NEXLEARN, LLC V. ALLEN INTERACTIONS, INC.

NEXLEARN, LLC V. ALLEN INTERACTIONS, INC., Appeal Nos. 2016-2170, 2221 (Fed. Cir. June 19, 2017).  Before Moore, Schall, and Hughes.  Appealed from D. Kan. (Judge Melgren).  (Personal Jurisdiction)

Background:

In this case, NexLearn sued Allen for patent infringement in the district of Kansas, but Allen moved to dismiss NexLearn’s complaint for lack of personal jurisdiction in Kansas.

In addition, NexLearn attempted to establish personal jurisdiction under specific jurisdiction based on Allen’s activities both prior to and after NexLearn’s patent issued.

Thus, the district court granted Allen’s motion to dismiss due to the district court not having personal jurisdiction over Allen in Kansas.  In summary, the district court determined that Allen did not have sufficient “minimum contacts” with Kansas.  Finally, NexLearn appealed.

Issue/Holding:

Did the district court err in holding that Allen did not have sufficient “minimum contacts” to establish personal jurisdiction in Kansas?  (continue reading)

Summary by:  Jacob Beers