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JURISDICTION - EX PARTE EDGETECH, I.G., INC.

Ex parte Edgetech, I.G., Inc. [Ms. 1121291, July 25, 2014] __ So. 3d. __ (Ala. 2014). Petition for Writ of Mandamus. Sufficient contacts are necessary in order for Alabama courts to exercise specific jurisdiction over a corporation located in another state. For contacts to be sufficient, "they must rise to such a level as to cause the defendant to anticipate being haled into court in the forum state." Moreover, Alabama courts may assert "personal jurisdiction over a corporation that delivers its products into the stream of commerce with the expectation that they will be purchased by consumers in the forum State." Here, the defendant sold a component part of a window unit to a company in Michigan. It did not seek to establish any business contacts in Alabama, and revenue from its sales here equaled less than 1/100% of its overall sales. The Court stated that defendant did not have sufficient contacts with Alabama. "Thus, under the tests set forth in World-Wide Volkswagen, Burger King, and Ex parte DBI," the Court "conclude[d] that the trial court erred when it held that an Alabama court can exercise personal jurisdiction over [defendant]." The Court holds that J. McIntyre Machinery v. Nicastro did not change the U.S. Supreme Court's jurisprudence on personal jurisdiction (as evidenced by the fact that Justice Breyer, writing the narrowest grounds for the holding, said the case did not call for any new pronouncements), Ex parte DBI is still good law, and Alabama continues to apply the stream-of-commerce doctrine rather than the narrower "stream of commerce plus" doctrine.

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