully violated a copyright held by a Washington corporation. The panel held that the plaintiff made a prima facie showing that the Arkansas retailer purposefully directed its activities at the forum state because it engaged in intentional acts expressly aimed at Washington, causing harm that it knew was likely to be suffered in that state. The panel concluded that the retailer’s alleged infringement of the plaintiff’s copyright, and its knowledge of both the existence of the copyright and the forum of the copyright holder, was sufficient “individual targeting” to satisfy the “express aiming” requirement.
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