AMERICAN GUARANTEE AND LIABILITY INSURANCE COMPANY v. GETFVP LLC

CourtDistrict Court, D. New Jersey
DecidedApril 14, 2025
Docket3:24-cv-08922
StatusUnknown

This text of AMERICAN GUARANTEE AND LIABILITY INSURANCE COMPANY v. GETFVP LLC (AMERICAN GUARANTEE AND LIABILITY INSURANCE COMPANY v. GETFVP LLC) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AMERICAN GUARANTEE AND LIABILITY INSURANCE COMPANY v. GETFVP LLC, (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

AMERICAN GUARANTEE AND LIABILITY INSURANCE COMPANY as subrogee of SRI International,

Civil Action No. 24-8922 (ZNQ) (RLS) Plaintiff,

OPINION v.

GETFPV LLC, et al.,

Defendants.

QURAISHI, District Judge THIS MATTER comes before the Court upon a Motion to Dismiss for lack of personal jurisdiction filed by Defendant GetFPV LLC (“GetFPV”) and Lumenier LLC (“Lumenier”) (collectively, “Defendants”) (the “Motion,” ECF No. 11). Defendants filed a brief in support of the Motion (“Moving Br.,” ECF No. 11-3) and various exhibits including a certification of Andy Graber, the Vice President of eCommerce at Lumenier (“Graber Certification,” ECF No. 11-2). Plaintiff American Guarantee and Liability Insurance Company (“Plaintiff” or “American Guarantee”) filed an opposition brief (“Opp’n Br.,” ECF No. 13) and various exhibits including a certification of counsel (ECF No. 13-1), a picture of a LinkedIn profile of a former employee of non-party subrogor SRI International (ECF No. 13-2), a copy of an email/shipping confirmation from GetFPV (ECF No. 13-3), copies of pages from GetFPV’s website (ECF No. 13-4), and information about GetFPV from the Delaware Secretary of State (ECF No. 13-5). Defendants filed a reply brief. (“Reply Br.,” ECF No. 17.) The Court has carefully considered the parties’ submissions and decides the Motion without oral argument pursuant to Federal Rule of Civil Procedure 78 and Local Civil Rule 78.1.1 For the reasons set forth below, the Court will DENY the Motion. I. BACKGROUND AND PROCEDURAL HISTORY2 A. FACTUAL BACKGROUND3

Plaintiff brings its claims as subrogee of SRI International4, its insured, against GetFPV, Lumenier, and Amazon.com, Inc. (“Amazon”). (See generally Am. Compl.) Plaintiff is a New York corporation who conducts business in New Jersey. (Id. ¶ 1.) GetFPV is a Delaware limited liability company with a principal place of business in Sarasota, Florida. (Id. ¶ 2.) GetFPV is “a product seller, retailer, and/or distributor that . . . ships products throughout the United States.” (Id.) Lumenier is a limited liability company formed under the laws of Delaware with a principal place of business in Florida. (Id. ¶ 3.) Lumenier is a wholly owned subsidiary of Lumenier Holdco LLC, whose sole member is a Delaware C-Corporation. (Graber Certification ¶¶ 4, 5.) GetFPV is also a wholly owned subsidiary of Lumenier Holdco LLC. (Id. ¶ 3.) Amazon, although not

involved in this Motion, is a Delaware corporation with a principal place of business in Washington. (Id. ¶ 4.)

1 Hereinafter, all references to “Rule” or “Rules” refer to the Federal Rules of Civil Procedure unless otherwise noted. 2 For the purposes of considering the Motion, the Court accepts all factual allegations in the Complaint as true. See Phillips v. County of Allegheny, 515 F.3d 224, 233 (3d Cir. 2008). 3 The facts are derived from the Amended Complaint. (ECF No. 23.) Although the Amended Complaint was filed in response to a pre-motion letter filed by Amazon, there are no changes to the allegations against GetFPV and Lumenier. Given that the Complaint and Amended Complaint are the same as to GetFPV and Lumenier, the Court applies the current Motion to Dismiss to the Amended Complaint. 4 As alleged, “SRI International is an independent nonprofit research institute which, among other things, builds and tests products, including night vision cameras. The company owns and operates a facility at 201 Washington Road, West Windsor, New Jersey.” (Am. Compl. ¶ 7.) American Guarantee is a subrogee of SRI International because it provided insurance coverage to it and the insurance policy between the parties states that American Guarantee is permitted to bring claims on SRI International’s behalf. (Id. ¶¶ 21, 24.) The facts involve multiple entities involved in the production, research, testing, and selling of drone and other technological equipment. (See generally Am. Compl.) The history begins when non-party subrogor SRI International provided night vision cameras to non-party Ansible Industries, Inc. (“Ansible”) in exchange for prototype night vision binoculars. (Id. ¶ 8.) The night vision binoculars acquired by SRI International required a battery and a charger to function. (Id.

