Gonzalez v. BAM Trading Services, Inc.

Summary

The United States District Court for the District of New Jersey considers motions to dismiss claims against BAM Trading Services, Inc., Binance Holdings Ltd., and related defendants arising from the alleged laundering of cryptocurrency stolen from the plaintiff’s Coinbase account. The court denies BAM’s issue-preclusion motion but grants the defendants’ motions to dismiss for lack of personal jurisdiction, dismissing the complaint without prejudice. The opinion is amended solely to correct an error concerning whether the motion to dismiss was filed on behalf of Changpeng Zhao.

Holdings

1. The prior action did not preclude relitigation of personal jurisdiction because it was voluntarily dismissed without prejudice and the court had not conclusively determined that it lacked personal jurisdiction over BAM.
2. The court lacked specific personal jurisdiction over BAM because, although BAM purposefully directed activities toward New Jersey, Plaintiff's claims did not arise out of or relate to those activities.
3. Because the court lacked specific personal jurisdiction over BAM, it could not exercise specific personal jurisdiction over Binance through Plaintiff's agency or alter-ego theory.
4. RICO § 1965 did not provide personal jurisdiction because Plaintiff failed to establish personal jurisdiction over at least one defendant under § 1965(a) and the traditional minimum-contacts analysis.
5. Rule 4(k)(2) could not support jurisdiction over BAM because BAM was subject to general jurisdiction in Delaware and Florida, and could not support jurisdiction over Binance because Plaintiff failed to make the required certification that Binance was not subject to general jurisdiction in any state.
6. Jurisdictional discovery was not warranted because Plaintiff did not allege with reasonable particularity the possible existence of additional relevant contacts between BAM and New Jersey.

Questions Presented

1. Whether the prior litigation precluded Plaintiff from relitigating personal jurisdiction under the doctrine of issue preclusion.
2. Whether the District of New Jersey could exercise specific personal jurisdiction over BAM under Rule 4(k)(1)(A).
3. Whether the court could exercise personal jurisdiction over Binance through an agency or alter-ego theory based on BAM's contacts.
4. Whether RICO's jurisdictional provisions under 18 U.S.C. § 1965 authorized personal jurisdiction over the defendants.
5. Whether Rule 4(k)(2) authorized personal jurisdiction over BAM or Binance.

Disposition

dismissed