Axiom Foods, Inc. v. Acerchem Int'l, Inc., No. 15-56450 (9th Cir. 2017)Annotate this Case
Following Walden v. Fiore, 134 S. Ct. 1115 (2014), the panel held that while a theory of individualized targeting may remain relevant to the minimum contacts inquiry, it will not, on its own, support the exercise of specific jurisdiction, absent compliance with what Walden requires. The Ninth Circuit affirmed the district court's dismissal of a copyright infringement action based on lack of personal jurisdiction over defendant, a United Kingdom limited company. In this case, the panel applied the "effects" test and held that defendant committed an intentional act, but did not expressly aim its intentional act at the forum state. The panel held that the district court properly declined to exercise jurisdiction over defendant pursuant to Federal Rule of Civil Procedure 4(k)(2).