Factory Direct Wholesale, LLC v. Henglin Home Furnishings Co., Ltd., 2:24-cv-07118

Factory Direct Wholesale, LLC (FDW), a Georgia company, sued Henglin Home Furnishings Co., Ltd. (Henglin), a Chinese company, for violating California's Unfair Competition Law via alleged unfair pricing and customs fraud.
FDW claims Henglin unfairly undercuts FDW through fraudulent undervaluation of imported goods to California, seeking restitution and an injunction.
Henglin filed a motion to dismiss the First Amended Complaint on grounds of lack of personal jurisdiction (Rule 12(b)(2)), arguing insufficient contacts with California.
The court previously directed limited jurisdictional discovery to assess Henglin’s forums contacts—particularly its exports and sales activities in California.
After discovery, FDW presented evidence from bills of lading and corporate reports indicating Henglin shipped goods to California and targeted the state through local warehouses and e-commerce.
The court considered both parties' supplemental briefs and evidence on whether Henglin’s actions constituted sufficient forum contacts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Henglin purposefully directed activities at California (jurisdiction)	Henglin exports products and targets California via subsidiaries and warehouses.	Henglin denies direct export/import to California and claims no direct targeting.	FDW showed a prima facie case of purposeful direction.
Whether FDW’s claims arise out of Henglin’s California-related activities	Injury flows from Henglin’s California shipments and business competition.	No facts tie alleged injury or fraud to California activities.	Claim arises from Henglin's forum-related activities.
Reasonableness of exercising jurisdiction over Henglin	California has interest; harm occurs in the forum; defendant targeted CA.	It would be unreasonable; FDW’s claims are unfounded or unclear.	Exercise of jurisdiction is reasonable.
Whether alter ego relationship is required to impute subsidiary contacts	No need; independent evidence shows Henglin’s own targeting of CA.	Must show alter ego to impute activities of subsidiaries.	No alter ego required given Henglin’s direct conduct.

Pebble Beach Co. v. Caddy, 453 F.3d 1151 (9th Cir. 2006) (sets plaintiff's burden and jurisdictional standard)
Ballard v. Savage, 65 F.3d 1495 (9th Cir. 1995) (prima facie showing and reasonableness presumption)
Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797 (9th Cir. 2004) (three-prong test for specific jurisdiction)
Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts/fair play standard)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (purposeful availment & jurisdiction)
Calder v. Jones, 465 U.S. 783 (1984) (effects test for purposeful direction)
Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 592 U.S. 351 (2021) (arising out of/relates to standard for jurisdiction)
Walden v. Fiore, 571 U.S. 277 (2014) (forum contacts must be defendant-created)
Ranza v. Nike, Inc., 793 F.3d 1059 (9th Cir. 2015) (requirements for imputing contacts via subsidiary)