Key Tronic Corporation v. Smart Technologies ULC, 2:16-cv-00028

Background

Key Tronic (WA) sued Steel Technologies de Mexico, S.A. de C.V. (Steel Tech Mexico), a Juarez-based Mexican steel processor, over alleged defects in components supplied for an electronic whiteboard project (the SMART Project). Complaint filed in EDWA; Steel Tech Mexico moved to dismiss for lack of personal jurisdiction and insufficient service. Court considered motion on written submissions.
The parties’ commercial relationship arose after Key Tronic’s parent purchased a Sabre manufacturing facility in Juarez; Key Tronic Mexico (a Mexican subsidiary) managed Mexican operations. Steel Tech Mexico performed, inspected, and delivered all goods in Mexico to Key Tronic’s Juarez facility.
Key Tronic sent purchase orders from its Spokane Valley, Washington offices; Steel Tech Mexico confirmed orders by email, sent invoices to Washington, and exchanged hundreds of communications with Key Tronic. Some contracts/NDA contained a Washington choice-of-law clause (the NDA only).
Steel Tech Mexico made two trips to Spokane after the dispute arose to try to resolve issues; most meetings (40+) and performance occurred in Mexico. No offices, employees, property, or taxes in the U.S.; no deliveries to Washington.
The district court treated disputed facts in Plaintiff’s favor but found Key Tronic failed to make a prima facie showing that Steel Tech Mexico purposefully availed itself of Washington. Court denied jurisdictional discovery and granted dismissal for lack of personal jurisdiction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has specific personal jurisdiction over Steel Tech Mexico	Key Tronic: Steel Tech Mexico purposefully availed itself of Washington through repeated contracts, emailed purchase orders and invoices sent to Spokane, choice-of-law NDA, and extensive communications managed from Washington	Steel Tech Mexico: All negotiation, performance, delivery, inspection, and alleged breaches occurred in Mexico; emails and billing to Washington were administrative and resulted from Key Tronic’s decision to centralize operations in Spokane	Held: No. Plaintiff failed to show purposeful availment—the contacts were incidental or resulted from Key Tronic’s unilateral conduct; performance and consequences were centered in Mexico.
Whether Steel Tech Mexico’s post-dispute visits to Washington support jurisdiction	Key Tronic: Two in-person visits to Spokane demonstrate purposeful contact	Steel Tech Mexico: Visits occurred after the dispute arose and thus are not considered for jurisdictional contacts	Held: Visits excluded from purposeful-availment analysis because they occurred post-dispute and cannot establish pre-suit contacts.
Relevance of contractual terms (NDA choice-of-law and indemnity clause) to jurisdiction	Key Tronic: NDA’s Washington choice-of-law and indemnity designation show intent to be tied to Washington	Steel Tech Mexico: NDA is not the contract at issue; purchase orders (not governed by Washington law) controlled performance, and indemnity designation is ambiguous/administrative	Held: NDA and indemnity provision are insufficient to establish jurisdiction because they are peripheral to the dispute and do not demonstrate deliberate targeting of Washington.
Whether jurisdictional discovery should be allowed	Key Tronic: Requests discovery to uncover additional Washington contacts	Steel Tech Mexico: Discovery unnecessary; record is clear and discovery would be burdensome	Held: Denied. Court found plaintiff failed to identify what discovery would show and the existing record was sufficient to decide jurisdiction.

Key Cases Cited

Int’l Shoe Co. v. Washington, 326 U.S. 310 (framework for minimum contacts/personal jurisdiction)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (purposeful availment and reasonableness analysis)
Walden v. Fiore, 134 S. Ct. 1115 (plaintiff cannot be the only link between defendant and forum)
Picot v. Weston, 780 F.3d 1206 (specific jurisdiction requires nexus between forum contacts and claim)
Mavrix Photo, Inc. v. Brand Techs., Inc., 647 F.3d 1218 (prima facie showing standard when jurisdictional facts challenged)
Harris Rutsky & Co. Ins. Servs. v. Bell & Clements Ltd., 328 F.3d 1122 (standard for reviewing denial of jurisdictional discovery)
Data Disc, Inc. v. Systems Technology Associates, Inc., 557 F.2d 1280 (prima facie showing and when courts may take evidence on jurisdiction)