D.C. Code § 13-423

Section 13-423(a)(1) does not treat a suit seeking relief after an unsuccessful federal agency petition as transacting business in the District of Columbia.

Mallinckrodt Medical, Inc. v. Sonus Pharmaceuticals, Inc. · filed 1998-01-05(a)(1)

Furthermore, under the government contacts exception, a person or entity that has unsuccessfully petitioned the Executive Branch, an independent agency or Congress and then seeks redress before the federal or local courts in the District of Columbia is not thereby “transacting business” for purposes of the’ long-arm statute.

Federal lobbying and regulatory contacts in the District of Columbia fall within the government contacts exception and do not establish personal jurisdiction under § 13-423(a)(1).

Atlantigas Corp. v. Nisource, Inc. · filed 2003-10-10(a)(1)

The Court easily concludes that such activities are precisely the type of activities protected by the “government contacts” exception and cannot serve as the basis for personal jurisdiction under Section 13-423(a)(1).

Section 13-423(a)(1) permits personal jurisdiction based on transacting business in the District, but whether the government contacts exception applies depends on the nature of the defendant’s activities.

Thomas v. Disabled American Veterans Ass'n · filed 2007-08-23(a)(1)

We hold that the trial court acted prematurely in granting NCOA’s motion to dismiss because there are unresolved factual questions concerning the applicability of the government contacts exception.

Section 13-423 permits personal jurisdiction based on a petition to a federal agency in the District when the petition fraudulently induces unwarranted government action against another; the government contacts exception does not protect that conduct.

Companhia Brasileira Carbureto De Calcio—CBCC v. Applied Industrial Materials Corp. · filed 2012-01-26

For these reasons, we hold that a person who uses the government as an instrumentality of fraud, see Naartex, 232 U.S.App. D.C. at 301, 722 F.2d at 787, and thereby causes unwarranted government action against another, forfeits the protection of the government contacts exception.

Section 13-423(a)’s fraud exception to the government contacts doctrine requires a fraudulent contact that induced unwarranted government action against the plaintiff.

Globe Metallurgical, Inc. v. Rima Industrial S.A. · filed 2016-03-31(a)

As explained below, this Court concludes that Defendants’ contacts fall outside the marrow fraud exception for two related reasons: first, because under the fraud exception, the' defendant’s alleged fraudulent contact must have induced unwarranted government action against the plaintiff, and second, because Globe has not made a persuasive argument that any such government action occurred against it under the circumstances presented here.

Section 13-423(a) does not establish personal jurisdiction over an individual based solely on contacts with D.C. made pursuant to federal employment.

Berman v. Crook · filed 2018-02-02(a)

Since neither of them currently reside in the District of Columbia, the Court only has personal jurisdiction over them if the conduct detailed in the suit is covered under the D.C. long-arm statute, D.C. Code § 13-423(a). ... But contact with D.C. pursuant to federal employment is not sufficient to assert jurisdiction “[I]t is Well- settled that this Court cannot assert jurisdiction over an individual defendant based on his actions taken pursuant to his employment.”

Under § 13-423(a)(4), the government contacts exception excludes only direct contacts with federal government members, agents, or instrumentalities from the personal jurisdiction analysis.

Akhmetshin v. Browder · filed 2020-12-29(a)(4)

Based on this controlling precedent, only direct contacts with members, agents, or instrumentalities of the federal government may be excluded from the jurisdictional calculus.

Section 13-423(a)(4) does not exclude government contacts from its persistent course of conduct requirement.

Akhmetshin v. Browder · filed 2022-05-26(a)(4)

For the foregoing reasons, we decline to construe the “persistent course of conduct” requirement in § (a)(4) of the D.C. long-arm statute to exclude government contacts.

Section 13-423(a) does not establish personal jurisdiction over nonresident government employees merely because their agency is headquartered in the District of Columbia.

Jolley v. Unknown Named Bop Directors · filed 2024-03-22(a)

Plaintiff’s arguments are contrary to established law. “A person’s status as a government employee who works for an agency headquartered in Washington, D.C. . . . does not constitute contacts sufficient to subject him to this Court’s personal jurisdiction.” ... The Court therefore concludes that it lacks personal jurisdiction over defendants Blanco, Nylen, Antonelli and Ballesteros.

Section 13-423(a)(4) allows contacts with federal agencies in D.C. to count toward personal jurisdiction.

Poss v. Kern · filed 2024-09-25(a)(4)

Although ordinarily, contacts exclusively with the federal government are not enough to establish personal jurisdiction, that rule does not apply to § (a)(4) of D.C.’s long-arm statute.

Section 13-423(a)(1)’s government-contacts exception applies only if the defendant establishes that relying on those contacts for personal jurisdiction would violate the First Amendment.

N'Jai v. U.S. Department of Education · filed 2025-09-04(a)(1)

For the foregoing reasons, we hold that, under the District’s long-arm statute, the government-contacts exception applies only if a defendant can establish that relying on the conduct at issue as a basis for personal jurisdiction would violate the First Amendment.

Section 13-423(a)(3) permits personal jurisdiction for tortious injury in the District only when the defendant’s act also occurred in the District.

Margoles v. Johns · filed 1971-11-18(a)(3)

The statute clearly separates the act from the tortious injury and affords personal jurisdiction over non-residents only when both act and injury occur in the District.

Section 13-423(a)(4) does not provide jurisdiction when the alleged tortious injury occurred outside the District of Columbia.

White v. Diamond · filed 1974-12-30(a)(4)

Therefore, long arm jurisdiction does not exist over UNH by virtue of D.C. ... Code § 13-423(a) (4) since that section speaks only of “tortious injury in the District of Columbia”.

Section 13-423(a)(3) requires the act causing injury to occur in the District; mailing allegedly libelous material into the District from elsewhere does not satisfy that requirement.

Moncrief v. Lexington Herald-Leader Co. · filed 1985-10-18(a)(3)

In this case, the libelous article was printed, and the newspapers were mailed, outside of the District of Columbia. The fact that they were mailed into the District of Columbia and caused injury here is not a sufficient basis for jurisdiction under the case law cited above. As no act occurred within the District of Columbia, this Court cannot exercise jurisdiction under D.C.Code § 13-423(a)(3).

Section 13-423(a)(4) does not require the injury in the District to be directly related to the defendant’s business solicitation, course of conduct, or revenue there.

Gatewood v. Fiat, S. P. A. · filed 1980-01-24(a)(4)

One who invokes section 13-423(a)(4) need not show that the injury in the District was directly related to the actual business solicitation, course of conduct, or derivation of revenue.

Section 13-423(a)(3) requires a tortious act and injury in the District; subsection (a)(4) requires District injury from an outside act plus specified business or other contacts with the District.

Lott v. Burning Tree Club, Inc. · filed 1980-12-22(a)(3), (a)(4)

Personal jurisdiction over the Club therefore cannot be based on D.C.Code § 13-423(a)(3). ... Plaintiff has failed to establish a prima facie basis for jurisdiction under either § 13-423(a)(3) or § 13-423(a)(4) of the District of Columbia Code.

Section 13-423(a)(1) requires both the act and its effect to occur in the District, while (a)(4) requires a local tort injury caused by an act outside the District and one of three specified contacts with the District.

Trager v. Wallace Berrie & Co., Inc. · filed 1984-08-27(a)(1), (a)(4)

Under § 13-423(a)(l), both the act and its effect must occur in the District of Columbia, and the provision is coextensive with due process considerations. ... Three criteria must be met for this Court to acquire jurisdiction under § 13-423(a)(4). There must be (1) a tortious injury within the District of Columbia which was caused by (2) defendants’ acts or omissions outside the District of Columbia, (3) if the defendants have one of the three specified “minimum contacts” within the District of Columbia. ... These “minimum contacts” are regularly doing or soliciting business within the District of Columbia; engaging in any other persistent course of conduct within the District of Columbia; or deriving substantial revenue from goods used or consumed, or services rendered, in the District of Columbia. The facts establish that there is no jurisdiction under either section.

