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Rockwood Select Asset Fund XI (6)-1, LLC v. Devine, Millimet & Branch, 2014 WL 1778048 (10th Cir. May 6, 2014) 

May 6, 2014

In this personal jurisdiction case, a Utah lender obtained an opinion letter from a New Hampshire law firm. The lender later sued the law firm in Utah federal court. Relying in part on Walden v. Fiore, 134 S. Ct. 1115 (2014), the Tenth Circuit held personal jurisdiction cannot be based solely on interaction with a “plaintiff known to bear a strong connection to the forum state.” Sending an opinion letter to a Utah address and participating in telephone communications with a Utah resident were also insufficient.