Melissa Dilworth and Thomas Trae Dilworth v. LG Chem, Ltd. and LG Chem America, Inc., 355 So.3d 201

In 2018 Melissa Dilworth suffered severe burns when an LG Chem 18650 lithium‑ion battery exploded in a vape device she carried; battery was purchased in Mississippi.
Plaintiffs sued LG Chem (South Korea manufacturer) and LG Chem America (Georgia subsidiary) among others; both moved to dismiss for lack of personal jurisdiction.
LG Chem submitted affidavits denying offices, property, employees, or authorized sales of standalone 18650 cells to consumers in Mississippi; plaintiffs alleged LG Chem places products into the U.S. stream of commerce and profits from nationwide sales.
The circuit court denied jurisdictional discovery, granted the motions to dismiss for lack of specific personal jurisdiction, and certified final judgment as to LG Chem and LG Chem America.
On appeal the Mississippi Supreme Court applied the stream‑of‑commerce and Ford Motor analysis, held LG Chem purposefully availed itself of the Mississippi market, reversed dismissal as to LG Chem, and reversed/remanded for jurisdictional discovery as to LG Chem America.

Issue	Dilworths' Argument	LG Chem's Argument	Held
Whether Mississippi has specific personal jurisdiction over LG Chem (foreign manufacturer)	LG Chem placed batteries into the U.S. stream of commerce and expected sales in Mississippi; injury arose in Mississippi	LG Chem lacks sufficient minimum contacts with Mississippi; batteries not authorized for standalone consumer use so exposure is fortuitous	Court: LG Chem purposefully availed itself of the Mississippi market; specific jurisdiction satisfies due process — reversal of dismissal
Whether unauthorized/third‑party resale (standalone vape use) defeats jurisdiction	Misuse is a merits issue; placement into stream of commerce is the relevant contact	Unauthorized standalone use severs the required nexus for jurisdiction and precludes foreseeability	Court: Misuse goes to merits, not jurisdiction; deliberate exploitation of U.S. market suffices to satisfy "relates to" requirement under Ford
Whether dismissal of LG Chem America (subsidiary) was appropriate without discovery	Plaintiffs sought jurisdictional discovery to develop facts about LG Chem America’s Mississippi contacts and distribution role	LG Chem America contended insufficient contacts and provided limited affidavits	Court: Dismissal premature; remanded for jurisdictional discovery regarding LG Chem America

Int'l Shoe Co. v. Washington, 326 U.S. 310 (1945) (establishes minimum contacts due‑process standard)
World‑Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (foreseeability alone insufficient; purposeful availment required)
Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 141 S. Ct. 1017 (2021) (manufacturer serving a forum's market can be subject to specific jurisdiction when product malfunctions there)
J. McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873 (2011) (plurality views on stream‑of‑commerce and targeted conduct)
Asahi Metal Indus. Co. v. Superior Court, 480 U.S. 102 (1987) (divided Court on stream‑of‑commerce standards)
Daimler AG v. Bauman, 571 U.S. 117 (2014) (limits on general jurisdiction)
Walden v. Fiore, 571 U.S. 277 (2014) (contacts must be with the forum state itself)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (purposeful availment and fair‑play analysis)
LG Chem, Ltd. v. Lemmerman, 863 S.E.2d 514 (Ga. Ct. App. 2021) (found Georgia specific jurisdiction over LG Chem under stream‑of‑commerce/Ford analysis)
Ainsworth v. Moffett Eng'g, 716 F.3d 174 (5th Cir. 2013) (Fifth Circuit follows stream‑of‑commerce approach to minimum contacts)
Sorrells v. R & R Custom Coach Works, Inc., 636 So. 2d 668 (Miss. 1994) (no purposeful availment where manufacturer did not target Mississippi market)
Christopher v. DePuy Orthopaedics, Inc., 888 F.3d 753 (5th Cir. 2018) (manufacturer may avail itself by sending goods into forum's stream of commerce)