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Sun Life Assurance Company of Canada v. U.S. Bank National Association

REPLY BRIEF re MOTION to Dismiss for Lack of Jurisdiction Over the Person in Support of Its Motion to Dismiss the First Amended Complaint or, in the Alternative, to Transfer

28 Cited authorities

  1. Asahi Metal Indus. Co. Ltd. v. Superior Court

    480 U.S. 102 (1987)   Cited 4,871 times   40 Legal Analyses
    Holding that, in suit by Taiwanese manufacturer for indemnification against Japanese manufacturer, the assertion by California court of personal jurisdiction over Japanese manufacturer was unreasonable

  2. Shaffer v. Heitner

    433 U.S. 186 (1977)   Cited 3,169 times   7 Legal Analyses
    Holding that, once a judgment is validly rendered against a debtor, the judgment creditor may sue to satisfy the debt with property in a state that lacks personal jurisdiction over the judgment debtor

  3. General Electric Co. v. Deutz AG

    270 F.3d 144 (3d Cir. 2001)   Cited 575 times   1 Legal Analyses
    Holding "communication by electronic facilities, rather than physical presence" can establish these relationships

  4. Reifer v. Westport Ins. Corp.

    751 F.3d 129 (3d Cir. 2014)   Cited 233 times   5 Legal Analyses
    Holding that "a remand order entered pursuant to the [Declaratory Judgment Act] is an appealable final decision"

  5. Medical Ass. Co. v. Hellman

    610 F.3d 371 (7th Cir. 2010)   Cited 193 times
    Holding that plaintiff had properly pleaded diversity by stating "on information and belief" that defendants were citizens of a particular state

  6. Boone v. Oy Partek Ab

    724 A.2d 1150 (Del. Super. Ct. 1997)   Cited 118 times
    In Boone, the Delaware Superior Court held that the stream of commerce theory is available under section 3104(c)(4). 724 A.2d at 1158; see also Siemens Aktiengesellschaft v. LG Semicon Co., 69 F.Supp.2d 622, 626-27 (D.Del. 1999).

  7. Acorda Therapeutics Inc. v. Mylan Pharms. Inc.

    817 F.3d 755 (Fed. Cir. 2016)   Cited 68 times   19 Legal Analyses
    Holding that Daimler did not overrule the line of precedent that supports the idea that consent is independent from general personal jurisdiction

  8. PHL Variable Insurance v. Price Dawe 2006 Insurance Trust ex rel. Christiana Bank & Trust Co.

    28 A.3d 1059 (Del. 2011)   Cited 77 times   2 Legal Analyses
    Holding that trustee has insurable interest in life of insured so long as insured "actually established the trust"

  9. Simon v. Navellier Series Fund

    Civil Action No. 17734 (Del. Ch. Oct. 19, 2000)   Cited 78 times
    Finding that multiple agreements "must be viewed together and in their entirety when determining the scope and nature of" the parties' obligations

  10. Ab v. Mylan Pharm., Inc.

    72 F. Supp. 3d 549 (D. Del. 2014)   Cited 45 times   14 Legal Analyses
    Holding that, “[i]n light of the holding in Daimler, the court finds that Mylan's compliance with Delaware's registration statutes—mandatory for doing business within the state—cannot constitute consent to jurisdiction, and the Delaware Supreme Court's decision in Sternberg can no longer be said to comport with federal due process”

  11. Section 3104 - Personal jurisdiction by acts of nonresidents

    Del. Code tit. 10 § 3104   Cited 568 times   16 Legal Analyses
    Allowing for personal jurisdiction over a nonresident who "[contracts to supply services or things in [Delaware]."

  12. Section 18-109 - Service of process on managers and liquidating trustees

    Del. Code tit. 6 § 18-109   Cited 79 times   9 Legal Analyses
    Allowing for service for claims "involving or relating to the business of the limited liability company"

  13. Section 3804 - Legal proceedings

    Del. Code tit. 12 § 3804   Cited 12 times
    Establishing that a Delaware statutory trust is a juridical entity that "may sue and be sued"