223A Mass. Gen. Laws § 3

Section 3(d) permits $5,000 in annual Massachusetts product sales to count as substantial revenue for personal jurisdiction.

Mark v. Obear & Sons, Inc. · filed 1970-05-27(d)

Obear derives approximately $5,000 a year from sales of its products in Massachusetts and, considering the purpose for which the long-arm statute was enacted, this Court concludes that $5,000 is “substantial revenue” within the meaning of the statute.

Section 3(d)'s substantial revenue requirement can be satisfied by goods used in Massachusetts even when the manufacturer sells them through an intermediary.

Heins v. WILHELM LOH WETZLAR OPTICAL MACH. GMBH · filed 1988-05-11(d)

The Superior Court judge concluded that, as the defendant sold its machines to Loh Optikmaschinen, the defendant did not derive substantial revenue from goods used in Massachusetts. That reasoning ignores economic reality and, for purposes of statutory construction, elevates form over substance.

Section 3(d) requires evidence of regular business activity or substantial revenue in Massachusetts; national advertising and Massachusetts sales of one to five percent, without dollar figures, did not establish those grounds for jurisdiction.

Cunningham v. Ardrox, Inc. · filed 1995-03-03(d)

Here, the only evidence that Ardrox “regularly does or solicits business, or engages in any other persistent course of conduct” in Massachusetts is its advertising in national publications and its Massachusetts customers, who account for from one to five percent of its annual sales. This evidence is insufficient to satisfy the statute. ... Since the evidence fails to quantify the dollar value of Ardrox’s Massachusetts business, the court is unable to determine whether those sales constitute “substantial revenues.”

Section 3(d)’s substantial revenue requirement can be met by revenue received indirectly through a third party’s sales in Massachusetts.

Aetna Casualty & Surety Co. v. Dencast, Inc. · filed 1995-09-25(d)

Dazey has met its burden of establishing jurisdiction under this section of the Massachusetts long-arm statute. ... A court may consider revenue obtained indirectly by a defendant through sales of the product into the forum state by a third party for purposes of satisfying the statutory requirement. ... The statutory test is thus met.

At the pleading stage, § 3(a) and (d) allow a claim against a railroad to proceed when the record reasonably supports Massachusetts business contacts, subject to later jurisdictional proof.

Salmon v. LeFrancois · filed 1997-05-15(a), (d)

In sum, enough presently appears in the court papers (supplemented by oral argument) to furnish directly or by reasonable inference (see Heins, 26 Mass.App.Ct. at 20-21), the contacts between ICR and Massachusetts necessary to satisfy the minimal requirements of the Long Arm Statute, G.L.c. 223A, §3(a) and (d), and of the Due Process Clause.

Section 3(d) requires a Massachusetts tortious injury and, for injury caused by an act outside the state, regular business, persistent conduct, or substantial revenue from goods or services in Massachusetts.

Jasmin v. Liss Bros. · filed 1997-11-26(d)

As to the second prong, Liss has failed to show that Universal regularly conducts or engages in a persistent course of conduct in Massachusetts. On the other hand, evidence does exists which supports the claim that Universal derives “substantial revenue” from “goods used or consumed” in the Commonwealth.

Section 3(d)’s substantial revenue requirement can be met by proceeds from in-state sales that reach a parent company indirectly through its subsidiaries.

Commonwealth v. Philip Morris Inc. · filed 1998-03-20(d)

For purposes of deciding where a corporation may be sued, the “deriv[ation] of revenue” component of the long-arm statute may include revenue obtained indirectly via subsidiaries without thereby making the foreign parent liable for the acts of its subsidiaries.

Section 3(d)'s substantial revenue requirement can be met by revenue from a manufacturer's product line used in Massachusetts even if the injury-causing product was never sold there.

Merced v. JLG Industries, Inc. · filed 2001-09-28(d)

The statute requires only that the manufacturer derive substantial revenue from the use or consumption of its product line in Massachusetts, not that the product at issue be sold in Massachusetts.

Section 3(d)’s substantial revenue requirement is not satisfied merely because a customer sells products in Massachusetts that contain the defendant’s component.

Merced v. JLG Industries, Inc. · filed 2001-12-27(d)

Hydraulic Fittings neither made direct sales in Massachusetts nor attempted to cultivate sales relationships in that state. It is not enough for JLG to argue that Hydraulic Fittings’ benefitted from sales JLG made in Massachusetts of JLG products containing a part it purchased from Hydraulic Fittings. ... Although Hydraulic Fittings has a degree of indirect dealings with the forum, § 3 does not extend to these attenuated contacts.

Section 3(d) counts revenue from sales through an independent distributor toward its substantial revenue requirement.

Knox v. MetalForming, Inc. · filed 2018-03-30(d)

At least in the circumstances of this case, revenues from indirect sales through an independent intermediary like MetalForming count as having been "derived" from the sale of machines in Massachusetts. ... The amount of revenues alleged in this case is sufficiently "substantial" for purposes of § 3(d).

Section 3(d) permits personal jurisdiction when an out-of-state act causes injury in Massachusetts and the defendant derives substantial revenue from goods used there, including vehicles sold outside the state to Massachusetts residents and later used there.

