Green Jeeva LLC v. Lokesh Pathak, et al.

Summary

The United States District Court for the District of Nevada considered motions to dismiss filed by Lokesh Pathak and Mclob America, LLC in a trade-secret and related commercial dispute. The court concluded that the pleadings did not establish general or specific personal jurisdiction in Nevada, but determined that limited jurisdictional discovery was warranted regarding the defendants’ business activities and travel to Nevada. The court allowed jurisdictional discovery through April 9, 2026 and deferred ruling on the defendants’ Rule 12(b)(3) and Rule 12(b)(6) arguments.

Holdings

1. The court lacked general personal jurisdiction in Nevada over Pathak and Mclob America because the record did not show continuous and systematic contacts rendering either defendant essentially at home in Nevada.
2. Green Jeeva did not establish the first prong of the Ninth Circuit's specific-jurisdiction test because the allegations and evidence did not plausibly show that Pathak or Mclob America expressly aimed their conduct at Nevada.
3. The court granted limited jurisdictional discovery concerning defendants' business activities and travel to Nevada, but denied discovery into five years of communications between defendants and Green Jeeva.

Questions Presented

1. Whether the allegations and evidence established general personal jurisdiction over Pathak and Mclob America in Nevada.
2. Whether the allegations and evidence established specific personal jurisdiction over Pathak and Mclob America under the Ninth Circuit's purposeful-direction and Calder effects analysis.
3. Whether Green Jeeva was entitled to jurisdictional discovery before the court ruled on the motions to dismiss.

Disposition

other