Yih v. Taiwan Semiconductor Man ufacturing Company,Ltd

Background

The court had previously dismissed Jihshyr Yih’s complaint against Taiwan Semiconductor Manufacturing Company, Ltd. (TSMC) for lack of personal jurisdiction. Personal jurisdiction is a court’s authority to hear a case against a particular defendant. Yih then asked for permission to file a motion for reconsideration, arguing that the court had failed to consider material facts or decisive legal arguments presented before the earlier order.

Arguments

Yih relied on two theories. First, he argued that California would have been one of his possible “job locations” if TSMC had hired him, and that this supported specific jurisdiction over TSMC. Second, he argued that TSMC experienced production and sales issues after it denied him the position of Chief Information Officer, allegedly affecting California individuals’ and companies’ ability to access TSMC’s website for online information and transactions.

Court’s Analysis

The court explained that specific-jurisdiction analysis focuses on contacts that the defendant itself created with the forum state. The possibility that California would have been one of Yih’s job locations did not show that TSMC made efforts to create contacts with California.

The court also found the alleged effects on access to TSMC’s website irrelevant to whether TSMC purposefully directed activities toward California or whether Yih’s discrimination claims arose from or related to TSMC’s activities connected to California. According to the court, the claims would have arisen regardless of the alleged effect that not hiring Yih had on California users’ access to the website.

Disposition

The court concluded that it had not failed to consider material facts or decisive legal arguments. It therefore denied Yih’s motion for leave to file a motion for reconsideration.