Rannoch, Inc. v. Rannoch Corp.
52 F. Supp. 2d 681; 1999 U.S. Dist. LEXIS 10063

Summary prepared by Devashish Bharuka
For the full version of the case, click here

Plaintiff Rannoch, Inc. ("Rannoch-Va"), a Virginia corporation, was engaged in the business of providing engineering services, computer systems and services in the fields of aviation, transportation, communications and navigation. It owns federal trademark registrations and applications for the mark RANNOCH and variations of RANNOCH for a variety of goods and services, including "RANNOCH".

Defendant Rannoch, Inc. ("Rannoch-Tx"), a Texas corporation, was established to promote interest and involvement in steam railroading. It had a few customers but none of them were from Virginia.

Rannoch-VA brought a federal and state trademark action against the defendant and asserted that personal jurisdiction exists primarily on the basis of Rannoch-Tx's Internet website, which is accessible via the domain names www.rannoch.org and www.steam-training.com. The issue was whether a defendant's Internet activities suffice constitutionally to support to exercise of personal jurisdiction.

Applying the principles of personal jurisdiction under the Due Process analysis, the Court concluded that personal jurisdiction cannot constitutionally be exercised over Rannoch-Tx. Rannoch-Va made no showing of any purposeful availment by Rannoch-Tx of Virginia, as distinct from any other state, or even any purposeful activity directed at or related to Rannoch-Va. There appeared to be nothing more than the placement of the website on the Internet with knowledge of the possiblity that the site might be accessed in Virginia. This alone did not satisfy the due process jurisdictional standard, particularly where, Rannoch-Va made no showing that Rannoch-Va no showing that Rannoch-Tx, when it chose its corporate name, had any knowledge of Rannoch-Va or its trademarks.

While "systematic and continuous contacts" in the forum state may not be necessary, some element of purposeful direction or availment is constitutionally necessary. Here, neither mere use of a similar name to that of a Virginia company nor the creation of the website, without more, is activity purposefully directed at Virginia. The mere fact that the defendants advertised on the Internet and manufactured tools with the knowledge that some would be sold in Virginia was insufficient to satisfy the constitutional requirements because, essentially, such conduct amounts to nothing more than "the placement of a product into the stream of commerce" and thus "in not an act ... that is purposefully directed toward the forum State".

The Court held that Rannoch-Tx's Internet website activities are alone constitutionally insufficient to support personal jurisdiction in Virginia.

Held, there is no personal jurisdiction.