District Court Grants Additional Jurisdictional Discovery on Norwegian Defendant’s Secondment Agreements With U.S. Entities

The World in U.S. Courts: Winter 2015 - Personal Jurisdiction

Patterson v. Blue Offshore BV, et al., U.S. District Court for the Northern District of California, November 10, 2014

Plaintiff Danny Patterson, alleging that he injured his knee and leg while working on a ship then located off the coast of the Russian Federation, brought suit against contractors providing equipment and technical supervision on the project on which he sustained his injury. In particular, he alleged that defendant FMC Kongsberg Subsea AS, a Norwegian contractor, provided unsafe sub-sea umbilical equipment.

FMC Kongsberg moved to dismiss for lack of personal jurisdiction, and Patterson moved to conduct additional jurisdictional discovery of secondment agreements under which FMC Kongsberg’s employees were placed on projects in the United States. FMC Kongsberg opposed this motion, claiming that it lacked minimum contacts with the forum sufficient to warrant the discovery. The Court found that the agreements might reveal contacts between FMC Kongsberg and the forum that could support specific personal jurisdiction.

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