Second Circuit Personal Jurisdiction: Chloe v Queen Bee – One Trap Sale "Might Well Be" Sufficient

This is now the latest Second Circuit decision on minimum contacts in NY in an IP context.
Chloe sues Defendant. Defendant sold 52 non-Chole bags into NY and one alleged Chloe-counterfeit to Chloe’s NY law firm. The 2d Cir finds the totality of those sales sufficient for personal jurisdiction Page 18: the court says that a single trap sale ‘might well be sufficent.’
Decision Chloe Queen Bee 2d Circuit PJ

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