¶ 10.) Non-party ToolkitRC Technology Co., Ltd.—a company with no United States presence— “designs, manufactures, and assembles Toolkit RC M7 200W 10A DC 7-28V Multi-Function Balance Chargers,” which are used to charge the binoculars. (Id. ¶¶ 11–12.) On one occasion, Ansible representative Daniel Hendrix (“Hendrix”) purchased a ToolkitRC charging pack from Amazon for use with the night vision binoculars. (Id. ¶¶ 13, 14.) Hendrix subsequently shipped the ToolkitRC charger to SRI International along with the binoculars. (Id. ¶ 14.) Lumenier also designs, manufactures, assembles, sells, or otherwise distributes lithium polymer batteries on the GetFPV website. (Id. ¶ 16.) These batteries are used to charge the binoculars and could themselves be charged by the Toolkit RC battery packs. (See generally id.

¶¶ 16–17.) On another occasion, Hendrix purchased two Lumenier batteries from the GetFPV website for use with the binoculars. (Id. ¶ 17.) Those batteries were subsequently shipped to Eric Braddom (“Braddom”), in Yardley, Pennsylvania. (Id.)5 In August 2023, an SRI International employee was using the charging pack from Toolkit RC to charge one of the Lumenier battery packs when the battery pack suddenly failed, causing a fire and resulting in damage to SRI International’s New Jersey facility. (Id. ¶ 18.) To be clear,

5 Braddom was the Vice President of Product Management at SRI International from September 2019 through June 2024. (ECF No. 13-2.) He worked in Princeton, New Jersey during his stint with SRI International. (Id.) Plaintiff attached a copy of his LinkedIn profile to its opposition brief. (ECF No. 13-2.) Amazon sold the alleged defective battery packs made by ToolkitRC, while GetFPV sold the alleged defective battery packs made by Lumenier. (Id. ¶¶ 19–20.) B. PROCEDURAL HISTORY Plaintiff filed its original complaint on September 3, 2024. (ECF No. 1.) On September 23, 2024, only GetFPV and Lumenier filed the present Motion to Dismiss. (ECF No. 11.)

Thereafter, Defendant Amazon filed a pre-motion letter pursuant to the undersigned’s judicial preferences stating its grounds for an anticipated motion to dismiss. (ECF No. 16.) Plaintiff responded to Amazon’s letter, noting that it would file an amended complaint to address Amazon’s concerns. (ECF No. 20.) Plaintiff then filed its Amended Complaint (ECF No. 23), and Amazon answered and filed a third-party complaint against a party not involved in this Motion (ECF No. 24). The Amended Complaint alleges two counts. Relevant here, Count One asserts a products liability claim against Lumenier and GetFPV for selling and manufacturing a defective product that directly and proximately caused a fire at SRI International’s New Jersey facility. (Am. Compl.

¶¶ 29, 30.) According to the Amended Complaint, Lumenier and GetFPV “are strictly liable for the fire and resulting losses.”6 (Id. ¶ 31.) II. SUBJECT MATTER JURISDICTION The Court has subject matter jurisdiction under 28 U.S.C. § 1332 because the parties are diverse and the amount in controversy exceeds $75,000. III. LEGAL STANDARD Pursuant to Rule 12(b)(2), a complaint is subject to dismissal for lack of personal jurisdiction. See Fed. R. Civ. P.

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AMERICAN GUARANTEE AND LIABILITY INSURANCE COMPANY v. GETFVP LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-guarantee-and-liability-insurance-company-v-getfvp-llc-njd-2025.