Polyloom Corporation of America v. Grassroots Environmental Education, Inc.
1:25-cv-00014
E.D. Tenn.Jul 29, 2025Background
- Plaintiff Polyloom Corporation of America (doing business as TenCate Grass North America) alleges defamation, trade libel, and tortious interference against Grassroots Environmental Education, Inc. ("Grassroots") and four individual defendants.
- The claims center on allegedly false statements about the health risks of artificial turf, including email campaigns, social media posts, and a webinar promoted by Grassroots.
- Plaintiff is headquartered in Tennessee and claims Grassroots deliberately targeted Tennessee residents by sending emails to specific individuals in the state.
- Defendants moved to dismiss for lack of personal jurisdiction, arguing insufficient contacts with Tennessee and denying intentional targeting.
- After jurisdictional discovery and an evidentiary hearing, the court considered whether specific jurisdiction existed over each defendant and whether the case should be transferred to New York.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal Jurisdiction over Grassroots | Grassroots purposefully directed tortious acts into TN | No sufficient contact or intentional targeting of TN | Jurisdiction proper due to targeted emails into TN |
| Personal Jurisdiction over Individuals | Individual defendants also responsible | No evidence individuals targeted TN or participated in emails | No jurisdiction over individuals, claims dismissed |
| Effect of Social Media Posts | Bennett's tweets harmed TN company | Tweets not specifically aimed at TN audience | Tweets not enough for jurisdiction under Calder |
| Forum Non Conveniens/Transfer | Retain venue in Tennessee | NY more appropriate; burden on non-profit, witnesses in NY | Parties to brief whether transfer to EDNY is warranted |
Key Cases Cited
- Air Prods. & Controls, Inc. v. Safetech Int’l, Inc., 503 F.3d 544 (6th Cir. 2007) (burden of establishing personal jurisdiction; post-discovery must show by preponderance)
- AlixPartners, LLP v. Brewington, 836 F.3d 543 (6th Cir. 2016) (personal jurisdiction analysis under Sixth Circuit's three-part test)
- Bird v. Parsons, 289 F.3d 865 (6th Cir. 2002) (personal jurisdiction standard; interaction with forum's long-arm statute)
- Calder v. Jones, 465 U.S. 783 (1984) ("express aiming" test for intentional tort jurisdiction)
- Neal v. Janssen, 270 F.3d 328 (6th Cir. 2001) (purposeful availment through communications into forum)
- Bridgeport Music, Inc. v. Still N The Water Pub., 327 F.3d 472 (6th Cir. 2003) (Tennessee's long-arm statute reaches as far as due process allows)
- Walden v. Fiore, 571 U.S. 277 (2014) (mere injury in forum is not enough—defendant must create contacts with forum)
- Reynolds v. Int’l Amateur Athletic Fed’n, 23 F.3d 1110 (6th Cir. 1994) (defendant must expressly target forum state for specific jurisdiction)