In January 2014, the U.S. Supreme Court decided Daimler AG v. Bauman, which substantially narrowed and simplified the test for a finding of general personal jurisdiction. 134 S. Ct. 746, 758 (2014). In the wake of Daimler, a corporation is subject to a court’s general personal jurisdiction only where its contacts are so substantial, continuous, and systematic that it is essentially “at home” in the forum state. Typically, this relationship with a forum is limited to where the entity is incorporated or has its principal place of business. In the wake of Daimler, plaintiffs have more difficulty establishing jurisdiction over a foreign parent corporation through the actions of a subsidiary.
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