Commercial Litigation and Arbitration

Personal Jurisdiction — Specific Jurisdiction — Multiple Claims

Specific personal jurisdiction is a claim-specific inquiry, and a ‛plaintiff bringing multiple claims that arise out of different forum contacts of the defendant must establish specific jurisdiction for each claim.“ Seiferth v. Helicopteros Atuneros, Inc., 472 F.3d 266, 274 (5th Cir. 2006). The question urged in Sutton v. Advance Aquaculture Sys., Inc., 2007 U.S. Dist. LEXIS 55396 (W.D. Tex. July 31, 2007), was whether a plaintiff bringing multiple claims arising out of the same contacts must establish specific jurisdiction for each claim. District Judge Xavier Rodriguez considered the question essentially superfluous because, once the Court has determined that the contacts satisfy the minimum contact standard, jurisdiction is by definition exercisable over all claims. Held: "This Court does not extend the Seiferth requirement to establish jurisdiction for each claim to cases where all claims arise from the same contacts. This is consistent with the general principle that jurisdiction is properly asserted over claims when the contacts meet the minimum contact standard. Because this Court has determined that [Defendant] Advanced Aquaculture's contacts meet that standard, it may assert jurisdiction over all related claims arising under them."

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