Section 13-423(a)(4) permits personal jurisdiction when an out-of-District act causes tortious injury in the District and the defendant or his agents regularly do business there or derive substantial revenue from services there.

National Bank of Washington v. Mallery · filed 1987-09-02(a)(4)

Thus, if the tortious injury of which plaintiff complains occurred within the District of Columbia, and defendant, himself or through his partners, regularly conducts business in the District of Columbia, or derives substantial revenue from services performed in the District of Columbia, the Court has jurisdiction over defendant under § 13-423(a)(4).

Subsection (a)(3) permits personal jurisdiction when a tortious act or omission and the resulting injury occur in the District.

Avianca, Inc. v. Corriea · filed 1989-02-06(a)(3)

The court ... finds it clear that plaintiffs have sufficiently demonstrated that tortious acts and omissions occurred within the District, resulting in injuries in the District, so that they come within the purview of subsection (3).

Section 13-423 does not permit personal jurisdiction over an out-of-state conspiracy defendant based on an alleged act in the District of Columbia when the resulting injury occurred in Texas.

Delgado v. Federal Bureau of Prisons · filed 1989-12-18(a)(3)

However, this act is not a sufficient basis upon which this Court can exercise personal jurisdiction over Defendant Kindt because the purported injury to Plaintiff was his assignment to Unit 10 which occurred in Texas.

Section 13-423(a)(4)’s injury requirement can be satisfied by economic loss from defamation felt at the plaintiff’s District place of business, even if the statement was not published in the District.

Crane v. New York Zoological Society · filed 1990-01-30(a)(4)

Quite clearly, economic loss resulting from defamation is most likely to be felt in one’s place of business whatever the locus of its publication; and mental suffering is self-evidently experienced where the mind is located.

Section 13-423(a)(4) permits personal jurisdiction for tortious injury in the District caused by an act outside it when the defendant regularly does or solicits business there or derives substantial revenue from goods used or services rendered there.

American Directory Service Agency, Inc. v. Beam · filed 1990-05-15(a)(4)

As for the first, it is well settled that if Kime regularly did or solicited business, or derived substantia] revenue from goods used or services rendered, in the District, he is subject to suit in the District for causing, “by an act or omission outside the District,” any tortious injury here.

Section 13-423(a)(4) requires tortious injury in the District; financial loss there does not satisfy that requirement when the underlying injury occurred elsewhere.

Perry v. Criss Bros. Iron Works, Inc. · filed 1990-08-03(a)(4)

Because the Survival Statute simply extends to the deceased’s estate his right to sue, and creates no right of action in his administrator, the only tortious injury in question is that which the decedent sustained in Maryland. Therefore, defendants Harkless and Criss Brothers inflicted no tortious injury in the District of Columbia, and are beyond the reach of the long-arm statute.

Section 13-423(a)(4) requires an injury in the District before the defendant’s other contacts with the District become relevant; moving there after an injury does not satisfy that requirement.

Gandal v. Telemundo Group, Inc. · filed 1993-07-20(a)(4)

But, as the tort defendants correctly insist, the statute calls for an injury inside the District before plus factors even become relevant. ... A plaintiff cannot establish an injury in the District simply by moving here after an injury.

Under § 13-423(a)(4), loss of consortium occurs at the marital domicile for the injury-location requirement, and three percent of a defendant’s sales in the District can constitute substantial revenue.

Masterson-Cook v. Criss Bros. Iron Works, Inc. · filed 1989-10-23(a)(4)

The Court disagrees, since plaintiff claims a loss of consortium, which occurred in her marital domicile, the District of Columbia. ... However, three percent of Harkless’s sales occur in the District and thereby constitute substantial revenue.

Section 13-423(a)(3) does not confer personal jurisdiction merely because a defendant sent a letter into the District, and a plaintiff relying on persistent conduct under subsection (a)(4) must allege facts supporting it.

Hayhurst v. Calabrese · filed 1992-01-16(a)(3), (a)(4)

Sending a letter into this jurisdiction is not an act sufficient to warrant the exercise of long-arm jurisdiction under 423(a)(3). ... Furthermore, plaintiff has not alleged that defendants have engaged in any “persistent course of conduct” in the District of Columbia which would warrant application of 423(a)(4).

Section 13-423(a)(4) looks to where the original physical injury occurred when deciding whether an out-of-District act caused tortious injury in the District.

Etchebarne-Bourdin v. Radice · filed 2000-06-01(a)(4)

In this regard, as the trial court recognized, “the original physical injury” is paramount in determining where the tortious injury has been caused.

Section 13-423(a)(3) does not provide personal jurisdiction for tortious injury in the District when the act causing it occurred outside the District.

Messina v. Fontana · filed 2003-05-08(a)(3)

Clearly, since the act of writing the alleged email(s) occurred outside the District of Columbia, Ms. Fontana committed no acts within the District of Columbia provoking injury to Dr. Messina within the District, and personal jurisdiction cannot be premised on § 13-423(a)(3).

Section 13-423 requires a specific showing of injury in the District of Columbia to establish jurisdiction based on tortious injury; allegations of a nationwide antitrust conspiracy are insufficient.

Diamond Chemical Co. v. Atofina Chemicals, Inc. · filed 2003-06-05(a)(3), (a)(4)

Engaging in an antitrust conspiracy executed in the United States does not meet the D.C. long-arm statute’s requirement that the injury be committed in the District of Columbia, and Plaintiff has not connected the alleged presence of the subsidiaries in the District to the conspiracy alleged.

Section 13-423(a)(3) does not provide personal jurisdiction when the alleged tortious injury occurred outside the District, even if the alleged act occurred there.

Helmer v. Doletskaya · filed 2003-10-27(a)(3)

Therefore, the court concludes that § 13-423(a)(3) does not provide a basis for the exercise of personal jurisdiction because Helmer’s injury from the alleged fraud did not occur in the District.

Section 13-423(a)(3) and (4) require tortious injury in the District of Columbia; alleging that the District is part of a nationwide market does not establish such an injury.

Jung v. Association of American Medical Colleges · filed 2004-02-11(a)(3), (a)(4)

Under both “tortious injury” subsections of the long-arm statute plaintiffs must allege that they have suffered a tor-tious injury in the District of Columbia. ... There has been no tortious injury to any plaintiff in the District of Columbia. If the Court were to find jurisdiction under this flawed premise, any plaintiff alleging an antitrust conspiracy could satisfy the tortious injury requirement under either “tort” prong of the long-arm statute simply by asserting that the District of Columbia is part of the relevant market.

Section 13-423(a)(4) requires a plaintiff seeking jurisdiction based on an act outside the District of Columbia to allege a tortious injury in the District.

Robinson v. Ashcroft · filed 2004-07-26(a)(4)

At the very least, plaintiff must allege a tortious injury in the District of Columbia even if the act causing the injury took place elsewhere. D.C.Code § 13-423(a)(4). ... And plaintiff has not alleged that a tortious injury resulted from any actions of the defendant that occurred in this jurisdiction. This Court therefore lacks jurisdiction over defendant Fears.

Subsection (a)(3) requires both the tortious act and the resulting injury to occur in the District of Columbia.

Helmer, John v. Doletskaya, Elena · filed 2004-12-21(a)(3)

This provision is “a precise and intentionally restricted tort section which stops short of the outer limits of due process,” and requires that both act and injury occur in the District of Columbia.

An infringing sale in the District of Columbia causes tortious injury there under subsections (a)(3) and (a)(4).

Trintec Industries, Inc. v. Pedre Promotional Products, Inc. · filed 2005-01-19(a)(3), (a)(4)

Thus, if an infringing product is sold in the District of Columbia, that sale causes “tortious injury” there under subsection (a)(3) or (a)(4) of the District of Columbia long-arm statute, patent infringement being a tort.

Section 13-423(a)(4) requires a defendant whose act outside the District causes injury inside it to have qualifying District contacts separate from that injury.

