MAXCHIEF INVESTMENTS LTD. v. WOK & PAN, IND., INC.

MAXCHIEF INVESTMENTS LTD. v. WOK & PAN, IND., INC., Appeal No. 2018-1121 (Fed. Cir. November 29, 2018).  Before Dyk, Reyna and Hughes.  Appealed from E.D. Tenn. (Greer, J.).  (Declaratory Judgment Personal Jurisdiction)

Background:

Maxchief and Wok are Chinese plastic table manufacturers.  Wok sued Staples, in California, alleging patent infringement.

Staples buys its tables from Meco, a Tennessee company, which is a Maxchief distributor.  Maxchief subsequently filed actions for declaratory judgment of non-infringement or invalidity in the Eastern District of Tennessee.

The Tennessee district court dismissed the declaratory judgment action, finding that Wok did not have sufficient minimum contacts with Tennessee, and thus, there was no personal jurisdiction for the suit.

Issue/Holding:

Did the district court err in dismissing the declaratory judgment action based upon a lack of personal jurisdiction?  (continue reading)

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Summary by:  Joel Gotkin