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."

Robinson v. Bartlow, et. al., 3-12-cv-00024 (VAWD October 3, 2012, Order) (Moon, J.).