Old Republic Ins. Co. v. Cont’l Motors, Inc., 877 F.3d 895 (10 Cir. Dec. 15, 2017).

In this appeal from the district court’s dismissal for lack of personal jurisdiction, the Tenth Circuit provides a thorough overview of specific personal jurisdiction jurisprudence, including the three means by which a plaintiff may establish the requisite “personal direction” by the defendant. The case involved claims against the manufacturer of an aircraft’s engine parts following a crash on a flight from Colorado to Idaho. The defendant-manufacturer is a Delaware corporation with its principal place of business in Alabama. The case was brought in Colorado. The defendant-appellant’s website allowed fixed-base operators (FBOs) to obtain unlimited access to its online service manuals in exchange for an annual fee. A Colorado-based FBO who participated in the program serviced the aircraft involved in the crash. The Tenth Circuit held the defendant-appellant’s website, its online service manuals, and the service company’s participation in the FBO program were insufficient to establish specific personal jurisdiction under any of the three “purposeful direction” tests – continuing relationships, market exploration, or harmful effects.