Temple v. Ghadimi, 2:22-cv-02261

Plaintiffs: Benjamin Temple (Kansas resident) and Watch Overkill, LLC (Kansas). Defendants: Pejman Ghadimi and Secret Consulting Florida, LLC d/b/a Watch Trading Academy (Florida).
Temple purchased access to WTA courses and, after connecting with Luis Miranda (a purported WTA "prize student"), contracted to buy eight watches for delivery to Kansas; only one watch was delivered.
Temple discovered Miranda’s false claims of profits (which Ghadimi had endorsed) and shared those findings with industry members; Ghadimi then posted allegedly defamatory statements about Temple in WTA’s private Facebook group.
The Facebook group was a preexisting, geographically neutral industry forum with hundreds of international members and automatic membership for WTA enrollees; the post did not mention Kansas.
Plaintiffs sued for fraud, defamation, and tortious interference; Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(2) for lack of personal jurisdiction.
The court granted Defendants’ motion: it found no purposeful direction at Kansas under the harmful‑effects test and rejected Plaintiffs’ agency theory (no evidence Miranda was Defendants’ agent).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether specific personal jurisdiction exists over Defendants for the defamatory Facebook post (purposeful direction/harmful‑effects test)	Ghadimi knew Temple was a Kansas resident and the injury would be felt in Kansas, so the post was expressly aimed at Kansas	Post was made in a neutral, global WTA Facebook group; content was geographically neutral and not targeted at Kansas	No specific jurisdiction: post not expressly aimed at Kansas; harms framework not satisfied
Whether mere knowledge of plaintiff's Kansas residency suffices to establish purposeful direction	Knowledge that Temple is in Kansas means defendants should expect harm to be felt there, supporting jurisdiction	Knowledge alone is insufficient; the forum must be the focal point of the tortious conduct	Knowledge alone is insufficient to establish purposeful direction
Whether Defendants are subject to jurisdiction under K.S.A. § 60‑308(b)(1)(E) because Miranda acted as their agent in a contract to be performed in Kansas	Miranda was Defendants’ agent and the contract to deliver watches to Kansas subjects Defendants to Kansas jurisdiction	Miranda was not Defendants’ agent; Defendants never agreed to ship watches to Kansas; affidavits deny agency	No jurisdiction under the statute: Plaintiffs offered no affidavit proving agency and Defendants’ uncontroverted affidavit denies it

Silver v. Brown, [citation="382 F. App'x 723"] (10th Cir. 2010) (holding targeted online content aimed at plaintiff’s forum can support specific jurisdiction)
Shrader v. Biddinger, 633 F.3d 1235 (10th Cir. 2011) (geographically‑neutral internet posts in a neutral forum do not establish specific jurisdiction)
Dudnikov v. Chalk & Vermilion Fine Arts, Inc., 514 F.3d 1063 (10th Cir. 2008) (articulating the harmful‑effects test and requiring the forum be the focal point)
Walden v. Fiore, 571 U.S. 277 (2014) (knowledge of a plaintiff’s forum alone does not establish purposeful availment or jurisdiction)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (minimum contacts and purposeful availment principles for specific jurisdiction)
Dental Dynamics, LLC v. Jolly Dental Grp., LLC, 946 F.3d 1223 (10th Cir. 2020) (applying the harmful‑effects framework to intentional torts)