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November 23, 2022

Dude Surfs (D) is a company that manufactures surfboards in California (CA). D is headquartered in CA and incorporated in Delaware. D is a small company and almost all of its sales are to local surfers in CA.

Hypothetical: Dude Surfs (D) is a company that manufactures surfboards in California (CA). D is headquartered in CA and incorporated in Delaware. D is a small company and almost all of its sales are to local surfers in CA.

Patty Panni (P) is a world-famous surfer who surfs around the world. She owns a house in Hollywood, CA, and a beach condominium in Miami, Florida (FL). She spends five months out of the year at her FL condominium so some of her mail is sent there. The rest of the time she is either in her Hollywood house or traveling around the world for work. P has a California driver’s license, and bank accounts in both CA and FL.

P reaches out to D and explains that they make her favorite surfboards. She also explains that she plans to use the surfboard for a surfing competition in Miami Beach, FL. P asks D to modify the length of the surfboard to meet the regulations of the FL competition. D modifies the length of the surfboard, and P takes it with her on an airplane when she travels from CA to FL. At the FL competition, P is injured when the tip of the surfboard breaks in a wave.

P sues D for a state-law claim of negligence for $75,000 in federal court in Miami, FL, where the accident occurred. D challenges subject matter jurisdiction and personal jurisdiction.

Did P sue D in the correct state? Specifically, using IRAC form, analyze whether FL has specific personal jurisdiction over D.

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