Kopff v. Battaglia · filed 2006-03-29(a)(4)

Yet there is nothing in the complaint or in plaintiffs’ subsequent filings to support a finding that one of the “plus factors” required by the statute — regularly doing or soliciting business in the District, engaging in a persistent course of conduct directed toward the District, or deriving substantial revenue from goods used or consumed, or services rendered, in the District — exists for Sadiq separate from and in addition to the faxes received by plaintiffs.

Section 13-423(a)(3) requires both the tortious act and the injury to occur in the District of Columbia; placing materials in the stream of commerce does not satisfy that requirement.

Burman v. Phoenix Worldwide Industries, Inc. · filed 2006-07-07(a)(3)

However, it is irrelevant in determining whether a defendant is subject to personal jurisdiction under section 13-423(a)(3), which requires that “both act and injury occur in the District of Columbia.” D.C.Code § 13-423(a)(3).

Section 13-423(a)(3) does not confer personal jurisdiction over tort claims arising from acts outside the District of Columbia.

Jungquist v. Sheikh Sultan Bin Khalifa Al Nahyan · filed 1997-08-12(a)(3)

Because the tort claims against the Sheikh for negligence, negligent entrustment, loss of filial consortium, and loss of services do not arise out of any act in the District of Columbia, but from the boating accident in Abu Dhabi, the district court did not have personal jurisdiction over him as to these claims.

Section 13-423(a)(4) requires a defendant whose out-of-District acts cause injury in the District to have qualifying business, revenue, or persistent conduct in the District.

United States v. Philip Morris Inc. · filed 2000-09-28(a)(4)

The Government’s fourth theory offered in support of the exercise of personal jurisdiction also fails, because the Government has not shown that BAT Ind. engages in business, derives substantial revenue, or engages in any persistent course of conduct in the District of Columbia, as required by D.C.Code § 13-423(a)(4).

Section 13-423(a)(4) requires specified ongoing contacts with the District for jurisdiction over an out-of-District act causing injury in the District, even when due process would permit jurisdiction with fewer contacts.

Mwani, Odilla Mutaka v. Bin Ladin, Usama · filed 2005-08-05(a)(4)

It is unlikely that the defendants would be susceptible to jurisdiction under that provision, as no evidence was proffered that meets the italicized prerequisites. But it is also clear that the Due Process Clause does not demand the level of contacts required by that provision, and hence that the provision does not extend as far as the Clause.

Section 13-423(a)(4) requires an injury in the District of Columbia to support personal jurisdiction for tortious injury claims.

Joyner v. Reno · filed 2006-12-07(a)(4)

With regard to tortious injury claims such as this one, the only applicable provision of the District of Columbia long-arm statute is D.C.Code § 13 — 423(a)(4), which requires that the injury must occur in the District of Columbia for personal jurisdiction to be proper in this Court.

Section 13-423(a) does not provide personal jurisdiction based on a plaintiff’s alleged injury when that injury occurred outside the District of Columbia.

Metcalf v. Federal Bureau of Prisons · filed 2008-01-07(a)

Nor do the pleadings establish that plaintiff suffered any injury in the District of Columbia. The actual injuries that plaintiff complains about occurred in Indiana. Regardless of whether these defendants acted in or outside of the District, plaintiff suffered no injury here. Accordingly, the Court concludes that it lacks personal over defendants Nalley, Bezy, Veach, Carlson, Baskerville, Erwin, Roal, Morin and Reel under the District’s long-arm statute.

Section 13-423(a)(3) permits personal jurisdiction over a claim arising from tortious conduct that causes injury in the District of Columbia.

Elemary v. Philipp Holzmann A.G. · filed 2008-02-06(a)(3)

Because her complaint alleges both tortious acts and tortious injury in the District of Columbia, she has satisfied long-arm statute subsection (a)(3).

Section 13-423(a)(4) requires tortious injury in the District and an additional statutory connection to the District before a court may exercise personal jurisdiction over a nonresident defendant.

D'ONOFRIO v. SFX Sports Group, Inc. · filed 2008-02-18(a)(4)

In order to exercise jurisdiction over a non-resident defendant pursuant to subsection (a)(4), the defendant must have caused tortious injury within the District and one of the “plus factors” in that subsection must also be present. ... In short, none of the plus factors identified in subsection (a)(4) are present here.

Section 13-423(a)(4) requires proof of an injury in the District caused by an act outside it, plus one of the defendant contacts with the District listed in the section.

Bailey v. J & B TRUCKING SERVICES, INC. · filed 2008-09-10(a)(4)

In order to establish personal jurisdiction under D.C.Code § 13-423(a)(4), after jurisdictional discovery is completed, Plaintiffs “must demonstrate by a preponderance of the evidence that (1) plaintiffs suffered a tortious injury in the District of Columbia; (2) the injury was caused by a defendant’s act or omission outside the District; and (3) the defendant had one of the three enumerated contacts with the District of Columbia.”

Subsection (a)(4) permits jurisdiction over a nonresident whose conduct outside the District causes injury inside it only if the nonresident has one of the specified connections to the District.

Wormley v. United States · filed 2009-02-24(a)(4)

The longarm statute does allow jurisdiction over a nonresident defendant alleged to have “caus[ed] tor-tious injury in the District of Columbia by an act or omission outside the District of Columbia,” but only “if he regularly does or solicits business, engages in any other persistent course of conduct, or derives substantial revenue from goods used or consumed, or services rendered, in the District of Columbia.”

Section 13-423(a)(4) requires a tortious injury in the District of Columbia to support personal jurisdiction.

National Resident Matching Program v. Electronic Residency LLC · filed 2010-07-06(a)(4)

It is not sufficient for NRMP to have “been injured” by ER’s conduct; the injury must be “tortious.” NRMP has failed to identify any tortious injury inflicted on it by ER.

Subsection (a)(4) requires tortious injury in the District; a plaintiff’s District residency alone does not establish it when the alleged fraud or conversion occurred in Maryland.

Kissi v. Hardesty · filed 2010-08-13(a)(4)

Appellant’s bare assertion that he is a D.C. resident is not sufficient to establish that he suffered “tortious injury” in the District as a result of an alleged fraud or conversion that took place in Maryland. Without injury in the District, the Superior Court of the District of Columbia cannot exercise personal jurisdiction over appellee under subsection (a)(4).

Section 13-423(a)(4) requires qualifying District business, persistent conduct, or revenue in addition to tortious injury in the District caused by conduct outside it.

Edmond v. Rogers · filed 2010-10-28(a)(4)

Plaintiff adequately alleges an act or omission occurring outside of the District of Columbia, that is, the report by Laurens County of the tax lien, and tortious injury in the District of Columbia because plaintiff resided here at all times relevant to the complaint. However, plaintiff does not allege that Laurens County regularly does or solicits business, or engages in any other course of conduct, or derives revenue from services rendered in the District of Columbia.

Section 13-423(a)(4) does not require a defendant’s additional District contacts to occur close in time to the plaintiff’s tort claim; contacts of an alter ego subsidiary may count.

IMARK Marketing Services, LLC v. Geoplast, S.P.A. · filed 2010-12-06(a)(4)

Geoplast S.p.A. has presented no authority, and the Court is aware of none, that supports imposing a temporal proximity requirement between D.C.Code § 13-423(a)(4)’s plus factors and a plaintiff’s tort claim. In conclusion, for the reasons stated above, the Court rejects Geoplast S.p.A.’s argument that Geoplast U.S.’s activities in the District may not be considered when determining whether Geoplast S.p.A.’s contacts with the District satisfy subsection (a)(4)’s plus factors.

Section 13-423(a)(3) requires an act and resulting tortious injury in the District of Columbia; when those locations are disputed, the court requires an evidentiary hearing.

Fudali v. Pivotal Corporation · filed 2011-04-26(a)(3)

But the crucial determination of whether the conveyances caused harm in the District of Columbia by an act done in the District of Columbia cannot be permitted to rest either on plaintiff’s allegations or the inferences Pivotal would draw from those allegations. As such, a hearing is required for each party to present evidence as to where both the act took place, and where the resultant harm occurred.

Under the tortious injury provisions, a D.C. court may exercise personal jurisdiction over a nonresident defendant only if the injury occurs in the District of Columbia.

