Alexandra Dugan v. Boston Digital Enterprises, LLC; Exergen Corporation

Summary

The United States District Court for the Western District of Oklahoma grants Boston Digital Enterprises, LLC's renewed motion to dismiss for lack of personal jurisdiction. The court concludes that Boston Digital lacked sufficient minimum contacts with Oklahoma and that exercising jurisdiction would not comport with traditional notions of fair play and substantial justice. The claims against Boston Digital are dismissed without prejudice under Federal Rule of Civil Procedure 12(b)(2).

Holdings

1. Boston Digital did not purposefully direct its activities toward Oklahoma. Its contacts resulted from Exergen's and Dugan's choices concerning the already scheduled photoshoot, were incidental to Boston Digital's website-design work for Exergen, and did not establish sufficient minimum contacts.
2. Even assuming that Boston Digital had barely sufficient minimum contacts, exercising personal jurisdiction would offend traditional notions of fair play and substantial justice.

Questions Presented

1. Whether Boston Digital Enterprises, LLC purposefully directed activities toward Oklahoma and thereby had sufficient minimum contacts for the exercise of specific personal jurisdiction.
2. Whether exercising personal jurisdiction over Boston Digital would comport with traditional notions of fair play and substantial justice.

Disposition

dismissed