B3DC NAVY YARD, LLC v. EPOCH DESIGN GROUP, INC, 1:19-cv-02939

B3DC (a D.C. LLC) contracted Epoch (Missouri architect) to design/build a Barre3 studio in D.C.; Epoch retained Catalyst (an Ohio mechanical-engineering firm) in 2017 to design the HVAC system.
Catalyst’s written proposal forbade in-person meetings and site visits and provided that Catalyst would send mechanical drawings to Epoch in Missouri; Catalyst billed only $3,250 and performed design work from Ohio.
Construction completed in late 2018; in 2019 an HVAC pipe ruptured, flooding the studio and causing months of closure for repairs.
B3DC sued Epoch (and the installer Alltherm) for breach and negligence; Epoch filed a third-party claim against Catalyst seeking indemnity if Epoch is held liable.
Catalyst moved to dismiss Epoch’s third-party complaint for lack of personal jurisdiction, arguing it had no sufficient contacts with D.C.; the Court granted the motion, finding Catalyst did not contract to supply services in D.C.

Issue	Plaintiff's Argument	Defendant's Argument	Held
General jurisdiction — whether Catalyst is "at home" in D.C.	Epoch did not seriously contest general jurisdiction.	Catalyst: incorporated and headquartered in Ohio, not subject to general jurisdiction in D.C.	Denied — no general jurisdiction; Catalyst not "at home" in D.C.
Specific jurisdiction under D.C. long-arm §13-423(a)(2) (contracting to supply services in D.C.)	Epoch: Catalyst supplied the HVAC design that caused the harm in D.C., so it contracted to supply services in the District.	Catalyst: contract required delivery of designs to Epoch in Missouri and disallowed site visits; all design work occurred in Ohio, not within D.C.	Denied — contract did not obligate Catalyst to supply services in D.C.; long-arm statute not satisfied, so no specific jurisdiction.

FC Inv. Grp. LC v. IFX Mkts., Ltd., 529 F.3d 1087 (plaintiff bears burden to establish personal jurisdiction)
Livnat v. Palestinian Auth., 851 F.3d 45 (resolve factual disputes in plaintiff’s favor when assessing jurisdictional facts)
United States v. Ferrara, 54 F.3d 825 (both long-arm statute and due process must be satisfied for jurisdiction)
Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (standard for general jurisdiction)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (general jurisdiction principles)
Daimler AG v. Bauman, 571 U.S. 117 (corporate "at home" standard for general jurisdiction)
Dumitrescu v. DynCorp Int’l, LLC, 257 F. Supp. 3d 13 (D.C. long-arm applies only where defendant contracted to supply services within D.C.)
D’Onofrio v. SFX Sports Group, Inc., 534 F. Supp. 2d 86 (no need to reach due-process minimum-contacts analysis if long-arm statute not satisfied)