Sneha Media & Ent. LLC v. Assoc’d Broad. Co. P Ltd. (P)

A Virginia company and an Indian company sued another Indian company, Associated Broadcasting, for breach of contract and related causes of action arising from a dispute over the plaintiffs’ right to distribute TV programming in the U.S. that Associated Broadcasting produced in India. The district court correctly held that the plaintiff companies failed to demonstrate that Associated Broadcasting had the minimum contacts with Virginia that are sufficient to satisfy the Due Process Clause.

Associated Broadcasting carries on its business solely in India and, by a contract executed in India, it gave one plaintiff the right to distribute its TV9 programming elsewhere. The only relevant contact that Associated Broadcasting had with Virginia was a single meeting, which involved the plaintiffs’ CEO’s expression of interest in distributing Associated Broadcasting TV9 content in the U.S. That discussion was informal and limited, leading to no arrangement.

Plaintiffs’ counsel also stated at the hearing that Associated Broadcasting used a plaintiff’s media office in Virginia as its broadcast center and sent files back to India. But the plaintiffs do not explain which personnel were allegedly involved (if not reporters), what content was broadcast, or what files were transferred to India. Moreover, there’s no suggestion whether the asserted activity included creation of any content. The use of the plaintiff’s office to transmit files to India could at most, if assumptions are made, be a weak, insufficient contact to establish jurisdiction.

Affirmed.

Sneha Media & Ent. LLC v. Assoc’d Broad. Co. P Ltd. (P), No. 17-2004, Dec. 18, 2018. 4th Cir. (Niemeyer) from EDVA at Alexandria (Brinkema).



Categories: 4th U.S. Circuit Court of Appeals, Opinions, Published

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