Pangaea, Inc. v. The Flying Burrito, LLC, et al.

Plaintiff, the owner of the federal trademark "The Flying Burrito Company," appealed the district court's dismissal of its trademark infringement action for lack of personal jurisdiction. At issue was whether a federal court in Arkansas had personal jurisdiction over an Iowa citizen and an Iowa limited liability company where the contact with Arkansas was a single meeting by the parties in Arkansas. The court held that defendants' actions in making the isolated trip to Arkansas do not reveal an intent to purposefully avail themselves of the protection of that state's laws, or otherwise established sufficient contacts with Arkansas to justify personal jurisdiction. As noted, defendants made the trip to Arkansas in an effort to avoid any trademark infringement resulting from the name of their Iowa restaurant and nothing in the record showed any other connection to Arkansas. Therefore, defendants have insufficient contacts with Arkansas to confer personal jurisdiction over them with respect to the subject of this lawsuit. With respect to plaintiff's ground of appeal seeking jurisdictional discovery, the district court did not expressly rule on that issue, but in any even, the court saw no basis for such discovery. View "Pangaea, Inc. v. The Flying Burrito, LLC, et al." on Justia Law