Alpha Technology USA Corporation d/b/a FutureCow v. Northern Dairy Equipment, Ltd., 6-17-cv-01000 (FLMD January 22, 2018, Order) (Presnell, USDJ)
Wednesday, January 24, 2018
Pre-Issuance Contacts Do Not Support Exercise of Personal Jurisdiction
The court granted a British defendant's motion to dismiss plaintiff's patent infringement claims for lack of personal jurisdiction under the state long-arm statute. "[Defendant] maintains that it has had no contacts with any individuals or entities in Florida, except with [one company], and it maintains that any business dealings with [that company] ended [5 years ago]. . . . Pre-issuance activity is generally irrelevant for purposes of determining personal jurisdiction in a patent infringement case. Because [plaintiff] did not submit any evidence supporting sales in Florida after issuance of either patent, the Court has no basis to consider sales to Florida in the minimum contacts analysis."