Snaprays v. Ontel Products Corporation, 2:16-cv-01198

SnapPower (Utah) designs and sells the Guidelight outlet cover with built-in LEDs; Ontel (New Jersey) marketed a competing product called Night Angel.
SnapPower alleges Ontel and its CEO Khubani purchased SnapPower products, copied images/video from SnapPower’s website, and used them in Night Angel marketing and a TV commercial.
SnapPower originally sued (Nov. 2016) asserting patent and other claims, obtained a TRO and then a stipulated preliminary injunction; Telebrands and another individual were later dismissed.
Ontel appeared at the TRO hearing and signed the stipulated preliminary injunction but moved to dismiss for lack of personal jurisdiction two months later.
Ontel provided redesigned product samples; SnapPower removed patent claims but later sought leave to amend to reassert patent and unfair competition claims after analyzing the samples.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal jurisdiction (12(b)(2))	SnapPower relies on Ontel's contacts and forum-related conduct; implicitly argues jurisdiction exists and defendants waived objections by participating in proceedings.	Ontel contends the court lacks personal jurisdiction over it and Khubani.	Court held Ontel waived the personal-jurisdiction defense by participating in the TRO/preliminary injunction proceedings; motion to dismiss denied.
Motion for leave to amend (Rule 15)	SnapPower sought leave to re-assert removed patent and unfair-competition claims after inspecting Ontel’s redesigned product; amendment timely and not prejudicial.	Ontel argued amendment is futile because SnapPower’s patents are invalid and SnapPower is not assignee of some patents, submitting expert declarations.	Court granted leave to amend, finding no apparent undue delay or prejudice and that futility arguments were premature and better addressed on motion to dismiss or summary judgment.

Dudnikov v. Chalk & Vermillion Fine Arts, Inc., 514 F.3d 1063 (10th Cir.) (prima facie showing standard for personal jurisdiction when no evidentiary hearing)
Ins. Corp. of Ir., Ltd. v. Compagnie des Bauxites de Guinee, 456 U.S. 694 (U.S.) (personal-jurisdiction is an individual right that can be waived)
Wyrough & Loser v. Pelmor Laboratories, Inc., 376 F.2d 543 (3d Cir.) (participation in preliminary injunction hearing can waive personal-jurisdiction defense)
Marquest Med. Prods., Inc. v. EMDE Corp., 496 F. Supp. 1242 (D. Colo.) (same waiver principle where defendants submitted to stipulation restraining them)
Minter v. Prime Equip. Co., 451 F.3d 1196 (10th Cir.) (Rule 15 standard; leave to amend within district court discretion)