von Prince v. DSM Nutritional Products LLC

Background

Beowulf von Prince sued DSM Nutritional Products LLC and Swiss Post Solutions. The opinion does not describe the underlying dispute in detail. The court considered motions to dismiss filed by the defendants.

Rulings on jurisdiction and standing

The court granted the motions to dismiss and dismissed the complaint against both defendants for lack of jurisdiction.

As to Swiss Post Solutions, the court held that von Prince had not pleaded facts showing personal jurisdiction—meaning a sufficient connection allowing a court in California to exercise authority over that defendant. The court said the complaint did not establish either general or specific personal jurisdiction. It also rejected joint and several liability as a basis for personal jurisdiction.

As to DSM Nutritional Products LLC, the court said von Prince did not adequately allege Article III standing—the constitutional requirement that a plaintiff show a legally sufficient injury connected to the defendant's conduct. In particular, the court said the complaint did not adequately allege that DSM Nutritional Products LLC, rather than DSM Nutritional Products AG, took action causing an injury. The court also said von Prince did not adequately allege an alter-ego or agency theory that would make the subsidiary liable for the parent's acts. The court concluded that the alleged assignment of rights did not cure the absence of allegations that the named defendant caused an injury.

Leave to amend and other rulings

Although the court said it seemed highly unlikely that von Prince could overcome the jurisdictional problems or state a claim against either defendant, it granted leave to amend the complaint. The amended complaint was due within 21 days of the ruling, and responses were due 14 days after that.

The court also stated that it seemed unlikely the Northern District of California was the proper venue because the dispute appeared to have no connection to that district. The court did not decide the merits of the claims.

The opinion's final, partially garbled text states that a motion for execution was denied and that a motion to strike the sur-reply was denied. The text does not provide additional explanation for those rulings.