A Love of Food I, LLC v. Maoz Vegetarian USA, Inc., 870 F. Supp. 2d 415

Maoz Vegetarian USA, Inc. moved for summary judgment on lack of personal jurisdiction; A Love of Food I, LLC cross-moved for summary judgment.
Court held an evidentiary hearing on June 18, 2012 to consider personal jurisdiction, ultimately finding no Maryland jurisdiction over Maoz and transferring the case to DC court per stipulation.
Maoz is a Delaware corporation based in New York; ALOF is a Delaware LLC with Maryland-listed principal office that operated a Maoz in Washington, DC from 2009 to 2012.
Franchise negotiations occurred primarily in New York and DC; Maoz did not visit Maryland and was not aware that Wallis co-owners resided in Maryland for much of the process.
ALOF alleged MD mailing of UFOC and Franchise Agreement and telephone communications into Maryland; discovery showed minimal Maryland-directed activity by Maoz and DC-focused negotiations.
Court granted Maoz’s summary judgment on personal jurisdiction, denied moot MOUs, and transferred case to the DC district court as proper venue under the stipulation of both parties.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 6-103(b)(1) supports Maryland jurisdiction	ALOF contends Maoz transacted business in Maryland.	Maoz had limited Maryland activity; negotiations centered in DC/NY.	No Maryland transacting business; § 6-103(b)(1) not satisfied.
Whether § 6-103(b)(3) supports Maryland jurisdiction	ALOF asserts injury and acts occurred in Maryland due to fraud.	Acts occurred in NY/DC; injury primarily DC; no Maryland-targeted conduct.	Insufficient Maryland-based injury/acts; § 6-103(b)(3) not satisfied.
Whether due process permits specific jurisdiction over Maoz	Maryland ties via principal office and mailing.	Contacts with Maryland are minimal; negotiations were in DC/NY; random Maryland ties.	No sufficient minimum contacts; due process not satisfied for Maryland.
Whether to dismiss or transfer the case	Dismissal to appeal jurisdiction or refile elsewhere.	Transfer preferable to avoid statute-of-limitations risk.	Transfer to DC district court ordered rather than dismissal.

Carefirst of Md., Inc. v. Carefirst Pregnancy Ctrs., Inc., 334 F.3d 390 (4th Cir. 2003) (long-arm and due process considerations merge; jurisdiction limits)
Int'l Shoe Co. v. Washington, 326 U.S. 310 (Supreme Court 1945) (establishes minimum contacts for due process)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (Supreme Court 1985) (purposeful availment; substantial connection required)
McGee v. Int’l Life Ins. Co., 355 U.S. 220 (Supreme Court 1957) (injury and forum connection considerations for jurisdiction)
Bahn v. Chi. Motor Club Ins. Co., 98 Md.App. 559, 634 A.2d 63 (Md. Ct. App. 1993) ( Maryland long-arm jurisdiction standards)