Tuesday, March 10, 2020

Case of the Day: Lutz v. Rakuten, Inc., 376 F.Supp.3d 455 (E.D. Pa. Apr. 22, 2019)


Plaintiff is a baseball player residing in Pennsylvania, who played for Rakuten Golden Eagles, a Japanese baseball team based in Sendai, Japan. Within weeks of having finalized the contract, Rakuten Baseball, Inc. (which operates the Golden Eagles) reneged on the contract, compelling the plaintiff to sign with Doosan Bears in South Korea for a smaller sum. Plaintiff sued Rakuten Baseball, and Rakuten Baseball moved to dismiss based on lack of personal jurisdiction.

The court rejected the motion to dismiss, finding that Rakuten Baseball purposefully directed its activities at Pennsylvania by knowingly negotiating with a Pennsylvania resident, recruiting in Pennsylvania and wiring money to Pennsylvania.


While the court is not wrong in terms of the law, this opinion seems unusual. What if the plaintiff was not a baseball player negotiating his own contract, but a manufacturer negotiating to purchase products from Japan? In such a situation, seems like the court would lean toward dismissing the case for lack of personal jurisdiction.

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