Civil Procedure

Brief

Pebble Beach Co. v. Caddy

Procedural History:

• District Court rules in favor of Caddy
• Pebble Beach Appeals
  • Affirmed

Facts:

• Caddy owns a bed and breakfast in Southern England.
• The name of the bed and breakfast is Pebble Beach.
• He has a website named www.pebblebeach-uk
• This of course resembles the California Golf Resorts name and website of Pebblebeach.com
• Caddy briefly worked in California.
• Caddy’s website is NOT interactive and only gives general information about his B and B.
• Pebble beach is suing Caddy under the Lanham Act which prohibits trademark infringement.
• Caddy moves for dismissal based on lack of jurisdiction. Approved.

Issue:

• Does California have Personal Jurisdiction over Caddy?

Holding:

• No. Affirmed.

Reasoning:

• 3-parts test to analyze minimum contacts. P.151. Pebble beach arguments fail under the first prong.
  • Pebble beach fails to prove that Caddy has performed some act or consummated some transaction within the forum or otherwise purposefully availed himself o the privileges of conducting activities in the forum or purposefully directed his activities towards the forum.
  • There was no conduct by Caddy that took place in California.
  • Caddy did not purposely aim its conduct at California.