Intellectual Ventures I LLC v. Ricoh Co., 67 F. Supp. 3d 656

IV I and IV II sued Ricoh defendants for patent infringement on March 25, 2013.
Defendants moved to dismiss for lack of personal jurisdiction over RCL and for failure to state joint/contributory infringement.
IV I/II are Delaware LLCs headquartered in Bellevue, Washington; RCL is a Japanese corporation; RAC and REI are its subsidiaries (DE and CA).
Court has jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
Court grants lack of personal jurisdiction over RCL and denies the contributory/joint infringement dismissal.
Court applies Delaware long-arm statute and due-process analysis; finds no general or dual jurisdiction; declines jurisdictional discovery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal jurisdiction over RCL	IV I/II assert general or dual jurisdiction under Delaware long-arm statute.	RCL has no in-state acts, no U.S. sales, and insufficient contacts; Daimler limits general jurisdiction.	Lack of personal jurisdiction over RCL granted.
Contributory/joint infringement pleadings	Plaintiffs plead plausible contributory infringement with knowledge and infringing components.	(Implied) challenge to sufficiency under Rule 12(b)(6).	Contributory and joint infringement claims denied to be dismissed; pleaded adequately.

Daimler AG v. Bauman, 571 U.S. 117 (2014) (general jurisdiction limits for foreign corporations)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (minimum contacts and forum state relationship to contract)
World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (foreseeability and due process in interstate issues)
Shoemaker v. McConnell, 556 F. Supp. 2d 351 (D. Del. 2008) (Delaware long-arm specific jurisdiction analysis)
Applied Biosystems, Inc. v. Cruachem, Ltd., 772 F. Supp. 1458 (D. Del. 1991) (general jurisdiction by continuous and systematic contacts)
Walker Digital, LLC v. Facebook, Inc., 852 F. Supp. 2d 559 (D. Del. 2012) (pleading sufficiency for contributory infringement)