Bonhac World Corporation v. Mellin Works LLC

Background

Bonhac World Corporation brought four claims against Mellin Works LLC, doing business as Eazyhold: unfair and deceptive trade practices under New York law, monopolistic contracts under New York law, common-law unfair competition, and tortious interference with contractual relations.

Bonhac World alleged that Mellin Works contacted it by email in December 2020 and claimed that Bonhac World’s grip-support devices sold on Amazon infringed Mellin Works’s design and utility patents. Bonhac World responded by email on September 2, 2021. The complaint appeared to allege that Mellin Works took some action that caused Amazon to remove product listings, but it did not identify which listings were removed. It alleged that Mellin Works misused its patents and notified Amazon to make a fraudulent claim under the Digital Millennium Copyright Act.

Bonhac World alleged that it was a New York corporation. The opinion states that Mellin Works was a California limited liability company with its principal place of business in Simi Valley, California.

Motion to Dismiss

Mellin Works moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient and plausible claim. Mellin Works’s primary argument was that the court lacked personal jurisdiction—the legal authority to exercise power over the defendant in the case.

Personal-Jurisdiction Analysis

The court first considered general jurisdiction under New York Civil Practice Law and Rules § 301. Bonhac World did not allege that Mellin Works was domiciled in New York, was served with process in New York, or continuously and systematically conducted business there. The court also found that Bonhac World’s allegation that Mellin Works transacted business in New York was conclusory. An allegation that a third party, Lowes, sold Mellin Works’s product in New York did not show that Mellin Works itself sold products there.

The court next considered specific jurisdiction under New York Civil Practice Law and Rules § 302(a)(1), which can apply when a defendant transacts business in New York and the claim arises from that business. The court found no allegation that Mellin Works itself made a sale in New York or to a New York resident. The alleged availability of Mellin Works’s products through a third-party seller and the ability of a website to reach New York customers were insufficient.

Under § 302(a)(2), the alleged tortious conduct generally must have been committed physically in New York by the defendant or an authorized agent. Bonhac World did not allege that Mellin Works was physically present in New York when it engaged in the alleged conduct or that the conduct occurred there. The court understood the complaint’s allegations to concern online communications between Mellin Works and Amazon.

Under § 302(a)(3), Bonhac World needed to plausibly allege, among other things, that an out-of-state tort caused an injury in New York and that Mellin Works expected or should have expected consequences in New York through a purposeful connection with the state. The court found that Bonhac World had not plausibly alleged that Mellin Works made sales to New York or otherwise targeted New York in a way that would support jurisdiction.

Disposition

The court held that Bonhac World had not stated a plausible claim that the court had personal jurisdiction over Mellin Works. Judge Nelson S. Roman granted Mellin Works’s motion to dismiss. The court dismissed all claims against Mellin Works, directed the Clerk to terminate the motion at ECF No. 22, and directed the Clerk to terminate the action. The opinion does not state whether the dismissal was with or without prejudice.