Lewis v. Samsung SDI America, Inc.

CourtDistrict Court, S.D. New York
DecidedJuly 2, 2025
Docket1:23-cv-06643
StatusUnknown

This text of Lewis v. Samsung SDI America, Inc. (Lewis v. Samsung SDI America, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lewis v. Samsung SDI America, Inc., (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SASHA LEWIS, Plaintiff, -v.- 23 Civ. 6643 (KPF) SAMSUNG SDI CO. LTD.; SAMSUNG, OPINION AND ORDER INC.; ABC CORPORATIONS (1-10) (FICTITIOUS ENTITIES), Defendants. KATHERINE POLK FAILLA, District Judge:1 Plaintiff Sasha Lewis brought this action against Defendants Samsung SDI Co. Ltd. (“SDI”), a designer and manufacturer of lithium-ion batteries, Samsung, Inc., and ABC Corporations (1-10) (fictitious entities), alleging claims of, inter alia, strict product liability, breach of an express warranty, breach of the implied warranty of merchantability, breach of the implied warranty of fitness for a particular purpose, failure to warn, and negligence, all under New York common law. Before the Court is SDI’s motion to dismiss Plaintiff’s Second Amended Complaint, the operative pleading in this case, for lack of personal jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(2). For the reasons set forth in the remainder of this Opinion, the Court grants SDI’s motion and dismisses all claims against it.

1 Olivia Ferdinand, a rising second-year student at Harvard Law School, provided substantial assistance in the research and drafting of this Opinion. BACKGROUND2 A. Factual Background 1. Plaintiff Plaintiff is a resident of New York. (SAC ¶ 2). On or about September 9, 2020 (the “Accident Date”), Plaintiff was the owner of a battery-powered scooter

bearing the visible markings of “Wuxing,” “38V 2019.10 76,” “Wuxing DK11,” and “01345512.5.” (Id. ¶ 12). Plaintiff does not allege where or when she purchased the scooter. Plaintiff contends that the scooter was equipped with a rechargeable battery manufactured by a “Samsung” entity. (Id. ¶¶ 14, 24). On the Accident Date, as Plaintiff was charging the scooter with its charging apparatus — which she also alleges to have been distributed and supplied by “Defendants” — “a dangerous condition developed and ultimately a fire started.” (Id. ¶¶ 13, 16, 24). As a result, Plaintiff sustained “serious and

permanent bodily injuries.” (Id. ¶ 37). 2. SDI SDI is a foreign business corporation incorporated in South Korea, with its headquarters and principal place of business in Yongin-si, Gyeonggi-do, South Korea. (SAC ¶ 3; Han Decl. ¶ 6). According to SDI, it is not registered to

2 This Opinion draws its facts from Plaintiff’s Second Amended Complaint filed on September 26, 2024 (“SAC” (Dkt. #85)), the well-pleaded allegations of which are taken as true for purposes of this Opinion. See Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009). The Court also sources facts from the Declaration of Young Chan Han submitted in support of SDI’s motion to dismiss (“Han Decl.” (Dkt. #86-3)). For ease of reference, the Court refers to SDI’s memorandum of law in support of its motion to dismiss as “Def. Br.” (Dkt. #86-1); to Plaintiff’s memorandum of law in opposition to the motion to dismiss as “Pl. Opp.” (Dkt. #89); and to SDI’s reply memorandum of law in further support of its motion to dismiss as “Def. Reply” (Dkt. #90). conduct business in New York; does not maintain an office or bank account in New York; has never conducted business in New York or with any entity based in New York; has never paid or incurred an obligation to pay taxes in New York;

and has no employees, officers, agents, directors, or representatives in New York. (Han Decl. ¶¶ 7-12). Plaintiff offers neither evidence nor allegations to the contrary. Instead, Plaintiff alleges that “Defendants,” which she defines to include SDI, “caused the subject [b]attery to be manufactured”; “caused the subject [b]attery to be sold” and “utilized in the state of New York”; “caused the subject [b]attery to be utilized in [Plaintiff’s s]cooter”; and “marketed” and “distributed” the subject battery and charger. (SAC ¶¶ 17-24). Notably, Plaintiff does not

