The Idaho ruling follows the firm’s successful dismissal of the same client in the U.S. District Court for the District of Arizona on December 2, 2025. In that case, the court held that the client had not purposefully availed itself of jurisdiction in Arizona and that the plaintiff had failed to establish that his claims arose out of or were related to the client’s forum contacts.

“These successive dismissals confirm that courts in the Ninth Circuit are faithfully applying the Supreme Court’s 2021 Ford Motor Co. framework and requiring plaintiffs to demonstrate that a foreign manufacturer’s contacts with the forum state are both substantive and temporally relevant,” said Michael J. Salimbene, Reed Smith partner. “We demonstrated in both Arizona and Idaho that a passive website, third-party dealer relationships, and post-injury contacts simply cannot substitute for genuine purposeful availment of the forum.”

In both cases, plaintiffs sought to establish personal jurisdiction based on the client’s website, dealer listings, and the activities of unaffiliated third-party distributors in Arizona and Idaho. Reed Smith moved to dismiss under Rule 12(b)(2), arguing that the client lacked sufficient minimum contacts with the states and that plaintiffs could not demonstrate that the manufacturer had purposefully availed itself of the forum states. The court applied the Ninth Circuit’s three-prong Schwarzenegger test and concluded that the plaintiffs had failed to satisfy their burden on both the purposeful availment and the “arise out of or relate to” prongs.

Salimbene conducted the oral argument in both cases.

Critical to both victories was Reed Smith’s argument regarding the timing of the defendant’s alleged contacts. Under Ninth Circuit precedent, including Steel v. United States, 813 F.2d 1545 (9th Cir. 1987), due process requires courts to evaluate a defendant’s forum contacts “when the events that gave rise to the suit occurred” – not at the time of the lawsuit. In both cases, Reed Smith demonstrated that plaintiffs relied on website content and dealer relationships that postdated the accrual of the cause of action, rendering those contacts irrelevant to the jurisdictional analysis.

The client was represented by a cross-border team or Reed Smith lawyers led by Cheryl Yu (Hong Kong) and Michael J. Salimbene (Philadelphia), with the assistance of Sarah B. Johansen (San Francisco) and Cheri Leung (Hong Kong).

The Hong Kong team was instrumental in managing the client relationship and ensuring alignment with the client’s strategic business objectives in China and the United States, while the U.S. team took the lead on litigation strategy and courtroom advocacy.