Jayco, Inc. v. National Indoor RV Centers, LLC
3:17-cv-00458
N.D. Ind.Sep 26, 2017Background
- Jayco (Indiana) owns Entegra Coach trademarks and sells through independent dealers; National (Texas) and subsidiaries (Arizona, Georgia) were Entegra dealers under dealership agreements limiting sales to designated territories.
- National Arizona and National Georgia ordered Entegra motorhomes and parts from Jayco (orders/invoices processed in Texas; parts portal hosted in Indiana); warranty requests and claims were submitted to Jayco’s Indiana warranty center.
- Jayco alleges National and sales agent Angie Morell used Entegra trademarks to market/sell motorhomes from National’s Lewisville, Texas location (outside their authorized territory), causing trademark infringement, unfair competition, and breach of contract.
- Jayco hired a private investigator who reported Morell and other National staff showing Entegra materials and arranging purchases from the Texas location; Morell sold Entegra units for National Arizona/Georgia and received sales incentives from Jayco.
- National terminated dealer agreements in response to Jayco’s cease-and-desist; National sued Jayco in Texas; Jayco sued National and Morell in the Northern District of Indiana for trademark infringement, unfair competition, and breach of contract.
- Defendants moved to dismiss for lack of personal jurisdiction and improper venue; court granted the motion and dismissed the case, vacating Jayco’s preliminary-injunction proceedings as moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction (specific) over National defendants | National’s regular contacts with Jayco (large purchases, parts orders via Indiana-hosted portal, thousands of warranty submissions, technician training, communications) subject them to specific jurisdiction in Indiana | The claims arise from defendants’ conduct in Texas (unauthorized use/sales there); Indiana contacts are unrelated to the alleged trademark infringement/unfair competition | Court held no specific jurisdiction: plaintiff’s claims do not arise out of defendants’ Indiana contacts; relevant wrongful conduct occurred in Texas |
| Personal jurisdiction over Angie Morell | Morell’s sales incentives, communications with Jayco, and some contacts with Indiana (customer lists, production requests, plant tour referrals) = sufficient contacts | Morell’s alleged infringing acts and sales activity occurred in Texas (or in Arizona/Georgia); her limited contacts with Indiana are unrelated to the claims | Court held no specific jurisdiction over Morell for the same reasons as other defendants |
| General jurisdiction | Jayco did not allege general jurisdiction; defendant not "at home" in Indiana | Defendants are not incorporated or principally based in Indiana; not subject to general jurisdiction | Court found general jurisdiction not alleged or supported |
| Venue in Northern District of Indiana | Jayco pleaded venue proper because it does business in Indiana and allegedly felt harm there | Defendants argued venue improper: defendants do not reside in Indiana and the substantial events giving rise to the claims occurred elsewhere (Texas) | Court held venue improper under 28 U.S.C. § 1391(b); dismissed case and denied related motions as moot |
Key Cases Cited
- Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796 (7th Cir.) (personal jurisdiction standards and evidence weighing)
- Tamburo v. Dworkin, 601 F.3d 693 (7th Cir.) (plaintiff must submit affirmative evidence after defendant rebuts jurisdictional allegations)
- Purdue Research Foundation v. Sanofi-Synthelabo, S.A., 338 F.3d 773 (7th Cir.) (district court may consider affidavits and other evidence on jurisdiction)
- Walden v. Fiore, 134 S. Ct. 1115 (Sup. Ct.) (plaintiff’s forum connections alone cannot authorize jurisdiction; defendant’s contacts with the forum required)
- Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (Sup. Ct.) (specific jurisdiction requires claim-by-claim connection to forum)
- Daimler AG v. Bauman, 134 S. Ct. 746 (Sup. Ct.) (limits on general jurisdiction; corporation is at home where incorporated or principal place of business)
- International Shoe Co. v. Washington, 326 U.S. 310 (Sup. Ct.) (minimum contacts and fair play and substantial justice test)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (Sup. Ct.) (purposeful availment and reasonable anticipation of being haled into court)