C-Innovation, LLC v. Premier Acquisition Holdings, LLC, et al.

Summary

The United States District Court for the Eastern District of Louisiana addresses motions to dismiss for lack of personal jurisdiction and insufficient service of process in a dispute arising from the charter of an offshore vessel for a Titanic wreckage expedition. The court finds a prima facie basis for specific personal jurisdiction over RMS Titanic, Inc. and Experiential Media Group LLC, while denying the remaining jurisdictional motions without prejudice and denying Apollo's service challenge. The court orders jurisdictional discovery and requires the plaintiff to file a discovery plan by March 31, 2026.

Holdings

1. RMS Titanic and EMG made a prima facie showing of sufficient Louisiana contacts to support specific personal jurisdiction because their representative came to Louisiana and oversaw the outfitting and mobilization of the DINO CHOUEST for the expedition, and the claims arose from those contacts.
2. Dismissal without prejudice was appropriate because additional factual development was needed to determine whether the defendants' relationships to the chartering entities and the Louisiana contacts supported personal jurisdiction.
3. Apollo's motion to dismiss for failure to properly serve process was denied.

Questions Presented

1. Whether Louisiana may exercise specific personal jurisdiction over RMS Titanic and EMG based on their contacts with Louisiana relating to the charter and mobilization of the DINO CHOUEST.
2. Whether the court should dismiss the claims against PAHL, Alta, Star, and Apollo for lack of personal jurisdiction or instead permit jurisdictional discovery.
3. Whether Apollo was properly served with process.

Disposition

other