Appellant subcontractor sued respondent animator for breach of contract. The San Diego Superior Court (California) granted the animator’s motion to quash the service of the summons and the complaint. The subcontractor appealed.

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Overview

The animator contracted with the subcontractor to have it provide the digital ink and paint portion of an animation production. The animator argued that as it was not a resident of California, and the bulk of the work was performed in the Philippines, it did not have sufficient contacts with the state. The appellate court held that the animator “purposefully directed” its activities at the primary contractor and purposefully availed itself of the privilege of conducting activities within the state and invoked the benefits and protections of its laws. The animator negotiated and contracted with the primary contractor (contractor), took directions from and communicated with the contractor within and outside California to perform that contract, held meetings with the contractor in California concerning performance of the contract, delivered the work in progress and final work to California, the animator purposefully directed its activities at the contractor and purposefully derived economic benefits from forum activities. The nexus required to establish specific jurisdiction was between the animator, the state, and the litigation, not between the subcontractor and the animator.

Outcome

The order of the court quashing the summons and complaint was reversed and the matter was remanded for further determinations consistent with the opinion.