However, the California Supreme Court upheld specific jurisdiction in this case, as to both the resident and non-resident plaintiffs.

Specific jurisdiction may exist only where the events underlying the lawsuit arise out of or relate to the defendant's contact with the forum state.

Northeastern University law professor Stephen Subrin and colleagues questions the value of making plaintiffs file in their own state, echoing Sotomayor.

He further wonders if the majority's alleged cause of "interstate federalism" was sufficient justification for a verdict that strongly favored well-resourced companies over injured plaintiffs.

[2] Berkeley law professor Andrew Bradt writes that the decision does much to favor companies, by further hindering class action and mass-joinder suits (to which the Federal judiciary is already quite hostile).

[4] University of Mississippi professor Michael Hoffheimer cites the case as one of six that have been part of a "stealth revolution" around personal jurisdiction.

He argues that this does not solve the underlying problem: that personal jurisdiction remains one of the hardest to understand and apply aspects of American law.