In B.D. v. Samsung SDI Co., Ltd., No. 24-2444 (July 9, 2025) S.D. Ind., Terre Haute Div. (BRENNAN), Plaintiff filed a lawsuit against the defendant, a South Korean manufacturer, after a battery manufactured by defendant exploded in the plaintiff’s pocket and injured him. The district court granted defendant’s motion to dismiss for lack of personal jurisdiction and plaintiff appealed. Here, the defendant purposefully availed itself of the Indiana forum by exploiting an end-product stream of commerce. But, Samsung SDI has not, however, availed itself of the forum through sales of individual batteries — that is, the derivative product. It instead conducted its business to prevent ordinary consumers from purchasing those individual batteries in Indiana. Still, B.D. received the individual battery that exploded in his pocket after his stepfather purchased it from an e-cigarette retailer through an unauthorized transaction. There is a disconnect, then, between Samsung SDI’s purposeful contacts with the Indiana forum, through an end-product stream of commerce, and B.D.’s lawsuit, which stems from a consumer purchase of the derivative product. That disconnect forecloses an exercise of specific personal jurisdiction. The Seventh Circuit therefore affirmed the district court’s decision granting Samsung SDI’s motion to dismiss, finding that while the defendant sold its products for use as a component in consumer products and had purposely availed itself of the Indiana forum through an end-product stream of commerce, there was a disconnect between the defendant’s contacts with the forum and the lawsuit, which resulted from a consumer purchase of a derivative product. The appellate court explained that the disconnect foreclosed the federal court’s exercise of personal jurisdiction. (SYKES and LEE, concurring).
