Tippsy, Inc. v. Tipsy, LLC, 2:24-cv-04025

Tippsy, Inc. (a California-based company), and Genki Ito (its CEO) sued Tipsy, LLC (a New York-based company), and its owner Amanda Neville over a trademark dispute involving alleged infringement and rights to similar marks related to alcohol sales.
Tippsy California has operated since 2018, selling sake and related goods online and in California; Tipsy New York runs a wine store and website in New York, with limited sales nationwide.
Tipsy New York made a very small percentage of sales to California residents (averaging 19 sales/year until 2021, none in 2022 or later except one gift card), and as of 2023 does not ship wine to California.
In 2023–2024, Tipsy New York sent cease-and-desist letters to Tippsy California, prompting this declaratory and infringement action in the Central District of California.
Defendants moved to dismiss for lack of personal jurisdiction, arguing insufficient minimum contacts with California; plaintiffs opposed, also requesting jurisdictional discovery if needed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the court have specific personal jurisdiction?	Tipsy NY sold to CA customers via its website	Sales to CA were minimal and stopped in 2022; no targeting	No jurisdiction—plaintiffs failed Calder's test
Purposeful direction towards California	Prior CA sales, interactive website shows aim	Minimal, isolated sales; removed CA in 2023	Purposeful direction not adequately shown
Knowledge of harm in forum state	Defendants knew or should have known of harm	No knowledge of Tippsy CA until after CA sales stopped	No knowledge; harm not foreseeable in CA
Are cease-and-desist letters sufficient contact?	Asserted as a basis for jurisdiction	Sending such letters does not create jurisdiction	Cease-and-desist letters are insufficient
Entitlement to jurisdictional discovery	Discovery could uncover more CA connections	No showing that discovery would change result	Discovery request denied

Menken v. Emm, 503 F.3d 1050 (9th Cir. 2007) (establishing burden of proof for personal jurisdiction)
Sher v. Johnson, 911 F.2d 1357 (9th Cir. 1990) (prima facie showing standard for jurisdiction)
Dole Food Co. v. Watts, 303 F.3d 1104 (9th Cir. 2002) (minimum contacts standard)
Calder v. Jones, 465 U.S. 783 (1984) (effects test for purposeful direction of conduct towards forum)
Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797 (9th Cir. 2004) (application of effects test and when to stop jurisdiction analysis)
AT&T v. Compagnie Bruxelles Lambert, 94 F.3d 586 (9th Cir. 1996) (complaint allegations in jurisdictional analysis)