Edward Raymond v. LSM Trading USA, LLC, et al.

Summary

The United States District Court for the Southern District of Florida granted the defendants’ motion to dismiss Edward Raymond’s amended complaint, which asserted claims arising from alleged unpaid employment compensation, disrupted business transactions, and defamatory statements. The court held that Raymond failed to establish personal jurisdiction over the nonresident defendants and failed to adequately plead the citizenship of the members of an LLC for diversity jurisdiction. The dismissal was without prejudice, and Raymond was granted leave to file a second amended complaint by February 16, 2026.

Holdings

1. The plaintiff failed to establish personal jurisdiction because he did not allege facts showing that defendants engaged in service activities in Florida, that qualifying products were used or consumed in Florida, or that the alleged tortious conduct occurred in Florida.
2. The plaintiff failed to establish specific personal jurisdiction because he did not allege that defendants had purposeful minimum contacts with Florida from which his claims arose or to which they related.
3. The plaintiff failed to establish complete diversity as to LSM Trading USA LLC because he did not identify the citizenship of each member of the LLC.
4. The plaintiff adequately alleged an amount in controversy exceeding $75,000.
5. The amended complaint was dismissed because it did not adequately plead the jurisdictional facts necessary for the court to adjudicate the asserted claims, and any deficiency in the substantive claims could not be cured by conclusory allegations or new allegations in the response.

Questions Presented

1. Whether the plaintiff adequately alleged personal jurisdiction over the nonresident defendants under Florida's long-arm statute and the Due Process Clause.
2. Whether the plaintiff adequately pleaded the citizenship of the members of defendant LSM Trading USA LLC to establish complete diversity.
3. Whether the amount in controversy exceeded $75,000 for purposes of diversity jurisdiction.
4. Whether the amended complaint stated plausible claims for relief under Rule 12(b)(6).

Disposition

dismissed