Robinson v. Bartlow, et. al., 3-12-cv-00024 (VAWD October 3, 2012, Order) (Moon, J.).
Friday, October 5, 2012
Kickstarter Posting Alone Was Insufficient to Support Exercise of State-Specific Personal Jurisdiction
The court granted plaintiff's motion for jurisdictional discovery while a group of individual defendants' motions to dismiss for lack of personal jurisdiction and improper venue were pending. "Plaintiff noted. . . that the individual Defendants personally recorded a Kickstarter advertising message in which they disclosed their names and position as students at the University of Washington. . . . However, their personal efforts for the online Kickstarter campaign seem most analogous to advertising in a national trade publication, which. . . does not give rise to state-specific jurisdiction where appellants could not show that an appellee-defendant had 'targeted' the state in question. . . . [W]hile it has not yet met its prima facie burden, Plaintiff has demonstrated that it may supplement its jurisdictional allegations as to the individual Defendants through discovery."