In a suit by a California resident against a Texas company that refurbished cellphones, the state of California lacked personal jurisdiction over the defendant because, although the Texas company was owned by a California corporation with overlapping executive personnel, there was insufficient evidence that the Texas company was the California parent’s agent or that it purposefully directed its injurious activities to California. California lacked personal jurisdiction over a Texas company that refurbished cellphones in a suit by a California resident who claimed that in refurbishing her phone, one of defendant’s employees downloaded personal information and embarrassing pictures from the phone and uploaded them to her Facebook page. The Texas company was owned by a California corporation with overlapping executive personnel. But that was not enough to show that the Texas company was the California parent’s agent or support attribution of the California corporation’s contacts to the Texas company. Plaintiff also failed to show that the Texas company purposefully directed its activities to California, thus harming plaintiff. Posting on Facebook was not directed at California as there was no evidence the Texas company or its employee knew plaintiff was a California resident or that most of her Facebook friends were as well. While plaintiff showed the Texas company had some business dealings with California companies, she could not show that her injury arose from those contacts.
California Court of Appeal, Fourth District, Division 1 (McConnell, P.J.); November 4, 2016; 2016 WL 6555013