Proof Analytics Americas, Inc. v. Netsmartz, LLC

CourtDistrict Court, S.D. Texas
DecidedSeptember 30, 2024
Docket4:23-cv-04702
StatusUnknown

This text of Proof Analytics Americas, Inc. v. Netsmartz, LLC (Proof Analytics Americas, Inc. v. Netsmartz, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Proof Analytics Americas, Inc. v. Netsmartz, LLC, (S.D. Tex. 2024).

Opinion

September 30, 2024 Nathan Ochsner, Clerk UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

PROOF ANALYTICS § CIVIL ACTION NO AMERICAS INC, § 4:23-cv-04702 Plaintiff, § § § vs. § JUDGE CHARLES ESKRIDGE § § NETSMARTZ LLC, § Defendant. § OPINION AND ORDER GRANTING MOTION TO DISMISS The motion to dismiss by Defendant Netsmartz, LLC, is granted with respect to lack of personal jurisdiction. Dkt 5. 1. Background Plaintiff Proof Analytics Americas, Inc, alleges that it entered into an agreement with Defendant Netsmartz, LLC, under which the latter “was to provide personnel for development of custom software.” Dkt 1 at 14; see also id at 20–25 (agreement attached to original petition). It also alleges that Netsmartz thereafter “failed to provide ‘personnel,’ but instead outsourced the development to non- personnel resources.” Dkt 1 at 15. Proof Analytics sued Netsmartz in the 295th District Court of Harris County, Texas. See id at 14–17 (original petition attached to notice of removal). It asserts causes of action including breach of contract, fraud, and violation of the Texas Deceptive Trade Practices Act, while also seeking a declaratory judgment that Netsmartz was prohibited from outsourcing development under the agreement. Id at 15–17. Netsmartz removed based on diversity jurisdiction. Id at 3–6. The notice of removal indicates that Proof Analytics is a Delaware corporation with its principal place of business in Arizona, and that Netsmartz is a New York limited liability company with its principal place of business in New York and its members domiciled in Florida, Singapore, and India. Id at 3–4. The underlying contract similarly states that the principal places of business for Proof Analytics and Netsmartz are Arizona and New York, respectively. Id at 20. Pending is a motion by Netsmartz to dismiss for lack of personal jurisdiction, for improper venue, and for failure to state a claim. Dkt 5. Only personal jurisdiction will be addressed here because it is dispositive. 2. Legal standard A federal court may exercise jurisdiction over a nonresident defendant if the long-arm statute of the forum state confers personal jurisdiction over that defendant and exercising that jurisdiction is consistent with the Due Process Clause of the Fourteenth Amendment. McFadin v Gerber, 587 F3d 753, 759 (5th Cir 2009). Challenge to personal jurisdiction proceeds under Rule 12(b)(2) of the Federal Rules of Civil Procedure. The reviewing court must accept as true uncontroverted allegations in the plaintiff’s complaint. Johnston v Multidata System International Corp, 523 F3d 602, 609 (5th Cir 2008). But the district court isn’t required “to credit conclusory allegations, even if uncontroverted.” Panda Brandywine Corp v Potomac Electric Power Co, 253 F3d 865, 869 (5th Cir 2001). The court may also receive “‘any combination of the recognized methods of discovery,” including affidavits, interrogatories, and depositions to assist it in the jurisdictional analysis.” Little v SKF Sverige AB, 2014 WL 710941, *2 (SD Tex), quoting Walk Haydel & Associates Inc v Coastal Power Production Co, 517 F3d 235, 241 (5th Cir 2008). Conflicts between any facts contained in the affidavits or other evidence submitted by the parties must be resolved in favor of the plaintiff. Johnston, 523 F3d at 609. The initial burden is upon the plaintiff to present a prima facie case that personal jurisdiction is proper. Quick Technologies Inc v Sage Group PLC, 313 F3d 338, 343 (5th Cir 2002). If the plaintiff establishes the necessary minimum contacts between the defendant and the forum state, the burden then shifts to the defendant to show that the assertion of jurisdiction is “unfair and unreasonable.” Sangha v Navig8 Ship Management Private Ltd, 882 F3d 96, 102 (5th Cir 2018), citing Wien Air Alaska Inc v Brandt, 195 F3d 208, 