The Federal Circuit reversed and remanded the decision of a federal district court in Florida dismissing for lack of personal jurisdiction Frida Kahlo Corporation and Frida Kahlo Investments S.A.'s action against Familia Kahlo S.A. de C.V. and an individual, which alleged violations of Florida tort law and the Lanham Act by sending threatening and false cease-and-desist letters to stop the use of Frida Kahlo trademarks. The appeals court said that the corporate shield doctrine doesn’t apply because the cease-and-desist letters were sent in the individual’s personal capacity, and that the effects test is satisfied.
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