## Facts

- Syngenta owned U.S. patents covering the fungicide azoxystrobin and related manufacturing processes, and claimed copyright in EPA-approved product labels for azoxystrobin products.
- Syngenta sued multiple Willowood entities for patent infringement, copyright infringement, and state-law unfair and deceptive trade practices.
- Willowood Limited (W-Limited) was a foreign company headquartered in Hong Kong that bought and sold pesticides outside the United States and had no offices, employees, property, or agents in North Carolina.
- A wholly owned U.S. subsidiary, Willowood USA, LLC (W-USA), was formed to market and sell azoxystrobin products in the United States and operated from Oregon.
- W-USA purchased azoxystrobin technical material exclusively from W-Limited, imported it into the United States, processed it in Oregon, and sold azoxystrobin fungicide products; W-USA registered products with the EPA.
- Syngenta, located in North Carolina, argued North Carolina personal jurisdiction over W-Limited based on the parent–subsidiary relationship, W-Limited’s role as exclusive supplier, and W-Limited’s awareness that products would be sold nationwide (including North Carolina).
- The record lacked evidence that W-Limited itself shipped to North Carolina, contracted there, marketed there, or specifically directed W-USA to target North Carolina.
- W-Limited moved to dismiss under Rule 12(b)(2) for lack of personal jurisdiction.

## Issues

1. Whether North Carolina could exercise general personal jurisdiction over W-Limited based on its relationship with and the U.S. distribution activities of its subsidiary.
2. Whether North Carolina could exercise specific personal jurisdiction over W-Limited where it supplied product used in goods sold nationwide but did not specifically target North Carolina.
3. Whether jurisdictional discovery was warranted to develop additional facts supporting personal jurisdiction over W-Limited.

## Decision

- The court granted W-Limited’s Rule 12(b)(2) motion and dismissed the claims against W-Limited without prejudice for lack of personal jurisdiction.
- The court held there was no general jurisdiction because W-Limited was not “at home” in North Carolina and the subsidiary’s contacts could not be imputed to the parent on the existing record.
- The court held there was no specific jurisdiction because Syngenta did not show purposeful availment of North Carolina by W-Limited; awareness that goods might reach the forum through downstream distribution was insufficient without forum-directed conduct.
- The court declined to permit jurisdictional discovery because Syngenta did not make a non-speculative, colorable showing that discovery would establish jurisdiction.

## Legal Principles

- General jurisdiction over a corporation is ordinarily limited to where it is “at home,” typically its place of incorporation or principal place of business; routine commercial ties or downstream sales in the forum do not suffice for a foreign corporation.
- A parent corporation is not subject to general jurisdiction in a forum solely because its subsidiary does business there; imputing contacts requires a supported alter-ego or veil-piercing showing.
- Specific jurisdiction requires purposeful availment: placing product into the stream of commerce, or awareness it may reach the forum, does not establish minimum contacts absent conduct directed at the forum state.
- Courts may deny jurisdictional discovery where the plaintiff offers only speculation rather than a concrete factual basis suggesting discovery will establish personal jurisdiction.

## Conclusion

The court dismissed the foreign parent supplier for lack of personal jurisdiction in North Carolina, holding that neither general nor specific jurisdiction existed on the record and that the subsidiary’s forum contacts could not be attributed to the parent absent evidence supporting alter-ego treatment.


Syngenta Crop Prot., LLC v. Willowood, LLC, 139 F. Supp. 3d 722 (M.D.N.C. 2015)