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."

Alpha Technology USA Corporation d/b/a FutureCow v. Northern Dairy Equipment, Ltd., 6-17-cv-01000 (FLMD January 22, 2018, Order) (Presnell, USDJ)