Ejikeme v. Meyer Corporation, U.S.

CourtDistrict Court, N.D. Georgia
DecidedMarch 29, 2024
Docket1:20-cv-05145
StatusUnknown

This text of Ejikeme v. Meyer Corporation, U.S. (Ejikeme v. Meyer Corporation, U.S.) is published on Counsel Stack Legal Research, covering District Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ejikeme v. Meyer Corporation, U.S., (N.D. Ga. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

NJIDENWA EJIKEME, Plaintiff, Civil Action No. v. 1:20-cv-05145-SDG MEYER CORPORATION, U.S., et al., Defendant.

OPINION AND ORDER This matter is before the Court on Defendant TTK Prestige, LTD’s renewed motion to dismiss [ECF 90] under Fed. R. Civ. P. 12(b)(2) for lack of personal jurisdiction. For the following reasons, TTK’s motion is DENIED. I. BACKGROUND TTK is an Indian manufacturer that markets itself as “India’s number one kitchenware brand” and a “total kitchen solutions provider.”1 Of particular importance to TTK’s portfolio are pressure cookers: TTK is the biggest brand in India’s pressure cooker business at nearly four times the size of its nearest competitor, controlling 40 percent of the domestic market and selling over 6.5 million pieces in the fiscal year ending in 2020.2 Relevant to this case are TTK’s stovetop pressure cookers, bearing the Farberware brand name under a licensing agreement between Defendants Farberware Licensing Company, LLC and Meyer

1 ECF 74-14, at 3. 2 ECF 74-4, at 5–6. Corporation, U.S.3 Meyer, a trading intermediary, receives the Farberware- branded pressure cookers from TTK through non-party Meyer Trading Company

Ltd. Hongkong, and delivers them to retailers like Defendant Walmart Inc.;4 Walmart in turns sells thousands of the pressure cookers to consumers in the United States.5

Plaintiff Njidenwa Ejikeme bought a TTK-manufactured, Farberware- branded stovetop pressure cooker from a Wal-Mart store6 in Lithia Springs, Georgia, in 2018.7 On October 2, 2019, while Ejikeme was using the pressure cooker

to prepare beans at home in her kitchen, its lid unexpectedly flew off and its hot contents spilled onto her.8 Ejikeme suffered burns causing permanent dermatological and neurological damage,9 and she sued for her injuries.10 After TTK moved to dismiss claims against it for lack of personal jurisdiction,11 the

3 See ECF 74-13, at 16. 4 ECF 91-1, at 6–7. 5 See ECF 74-13, at 17. 6 For clarity, this Opinion refers to Defendant Walmart as “Walmart” and to its stores as “Wal-Marts.” 7 ECF 55, ¶ 23. 8 Id. ¶ 35. 9 Id. 10 ECF 1. 11 ECF 70. Court granted Ejikeme’s request for limited jurisdictional discovery.12 At the close of discovery, TTK renewed its motion to dismiss.13

II. DISCUSSION For a court to have the power to “render a valid personal judgment against a nonresident defendant,” the defendant must be subject to the court’s personal jurisdiction. Worldwide Volkswagen Corp. v. Woodson, 444 U.S. 286, 291 (1980). A

federal court has personal jurisdiction over a nonresident defendant if (1) authorized by the relevant state’s long-arm statute and (2) consistent with the Due Process Clause of the Fourteenth Amendment. Diamond Crystal Brands, Inc. v.

