CarData Website Insufficient for Trademark Suit in Massachusetts

Jan. 19, 2022, 2:30 PM UTC

CarData Consultants Inc. beat a trademark infringement suit filed against it in a Massachusetts federal court by Motus LLC, as it isn’t subject to the court’s personal jurisdiction, the First Circuit said.

The employee expense management company’s website wasn’t directed at the state, and Motus didn’t allege CarData took any action to “purposely avail” itself of doing business in Massachusetts, the U.S. Court of Appeals for the First Circuit said.

Asserting personal jurisdiction over a company based on its website requires more than showing that the site can be accessed by people in the forum state, the court said.

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