Monbo v. Fogle

Summary

The District Court for the District of Columbia granted Timothy Fogle’s motion to dismiss Deafueh Monbo’s copyright and trademark infringement claims for lack of personal jurisdiction. The court concluded that Fogle was not subject to general or specific jurisdiction in the District and dismissed the claims without prejudice under Federal Rule of Civil Procedure 12(b)(2).

Holdings

1. The court lacked general personal jurisdiction over Fogle because Monbo alleged no continuous and systematic contacts with the District of Columbia; Fogle neither resided nor maintained his principal place of business there and had visited only once.
2. The court lacked specific personal jurisdiction over Fogle because Monbo failed to show that Fogle transacted business in the District of Columbia or otherwise had minimum contacts with the District relating to the claims.

Questions Presented

1. Whether the District Court for the District of Columbia had general personal jurisdiction over Fogle.
2. Whether the court had specific personal jurisdiction over Fogle under D.C. Code § 13-423(a)(1) and constitutional due process.

Disposition

dismissed