Personal Jurisdiction Upheld Over English Manufacturer That Was Aware Goods Were Destined for New York

The World in U.S. Courts: Spring 2014 - Personal Jurisdiction

Roberts-Gordon LLC v. Pektron PLC, U.S. District Court, Western District of New York, February 13, 2014

New York’s personal jurisdiction statute confers personal jurisdiction if a defendant "transacts business within the state or contracts anywhere to supply goods or services in the state." Defendant Pektron, an English manufacturer of ignition control units, moved to dismiss claims regarding defective products for lack of personal jurisdiction, arguing that because it did not ship any goods directly to New York it could not be subject to personal jurisdiction under this provision. The U.S. District Court in Buffalo, New York concluded, however, that Pektron was aware the goods were destined for New York, which the court held was the relevant criterion under the statute. The court rejected Pektron’s attempt to argue that its knowledge was irrelevant because it did not personally arrange for shipping the goods to New York, citing the fact that Pektron had manufactured the goods specifically for a New York company and knew at the time of contracting that the goods were destined for New York. Following other decisions within the Second Circuit, the court held knowledge that the goods will be supplied in New York is sufficient to confer jurisdiction under the statute.

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