The Supreme Court wrote two major personal jurisdiction opinions in 2011: Goodyear Dunlop Tires v. Brown, 131 S. Ct. 2846, about general personal jurisdiction based on product sales into a state, and J. McIntyre Machinery v. Nicastro, 131 S. Ct. 2780, analyzing specific personal jurisdiction based on a “stream of commerce” theory. In ITL International v. Constenla, S.A., the Fifth Circuit’s first lengthy personal jurisdiction opinion since then, the Court found that a defendant’s acceptance of 55 shipments of goods in Mississippi was “purposeful contact,” but went on to find no specific jurisdiction because the parties’ trademark dispute had too weak a link to those contacts. No. 10-60892 at 11 (Jan. 31, 2012) The Court did not address general jurisdiction and thus did not directly engage the Goodyear case.
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