In Ethridge v. Samsung SDI Co., the US Court of Appeals for the Fifth Circuit rejected the defendant’s “different markets” analysis of the relatedness prong of the “arises out of or relates to” requirement for specific personal jurisdiction under Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 592 U.S. 351 (2021). Instead, the Fifth Circuit held that under Ford, relatedness does not require the defendant’s in-state activities to directly cause the plaintiff’s injury and, therefore, Texas’s exercise of specific personal jurisdiction over Samsung was proper.
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Ethridge v. Samsung: Fifth Circuit Rejects Different Markets Analysis of Relatedness for Specific Personal Jurisdiction Under Ford
