Antitrust Law Daily Wrap Up, FRANCHISING & DISTRIBUTION—D. Idaho: Chinese e-bike manufacturer does not have enough contacts in Idaho to be subject to personal jurisdiction, (Jul 10, 2026)

By Molly Platnick

A couple injured by their bike’s battery could not satisfy the Ninth Circuit’s test for specific personal jurisdiction.

The federal district court for the District of Idaho granted a Chinese e-bike manufacturer’s motion to dismiss in an action brought by a couple whose house burned down when the battery on their bike overheated. The manufacturer moved to dismiss for lack of personal jurisdiction because it did not sell its bikes directly to consumers in the United States. The couple did not introduce any evidence showing the manufacturer targeted Idaho specifically and, relying on Supreme Court decisions, the court stated it was not enough that the manufacturer had a presence throughout the United States. Even if the couple had been able to show the manufacturer had minimum contacts with Idaho, their cause of action was not related to those contacts (Nelson v. Chongqing Qiulong Tech., No. 2:25-cv-00010-BLW (D. Idaho Jun. 5, 2026)).

Battery caught fire. The husband-and-wife plaintiffs ordered two e-bikes to their home in Coeur d’Alene, Idaho in May 2021. About a year and a half later, a battery in one of the bikes experienced a “thermal runaway” and caught fire in the couple’s garage. The fire resulted in a “total loss of their real and personal property,” including their house and garage.

No offices in Idaho. The e-bike manufacturer is a Chinese corporation with its principal place of business in China and is not licensed to sell directly to American consumers. The manufacturer has no offices, employees, or business operations in Idaho, and there is no evidence it engaged in “Idaho-specific” marketing. Consumers in the United States can purchase an e-bike from a third-party distributor. At the relevant time, the manufacturer did not have any dealers or distributors, and the couple’s bikes were shipped from California. The manufacturer offers an app on its website that instructs purchasers how to maintain their bikes and make an appointment for repair of maintenance. The couple acknowledges they did not use the app.

Complaint filed. The couple brought this case in state court in October 2024, alleging failure to warn, breach of warranty, and strict liability and negligence based on design and manufacturing defects. One of the defendants removed the case to federal court for the District of Idaho. The Chinese manufacturer moved to dismiss based on FRCP 12(b)(2), lack of personal jurisdiction. The couple replied with the instant Motion for Leave to Conduct Jurisdictional Discovery.

In response to the motion, the couple introduced statements from the manufacturer’s website as evidence it sold its e-bikes directly to consumers in Idaho. However, these claims directly contradicted the general counsel’s sworn testimony that the manufacturer does not sell directly to American consumers.

The manufacturer argued the statements the couple introduced were from “counterfeit or unaffiliated third-party websites.” The couple’s counsel declined the manufacturer’s request to resolve the misattributed statements and the court disregarded “factual assertions that rely solely on statements contained in non-[manufacturer] websites.”

Personal jurisdiction. A plaintiff must establish personal jurisdiction by showing “the statute of the forum confers personal jurisdiction over the nonresident defendant and that the exercise of jurisdiction conforms with the federal constitutional principles of due process.” Because Idaho’s long-arm statute is broader than personal jurisdiction under the Due Process Clause, the court analyzed personal jurisdiction solely based on the Constitution. The Fourteenth Amendment requires nonresident defendants have sufficient minimum contacts with the forum state so as not to “offend notions of fair play and justice.”

Personal jurisdiction may be general or specific. General personal jurisdiction exists when a defendant has “continuous and systemic” contacts with the forum state such that it is “essentially at home.” A court may exercise specific personal jurisdiction where a plaintiff’s claims “arise out of or relate to” the defendant’s minimum contacts with the forum state. The court in this case relied on the Ninth Circuit’s tri-part test for determining specific jurisdiction: (1) the non-resident defendant must purposefully direct its activities to the forum state or purposefully avail itself of the privileges of the forum state, thus “invoking the benefits and protections of its laws; (2) the claim must arise out of or relate to the defendant’s activities in the forum state; (3) the exercise of jurisdiction must be reasonable.

The plaintiff must establish the first two elements, then the burden shifts to the defendant to show the exercise of personal jurisdiction would not be reasonable.

The court here found it “clearly” did not have general jurisdiction over the Chinese corporation and only considered specific jurisdiction.

Did not target Idaho market. To satisfy the Ninth Circuit’s test for specific personal jurisdiction, the couple needed to show the e-bike manufacturer purposefully availed itself of the Idaho market. Relying on the Idaho Supreme Court’s decision in Griffen v. St. Michelle Wine Estates, the couple contended the manufacturer was subject to personal jurisdiction because it placed its products into the “stream of commerce.” The court in this case rejected that rule, explaining it was bound by federal law and the Ninth Circuit’s test described above. Instead, the couple was required to show the manufacturer targeted the Idaho market specifically through conduct like designing the product for the forum state or advertising in the forum state.

Here, the e-bike manufacturer did not do “something more” to sell its product in Idaho specifically. In fact, there were no authorized dealers or distributors in the state, and the couple had to purchase their bikes from a California company. The court’s determination rested on J. McIntyre Machinery v. Nicastro. In that case, the Supreme Court held a foreign manufacturer was not subject to jurisdiction in New Jersey because the evidence showed an “intent to serve the United States market as a whole…[not] that the manufacturer purposefully availed itself of any particular state’s market.”

The court rejected the couple’s argument the manufacturer’s app evidenced minimum contacts with the forum state. The couple did not show how the app’s services “enabled sales” or created advertising toward Idaho. Even if the app did suggest the manufacturer had minimum contacts with the state, jurisdiction would be inappropriate because the couple’s claim did not arise out of or relate to the app.

The court decided it could not exercise specific personal jurisdiction because the couple did not meet the Ninth Circuit test’s first two prongs. The couple could not show the e-bike manufacturer specifically targeted Idaho, nor that their claims arose from the manufacturer’s conduct in Idaho.

Motion for jurisdictional discovery. District courts have “broad discretion” in granting jurisdictional discovery but are limited to requests that do not rely on speculation. Here, the couple did not identify further facts for discovery that would show the e-bike manufacturer had minimum contacts with Idaho. Based on the existing record, the court was not persuaded discovery would change its decision it could not exercise personal jurisdiction and declined to go on a “fishing expedition.”

The case is No. 2:25-cv-00010-BLW.

Judge: Winmill, B.

Attorneys: Melanie Elise Baillie (James, Vernon & Weeks, P.A.) for Lindsay Nelson. Andrew C. Brassey (Brassey Crawford, PLLC) for Chongqing Qiulong Technology Co. Ltd.

Companies: Chongqing Qiulong Technology Co. Ltd.

Cases: FranchisingDistribution IdahoNews