Rejuvi Laboratory, Inc. v. Maria Corso

I. Background

Maria Corso is a resident of South Australia, a State in the Commonwealth of Australia. Rejuvi is a California corporation that produces and sells cosmetic products, including a tattoo removal paste. Rejuvi operates a facility in South San Francisco, employs 6 to 9 people, and generates an annual revenue of about $1.4 million.

Rejuvi sells its products in the international market through a network of distributors. In July 2006, Rejuvi entered into an exclusive distribution agreement with Arias Holdings, located in the State of Queensland, Australia. Arias Holdings handled the sale of Rejuvi products in all of Australia, either directly or through subcontracts with others. From 2006 to 2009, Rejuvi made sales in Australia totaling $97,196.80, including $6,560 of tattoo removal products.

Rejuvi’s CEO, Wei Cheng, made two sales trips to Australia. Between November 24 and 30, 2006, he was in Brisbane, in Queensland, and Sydney, in the State of New South Wales. Between August 10 and 23, 2007, he was in Sydney, and in Melbourne, in the State of Victoria. Arias Holdings organized “seminars” on these sales trips, at which Cheng gave lectures about Rejuvi products, and…