Safety Management and Related Training, Inc. a California Corporation doing business as Smart Safety Group v. Safety and Compliance Holdings LLC, Carr’s Hill Partners LLC, Solomon Group Holdings, LLC. et. al

CourtDistrict Court, N.D. Texas
DecidedMay 6, 2026
Docket7:26-cv-00052
StatusUnknown

This text of Safety Management and Related Training, Inc. a California Corporation doing business as Smart Safety Group v. Safety and Compliance Holdings LLC, Carr’s Hill Partners LLC, Solomon Group Holdings, LLC. et. al (Safety Management and Related Training, Inc. a California Corporation doing business as Smart Safety Group v. Safety and Compliance Holdings LLC, Carr’s Hill Partners LLC, Solomon Group Holdings, LLC. et. al) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Safety Management and Related Training, Inc. a California Corporation doing business as Smart Safety Group v. Safety and Compliance Holdings LLC, Carr’s Hill Partners LLC, Solomon Group Holdings, LLC. et. al, (N.D. Tex. 2026).

Opinion

1 2 3 4 5 6 7 8 9 10 UNITED STATES DISTRICT COURT 11 SOUTHERN DISTRICT OF CALIFORNIA 12 13 SAFETY MANAGEMENT AND Case No. 25-cv-02625-BAS-MMP RELATED TRAINING, INC. a 14 California Corporation doing business as ORDER: 15 Smart Safety Group, (1) GRANTING WITHOUT PREJUDICE DEFENDANTS’ 16 Plaintiff, SAFETY AND COMPLIANCE 17 v. HOLDINGS LLC, CARR’S HILL PARTNERS LLC, 18 SAFETY AND COMPLIANCE SOLOMON GROUP HOLDINGS, LLC. et. al, 19 PRODUCTIONS LLC, AND Defendants. CARR’S HILL CAPITAL 20 PARTNERS MANAGEMENT 21 LP’S MOTION TO DISMISS FOR LACK OF 22 JURISDICTION (ECF No. 39);

23 (2) GRANTING WITHOUT 24 PREJUDICE DEFENDANT SOLOMON GROUP 25 PRODUCTIONS, LLC’S 26 MOTION TO DISMISS FOR LACK OF JURISDICTION 27 MOTION (ECF No. 40); 28 1 (3) VACATING AS MOOT DEFENDANTS CARR’S HILL 2 PARTNERS LLC’S AND 3 SMART PROFITABILITY SOLUTIONS LLC’S MOTION 4 TO TRANSFER (ECF No. 26); 5 AND

