In this quarter’s column, we explore three cases dealing with important procedural issues: personal jurisdiction for corporations, the local controversy exception to the Class Action Fairness Act, Pub. L. No. 109-2, 119 Stat. 4 (2005) (codified, in part, at 28 U.S.C. §1332(d)), and required expert disclosures.

Personal Jurisdiction for Corporations

In Greenwood v. Arthrex, 21-CV-1101S, 2022 WL 2117763 (W.D.N.Y. June 13, 2022), plaintiff was a New York resident alleging a claim of product liability against defendants, Arthrex, a corporation with Florida as its principal place of business, TE Connectivity, a corporation with Texas as its principal place of business, and Precision Edge Surgical Products Company, an LLC with Michigan as its principal place of business. Plaintiff was injured by an Arthrex device with inner and outer tubing made by Precision, as well as heat shrink tubing made by TE. After being removed to federal court based on diversity jurisdiction, Precision and TE both moved to dismiss the complaint—Precision for lack of personal jurisdiction, and TE for failure to state a claim under FRCP 12(b)(6). Plaintiff cross-moved for jurisdictional discovery from both Precision and TE.