Chief Judge Gregory M. Sleet: Manufacturing and Selling Automobile Parts Incorporated Into Vehicles Manufactured in Delaware is Sufficient to Confer Personal Jurisdiction
In a patent infringement case, Chief Judge Sleet recently denied Defendant’s motion to dismiss for lack of personal jurisdiction despite the fact that Defendant (a Georgia corporation with its principal place of business in Georgia) has never had an office in Delaware, is not licensed to conduct business in Delaware and has never had any employees in Delaware. W.L. Gore & Assoc., Inc. v. Label Tech., Inc., No. 08-111-GMS, at 1 (D. Del. May 15, 2009). Judge Sleet determined that Defendant was subject to specific jurisdiction under Delaware’s long-arm statute because Defendant manufactures and sells automobile parts “knowing that its products would be installed into vehicles at Chrysler’s plant in Newark, Delaware.” Id. at 4 Any injury resulting from introducing Defendant’s product into the Delaware market is “sufficient to permit a Delaware court to exercise jurisdiction over [Defendant] under sections 3104 (c)(1) and (c)(4) of title 10 of the Delaware Code” Id. at 6. Although Defendants “contacts” with Delaware was minimal, due process is satisfied because Delaware’s interest in “discouraging injuries that occur within the state, which extends to patent infringement actions[,] is not outweighed by the burden on [Defendant] of litigating this action in Delaware.” Id. at 6-7.