Haynes North America, Inc. and Haynes Group Limited v. eManualOnline.com

Summary

The United States District Court for the Central District of California denied Plaintiffs’ renewed motion for a preliminary injunction in a copyright and trademark infringement action for lack of personal jurisdiction over Defendant. The Court found that Plaintiffs had not shown Defendant purposefully directed its activities toward California under the Calder effects test. The Court nevertheless granted limited expedited discovery concerning personal jurisdiction and damages, to be completed by August 1, 2025.

Holdings

1. Plaintiffs failed to establish that defendant purposefully directed its activities toward California under the Calder effects test, and therefore failed to establish specific personal jurisdiction.
2. The Court denied the preliminary-injunction motion because plaintiffs had not established personal jurisdiction over defendant.
3. Plaintiffs demonstrated good cause for expedited discovery concerning personal jurisdiction and damages, so the Court granted the request.

Questions Presented

1. Whether plaintiffs established specific personal jurisdiction over the nonresident defendant based on online sales and alleged infringement directed toward California.
2. Whether plaintiffs were entitled to a preliminary injunction.
3. Whether plaintiffs demonstrated good cause for expedited discovery concerning personal jurisdiction and damages.

Disposition

other