Mavrix Photo, Inc. v. Brand Technologies, Inc.

2011), is a case in American intellectual property law involving personal jurisdiction in the context of internet contacts.

First, the defendant, Brand Technologies, Inc., lacked sufficient contacts with California for exercise of general jurisdiction.

Second, the defendant's alleged copyright infringement on its website was expressly aimed at California enough to find specific jurisdiction.

Finally, the defendant's alleged copyright infringement caused harm that it recognized was likely to be suffered in California enough to find specific jurisdiction.

Mavrix registered copyright of those photographs for its business to exclusively license them to celebrity news outlets.

It said that if it permit general jurisdiction based on access to such website, it would lead to the result inconsistent with constitutional requirement of "the continuous corporate operation within a state" be "so substantial and of such a nature as to justify suit against" the non-resident defendant.

First, the court declared three-pronged test, so called "minimum contact" test that "(1) The non-resident defendant must purposefully direct his activities or consummate some transaction with the forum or resident thereof; or perform some act by which he purposefully avails himself of the privilege of conducting activities in the forum, thereby invoking the benefits and protections of its laws; (2) the claim must be one which arises out of or relates to the defendant's forum-related activities; and (3) the exercise of jurisdiction ... must be reasonable.

Regarding the effects test (a), the court found that Brand obviously intentionally posted the assertedly copyright-infringing photos.