Hastens Sangar AB v. The Garrigan Group, LLC

facts that suggest the Garrigan Group otherwise targeted California. Indeed, the Garrigan Group did not advertise, sell, or ship the sofa to anyone in California. The two prior California sales likewise fail to suggest purposeful direction. Those sales make up less than 0.02% of the Garrigan Group’s total gross revenue since it started listing items

1 This order assumes that the reader is familiar with the case. on Chairish. And the fact that the purchasers were in California seems entirely incidental, not purposeful. As with the sofa, the Garrigan Group listed the relevant items on a platform available anywhere with internet access. California customers were not specifically targeted for those sales, nor did the sales create for the Garrigan Group any “‘substantial connection’ or ongoing obligations” in California. See Boschetto v. Hansing, 539 F.3d 1011, 1019 (9th Cir. 2008). In any event, even if those two sales somehow suggested purposeful direction and thus constituted “forum-related activities,” Hästens cannot seriously argue that its claim here “arises out of or relates to” those activities. See Williams v. Yamaha Motor Co. Ltd., 851 F.3d 1015, 1023 (9th Cir. 2017). Those…