6 (4) VACATING AS MOOT DEFENDANT SOLOMON 7 GROUP PRODUCTIONS 8 LLC’S MOTION TO TRANSFER (ECF No. 27) 9

10 Presently before the Court are motions to dismiss for lack of jurisdiction (“Motions”) 11 submitted by Defendants Safety and Compliance Holdings, LLC, Carr's Hill Partners, 12 LLC, Solomon Group Productions, LLC, and Carr's Hill Capital Partners Management, LP 13 (“Jurisdiction Defendants”). (ECF Nos. 26, 27, 39, 40.) For the reasons below, the Court 14 GRANTS WITHOUT PREJUDICE the Jurisdiction Defendants’ motions to dismiss. 15 (ECF Nos. 39, 40.) The Court also VACATES AS MOOT Jurisdiction Defendants’ 16 remaining two motions to transfer venue. (ECF Nos. 26, 27.) Plaintiff is granted leave to 17 amend its complaint (ECF No. 30) by no later than May 20, 2026. 18 I. BACKGROUND 19 On October 3, 2025, Plaintiff Safety Management and Related Training, Inc. filed 20 this action. (ECF No. 1.) On December 29, 2025, Plaintiff filed the operative complaint— 21 asserting that Jurisdiction Defendants used Plaintiff’s trademarks when advertising and 22 performing safety auditing services and bringing the following causes of action against all 23 Jurisdiction Defendants:1 24 (1) Declaratory relief that Defendants’ past, ongoing, and future use of Plaintiff’s 25 trademarks is not authorized by Plaintiff (Count 1) (ECF No. 30 ¶¶ 113–120); 26 27 1 Plaintiff also brought claims against Defendants Smart Profitability Solutions, LLC and Pala 28 1 (2) Unjust enrichment for financial benefit received from Defendants’ unauthorized use 2 of Plaintiff’s trademarks (Count 3) (id. ¶¶ 128–133); 3 (3) Common law trademark infringement (Count 5) (id. ¶¶ 143–161); 4 (4) Unfair competition, false designation of origin, passing off, and false advertising 5 under 15 U.S.C. § 1125(a) (“Section 43(a) of the Lanham Act”) (Count 6) (id. ¶¶ 6 162–173); 7 (5) Unfair competition under Cal. Bus. & Prof. § 17200 (Count 7) (id. ¶¶ 174–179); 8 (6) Trade dress infringement under Section 43(a) of the Lanham Act (Count 8) (id. ¶¶ 9 180–187); and 10 (7) Common law trade dress infringement (Count 9) (id. ¶¶ 188–195). 11 Jurisdiction Defendants moved to dismiss Plaintiff’s amended complaint on grounds 12 of lack of personal jurisdiction. (ECF Nos. 39, 40.) Jurisdiction Defendants have also 13 previously moved to transfer venue to the Northern District of Texas regarding Plaintiff’s 14 original complaint—which the Court expressly stated it would consider in evaluating 15 Plaintiff’s amended complaint as well. (ECF Nos. 26, 27, 44.) 16 The Court finds it appropriate to rule on Jurisdiction Defendants’ motions (ECF Nos. 17 26, 27, 39, 40) on the papers and without oral argument. See CivLR 7.1.d.1. 18 II. LEGAL STANDARD 19 When raised as a defense by motion, Rule 12(b)(2) authorizes the dismissal of an 20 action for lack of personal jurisdiction. See Fed. R. Civ. P. 12(b)(2). When a dispute 21 between the parties arises concerning whether personal jurisdiction over a defendant is 22 proper, “the plaintiff bears the burden of demonstrating that jurisdiction is appropriate.” 23 Will Co. v. Lee, 47 F.4th 917, 921 (9th Cir. 2022). When the defendant’s motion is based 24 on written materials, and no evidentiary hearing is held, the court will evaluate only 25 whether the plaintiff demonstrates a prima facie showing of personal jurisdiction based on 26 the plaintiff’s pleadings and affidavits. Id. The court must take unchallenged allegations 27 in the complaint as true, and conflicts between the parties over statements within any 28 affidavits must be resolved in favor of the plaintiff. Id. 1 III. DISCUSSION 2 The general rule provides personal jurisdiction over a defendant is proper if it is 3 permitted by a long-arm statute and if the exercise of that jurisdiction does not violate 4 federal due process. Pebble Beach Co. v. Caddy, 453 F.3d 1151, 1154 (9th Cir. 2006). For 5 due process to be satisfied, a defendant must have “minimum contacts” within the forum 6 state such that asserting jurisdiction over the defendant would not “offend traditional 7 notions of fair play and substantial justice.” Id. at 1155 (citing Int’l Shoe Co. v. 8 Washington, 326 U.S. 310, 315 (1945)). Both California and federal long-arm statutes 9 require compliance with due process requirements. Daimler AG v. Bauman, 571 U.S. 117, 10 125 (2014). 11 There are two types of personal jurisdiction: general and specific. Id. at 118. 12 General jurisdiction allows a court to hear cases unrelated to the defendant’s forum 13 activities and exists if the defendant has “substantial” or “continuous and systematic” 14 contacts with the forum state. Fields v. Sedgewick Assoc. Risk, Ltd., 769 F.2d 299, 301 15 (9th Cir. 1986). Specific jurisdiction permits the court to exercise jurisdiction over a 16 defendant who has availed itself through forum-related activities that gave rise to the action 17 before the court. Bancroft & Masters, Inc. v. August Nat’l Inc., 223 F.3d 1082, 1086 (9th 18 Cir. 2000). 19 A. General Jurisdiction 20 A court may exercise general jurisdiction “only when a defendant is ‘essentially at 21 home’ in the State.” Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 592 U.S. 351, 358 22 (2021) (quoting Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 919 23 (2011)). For a corporate defendant, general jurisdiction is paradigmatically appropriate in 24 the state in which the entity is incorporated or where it maintains its principal place of 25 business (where the corporate defendant is “at home”). See Daimler AG v. Bauman, 571 26 U.S. 117, 137 (2014); see also Impossible Foods Inc. v. Impossible X LLC, 80 F.4th 1079, 27 1086 (9th Cir. 2023). 28 1 Jurisdiction Defendants move to dismiss Plaintiffs’ claims on the basis that they are 2 not subject to general jurisdiction in California because their principal places of business 3 are elsewhere. Carr's Hill Partners, LLC is at home in Louisiana. (ECF Nos. 39, 39-1 at 4 11:11-15.) Carr’s Hill Capital Partners Management, LP is at home in Delaware. (Id. at 5 11:16-19.) Safety and Compliance Holdings, LLC is at home in Delaware. (Id. at 11:20- 6 23.) Solomon is at home in Louisiana. (ECF No.

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Safety Management and Related Training, Inc. a California Corporation doing business as Smart Safety Group v. Safety and Compliance Holdings LLC, Carr’s Hill Partners LLC, Solomon Group Holdings, LLC. et. al, Counsel Stack Legal Research, https://law.counselstack.com/opinion/safety-management-and-related-training-inc-a-california-corporation-doing-txnd-2026.