CollegeSource, Inc. v. AcademyOne, Inc.

CollegeSource, Inc. (“CollegeSource”) sued AcademyOne, Inc. (“AcademyOne”) in federal district court for the Southern District of California, alleging that AcademyOne misappropriated material from CollegeSouree’s websites. AcademyOne moved to dismiss for lack of personal jurisdiction. See Fed.R.Civ.P. 12(b)(2). After jurisdictional discovery, the district court granted AcademyOne’s motion to dismiss. We reverse. We hold that AcademyOne is not subject to general personal jurisdiction in California, but that it is subject to specific personal jurisdiction there.

I. Background

CollegeSource and AcademyOne compete in the market to assist students and educational institutions with the college transfer process. CollegeSource, a California corporation with its principal place of business in California, maintains a digital collection of 44,000 course catalogs from 3,000 colleges and universities dating back to 1993. Each catalog is available as a .pdf file on CollegeSource’s websites collegesource.com, collegesource.org, and tes.collegesource.org. Students and college administrators may consult the catalogs to compare courses at different schools, or to research what credits a…