Samsung SDI Gets Exploding Battery Lawsuit Dismissal Affirmed

Foreign battery manufacturer Samsung SDI Co. convinced a federal appeals court to affirm the dismissal of a plaintiff’s battery explosion lawsuit Wednesday because the lower court lacked jurisdiction over the company.

The US Court of Appeals for the Seventh Circuit said two streams of commerce were at play in the suit, and while the first one meant the manufacturer had purposefully availed itself of the forum state of Indiana, the second and more relevant stream of commerce meant it didn’t.

Judge Michael B. Brennan acknowledged that circuits have split on the contours of the stream of commerce theory, but that ...