Whether specific personal jurisdiction is limited to circumstances where a nonresident serves a market for a product in the forum and the product causes injury in the forum, or if the place of injury provides no territorial limit to the exercise of specific jurisdiction

QUESTIONS PRESENTED The Due Process Clause permits a state court to exercise specific personal jurisdiction over a non-resident defendant only when the plaintiff’s claims “arise out of or relate to” the defendant’s forum activities. Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 141 S. Ct. 1017, 1026 (2021). The questions presented are: 1. Under the “relate to” prong, is specific jurisdiction limited to circumstances where a nonresident serves a market for a product in the forum and the product causes injury in the forum? Or, as the Court of Appeal held here, does the place of injury provide no territorial limit to the exercise of specific jurisdiction? 2. If specific jurisdiction “does not mean anything goes” and “incorporates real limits,” as this Court held in Ford, what are those limits in California for nonresidents like Petitioner who are sued for a plaintiff’s accident and injury that occurs thousands of miles away in another state where they used a product that was also designed, manufactured, and sold in other states far outside of California? 3. Because specific jurisdiction is based on the defendant’s contacts with the forum, is it proper for courts to consider a plaintiff’s residency in the forum, the availability of a passive website that can be accessed by anyone inside and outside the forum, or activity by an independent local third-party such as a dealer, distributor or repair facility?