In a significant ruling, the CAFC determined that by using Amazon's APEX program, patent owners could expose themselves to personal jurisdiction in unexpected states, thus reshaping enforcement strategies.
The court found that LDG's participation in the APEX program provided enough connection to Utah, establishing personal jurisdiction through purposeful direction of activities linked to the claim.
This decision imposes new considerations for patent holders using online platforms, emphasizing the need for updated strategies to manage risks of personal jurisdiction arising from third-party program involvement.
The CAFC's ruling suggests a broader interpretation of personal jurisdiction, advising patent owners to carefully weigh their actions in conjunction with their participation in expedited programs like APEX.
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