70/Plumbing Engineer September 2020
did not perform services within the district. Epoch was the only entity that had a contract with Catalyst. B3DC did not have a contract with Catalyst. After Epoch received Catalyst's designs from Ohio, Epoch forwarded them to Alltherm so that Alltherm could perform the installation. For the federal district court to have specific jurisdiction over Catalyst, "the contract giving rise to this dispute must have obligated Catalyst to supply a service in this city. That is not what happened here, however. The Epoch-Catalyst contract provided that the designs for the HVAC system would be sent to Epoch, not B3DC, and it specifically disavowed any contact with the job site here." B3DC Navy Yard, LLC, 2020 WL 888574, at *3. Finding that Catalyst's conduct at issue here did not meet the D.C. statutory requirements, the federal district court held that it lacked specific jurisdiction over Catalyst (without even having to address the due process issue of minimum contacts). In sum, the court held that it did not have personal juris- diction over Catalyst. It did not have general jurisdiction over Catalyst, an Ohio LLC. It also did not have specific jurisdiction over Catalyst because Catalyst's conduct at issue here does not satisfy the D.C. statutory requirements. As a result, the federal district court lacked power to hear this dispute involving Catalyst and dismissed the claims against it. place of incorporation or principal place of business. Thus, it is technically possible for a corporation to be subject to general jurisdiction in two states if it is incorporated in a different state than its principal place of business. Here, Catalyst is incorporated and maintains its principal place of business in Ohio. Accordingly, the court found that Catalyst is not "fairly regarded as at home" in Washington, D.C., and that general jurisdiction does not lie there. B3DC Navy Yard, LLC, 2020 WL 888574, at *2. Specific Jurisdiction Specific jurisdiction is a different analysis. To show spe- cific jurisdiction, a plaintiff must meet the requirements of the due process clause of the U.S. Constitution (i.e., have the requisite "minimum contacts" with the forum state) and the applicable statutory requirements. For specific jurisdic- tion, the court looks to the specific conduct (i.e., Catalyst's actions) at issue in the case. Here, Epoch noted that D.C. statutes allow the court to exercise jurisdiction over a party where there is a "claim for relief arising from the person's ... contracting to supply ser- vices in the District of Columbia." B3DC Navy Yard, LLC, 2020 WL 888574, at *2. Epoch argued that Washington courts have personal jurisdiction over foreign entities that perform services within Washington. The federal district court disagreed, finding that Catalyst
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