Abetting Collection Avoidance Is Purposeful Availment

Gilmore Bank v. AsiaTrust New Zealand, Ltd., No. G048053 (D4d3 Jan. 21, 2014)

The court of appeal reverses an order quashing service for lack of personal jurisdiction. In doing so, it reads the effects test enunciated in Calder v. Jones, 465 U.S. 783 (1984) and subsequent California Supreme Court cases to require only the knowing direction of an intentional tort into the California forum, but not necessarily at the plaintiff in the case.