American Girls sells dolls. Defendant, located in China, allegedly sells counterfeits of plaintiff’s dolls. Plaintiff attempted trap buys into the district, however no orders were fulfilled. Defendant alleged that it had a policy of not shipping into the U.S. Court dismisses for lack of specific jurisdiction, as mere accessibility of the website in the district was insufficient.

What if a defendant never fulfills orders – but just charges credit cards. Where does the tort take place?

Text of decision:

van leeuwen v rebel creamery