Southern District Dismisses Patent Infringement Case over Motorcycle Suspension for Lack of Personal Jurisdiction

Indianapolis, IN – The Southern District of Indiana has dismissed a patent infringement lawsuit finding a lack of personal jurisdiction over a California company accusing of patent infringement. Patent lawyers for AirFx LLC of Indianapolis, Indiana filed a patent infringement lawsuit in the Southern District of Indiana alleging J.D. Braun, of Los Angeles, California, doing business as Goldenstate Custom Cycles, Dr. V-Twin, Inc. of Sherman Oaks, California, infringed Patent No. 7,559,396 B2, Motorcycle air suspension system, which has been issued by the US Patent Office. Indiana Intellectual Property Law and News blogged about the case when it was filed in July.

The California defendant moved to dismiss the complaint, arguing that the court lacked personal jurisdiction. Patent attorneys for AirFX had argued that the Indiana district court had personal jurisdiction because the company had a website that was accessible in Indiana and listed an Indiana store where its products could be purchased. Judge William T. Lawrence, writing for the court, held that “the mere existence of nationally-accessible websites is a poor foundation on which to base personal jurisdiction.” Thus the court dismissed the case with prejudice.

Practice Tip: This case reiterates that simply having a website that is accessible within a district does not create personal jurisdiction. In order to achieve personal jurisdiction, the plaintiff must establish “minimum contacts” with the district.

This case was assigned to Judge William T. Lawrence and Magistrate Judge Denise K. LaRue in the Southern District of Indiana, and assigned Case No. 1:11-cv-00802-WTL-DKL.AirFX Decision