Nu Image, Inc. v. Does 1-23,322 · filed 2011-07-29(a)(3)-(4)

Thus, a District of Columbia court may only exercise personal jurisdiction over a nonresident defendant in this matter if the defendant “causes tortious injury in the District of Columbia.”

Section 13-423(a)(3) requires both the tortious injury and the act causing it to occur in the District of Columbia.

Stoddard v. Carlin · filed 2011-07-29(a)(3)

Because defendant Ells does not regularly do business in this forum, the only potential grounds for jurisdiction over her would be if she caused tortious injury within the District of Columbia, and the act or omission that caused the injury also occurred in the District of Columbia.

Section 13-423(a)(4) requires regular District business or another persistent course of conduct to support jurisdiction over an out-of-state act causing injury in the District; a single prescription call to a District pharmacy is insufficient.

Harris v. Omelon · filed 2009-12-03(a)(4)

However, to find personal jurisdiction under this provision, there must be an additional connection between the individual and some regularly conducted or solicited business or another persistent course of conduct in D.C. D.C.Code § 13-423(a)(4). ... As such, the appellant has not shown any interaction that would allow the long-arm statute to create personal jurisdiction over the doctor for acts or omissions undertaken from his office in Virginia relating to the appellant’s injuries.

Section 13-423(a)(3) requires an alleged copyright infringement to have occurred in the District of Columbia to support personal jurisdiction over a nonresident; the location of the computers involved guides that inquiry.

Sbo Pictures, Inc. v. Does · filed 2012-01-23(a)(3)

Irrespective of whether the injury is viewed to be the uploading of the movie, the downloading of the movie, or both, the focus would be on the physical location of the computers bearing the unique IP addresses plaintiff claims were involved in the unauthorized distribution of its film.

For alleged online copyright infringement, § 13-423(a)(3) focuses on the physical location of the computers linked to the infringing IP addresses when assessing whether the conduct occurred in the District of Columbia.

Exquisite Multimedia, Inc. v. Does · filed 2012-01-23(a)(3)

Irrespective of whether the injury is viewed to be the uploading of the movie, the downloading of the movie, or both, the focus would be on the physical location of the computers bearing the unique IP addresses plaintiff claims were involved in the unauthorized distribution of its film.

Section 13-423(a)(4) requires ongoing business or conduct ties to the District for jurisdiction over an out-of-District act causing tortious injury in the District.

Sweetgreen, Inc. v. Sweet Leaf, Inc. · filed 2012-03-23(a)(4)

Because there is no evidence that defendants regularly do or solicit business or engage in any other persistent course of conduct in the District, the Court does not have jurisdiction under § 13-423(a)(4).

Section 13-423(a)(4) requires a plaintiff to identify an out-of-District act or omission attributable to the defendant that caused tortious injury in the District, along with the defendant’s qualifying business, conduct, or revenue there.

Cannon v. Wells Fargo Bank, N.A. · filed 2013-03-01(a)(4)

Turning to the merits of the Plaintiff’s argument, the Court notes that the Plaintiff fails to allege—in the Complaint or in her pleadings—what act(s) or omission(s) attributable to QBE Specialty caused tortious injury to the Plaintiff in the District of Columbia, as required by section 13-423(a)(4).

Section 13-423(a)(3) requires both a tortious injury and a predicate act in the District; subsection (a)(4) requires a District injury caused by an outside act and one of three specified District contacts.

Corrinet v. Burke · filed 2013-05-29(a)(3), (a)(4)

In other words, in order for the court to have personal jurisdiction pursuant to subsection (a)(3), “both tortious injury and an act predicate to it must take place within the District.” McFarlane v. Esquire Magazine, 74 F.3d 1296, 1300 (D.C. Cir. 1996). ... Thus, subsection (a)(4) provides for personal jurisdiction even if the acts causing the injury took place outside of the District, but only if the defendant “caused a tortious injury in the District, the injury was caused by the defendant's act or omission outside of the District, and the defendant had one of the three enumerated contacts with the District.” GTE New Media Services Inc. v. BellSouth Corp., 199 F.3d 1343 (D.C. Cir. 2000).

Section 13-423(a)(4) requires a plaintiff alleging injury in the District from an act elsewhere to establish the defendant’s additional business or other sustained contacts with the District.

White v. Hillcrest Davidson & Associates · filed 2013-07-05(a)(4)

This bare assertion is insufficient however, because the plaintiff fails to establish “any of subsection (a)(4)’s so-called ‘plus factors’: regularly do[ing] or solicit[ing] business, engag[ing] in any other persistent course of conduct, or deriv[ing] substantial revenue from goods used or consumed, or services rendered, in the District of Columbia.” McIntosh v. Gilley, 753 F. Supp. 2d 46, 59 (D.D.C. 2010) (quoting D.C. Code § 13-423(a)(4)).

Section 13-423(a)(4) permits jurisdiction for an injury in the District caused by conduct outside it only if the defendant also has the specified business activity, persistent conduct, or substantial revenue connected to the District.

['BARROS v. BECK'] · filed 2014-03-19(a)(4)

The only provision of the long-arm statute that even comes close to applying is the fourth provision, which permits the exercise of personal jurisdiction when the defendant causes tortious injury in the District by an act or omission outside the District, but even this provision is qualified to require a demonstration that the defendant regularly conducts business in the District, engages in other persistent courses of conduct in the District, or derives substantial revenue from goods or services in the District. D.C. Code § 13-423(a)(4). The Complaint is devoid, however, of any allegations suggesting that the Becks regularly conduct business in the District of Columbia or ... otherwise engage in conduct sufficient to fall within the fourth provision of the long-arm statute. Consequently, because no provision of the long-arm statute applies to permit this Court to exercise personal jurisdiction over the Becks, the Court concludes that dismissal of the Complaint against them is warranted.

Section 13-423(a)(4) permits specific jurisdiction when an out-of-District act causes tortious injury in D.C. and the defendant derives substantial revenue from services rendered there.

Guttenberg v. Emery · filed 2014-05-16(a)(4)

Hence, this Court may exercise specific jurisdiction over Borg-Emery under section 13-423(a)(4), and defendants’ motion to dismiss for lack of personal jurisdiction will be denied.

Section 13-423(a)(3) requires the act causing tortious injury to occur in the District; communications sent into the District from California do not satisfy it.

Naegele v. Albers · filed 2015-06-23(a)(3)

Communications from California cannot provide a basis for the exercise of personal jurisdiction in the District of Columbia under section 13-423(a)(3).

Section 13-423(a)(4) requires tortious injury in the District; lingering effects there of an injury suffered elsewhere do not satisfy that requirement.

Duarte v. Nolan · filed 2016-05-17(a)(4)

Yet Nolan is plainly alleged to have caused tortious injury outside the District, the lingering effects of which were felt within the District only because Duarte happened to travel there after suffering an injury elsewhere.

Section 13-423(a)(4) requires a claim arising from the defendant’s qualifying conduct and tortious injury in the District of Columbia.

Duarte v. Nolan · filed 2016-07-20(a)(4)

That provision permits personal jurisdiction “as to a claim for relief arising from” a defendant’s “causing tortious injury in the District of Columbia by an act or omission outside the District of Columbia if he regularly does or solicits business [or] engages in any other persistent course of conduct . . . in the District of Columbia” (emphasis added). This argument is baseless, given that—by Duarte’s own admission—“Helix’s contacts did not give rise to the claim in the case at hand.” Pl.’s Mot. Alter Amend 9.

Section 13-423(a)(3) requires tortious injury in the District of Columbia; damage to a Delaware home does not qualify because its owners live in the District.

Katopothis v. Windsor Mount Joy Mutual Insurance Company · filed 2016-09-26(a)(3)

The Court need not, however, rest its decision on the locus of the allegedly tortious act because it is clear that the alleged injury did not occur in the District of Columbia. ... The Court, accordingly, concludes that D.C. Code section 13-423(a)(3) does not provide a basis for asserting personal jurisdiction over Gale Force in this matter.

Section 13-423(a)(4) does not treat continuing pain in the District from an injury sustained elsewhere as a separate tortious injury in the District.

