## Facts

- Trintec Industries, Inc. (Canada) and Time to Invent, LLC (D.C.) sued Pedre Promotional Products, Inc. (New York) for infringement of patents covering automated small-volume production of printed faces used in watches and clocks.
- Trintec filed the infringement action in the U.S. District Court for the District of Columbia.
- Pedre’s president declared Pedre had no offices, employees, manufacturing facilities, or sales representatives in Washington, D.C.
- Pedre sold watches and clocks nationwide through distributors; approximately 0.1% of its total sales were in the District of Columbia.
- Pedre used an independent sales representative who spent about four to five days per year in Washington, D.C. for Pedre and other clients.
- Pedre maintained a commercially oriented website advertising its products and enabling sales accessible from the District of Columbia.
- Pedre moved to dismiss for lack of personal jurisdiction and improper venue (or to transfer); the district court dismissed for lack of personal jurisdiction.
- Trintec appealed to the Federal Circuit.

## Issues

1. Whether Pedre’s Internet activity, sales through distributors, and limited in-forum activity supported personal jurisdiction in the District of Columbia for a patent infringement claim under the D.C. long-arm statute and the Due Process Clause.
2. Whether the district court erred by dismissing for lack of personal jurisdiction without adequately analyzing how Pedre’s contacts related to the alleged infringing sales or offers for sale in the District.

## Decision

- The Federal Circuit vacated the dismissal and remanded.
- The court did not decide whether personal jurisdiction existed; it held the district court’s jurisdictional analysis was incomplete.
- The district court was directed to reconsider personal jurisdiction, including the website’s commercial operation and any nexus between D.C.-related transactions and the alleged infringement.
- The court indicated that additional factual development could be appropriate on remand.

## Legal Principles

- In patent cases, personal jurisdiction is analyzed under Federal Circuit law, but amenability to jurisdiction is constrained by the forum’s long-arm statute and constitutional due process.
- Courts must evaluate both (1) the forum long-arm statute and (2) whether asserting jurisdiction satisfies minimum-contacts due process and fair play/substantial justice.
- Specific jurisdiction requires that the claim arise out of or relate to the defendant’s forum-directed contacts; general jurisdiction requires continuous and systematic contacts approximating physical presence.
- Internet contacts require scrutiny of the nature and quality of online commercial activity; an interactive, sales-capable website may support specific jurisdiction depending on targeting, actual transactions, and connection to the asserted claims.
- Even modest in-forum sales may support specific jurisdiction if they involve the accused products and reflect purposeful direction toward the forum.
- For infringement claims, the jurisdictional inquiry should tie alleged sales/offers for sale and shipment channels (direct, distributor-based, or representative-driven) to the asserted infringement and to statutory long-arm predicates such as transacting business or causing in-forum injury.

## Conclusion

The Federal Circuit required a more fact-specific, contact-by-contact analysis of Pedre’s commercial website activity, distributor sales, and other D.C.-related conduct before a patent case could be dismissed for lack of personal jurisdiction under the District of Columbia long-arm statute and due process.


Trintec Indus., Inc. v. Pedre Promotional Prods., Inc., 395 F.3d 1275 (Fed. Cir. 2005)