Advanced Tactical Ordnance Systems, LLC v. Real Action Paintball, Inc.
United States Court of Appeals for the Seventh Circuit
751 F.3d 796 (2014)
Advanced Tactical (plaintiff), an Indiana-based maker of pepper-spray paintballs, sued Real Action (defendant), a California company, for trademark infringement in Indiana federal court after Real Action advertised on its website and in a mass email that it used materials "once used by" Advanced Tactical's trademark predecessor. Advanced Tactical argued personal jurisdiction existed because Real Action's website was accessible everywhere, its email reached subscribers nationwide including in Indiana, and it had made some sales to Indiana customers. The district court agreed and denied Real Action's motion to dismiss.
Whether a defendant's operation of an interactive website accessible from a particular forum is, without more, sufficient to establish personal jurisdiction over the defendant in that forum.