Lindblad v. Linde AG

Background

Robert Lindblad, who represented himself, sued three defendants in seven causes of action concerning his alleged ownership rights in Linde AG. The opinion refers to one defendant as Linde GmbH, while the caption names Linde AG. The other defendants were Stephen Angel, identified as Linde’s former chief executive officer, and Sanjiv Lamba, identified as its current chief executive officer. The opinion states that Angel is a Texas resident and Lamba is a Connecticut resident.

Lindblad alleged that his family’s company had been unlawfully taken over and that he had broad ownership rights in Linde based on the use of his family name in “Linde Gas Corp.” He sought equitable relief and $25,034,074,999 in damages. The case was originally filed in San Mateo County Superior Court and was later removed to federal court based on diversity jurisdiction.

Personal Jurisdiction

The defendants moved to dismiss for lack of personal jurisdiction and insufficient service of process. Personal jurisdiction is a court’s authority to exercise power over a defendant. The court explained that this authority may be general, based on a defendant’s continuous and substantial relationship with the forum, or specific, based on conduct connected to the claims.

As to Linde, the court found no general jurisdiction because Linde was organized under German law, had its principal place of business in Germany, and had no employees, licenses, real property, bank accounts, corporate records, or places of business in California. Lindblad did not allege facts showing that Linde was essentially at home in California.

The court also found no specific jurisdiction over Linde. Lindblad did not allege facts showing that Linde purposefully directed activities toward California or that his claims arose from conduct connected to California. The court therefore did not need to address whether exercising jurisdiction would be reasonable.

As to Angel and Lamba, the court found that Lindblad made no specific jurisdictional allegations and did not show that either individual had the minimum contacts with California required for personal jurisdiction. The court rejected Lindblad’s argument that California was an appropriate forum because it was convenient for him.

Ruling

The court granted the defendants’ motion to dismiss for lack of personal jurisdiction as to Linde, Angel, and Lamba. Because the court found that no personal jurisdiction existed, it did not reach the defendants’ argument about insufficient service of process. The court also stated that jurisdictional discovery would be futile and that the order disposed of Docket Nos. 6 and 17.