The Long Arm of APEX: When (and Where) does Amazon’s Private Enforcement Mechanism Create Personal Jurisdictional

The Federal Circuit's decision in SnapRays, LLC v. Lighting Defense Group, LLC has sparked debate, with the patentee's use of Amazon's APEX process leading to a jurisdictional dispute. The case involves SnapRays, a Utah company, suing LDG, a Delaware company, in Utah federal court over patent infringement. The Federal Circuit reversed the district court's dismissal, asserting that LDG's enforcement activities targeted SnapRays in Utah, justifying specific jurisdiction. However, LDG argues that the decision conflicts with Supreme Court precedent, particularly Walden v. Fiore, emphasizing the need for intentional conduct by the defendant aimed at the forum state. LDG seeks en banc rehearing, highlighting conflicts with prior Federal Circuit cases and other courts' interpretations of Walden's directive.

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