Arora v. Buckhead Family Dentistry, Inc. · filed 2017-06-26(a)(4)

The fact that he continued to suffer “minor to moderate pain” as a result of the injury that he sustained in Georgia does not qualify as a separate injury occurring in the District of Columbia for purposes of the D.C. long-arm statute.

Section 13-423(a)(3) covers a negligent misrepresentation claim when the statements and resulting injury occur in the District, but personal jurisdiction remains subject to due process limits.

Foote v. Williams · filed 2017-08-31(a)(3)

Thus, subsection (a)(3) of the long-arm statute is satisfied with regard to the negligent misrepresentation claim only, and this Court must therefore proceed to a due process analysis. ... Accordingly, the Court cannot exercise personal jurisdiction over the defendant under subsection (a)(3) of the long-arm statute.

Section 13-423(a)(4) requires more than an act outside the District that causes injury inside it; the defendant must also have qualifying business, conduct, or revenue ties to the District.

Vasquez v. Whole Foods Market, Inc. · filed 2018-02-09(a)(4)

Consequently, subsection (a)(4) requires “something more” of plaintiffs than simply asserting that tortious conduct outside the District caused injury inside the District.

Section 13-423(a)(4) requires more than an out-of-District act causing injury in the District; the defendant must also have the specified business, conduct, or revenue ties to the District.

Vasquez v. Whole Foods Mkt., Inc. · filed 2018-02-09(a)(4)

Consequently, subsection (a)(4) requires "something more" of plaintiffs than simply asserting that tortious conduct outside the District caused injury inside the District.

Section 13-423(a)(4) requires sufficient District business, persistent conduct, or substantial revenue to support jurisdiction over a tortious act committed outside the District; fundraising and communications with District residents did not suffice here.

Bigelow v. Tom Garrett & Tom Garrett for Cong. · filed 2018-03-13(a)(4)

Here, Mr. Bigelow's allegations that the defendants raised funds from donors in the District and communicated with District residents are insufficient to show that the defendants solicited business, engaged in any persistent course of conduct, or derived substantial revenue from any activity conducted in the District for purposes of Section 13-423(a)(4).

For a tortious act committed outside the District, § 13-423 requires the plaintiff to show a tortious injury in the District of Columbia.

Woodruff v. United States of America · filed 2018-04-23(a)(4)

Although it is “far from clear” that any of the officers have established ties with the District of Columbia, the Court need not reach that question because Plaintiff “founder[s] at the first step—he has failed to allege, or otherwise to identify, any ‘tortious injury’ that he sustained in the District of Columbia.”

Geolocation placing an alleged infringer’s IP address in the District can support a good faith belief that personal jurisdiction exists under § 13-423.

Strike 3 Holdings, LLC v. Doe · filed 2018-08-03(3), (4)

Under the District of Columbia’s long-arm statute, “the only conceivable way that personal jurisdiction might properly be exercised” is if Defendant is a “resident[] of the District of Columbia or at least downloaded the copyrighted work in the District.” AF Holdings, 752 F.3d at 996 (citing D.C. Code § 13-423(3), (4)). ... Plaintiff has also established a good faith belief that this Court has personal jurisdiction over Defendant. Plaintiff used geolocation technology to trace Defendant’s IP address to a physical location within the District of Columbia.

Section 13-423(a)(3)-(4) does not provide personal jurisdiction based on tortious injury when the alleged injuries occurred outside the District of Columbia.

Cannady v. State of Maryland · filed 2020-06-08(a)(3)-(4)

Though not raised by Mr. Cannady, the only other possible relevant contact under the long-arm statute could be “causing tortious injury in the District of Columbia.” ... But the injuries Mr. Cannady alleges all occurred in Maryland.

Section 13-423(a)(3) requires a tortious act in the District, while subsection (a)(4) requires additional qualifying District contacts when the act occurs elsewhere.

Doe v. City of Boston · filed 2021-06-16(a)(3), (a)(4)

Absent such an intra-forum “act,” this Court cannot exercise specific jurisdiction over Defendants under subsection (a)(3) of the D.C. long-arm statute. ... Absent such a showing or any other applicable “plus factor,” the Court finds no basis for the exercise of jurisdiction over Defendants under subsection (a)(4) of the D.C. long-arm statute.

Section 13-423(a)(4) requires an additional District contact, such as regular business or persistent conduct there, when an out-of-District tort causes injury in the District.

Bauman v. Butowsky · filed 2019-03-28(a)(4)

Instead, in addition to injury within the District, D.C.'s long-arm statute requires what courts refer to as a "plus factor"-i.e., the tortfeasor regularly does business or engages in persistent conduct in, or derives substantial revenue from, the District.

Section 13-423(a)(4) requires a defendant whose out-of-District act causes injury in the District to have additional District contacts, such as regular business, a persistent course of conduct, or substantial revenue from the District.

Groop Internet Platform Inc. v. Psychotherapy Action Network · filed 2020-01-21(a)(4)

Although D.C. law contemplates the exercise of personal jurisdiction over defendants whose out-of-District acts cause in-District injuries, because the plaintiff has failed to show any necessary plus factor, the defendants remain outside the reach of D.C.’s long-arm statute.

Section 13-423(4) permits specific jurisdiction for an out-of-state act causing tortious injury in the District only when the defendant has the specified business, conduct, or revenue ties to the District.

Stark III v. Swift · filed 2019-11-04(4)

Plaintiff has not, however, met his burden of establishing the other requirements under subsection 4. ... Because the court finds that it cannot exercise specific jurisdiction over any of the seven moving defendants under the District of Columbia’s long-arm statute, it need not address whether exercising jurisdiction over the defendants would satisfy the Constitution’s due process requirements.

Section 13-423(a) does not authorize specific jurisdiction over a state commission or its chair sued in her official capacity because the District’s long-arm statute applies to persons, not state entities.

Phillips v. Commission on Character & Fitness · filed 2021-04-30(a)

The District of Columbia’s long-arm statute, however, applies only to “persons,” and not to “state” entities like Defendants. D.C. Code § 13–421; see also Kwok Sze, 172 F. Supp. 3d at 123. For these reasons, the Court concludes that the District of Columbia’s long-arm statute, D.C. Code § 13-423(a), does not support the exercise of specific jurisdiction over either Defendant.

Section 13-423(a)(4) requires an injury in the District and specified ongoing contacts with the District to establish personal jurisdiction for tortious conduct outside it.

Sanchez-Mercedes v. Bureau of Prisons · filed 2020-04-10(a)(4)

Thus, the District’s long-arm statute does not reach Patterson or Wilson, so this Court lacks personal jurisdiction over them in their individual capacities.

Section 13-423 does not authorize personal jurisdiction when the defendant resides in California and the alleged events occurred there, with no conduct satisfying the District’s long-arm statute.

Al Seraji v. McAleenan · filed 2020-12-22(a)

Therefore, the plaintiff cannot establish this Court’s personal jurisdiction over Vicencia under any of the provisions of the District of Columbia’s long-arm statute.

Section 13-423(a)(3) does not confer jurisdiction merely because an allegedly tortious statement made outside the District was communicated to a government agency in the District.

Chien v. Freer · filed 2021-11-23(a)(3)

The mere fact that the allegedly tortious statement here was communicated to a government agency in the District of Columbia does not mean that the communication itself occurred within the District of Columbia or that Plaintiff suffered harm in the District of Columbia. It therefore does not fall within subsection (a)(3).

Section 13-423(a)(4) permits personal jurisdiction over acts or omissions outside the District that cause tortious injury within it when the defendant engages in a persistent course of conduct in the District.

Doe v. Roman Catholic Diocese of Greensburg · filed 2022-01-24(a)(4)

Accordingly, the Court has personal jurisdiction over all three Greensburg Defendants under D.C. Code § 13-423(a)(4), for acts or omissions outside of the District of Columbia that caused tortious injury within the District.

Section 13-423(a)(3) permits personal jurisdiction when allegedly tortious service of process occurs in the District and causes harm there.

