Brayton Purcell LLP v. Recordon & Recordon

In Brayton Purcell LLP v. Recordon & Recordon, 606 F.3d 1124, 1127 (9th Cir.2010), the Court found the express aiming prong of the purposeful direction test satisfied where a nonresident defendant law firm plagiarized copyrighted material from the forum plaintiff law firm's website and republished the material. 606 F.3d at 1129-31. Because both firms practiced in the relatively specialized field of elder abuse law, we concluded that the nonresident defendant "knew of the plaintiff's existence, targeted the plaintiff's business, and entered direct competition with the plaintiff." Id. at 1130.