Earl v. Southern Pac. Co.

Summary

The court denies the Southern Pacific Company's motion to dismiss for lack of personal jurisdiction in a patent infringement action, holding that jurisdiction may be obtained in a district where valid service can be made. It also rejects defendant Graham's jurisdictional objection because he had previously appeared in the court and was personally served in the district. Based on a prior adjudication sustaining the patent's validity, the court grants the complainant's motion for a preliminary injunction.

Holdings

1. The court had jurisdiction over Southern Pacific Company because the statutory restriction requiring civil suits to be brought in the district where the defendant was an inhabitant did not apply to patent suits, and jurisdiction could be obtained in any district where valid service could be made.
2. The court had personal jurisdiction over Graham because he had previously submitted to the court's jurisdiction without objecting to residence and was personally served in the district in the present action.
3. A prior adjudication in the same circuit sustaining the validity of the patent after a bona fide contest is sufficient to support a preliminary injunction, unless the defendant presents new evidence so conclusive that it probably would have changed the result of the prior case.

Questions Presented

1. Whether the federal court had personal jurisdiction over Southern Pacific Company, a Kentucky corporation doing business in the Northern District of California, in a patent-infringement suit.
2. Whether the court had personal jurisdiction over Graham when he was not an inhabitant of the district but was personally served there.
3. Whether Earl was entitled to a preliminary injunction based on the prior adjudication sustaining the validity of the patent.

Disposition

other