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ClearOne, Inc. v. Revolabs, Inc., 2016 UT 16 (Mar. 23, 2013)

Mar 23, 2016

Massachusetts company that recruited Texas employee of Utah company lacked sufficient contacts with Utah to support specific or general jurisdiction here. The court scaled back the “effects” test of Pohl, Inc. of America v. Webelhuth, 2008 UT 889, 201 P.3d 944, to require that the effects be broader than just impact on the plaintiff who resides here, and that instead they create a “substantial connection” with the state. The court also rejected a general “doing business” argument that was based primarily on an Internet presence here.