215 (5th Cir 1999). Such a showing must be “‘compelling.’” Sangha, 882 F3d at 102, quoting Burger King Corp v Rudzewicz, 471 US 462, 477 (1985). Whether jurisdiction is fair and reasonable itself requires consideration of five factors, being (i) the burden on the nonresident defendant of having to defend itself in the forum, (ii) the interests of the forum state in the case, (iii) the interest of the plaintiff in obtaining convenient and effective relief, (iv) the interest of the interstate judicial system in the most efficient resolution of controversies, and (v) the shared interests of the states in furthering fundamental social policies. Sangha, 882 F3d at 102. 3. Analysis The long-arm statute of Texas provides for jurisdiction over a nonresident who (i) contracts by mail or otherwise with a Texas resident and either party is to perform the contract in whole or in part in Texas, (ii) commits a tort in whole or in part in Texas, or (iii) recruits Texas residents, directly or through an intermediary located in this state, for employment inside or outside this state. Texas Civil Practice and Remedies Code §17.042. The Fifth Circuit holds that this confers jurisdiction to the limits of due process. Latshaw v Johnston, 167 F3d 208, 211 (5th Cir 1999). This means that “the two-step inquiry collapses into one federal due process analysis.” Johnston, 523 F3d at 609. Federal due process permits personal jurisdiction over a nonresident defendant who has minimum contacts with the forum state, so long as the exercise of jurisdiction doesn’t offend “traditional notions of fair play and substantial justice.” Ibid. Such contacts may establish either general or specific jurisdiction, as explained below. The notice of removal states without dispute that Netsmartz is a New York limited liability company with its principal place of business in New York and its members domiciled in Florida, Singapore, and India. Id at 4. The burden is thus on Proof Analytics in the first instance to show that Netsmartz has sufficient minimum contacts with Texas to establish either general or specific jurisdiction. a. General jurisdiction A federal court has general jurisdiction over a nonresident defendant “to hear any and all claims” if that defendant’s contacts with the state are so “continuous and systematic” as to render it “essentially at home” in the forum state. Daimler AG v Bauman, 571 US 117, 127 (2014), quoting Goodyear Dunlop Tires Operations SA v Brown, 564 US 915, 919 (2011). This is a difficult showing to make, requiring “extensive contacts between a defendant and a forum.” Johnston, 523 F3d at 609, quoting Submersible Systems Inc v Perforadora Central SA, 249 F3d 413, 419 (5th Cir 2001) (quotation marks omitted). Indeed, “with respect to a corporation,” the Supreme Court holds that “the place of incorporation and principal place of business are paradigm bases for general jurisdiction.” Daimler, 571 US at 137 (quotation omitted). Only in an “exceptional case” will a corporation’s operations in a state in some other respect be so substantial as to render the corporation at home. Id at 139 n 19. Proof Analytics refers to general jurisdiction in its response. Dkt 12 at 5. But it in no way seeks to establish the requisite continuous and systematic contacts that might indicate that Netsmartz is somehow at home in Texas. Nor could it. Netsmartz is a New York limited liability company with its principal place of business also in New York. Dkt 1 at 3–4. As the Fifth Circuit observes, “in order to confer general jurisdiction a defendant must have a business presence in Texas. It is not enough that a corporation do business with Texas.” Johnston, 523 F3d at 611 (emphasis in original). General jurisdiction over Netsmartz doesn’t exist. b. Specific jurisdiction A federal court has specific jurisdiction over a nonresident defendant to adjudicate “issues deriving from, or connected with, the very controversy that establishes jurisdiction.” Goodyear, 564 US at 919.

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Bluebook (online)
Proof Analytics Americas, Inc. v. Netsmartz, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/proof-analytics-americas-inc-v-netsmartz-llc-txsd-2024.