Planning Group of Scottsdale, L.L.C. v. Lake Mathews Mineral Props., Ltd
In Planning Group of Scottsdale, L.L.C. v. Lake Mathews Mineral Props., Ltd., 226 Ariz. 262, 264,2, n.1, 246 P.3d 343, 345 (2011), the defendant California company sent a solicitation document to the Arizona investor; "extensive" telephone calls, emails, letters and faxes then ensued between the California company and the Arizona investor. 226 Ariz. at 264,4, 246 P.3d at 345.
After an in-person meeting in Los Angeles, the California company sent a letter setting out the "basic propositions" on which a transaction could proceed, to which the Arizona investor agreed in writing. Id. at 265,6-7, 246 P.3d at 346.
Payments of $190,000 by the Arizona investor followed. Id. at7.
The court directed that the defendant's various contacts with the state must "be analyzed not in isolation, but rather in totality." Id. at 269,29, 246 P.3d at 350.
It concluded with "little difficulty" that the California defendant's communications with the Arizona investor, on which the Arizona investor's claims were based, demonstrated "purposeful direction" by the defendant sufficient to establish personal jurisdiction in Arizona. Id. at31.
Continuing its analysis, the court came to the same conclusion under a "purposeful availment rubric." Id. at32.