Advanced Tactical Ordinance Systems, LLC v. Real Action Paintball, Inc.

Federal 7th Circuit Court
Civil Court
Personal Jurisdiction
Case Number: 
No. 13-3005
Decision Date: 
May 9, 2014
Federal District: 
N.D. Ind., Ft. Wayne Div.
Vacated and remanded
Dist. Ct. lacked personal jurisdiction over defendant-California entity in plaintiff’s trademark infringement action, where defendant’s contacts with Indiana consisted of: (1) fulfilling several Internet orders on allegedly infringing product from Indiana customers; (2) sending at least two allegedly misleading email blasts about said product from list that contained Indiana customers; and (3) maintaining interactive website that was available to Indiana customers. Instant activities attributable to defendant were insufficient to establish personal jurisdiction over defendant since: (1) said Internet sales were too few in number to demonstrate that defendant had targeted Indiana customers; and (2) defendant’s maintenance of email list or interactive website, without more, was conduct that was unrelated to any alleged trademark infringement.