Integrity Medical Product Solutions, LLC v. Seroclinix Corporation, a Delaware Corporation, et al.

Summary

The United States District Court for the Southern District of California granted Third-Party Defendant Honu Management Group, LLC's motion to dismiss the amended third-party complaint for lack of personal jurisdiction. The court concluded that the third-party plaintiffs failed to establish either purposeful availment or purposeful direction sufficient to support specific jurisdiction in California. The claims were dismissed without prejudice, and the third-party plaintiffs were granted leave to amend by November 5, 2025.

Holdings

1. Honu was not subject to general personal jurisdiction in California because its principal place of business was in Washington and the third-party plaintiffs did not dispute that Honu was not otherwise at home in California.
2. The court lacked specific personal jurisdiction over Honu for Seroclinix’s contract-based claims because the third-party plaintiffs failed to show that Honu purposefully availed itself of conducting business in California.
3. The court lacked specific personal jurisdiction over Honu for the alleged misrepresentation claims because Honu’s conduct was not expressly aimed at California and therefore failed the Calder effects test.
4. The court did not reach Honu’s remaining arguments concerning pleading defects, indemnity, and statutes of limitations because the absence of personal jurisdiction was dispositive.
5. The third-party plaintiffs were granted leave to amend their complaint to correct jurisdictional deficiencies.

Questions Presented

1. Whether the court had general personal jurisdiction over Honu in California.
2. Whether the court had specific personal jurisdiction over Honu for the third-party contract claims under a purposeful-availment analysis.
3. Whether the court had specific personal jurisdiction over Honu for the alleged misrepresentation claims under a purposeful-direction and Calder effects analysis.
4. Whether the remaining grounds for dismissal needed to be addressed after the court concluded that personal jurisdiction was lacking.
5. Whether Seroclinix should receive leave to amend its jurisdictional allegations.

Disposition

dismissed