Legacy Hemp LLC v. Terramax Holdings Corporation, 3:20-cv-00303

Plaintiff Legacy Hemp LLC (Anderson) entered a 2016 distributor/license agreement with defendant Terramax Holdings Corp., a Saskatchewan, Canada seed company, to distribute X-59 hemp seed in specified U.S. states; the contract identified Legacy’s address as Kentucky and did not list Wisconsin among the specified states.
Anderson conducted negotiations and regular communications from his home in Prescott, Wisconsin; Legacy registered to do business in Wisconsin in April 2018 and later informed Terramax of a Prescott address by email.
Legacy purchased large quantities of X-59 (over 322,890 lbs.) and claims most 2018 sales were to Wisconsin farmers; Legacy arranged pickup of seed in Saskatchewan and received royalty checks in Wisconsin.
Terramax is not registered to do business in Wisconsin, denies marketing, shipping, or directing sales into Wisconsin, and says it never authorized or invoiced Legacy for in-state services.
Procedural posture: Terramax moved to dismiss for lack of personal jurisdiction; Legacy sought a preliminary injunction. The court granted Terramax’s motion to dismiss for lack of specific jurisdiction and denied the injunction as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wisconsin courts have specific personal jurisdiction over Terramax	Terramax contracted with and repeatedly communicated with Legacy (whose principal acted from Wisconsin), built a market and sold seed in Wisconsin, and thus directed activities at Wisconsin	Terramax’s contacts were with Legacy (a separate entity), contract listed Kentucky and other states not Wisconsin, Legacy picked up seed in Canada, and Terramax neither marketed nor shipped to Wisconsin	No: Legacy failed to make a prima facie showing of purposeful availment or minimum contacts with Wisconsin; dismissal for lack of personal jurisdiction granted
Plaintiff’s motion for preliminary injunction	Legacy sought to enjoin termination of distributor rights pending litigation	Terramax argued lack of jurisdiction and opposed relief	Denied as moot after dismissal for lack of personal jurisdiction

Purdue Research Foundation v. Sanofi–Synthelabo, S.A., 338 F.3d 773 (7th Cir. 2003) (prima facie standard for jurisdictional facts)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (purposeful availment and foreseeability analysis)
International Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts and fair play standard)
Walden v. Fiore, 571 U.S. 277 (2014) (contacts must be with the forum state itself)
Felland v. Clifton, 682 F.3d 665 (7th Cir. 2012) (merger of state long-arm and due process analysis)
Lakeside Bridge & Steel Co. v. Mountain State Construction Co., 597 F.2d 596 (7th Cir. 1979) (no jurisdiction where contacts are solely plaintiff’s unilateral activity)
Northern Grain Mktg., LLC v. Greving, 743 F.3d 487 (7th Cir. 2014) (contracting alone insufficient for jurisdiction)
Philos Techs., Inc. v. Philos & D, Inc., 802 F.3d 905 (7th Cir. 2015) (foreign party’s contract with in-state party alone does not establish jurisdiction)