Maria Chen (“Chen”) is a resident of Fresno, California. In…

Questions

Mаriа Chen (“Chen”) is а resident оf Fresnо, Califоrnia. In June 2025, Chen purchased a “HeatMaster” outdoor gas grill from a retail store in Fresno. The grill was designed, manufactured, and assembled entirely in California by Golden State Grills, Inc., a California corporation with its only facility in Fresno. Every HeatMaster grill is equipped with a safety shut-off valve manufactured by Empire Valve Co. (“Empire”), a corporation incorporated in New York with its only manufacturing facility in Buffalo, New York. Empire has no offices, employees, agents, bank accounts, or real property in California. Empire has never advertised in California and has never sent any employee or representative to California. Five years ago, Empire and Golden State entered into a written supply contract under which Empire agreed to manufacture shut-off valves exclusively for installation in HeatMaster grills. Under the contract, Empire ships the valves directly from its Buffalo facility to Golden State’s plant in Fresno four times each year, and has done so without interruption for five years. Golden State is Empire’s only customer, and Empire knows that Golden State sells HeatMaster grills only to consumers in California. In July 2025, while Chen was using her HeatMaster grill at her home in Fresno, the shut-off valve malfunctioned and failed to stop the flow of gas. The grill exploded, and Chen suffered serious burns. Chen sued Empire in the United States District Court in California. Chen’s complaint alleges that the shut-off valve installed in her grill was defectively designed and manufactured by Empire. Empire timely filed a motion to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(2), contesting personal jurisdiction. California has a long-arm statute that states: “A court of this state may exercise jurisdiction on any basis not inconsistent with the Constitution of this state or of the United States.” Assume, for the purposes of this question, the Federal Rules of Civil Procedure apply. How should the court rule on Empire’s Motion to Dismiss? Fully discuss and explain your answer.