Food Movers Int’l, Inc., 593 F.3d 1249, 1257–58 (11th Cir. 2010). Here, Ejikeme has established that this Court’s exercise of personal jurisdiction over TTK satisfies both Georgia’s long-arm statute and procedural due process. A. Legal Standard for Personal Jurisdiction

The Eleventh Circuit analyzes challenges to a court’s personal jurisdiction through burden-shifting. The burden first falls on the plaintiff to make a prima facie case for the court’s jurisdiction through allegations in the complaint. Id. at 1257. The burden then shifts to the defendant to rebut the allegations with “affidavit

evidence.” Id. Once the defendant introduces evidence, the burden “shifts back to

12 ECF 75. 13 ECF 90. the plaintiff” to produce its own evidence in support of personal jurisdiction. Id. Where the plaintiff’s and nonresident defendant’s proofs conflict, courts must

“construe all reasonable inferences in favor of the plaintiff,” as in a motion for directed verdict. Madara v. Hall, 916 F.2d 1510, 1514 (11th Cir. 1990). B. Personal Jurisdiction Is Authorized by Subsection (3) of the Georgia Long-Arm Statute. Under Georgia law, the Court can exercise personal jurisdiction over TTK only if it has “do[ne] certain acts within the State of Georgia.” Innovative Clinical &

Consulting Servs., LLC v. First Nat. Bank of Am., 279 Ga. 672, 673 (2005). These jurisdiction-conferring acts are listed in the long-arm statute, O.C.G.A. § 9-10-91. Id. Consistent with the Georgia Supreme Court’s interpretation, § 9-10-91 is given

a “literal construction.” Id. And, as the Eleventh Circuit has explained, the statute “imposes independent obligations that a plaintiff must establish” distinct from due process. Diamond Crystal, 593 F.3d at 1258–59. Section 9-10-91 has three subsections; the third authorizes personal jurisdiction over a nonresident

defendant that “derives substantial revenue from goods used” in Georgia, if the defendant “[c]ommits a tortious injury in this state caused by an act … outside this state” and the cause of action “aris[es] from” that act. O.C.G.A. § 9-10-91(3).14

14 As written, subsection (3) requires a connection between the tortious out-of- state act and the cause of action, but not between the cause of action and the substantial revenue. (The latter is relevant to the due-process analysis.) Subsection (3) gives the Court long-arm jurisdiction over TTK. According to Ejikeme’s unrebutted allegations, TTK injured her in Georgia by defectively

manufacturing her pressure cooker in India.15 In other words, Ejikeme contends that TTK committed a tortious injury in Georgia caused by an act outside of it. And she has presented enough evidence to support the reasonable inference that TTK

derives substantial revenue from goods used in Georgia. Specifically, the evidence shows that TTK sells its products to consumers in the United States through large retailers like Walmart, Target, Kmart, Kohl’s, Belk, Sears, Macy’s and JC Penny.16 Walmart alone sells “1000+” TTK-branded products that it markets both online

and in physical stores,17 214 of which are in Georgia.18 Just one of those 1000+ products—the Farberware-branded pressure cooker that allegedly injured Ejikeme—has been distributed over 4000 times to physical stores in Georgia,19 and

over 227,000 times to Wal-Mart stores nationwide.20 Overall, TTK has sold more than one million pressure cookers to U.S. consumers.21

15 ECF 55, ¶ 26. 16 ECF 74-14, at 6. 17 ECF 74-30, at 2. 18 ECF 74-29, at 2. 19 See ECF 91-3. 20 ECF 92-4, at 2. 21 ECF 74-4, at 6. From this evidence, the Court can reasonably infer that TTK’s Georgia revenue is not limited to Farberware-branded pressure cookers sold in Wal-Mart

stores, and that the total revenue TTK derives in Georgia from its products— hundreds of varieties sold by a constellation of big-box retailers—is “substantial.” See Collett v. Olympus Med. Sys. Corp., 437 F. Supp. 3d 1272, 1278 (M.D. Ga. Jan. 22,

2020) (inferring substantial revenue in Georgia from record of nationwide sales) and Quashie v. Olympus Am., Inc., 315 F. Supp. 3d 1329, 1336 (N.D. Ga. June 19, 2018) (inferring substantial revenue in Georgia from “bare minimum” allegations that defendant placed goods into “stream of commerce”). Notwithstanding the

conclusory testimony of TTK’s Wholetime Director, K.

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