Interdata Network v. Wang

Background

Interdata Network, Inc. and Cerebellum Networks, Inc. alleged a series of events involving extortion, false imprisonment, cryptocurrency theft, and related conduct. Sandeep Nailwal was named in two of the complaint’s fifteen claims: aiding and abetting fraud and attempted extortion.

The complaint alleged that Nailwal participated in a meeting with Cerebellum’s CEO in Dubai, echoed threats made by Kenzi Wang, later contacted the CEO with what the complaint described as a mild apology, and met with him at a Dubai hotel. The court said these allegations were sparse and did not clearly connect Nailwal’s allegedly tortious conduct to California. Nailwal stated that he is a permanent resident of the United Arab Emirates, is the CEO of a company headquartered there, and has never resided, worked, or owned property in the United States. The plaintiffs did not challenge those facts.

Personal Jurisdiction

Nailwal moved to dismiss under Federal Rule of Civil Procedure 12(b)(2) for lack of personal jurisdiction, meaning that the court allegedly lacked authority over him. Because no federal statute supplied personal jurisdiction, the court applied California’s long-arm statute, which the court said reaches as far as the federal Constitution’s due-process limits.

The court focused on specific personal jurisdiction, which asks whether the claims are connected to the defendant’s contacts with the forum state. Because the claims sounded in tort, the court applied the purposeful-direction test: whether Nailwal committed an intentional act, expressly aimed it at California, and caused harm he knew was likely to occur there. The court said the complaint did not plausibly establish those requirements. Possible continuing business dealings in California, a possible relationship with a third party in California, and the plaintiffs’ own California contacts were not enough to establish jurisdiction.

Ruling

The court concluded that the allegations pointed toward dismissing Nailwal but that the record was just sufficient to make the possibility of personal jurisdiction more than speculation. It therefore allowed the plaintiffs to conduct a short period of discovery limited to jurisdictional facts about Nailwal’s conduct within California.

The court denied Nailwal’s motion to dismiss without prejudice. The discovery was to be completed by March 6, 2026. The plaintiffs may file an amended complaint by March 16, 2026, alleging facts supporting specific personal jurisdiction. Nailwal may again seek dismissal on jurisdictional grounds, or the plaintiffs may dismiss him as a defendant.