Skidmore v. Led Zeppelin, 106 F. Supp. 3d 581

Plaintiff Michael Skidmore, as trustee for the Randy Craig Wolfe Trust, sued Led Zeppelin members (Page, Plant, Jones) and several music companies for direct, contributory, and vicarious copyright infringement, alleging "Stairway to Heaven" copied Wolfe’s composition "Taurus."
Corporate defendants include Super Hype Publishing, Warner/Chappell Music, Atlantic Recording Corporation, Warner Music Group, and Rhino Entertainment.
Defendants moved to dismiss for lack of personal jurisdiction or improper venue, or alternatively to transfer the case to the Central District of California (CDCA); all defendants consented to jurisdiction and venue in CDCA.
Plaintiff sought jurisdictional discovery if the court required more facts to decide jurisdiction. Plaintiff relied on sales, broadcasts, performances, and one recent radio interview (Page) to establish contacts with the Eastern District of Pennsylvania.
The court analyzed both general (all-purpose) and specific personal jurisdiction under Pennsylvania law (which extends to the constitutional limit) and relevant Supreme Court and Third Circuit precedents, and applied the three-year statute of limitations for copyright claims.
The court found no basis for personal jurisdiction over the individual defendants in Pennsylvania, concluded transfer (rather than dismissal) was appropriate, and transferred the entire action to the Central District of California.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether this Court has general personal jurisdiction over individual defendants	Individuals have continuous, systematic contacts through sales, broadcasts, performances, merchandising in PA	Individuals are UK domiciliaries with no recent or continuous contacts in PA; corporate contacts cannot be imputed	No general jurisdiction — individuals not "essentially at home" in PA
Whether this Court has specific personal jurisdiction over individual defendants	Repeated marketing/sales and past performances (including Page interview) purposefully directed at PA and give rise to the claim	Contacts are too attenuated or stale; only one recent interview and old performances outside limitations period	No specific jurisdiction — alleged contacts insufficient and stale
Whether jurisdictional discovery should be allowed to develop plaintiff's prima facie case	Discovery may reveal additional contacts and should be permitted	Plaintiff failed to allege sufficient facts; discovery would be futile	Denied — plaintiff failed to show a plausible basis for further jurisdictional discovery
Whether to dismiss or transfer the action given improper venue for some defendants	Plaintiff preferred to litigate in EDPA	Defendants consented to CDCA; transfer avoids duplicative litigation and suits all defendants in a forum with relevant witnesses and law	Transferred entire case to the Central District of California in the interest of justice

Int’l Shoe Co. v. Washington, 326 U.S. 310 (established minimum contacts standard for personal jurisdiction)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 131 S. Ct. 2846 (all-purpose jurisdiction requires defendant to be essentially at home in forum)
Daimler AG v. Bauman, 134 S. Ct. 746 (clarified limited circumstances for general jurisdiction)
O’Connor v. Sandy Lane Hotel Co., 496 F.3d 312 (3d Cir.) (personal jurisdiction analyzed under forum state law and federal rules)
Walden v. Fiore, 134 S. Ct. 1115 (due process requires defendant’s own forum contacts; third-party contacts insufficient)
Petrella v. Metro-Goldwyn-Mayer, Inc., 134 S. Ct. 1962 (statute of limitations for copyright claims governs accrual window)
Goldlawr, Inc. v. Heiman, 369 U.S. 463 (transferring, not dismissing, is appropriate when venue improper and transfer is in interest of justice)
Cottman Transmission Sys., Inc. v. Martino, 36 F.3d 291 (3d Cir.) (severance vs transfer considerations when venue improper for some defendants)
Sunbelt Corp. v. Noble, Denton & Assocs., Inc., 5 F.3d 28 (3d Cir.) (avoid severance where issues overlap and would duplicate litigation)