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Magistrate Judge Thynge: Personal Jurisdiction over Pro Hac Vice Counsel

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In Ricoh Co. v. Oki Data Corp., C.A. No. 09-694-SLR (D. Del. Aug. 15, 2011), Judge Thynge interpreted Delaware’s long arm statute, which states that “‘any nonresident’ that ‘performs any character of work or service in the state’ is subject to personal jurisdiction[,]” to include counsel’s legal representation in this case — “[e]ven if the contact is as minimal as pro hac vice admission[.]” Id.at 8. Judge Thynge nonetheless held that Ricoh’s attempted subpoena of Oki Data’s pro hac vice counsel, a resident of Japan, was unenforceable due to improper service of process.


Ricoh Co. v. Oki Data Corp., C.A. No. 09-694-SLR (D. Del. Aug. 15, 2011)

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