Facts

Jobiak LLC was a Delaware corporation with its principal place of business in Massachusetts that was founded in 2018 as an AI-based recruitment platform designed to publish job postings on Google. Aspen Technology Labs Inc. (Aspen) was a Colorado corporation with its principal place of business in Colorado that scraped job postings from across the internet and optimized them to meet Google's schema requirements. Aspen claimed intellectual property rights in its automated database, which was a compilation of information including descriptions, categories, job listings, and layout designs. In March 2022, Jobiak learned that Aspen was using its database for commercial purposes. Jobiak brought a lawsuit against Aspen, alleging copyright infringement, violation of the Computer Fraud and Abuse Act, the California Comprehensive Computer Access and Fraud Act, the Digital Millenium Copyright Act, and unfair competition.

PLAINTIFF'S CONTENTIONS: Plaintiff alleged that defendant used a similar layout design and search key title words at the end of job descriptions. Plaintiff also argued that defendant's website contained copyrighted material. Plaintiff maintained that defendant's software placed several irrelevant keywords that had no relation to the posting listed and that defendant copied these dummy keywords in defendant's postings. As to jurisdiction, plaintiff contended that defendant had consistently, knowingly, and intentionally directed their wrongful actions towards plaintiff, a company with clients, contracts, and employees located within California, catered its business towards California, and was allegedly injured in California.

DEFENDANT'S CONTENTIONS: Defendant alleged that plaintiff lacked jurisdiction for its claim because defendant was a Colorado corporation that was not essentially at home in California and there were no allegations that defendant's database or website were hosted in servers in California.

Result

The court dismissed for lack of personal jurisdiction.