Skillsoft Corp. v. Harcourt General, Inc.

Summary

The New Hampshire Supreme Court held that the superior court lacked specific personal jurisdiction over Harcourt General, Inc. and National Education Training Group, Inc. in a declaratory judgment action brought by Skillsoft and its officers. The court concluded that the defendants' letters to the plaintiffs in New Hampshire related to the litigation but did not constitute purposeful availment of New Hampshire law. The court also determined that fairness and reasonableness considerations weighed against exercising jurisdiction and reversed the superior court's order.

Holdings

1. The defendants' three letters related directly to the litigation because they precipitated the plaintiffs' declaratory judgment action, but the plaintiffs' business practices and the parties' general employment relationship did not constitute relevant contacts by the defendants for specific jurisdiction.
2. The defendants did not purposefully avail themselves of the protections of New Hampshire law by sending letters to plaintiffs in New Hampshire that asserted violations of Illinois law and demanded cessation of the alleged violations.
3. Exercising specific personal jurisdiction over the defendants in New Hampshire would not be fair and reasonable because the relevant fairness factors, apart from possible burden on the defendants, weighed against jurisdiction.
4. New Hampshire could not exercise specific personal jurisdiction over Harcourt and NET because the defendants did not purposefully avail themselves of New Hampshire law and jurisdiction would not be fair and reasonable under the Due Process Clause.

Questions Presented

1. Whether New Hampshire could exercise specific personal jurisdiction over Harcourt and NET consistent with the Due Process Clause of the Fourteenth Amendment.
2. Whether the defendants' employment-related contacts with New Hampshire and letters sent to Moran in New Hampshire established sufficient minimum contacts, purposeful availment, and fairness for specific personal jurisdiction.

Disposition

reversed