Media Matters for America v. Paxton · filed 2024-08-23(a)(3)

Second, Plaintiffs have also established personal jurisdiction under § 13-423(a)(3) because they allege that tortious conduct––service of the Petition––occurred in the District and caused Plaintiffs harm here.

Section 13-423(a)(3) requires both the act and injury to occur in D.C.; under subsection (a)(4), a nonresident’s economic injury does not occur in D.C. merely because its effects are felt there.

Lambert Law Firm Prof. Corp. v. Hansel · filed 2024-12-05

That section requires that “both act and injury occur in the District of Columbia” for a court to have personal jurisdiction over a defendant. ... Finally, Section 13-423(a)(4) does not apply because Lambert’s alleged injury did not occur in D.C. ... As the D.C. Circuit has held, when the plaintiff is not domiciled in D.C., an economic injury such as fraud occurs where “the original events that caused the alleged injury” occurred, not where the injury is later felt by the plaintiff.

Section 13-423(a)(3) requires an act or omission in the District of Columbia that causes tortious injury there.

Employment Law Group, P.C. v. San Diego Employment Law Group · filed 2022-01-04(a)(3)

Regardless of where the injury occurred, without an act or omission in the District of Columbia causing that injury, paragraph (a)(3) is unavailable as a basis for personal jurisdiction.

Section 13-423 permits jurisdiction based on tortious injury in the District of Columbia caused by conduct inside or outside the District; alleged injury in Florida does not satisfy that basis.

Zavadovsky v. Republic of Austria · filed 2026-03-31

That statute allows a District of Columbia court to exercise personal jurisdiction over a ... defendant based on conduct with a connection to the District of Columbia, including when a claim arises from tortious injuries in the District of Columbia caused by acts or omissions in or outside the District of Columbia. See generally D.C. Code § 13-423. ... Because Plaintiffs do not plead that Harwell works or is domiciled in the District of Columbia, and because Plaintiffs claim that Harwell’s acts or omissions caused them injuries in their Fla. State Case—decided in Hillsborough County, Florida, rather than the District of Columbia—Plaintiffs have not shown that this Court can assert personal jurisdiction over Harwell.

Section 13-423(a)(3) does not treat telephone calls or emails sent into the District from elsewhere as acts or omissions in the District.

Zavadovsky v. Cheatle · filed 2025-08-27(a)(3)

But the fact that the Austrian Defendants allegedly contacted a USSS agent in the District of Columbia via telephone calls and e-mails sent from Austria does not constitute an act or omission in the District of Columbia.

Subsection (a)(4) permits jurisdiction for tortious injury in D.C. caused by conduct outside the District when the defendant also has qualifying continuing contacts with D.C.

Johnson v. Georgetown University · filed 2026-03-31(a)(4)

Section 13-423(a)(4) provides for personal jurisdiction where a defendant “caus[es] tortious injury in the District of Columbia by an act or omission outside the District of Columbia,” so long as the defendant “[1] regularly does or solicits business, [2] engages in any other persistent course of conduct, or [3] derives substantial revenue from goods used or consumed, or services rendered, in the District of Columbia[.]”

For alleged online copyright infringement, § 13-423(3) and (4) require a connection to the District, such as downloading the work there, to support personal jurisdiction.

AF Holdings, LLC v. Does 1-1058 · filed 2014-05-27(3), (4)

AF Holdings concedes that under the District of Columbia’s long-arm statute, which along with the Due Process Clause governs this question, see GTE New Media Services Inc. v. Bellsouth Corp., 199 F.3d 1343, 1347 (D.C. Cir. 2000), the only conceivable way that personal jurisdiction might properly be exercised over these Doe defendants is if they are residents of the District of Columbia or at least downloaded the copyrighted work in the District. See D.C. Code § 13-423(3), (4) (providing for personal jurisdiction over a person “causing tortious injury in the District of Columbia”); Nu Image, Inc. v. Does 1–23,322, 799 F. Supp. 2d 34, 38–40 (D.D.C. 2011). But AF Holdings has made absolutely no effort to limit its suit or its discovery efforts to those defendants who might live or have downloaded Popular Demand in the District of Columbia.

Section 13-423(a)(3) supports personal jurisdiction where allegedly discriminatory statements target a person attending school in the District and activities occurring there.

Dumpson v. Ade · filed 2019-08-09(a)(3)

Venue is proper in this Court and the Court has personal jurisdiction over the Defendants because the allegedly discriminatory statements were targeted at an individual that attended school in, and activities that occurred in, the District of Columbia. See Fed. R. Civ. P. 4; D.C. Code § 13-423(a)(3); 28 U.S.C. § 1391(b)(2).

Section 13-423(a)(4) permits jurisdiction over a manufacturer that derives substantial revenue from goods used in the District, even when it sold those goods to an out-of-state distributor.

Liberty Mutual Insurance Co. v. American Pecco Corp. · filed 1971-11-30(a)(4)

All that is required is that the manufacturer derive substantial revenue from the production and sale of the goods and that the goods be used in the District; to hold otherwise would be to defeat the purpose of the statute.

Section 13-423(a)(4) measures substantial revenue from District sales by considering both the amount and its share of total sales in light of the facts of the case.

The Founding Church of Scientology of Washington, D. C. v. Verlag · filed 1976-06-01(a)(4)

Thus the test looks both at the absolute amount and at the percentage of total sales, and determines what is “substantial” on the facts of each case. Here, recognizing the low unit price of each magazine, we think that sales of $26,000 in ten months constitute “substantial revenue” and demonstrate contacts that are sufficiently substantial to establish the “reasonable connection” with the District required by D.C.Code § 13-423 and the Constitution.

Section 13-423(a)(4)’s substantial revenue requirement is satisfied by about $32,897 in annual District sales representing approximately 0.7% of total sales.

Akbar v. New York Magazine Co. · filed 1980-02-12(a)(4)

We find that average total annual sales in the District of Columbia, of $32,-897.04, which represents approximately .7% of total sales, constitutes substantial revenue under the meaning of § (a)(4).

Section 13-423(a)(4) requires contacts with the District that are continuing in character.

Security Bank, N. A. v. Tauber · filed 1972-09-11(a)(4)

The use of “persistent” and “regularly” to describe the type of contact contemplated indicates that Congress was more concerned with a continuing contact than with the impact or substance of a single contact. Therefore, the minimal contacts with the District that are required should at least be continuing in character.

Section 13-423(a)(4)'s persistent-course-of-conduct requirement can be satisfied by regular liaison with the District, even when those contacts do not amount to doing business there.

Steinberg v. International Criminal Police Organization · filed 1982-02-16(a)(4)

Even without the further Interpol-Washington, D. C., links indicated in discovery pursued in this action (e.g., dealings between Interpol and United States agencies other than USNCB; meetings here attended by Interpol officers), the subsection (a)(4) "persistent course of conduct" proviso is met.

Under subsection (a)(4), substantial revenue means enough commercial impact in the District that a defendant could fairly expect to be sued there.

Delahanty v. Hinckley · filed 1986-07-03(a)(4)

Thus “substantial revenue” means enough revenue to indicate a commercial impact in the forum, such that a defendant fairly could have expected to be hauled into court there.

Section 13-423(a)(4) requires a defendant whose out-of-District act causes injury in the District to have an additional connection to the District, but that connection can be less substantial than the contacts needed for general jurisdiction.

Crane v. Archie Carr, III · filed 1987-03-27(a)(4)

Under (a)(4), the business done or persistent course of conduct “plus factor” is satisfied by connections considerably less substantial than those it takes to establish general, all-purpose “doing business”- or “presence”-based jurisdiction.

Section 13-423(a)(4) requires continuing contacts with the District; appearing as counsel in two or three matters over ten years does not establish a persistent course of conduct.

Parsons v. Mains · filed 1990-10-16(a)(4)

We do not agree. Whatever the concept of a “continuous and persistent course of business” means, it is not satisfied by the defendant’s entry of an appearance as counsel in two or at most three matters over a conceded period of ten years or longer.

Section 13-423(a)(4)’s substantial revenue requirement can be satisfied by the commercial impact of goods used in the District.

