C.W. Downer & Company v. Bioriginal Food & Science Corp

LYNCH, Chief Judge.

The Due Process Clause of the Fourteenth Amendment allows a state’s courts to exercise jurisdiction over a nonresident defendant only when doing so “does not offend ‘traditional notions of fan-play and substantial justice.’ ” Int’l Shoe Co. v. Washington, 326 U.S. 310, 316, 66 S.Ct. 154, 90 L.Ed. 95 (1945) (quoting Milliken v. Meyer, 311 U.S. 457, 463, 61 S.Ct. 339, 85 L.Ed. 278 (1940)). This contract case presents these issues where the parties’ contacts were not first-hand and involved no physical presence in Massachusetts, but were by phone, e-mail, and internet over an…