allege that the manufacturing occurred in New York, or that SDI marketed or distributed the subject battery and charger to New York residents specifically. Plaintiff also does not make any allegations regarding SDI’s manufacturing or distribution chain (i.e., how the subject battery, or others like it, came to be in New York). For its part, SDI explains that it manufactures different models of lithium-ion battery cells, which are used to power a wide range of rechargeable products, including electric vehicles, power tools, and laptops. (Han Decl.

¶ 13). Its battery cells are designed to function as part of sealed battery packs. (See id.). SDI does not sell battery cells for individual use outside a battery pack, and it has never authorized any third party to do so. (See id. ¶¶ 13, 14). SDI exclusively markets and sells its lithium-ion battery cells to companies it deems sophisticated. (Id. ¶ 16). It generally sells to two categories of companies, to whom SDI refers as “Packers” and “Manufacturers.” (Id.). Packers purchase SDI’s battery cells to assemble them into sealed battery

packs, which Packers then sell to their own corporate customers. (Id.). Manufacturers purchase either preassembled sealed battery packs or battery cells from SDI and then incorporate the batteries into their own, pre-authorized products. (Id.). When Manufacturers purchase battery cells, they first assemble them into sealed battery packs before incorporating the batteries into their products. (Id.). As potentially relevant here, SDI asserts that it does not have any customers (i.e., Packers or Manufacturers) or distributors based in New York; it

“does not design, manufacture, sell, distribute, market, or provide customer support for any of its battery cells or battery packs in New York”; and it does not work with any “entities who purchase or take delivery of SDI’s [batteries] for purposes of resale or distribution to other distributors, wholesalers, retailers, or resellers [ ] in the United States, including any distributors based in New York, who serve the New York market, or who serve a regional area in the United States that encompasses New York.” (Han Decl. ¶¶ 18-20). SDI also “has never sold or supplied battery cells or battery packs to ‘Wuxing’

electric scooters or for electric scooters with … ‘Wuxing’ markings[.]” (Id. ¶ 23). Finally, SDI avers that it has no knowledge or control over its batteries after the point of sale. (Id. ¶ 17). B. Procedural Background Plaintiff commenced this action by filing her initial complaint on July 31, 2023. (Dkt. #1). On August 4, 2023, Plaintiff filed a corrected complaint naming the entities Samsung Electronics America, Inc.; Samsung Electronics

USA, Inc.; Samsung Electronics, L.L.C.; Samsung SDI America, Inc.; Samsung Corp.; Samsung, Inc.; and ABC Corporations 1-10 as Defendants. (Dkt. #15). On September 6, 2023, Samsung SDI America, Inc. filed a pre-motion letter in anticipation of filing a motion to dismiss, primarily on the basis of lack of personal jurisdiction. (Dkt. #19). The Court held a pre-motion conference on October 6, 2023, and — in view of Samsung SDI America, Inc.’s assertions that it had “never manufactured, sold, distributed, or otherwise placed into the stream of commerce batteries for use with electric scooters” (id.) — ordered a

period of jurisdictional discovery (see October 6, 2023 Minute Entry; see also Dkt. #51). On November 28, 2023, the Clerk of Court issued Certificates of Default as to each of Samsung Electronics America, Inc. (Dkt. #36); Samsung Electronics USA, Inc. (Dkt. #40); Samsung Electronics, L.L.C. (Dkt. #38); Samsung Corp. (Dkt. #37); and Samsung, Inc. (Dkt. #39). On December 15, 2023, the Court issued an order to show cause as to why a default judgment ought not be entered against these Defendants and in favor of Plaintiff,

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Lewis v. Samsung SDI America, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/lewis-v-samsung-sdi-america-inc-nysd-2025.