735 JURISDICTION ? No Personal Jurisdiction if No Contacts (2020)

In Lexington Ins. Co. v. Hotai Ins. Co., Ltd., No. 18-1141 (September 12, 2019), the Seventh Circuit held that the Dist. Ct. did not err in dismissing, for lack of personal jurisdiction, plaintiff’s primary insurance company’s action against two defendant Taiwan insurance companies, where plaintiff sought indemnification for products-liability settlement that plaintiff paid on insured’s behalf for accident that occurred in Texas. Each defendant provided Lexington?s insured with “worldwide” products-liability coverage in agreements with insured. Dist. Ct. could properly find that neither defendant had purposely availed themselves of privilege of conducting business in Wisconsin where: (1) neither defendant had solicited insured’s business or targeted Wisconsin market; (2) defendants’ agreements were negotiated and drafted in Taiwan with Taiwanese companies; (3) said agreements required that disputes be resolved in Taiwan through use of Taiwan law; and (4) neither defendant visited Wisconsin or contacted anyone residing there. Fact that defendants provided “worldwide coverage” or that defendants may be liable to insured did not require different result or establish sufficient contacts with state of Wisconsin to establish personal jurisdiction over the defendants.