Mavrix Photo, Inc. v. Brand Technologies, Inc.

Mavrix Photo, Inc. (“Mavrix”) sued Brand Technologies, Inc. and its CEO, Brad Mandell (collectively, “Brand”), in federal district court for the Central District of California, alleging that Brand infringed Mavrix’s copyright by posting its copyrighted photos on its website. Brand moved to dismiss for lack of personal jurisdiction. See Fed.R.Civ.P. 12(b)(2). The district court denied Mavrix’s motion for jurisdictional discovery and granted Brand’s motion to dismiss. We reverse. We hold that Brand is not subject to general personal jurisdiction in California, but that its contacts with California are sufficiently related to the dispute in this case that it is subject to specific personal jurisdiction.

I. Background

Mavrix, a Florida corporation with its principal place of business in Miami, is a celebrity photo agency. Mavrix pays photographers for candid photos of celebrities. Its primary business is licensing and sell ing those photos to purveyors of celebrity news such as People and Us Weekly magazines. Many of the celebrities whom Mavrix photographs live and work in Southern California. Mavrix keeps a Los Angeles office, employs Los Angeles-based photographers, has a…