Fogle v. Ramsey Winch Co., Inc. · filed 1991-09-20(a)(4)

This prevalence of Ramsey winches constitutes a “commercial impact” on the District sufficient to meet the substantial revenue test.

Section 13-423(a)(4) permits personal jurisdiction when an out-of-state act injures someone in the District and the defendant has a persistent course of conduct there.

Blumenthal v. Drudge · filed 1998-04-22(a)(4)

The Court concludes that plaintiffs have the better of the argument; defendant Drudge has had sufficient contacts with the District of Columbia to warrant the exercise of personal jurisdiction.

Section 13-423(a)(4) requires a reasonable connection between the defendant and the District of Columbia beyond the act causing injury there; profit from the forum alone does not establish personal jurisdiction.

GTE New Media Services Inc. v. Ameritech Corp. · filed 1999-03-29(a)(4)

The fact that the defendants derived profit in the District of Columbia, standing alone, did not establish personal jurisdiction. Rather, under the District of Columbia long-arm statute persistent contact “plus factor” analysis, the plaintiff must show some reasonable connection between the defendant and the forum, other than the injury-causing act.

Section 13-423(a)(4) permits personal jurisdiction when acts outside the District cause tortious injury inside it and the defendant has the required District contacts, which can include interactive, commercially significant websites.

GTE New Media Services, Inc. v. Ameritech Corp. · filed 1998-09-28(a)(4)

Accordingly, the court finds the non-resident defendants gain significant economic benefit from their Internet Yellow Pages websites in the District of Columbia, thereby satisfying the § 13-423(a)(4) prong of the District of Columbia long-arm statute.

Section 13-423(a)(4) does not permit personal jurisdiction over a university based on student recruitment, enrollment of District residents, and a small number of adjunct faculty living in the District.

Richards v. Duke University · filed 2007-03-30(a)(4)

Duke University’s recruiting activities to meet with students in the District of Columbia, the fact that students from the District of Columbia attend Duke University and Duke University Law School and a small number of adjunct faculty at Duke University live in the District of Columbia do not separately, or in the aggregate, constitute regular business, persistent conduct or receipt of substantial revenue from the District of Columbia as required under the D.C.Code § 13-423(a)(4) to assert personal jurisdiction.

Section 13-423(a)(4) requires a website to have some interactivity with users in the District of Columbia to qualify as a persistent course of conduct there.

Bible Way Church of Our Lord Jesus Christ World Wide, Inc. v. Showell · filed 2008-09-29(a)(4)

For a website to constitute a persistent course of conduct within the District of Columbia, it must meet a certain level of interactivity.

Section 13-423(a)(4) requires a sufficient business connection or persistent course of conduct in the District; three unsuccessful business trips do not meet that requirement.

The Urban Institute v. Fincon Services · filed 2010-02-01(a)(4)

Although there is a “notable lack” of authority regarding what level of contact with the District suffices for purposes of this analysis, ... the Court can only conclude that three trips for meetings at which no business was successfully conducted do not rise to the requisite level.

Section 13-423(a)(4) permits personal jurisdiction when a defendant’s sustained contacts with the District constitute a persistent course of conduct.

Lewy v. Southern Poverty Law Center, Inc. · filed 2010-07-13(a)(4)

In sum, the Court finds that SPLC has engaged in a “persistent course of conduct” in the District of Columbia by maintaining a website that D.C. residents use to interact with SPLC, regularly distributing publications to hundreds of D.C. residents over the internet and through the mail, soliciting millions of dollars in donations from D.C. residents through various means, sending employees to the District for conferences and meetings with nongovernmental organizations, and collecting information in the District for its website and national publications. Therefore, SPLC is amenable to suit under D.C.Code § 13-423(a)(4).

Section 13-423(a)(4) requires evidence of qualifying contacts with the District; a website accessible there does not, by itself, establish a persistent course of conduct.

Parisi v. Sinclair · filed 2011-08-23(a)(4)

Thus, plaintiffs have not shown that Rense, through his website, “regularly does or solicits business” or “engages in any other persistent course of conduct ... in the District of Columbia.” D.C.Code § 13-423(a)(4).

Section 13-423(a)(4) requires qualifying contacts with the District for jurisdiction over a defendant whose conduct outside the District causes injury within it; access to the defendant’s website alone does not establish a persistent course of conduct.

Parisi v. Sinclair · filed 2011-08-24(a)(4)

As to Rense's website, it is well established in our Circuit that the ability of District residents to access a defendant's website does not, by itself, show any "persistent course of conduct" in the District.

Section 13-423(a)(4) requires a persistent course of conduct in the District; communications sent into the District from another state do not satisfy that requirement.

Futuregen Company v. Carter · filed 2013-01-15(a)(4)

This argument is unpersuasive because section (a)(4) requires that the persistent course of conduct occur in the District; directing conduct from another state into the District via telephone, internet, and mail is insufficient.

Section 13-423(a)(4) requires contacts with the District beyond the alleged injury; untargeted national job postings and a generally accessible website do not establish a persistent course of conduct there.

Budik v. Dartmouth-Hitchcock Medical Center · filed 2013-04-05(a)(4)

Accordingly, the Court cannot exercise personal jurisdiction over defendant Dartmouth-Hitchcock under § 13-423(a)(4).

Subsection (a)(4) requires a plaintiff relying on an out-of-District tort to show injury in the District and a persistent course of conduct there by the defendant.

Houlahan v. Brown · filed 2013-10-09(a)(4)

Therefore, he must establish that Defendants committed a tortious act outside the District of Columbia, which caused him injury in the District of Columbia and, additionally, that they "engage[d] in any other persistent course of conduct . . . in the District of Columbia." D.C. Code § 13-423(a)(4).

Section 13-423(a)(4) does not require a relationship between a defendant’s persistent course of conduct and the act causing tortious harm.

District Title v. Warren · filed 2014-12-15(a)(4)

But there is no requirement that there be a relationship between the “persistent course of conduct” and the act causing tortious harm for purposes of this provision.

Section 13-423(a)(4) requires more than five or more calls from an out-of-state defendant to establish a persistent course of conduct in the District.

Betz v. Aidnest · filed 2018-10-26(a)(4)

Nor do “five-plus” phone calls from an out-of-state defendant constitute a “persistent course of conduct” in the District for the purposes of (a)(4)(ii).

Section 13-423(a)(4) does not treat emails or phone calls to District residents alone as regular business or a persistent course of conduct in the District.

Nuevos Destinos, LLC v. Peck · filed 2019-01-02(a)(4)

D.C. Code § 13-423 subsection (a)(4) is also inapplicable. ... Sending emails or making phone calls to District residents does not constitute conducting “regular business” or engaging in a “persistent course of conduct” in the District of Columbia.

Section 13-423(a)(4) requires additional contacts with the District when the alleged tortious act occurred outside it; a website listing the District as an area served does not establish those contacts.

Dyson v. Dutko Ragen Homes & Investments, Kw United · filed 2022-04-27(a)(4)

The mere fact that RPMP’s website identifies Washington, D.C., as an “Area Served” is not enough to establish a non-internet related contact with this jurisdiction. Accordingly, Plaintiff has failed to establish personal jurisdiction over RPMP under § 13-423(a)(4).

Section 13-423(a)(4) requires a persistent course of conduct in the District to support jurisdiction based on an out-of-state act causing injury there.

Plastics Industry Association, Inc. v. Bonta · filed 2024-11-06(a)(4)

These scant contacts fall well short of those required to show a persistent course of conduct in the District of Columba for purposes of § 13-423(a)(4).

Section 13-423(a)(4)’s persistent course of conduct requirement can be met by repeated visits and other contacts with the District, including government contacts.

Akhmetshin v. Browder · filed 2024-12-23(a)(4)

For these reasons, the Court concludes that subsection (a)(4)’s “persistent course of conduct” requirement is met, and personal jurisdiction comports with D.C.’s long-arm statute.

Section 13-423(a)(4) requires a persistent course of conduct in the District; isolated communications sent there from another state do not establish jurisdiction.

