Dudnikov v. Chalk & Vermilion Fine Arts, Inc

In Dudnikov v. Chalk & Vermilion Fine Arts, Inc., 514 F.3d 1063 (10th Cir.2008), the Tenth Circuit found personal jurisdiction over a patentee appropriate in Colorado where the patentee had contacted an Internet retailer headquartered in California regarding the plaintiff's alleged infringement activities, resulting in the retailer's withdrawal of the plaintiff's products from its website. The court reasoned that the patentee's extrajudicial enforcement efforts, although they occurred in California, were targeted at the plaintiff's business interests in Colorado. 514 F.3d at 1082.