July 17, 2019

Colorado Supreme Court: E-mail and Telephone Communications Sufficient to Establish Jurisdiction

The Colorado Supreme Court issued its opinion in Foundation for Knowledge in Development v. Interactive Design Consultants, LLC on June 28, 2010.

Personal Jurisdiction—Minimum Contacts.

In this original proceeding, the Supreme Court affirmed the district court’s finding that plaintiff, a Colorado nonprofit corporation, adequately established personal jurisdiction in Colorado over defendants. Defendants are Interactive Design Consultants, a Rhode Island company, and its sole owner, Rick DiNobile, a Rhode Island resident. Defendants entered into an agreement with plaintiff to collaborate extensively to create an online educational program. The parties exchanged hundreds of e-mail and telephone communications relating to the agreement.

The Court held that, based on the documentary evidence submitted by the parties, defendants’ numerous contacts with the Colorado corporation are sufficient for the trial court to exercise specific jurisdiction, and personal jurisdiction over defendants is reasonable under the due process clause of the Colorado Constitution. Accordingly, the Court affirmed the trial court’s order and remanded the case for further proceedings.

Summary and full case available here.

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