Saha v. Teladoc Health Medical Group, P.A. · filed 2025-09-30(a)(4)

But courts have held that the relevant conduct itself needed to occur in the District, not merely be directed at a District resident or entity. ... In sum, Plaintiff has alleged isolated incidents in which Defendants have sent communications to the District, without any ongoing ties or activities in the forum.

Section 13-423(b) permits a claim against a person subject to jurisdiction solely under the long arm statute only if the claim arises from the acts establishing that jurisdiction.

Charles F. Willis, Jr. v. Elizabeth Firestone Willis Charles F. Willis, Jr. v. Elizabeth Firestone Willis, Cleveland Trust Company · filed 1981-06-26(b)

The District of Columbia courts have interpreted section 13-423(b) as a bar to claims unrelated to the acts forming the basis for personal jurisdiction. ... Because Charles’ remaining claims against Harvey neither derived from nor are connected with Harvey’s interest in the real estate, we find that the District Court erred in relying on the real estate as a basis for asserting in personam jurisdiction over Cleveland Trust with respect to the other unrelated claims.

Section 13-423(b) requires a claim to arise from the District conduct used to establish personal jurisdiction; conduct occurring at the same time as the alleged wrongdoing is insufficient.

Maryland Ex Rel. Sachs v. Mid-Atlantic Toyota Distributors, Inc. · filed 1981-10-14(b)

Plaintiff’s claim based upon an alleged violation of the antitrust laws does not “aris[e] from” the conduct of normal MAT business. The mere coincidence in time of the alleged price-fixing conspiracy and Weisman’s conduct of MAT business in the District of Columbia does not mean that the former arose from the later.

Section 13-423(b) permits a claim against a nonresident only if it arises from the District contacts used to establish personal jurisdiction.

Naartex Consulting Corporation, Russell Huff v. James G. Watt, Secretary of Interior · filed 1983-11-29(b)

These provisions are limited by section 423(b), which states that “only a claim for relief arising from the acts enumerated in this section may be asserted against him.”

Section 13-423 permits jurisdiction based on transacting business in the District only when the claim arises from that business.

Beachboard v. Trustees of Columbia University in the City of New York · filed 1984-04-30(b)

Since appellant’s claim is unrelated to the university’s activities in the District of Columbia, the long-arm statute cannot be invoked as a basis for personal jurisdiction over appellees.

Section 13-423(b) permits a claim under the long-arm statute only if the claim arises from the acts used to establish personal jurisdiction.

Cardwell v. Investor's Analysis, Inc. · filed 1985-10-31(b)

The Court need not address these contentions, however, because plaintiff has not met the requirements of Section 13-423(b), which provides, “When jurisdiction over a person is based solely upon [the long-arm statute], only a claim for relief arising from acts enumerated in this section may be asserted against him.” ... As such, plaintiff’s claim arises from the Board’s decision, not from defendant’s contacts with the District. The Board’s decision was unrelated to those contacts; indeed, plaintiff’s statement of opposition to the registration did not mention defendant’s contacts with the District, much less allege harm arising from them. As such, this Court cannot find personal jurisdiction over defendant through the long-arm statute.

Section 13-423(b) requires a claim to arise from the defendant’s District contacts; an unrelated contracting relationship does not satisfy that requirement.

Coalition on Sensible Transportation Inc. v. Dole · filed 1986-04-02(b)

Plaintiffs’ claims arise from alleged improprieties in the administrative process and not from the SHA’s contracting relationship, if any, with D.C. firms. The statutory requirement that a claim must arise from the alleged contacts is closely enforced by the courts.

Section 13-423(b) requires the claim to arise from the defendant’s District contacts; advertising in the District does not establish jurisdiction over an injury at a Virginia store.

Bayles v. K-Mart Corp. · filed 1986-06-16(b)

Where “all of the alleged acts at issue ... occurred other than in the District of Columbia,” D.C.Code § 13-423(b) is not satisfied.

Section 13-423(b) limits jurisdiction based on specified conduct to claims arising from that conduct.

FIRST CHICAGO INTERN. v. United Exchange Co., Ltd. · filed 1987-02-20(b)

The bases for jurisdiction enumerated in D.C.Code § 13-423(a) apply only to claims “arising from” conduct described therein. Section 13-423(b) makes this point expressly clear.

Section 13-423 does not confer personal jurisdiction over a defendant when the plaintiff’s claims do not arise from that defendant’s activities in the District.

Kapar v. Kuwait Airways Corp. · filed 1987-07-08

Finally, there is no basis for jurisdiction over Mid-East under the District of Columbia long arm statute, D.C.Code § 13-423, since plaintiff’s claims do not arise out of that defendant’s activities in the District, or under D.C.Code § 13-334 since the defendant has had neither an office nor personnel in the District since 1984.

Section 13-423(a)(1) requires a claim to arise from the defendant’s business contacts with the District; the creditor’s location there alone does not establish personal jurisdiction.

Connors v. Marontha Coal Co., Inc. · filed 1987-08-31(a)(1)

Although extraterritorial service of process is authorized for federal claims under ERISA, because no federal statute explicitly authorizes extraterritorial service of process for the plaintiffs’ state law claims, we must look to see whether the D.C. long-arm statute, D.C.Code § 13-423(a)(l), permits personal jurisdiction over these claims. We conclude that it does not. Although Moore and Fields were arguably “transacting any business in the District of Columbia” when they participated in the Plans, the state law claims for relief do not arise from these contacts.

Section 13-423(b) allows a claim based solely on the long-arm statute only if it arises from the defendant’s covered acts in the District of Columbia.

Northwest Airlines, Inc. v. International Ass'n of MacHinists & Aerospace Workers · filed 1989-03-17(b)

Moreover, D.C.Code § 13-423(b) requires that the acts establishing the contracts with the District must be related to the litigation: “When jurisdiction over a person is based solely upon this section, only a claim for relief arising from acts enumerated in this section may be asserted against him.” ... Northwest’s claims against Cook and District 143 do not arise from any particular transaction of business by them in the District of Columbia.

Section 13-423(b) requires a claim based on a nonresident’s District business to have a discernible relationship to that business; the employee’s retirement gift claim lacked that relationship.

Trerotola v. Cotter · filed 1991-12-20(b)

For proper jurisdiction, therefore, the long-arm statute requires that the claim raised have a discernible relationship to the “business” transacted in the District. ... In sum, Cotter’s claim — breach of a contract to pay a severance “gift” upon retirement — does not have the required relationship to the Conference’s business activities in the District to meet the due process requirements for personal jurisdiction.

Section 13-423(a)(1) requires a claim to arise from the defendant’s business contacts with the District; distributing cars in a region that includes the District does not establish jurisdiction over an unrelated collision elsewhere.

Everett v. Nissan Motor Corp. in U.S.A. · filed 1993-07-19(a)(1)

Nissan’s distribution of automobiles in a “region” that includes the District of Columbia is not sufficient to demonstrate jurisdiction over Nissan U.S.A. in the District of Columbia itself. ... Here, too, the nexus between the car collision in North Carolina and ap-pellee’s business of distributing cars in the metropolitan area is simply too tenuous to satisfy the requirement of the long-arm statute.

Section 13-423(b) requires the claim to arise from the specific District of Columbia activity on which personal jurisdiction is based.

Novak-Canzeri v. Saud · filed 1994-09-30(b)

As this Court has held, Section 13-423(b) bars any claims unrelated to the particular transaction carried out in the District of Columbia upon which personal jurisdiction allegedly is based: The claim itself must have arisen from the business transacted in the District or there j£ no jurisdiction.

Section 13-423(b) permits specific jurisdiction only for claims arising from acts listed in the statute; speculation that a defendant processed checks in the District does not establish that connection.

Capital Bank International Ltd. v. Citigroup, Inc. · filed 2003-08-04(b)

Moreover, even if the plaintiff were able to establish a contact between the District and defendants Citigroup or Citibank Delaware, it has not shown that its claims “aris[e] from acts enumerated in” the District’s long-arm statute or that the exercise of jurisdiction would satisfy due process.