D-J Engineering, Inc. v. 818 Aviation, Inc., 6:14-cv-01033

D-J Engineering (Kansas) and 818 Aviation (California) entered a contract to repair aircraft components; work largely performed at D-J's Augusta, Kansas facility.
818 Aviation's agent (Mark Jeter) solicited bids from D-J in Kansas; 818 submitted purchase orders to D-J in Kansas in 2012 and sent components for repair.
818 Aviation personnel visited the Kansas facility to inspect work and communicated with D-J by phone and email during the relationship.
818 Aviation stopped paying and demanded cessation of work; D-J seeks payment and declaratory relief regarding refunds and delivered components.
818 Aviation filed suit in California alleging multiple contract-related claims; D-J removed to the District of Kansas and then consolidated with the Kansas action.
Judge denied the Rule 12(b)(2) motion to dismiss for lack of personal jurisdiction and held the California action, transferred to Kansas, is consolidated; venue-based dismissal was moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Kansas has specific personal jurisdiction over 818 Aviation	D-J contends 818 purposefully availed Kansas by ongoing contract	818 argues no minimum contacts; contract alone insufficient	Yes; minimum contacts shown via purposeful availment and ongoing relation
Whether the exercise of jurisdiction is reasonable under due process	Jurisdiction burden on plaintiff is manageable; witnesses in Kansas	Defendant may face burden as a California firm	Yes; factors favor plaintiff; jurisdiction reasonable

Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (tests for minimum contacts and reasonableness under due process)
Dudnikov v. Chalk & Vermilion Fine Arts, Inc., 514 F.3d 1063 (10th Cir. 2008) (purposeful direction/availment analysis in 10th Circuit)
Omi Holdings, Inc. v. Royal Ins. Co. of Canada, 149 F.3d 1086 (10th Cir. 1998) (minimum contacts and relatedness in jurisdictional analysis)
Marcus Food Co. v. DiPanfilo, 671 F.3d 1159 (10th Cir. 2011) (contract-based jurisdiction, related to forum state)
Emp’rs Mut. Cas. Co. v. Bartile Roofs, Inc., 618 F.3d 1153 (10th Cir. 2010) (overall framework for analyzing jurisdiction and reasonableness)