Bateman v. Nissan Motor Co., Ltd. · filed 2025-09-29(d)

The vehicles sold from the out-of-state location to Massachusetts residents were goods later used in Massachusetts. Therefore, NOKI derived substantial revenue from goods used in this Commonwealth.

Section 3 does not permit personal jurisdiction over an out-of-state defendant whose only Massachusetts contact is correspondence responding to a Massachusetts plaintiff’s request.

Suffolk Grocery Co. v. Evans Packing Co. · filed 1970-12-21

It is significant that in the cause under review an ideal opportunity is provided to test the limits within which the privileges conferred by G.L.c.223A, § 3 may be examined. ... We fail to discover these minimal contacts in the cause under review. ... We have serious doubts that all these facts can qualify as “minimal contacts” sufficient to confer jurisdiction on the Massachusetts courts.

Section 3(a) requires a claim arising from business transacted in Massachusetts, and § 3(e) requires a claim arising from the defendant’s interest in Massachusetts real property.

McClellan v. Woonsocket Institution for Savings · filed 1979-03-16(a), (e)

Accordingly, plaintiff has failed to meet its burden of establishing the facts necessary to bring defendant within the reach of Section 3(a). ... Defendant’s interest in real property in Massachusetts must be related to the cause of action. ... I rule that plaintiff’s cause of action is merely incidental to defendant’s interest in real property in Massachusetts and does not arise from that interest.

Section 3 permits personal jurisdiction over a defendant with an interest in a Cape Cod restaurant.

Nevins v. Tinker · filed 1980-11-18

The defendant owns or has an interest in a restaurant on Cape Cod, thereby conferring personal jurisdiction of the defendant upon the trial court. G.L. c. 223A, § 3 (inserted by St. 1968, c. 760).

Section 3 does not confer personal jurisdiction over a North Carolina resident for a motor vehicle collision in North Carolina.

Mulcahy v. Guertler · filed 1976-07-13

Accordingly, this Court does not have jurisdiction over the defendant by reason of Massachusetts’ long-arm statute, M.G.L. ch. 223A, § 3, or otherwise, and service of process on the defendant in North Carolina was insufficient.

Section 3 permits personal jurisdiction over nonresident guarantors whose financial interests and business contacts connect them substantially to Massachusetts.

First National Bank v. Bergreen · filed 1981-03-02

The judge correctly denied the defendants’ motion to dismiss for lack of personal jurisdiction. See G. L. c. 223A, § 3, as amended through St. 1976, c. 435. ... The defendants here, through their financial interests in Innovex as well as through Morris’ contact with First National, availed themselves of “the privilege of conducting activities within the forum State,” Hanson v. Denckla, 357 U.S. 235, 253 (1958), and thus subjected themselves to the personal jurisdiction of the courts of the Commonwealth.

Section 3 provides the grounds for Massachusetts long-arm jurisdiction; a complaint must allege facts bringing an out-of-state defendant within one of them to support a default judgment.

Cracknell v. Hunter · filed 1978-11-21

The complaint, however, cites no statute that provides for service to be made outside of Massachusetts and no facts are alleged which would bring the defendant within any of the provisions of the Massachusetts long-arm statute. ... The Massachusetts long-arm statute is found in Mass.Gen.Laws ch. 223A, § 3. ... Because no facts have been alleged in the complaint which indicate that the court has obtained personal jurisdiction over the defendant, plaintiffs’ Motion for Judgment by Default is denied.

Section 3 requires the claim to arise from the defendant’s qualifying conduct in Massachusetts; a connecting carrier’s activities there are not attributed to the defendant.

Community-Suffolk, Inc. v. Denver & Rio Grande Western Railroad · filed 1979-07-30

Thus, for purposes of establishing jurisdiction pursuant to the Massachusetts Long Arm Statute, the activities of connecting carriers within Massachusetts are not attributable to the defendant and plaintiff must establish that the controversy has arisen from some conduct of the defendant which satisfies the Massachusetts statute. Plaintiff has failed to do so.

Section 3 does not permit personal jurisdiction when the claim does not arise from the defendant’s Massachusetts contacts.

Mas Marques v. Digital Equip. Corp. · filed 1980-02-08

As the contracts are unrelated to the policies at issue, and it has been established that Digital Corp. exercises no control over Digital GmbH’s employment decisions, the cause of action does not arise from any acts within the Commonwealth. Personal jurisdiction may not lie under M.G.L. c. 223A, § 3.

Section 3(a) permits jurisdiction over a contract claim when business conducted in Massachusetts furthers the defendant’s duties under that contract.

Willis v. American Permac, Inc. · filed 1982-02-10(a)

The survey was therefore conducted in furtherance of its contractual obligations. Since part of those duties was discharged within the Commonwealth, API has in fact transacted business here in furtherance of its contract duties. The contract thus has a sufficient nexus with this forum to allow this court to entertain a suit for its alleged breach. Accordingly, API’s motion to dismiss is DENIED.

Section 3 requires the claim to arise from business, an act, or an omission in Massachusetts; accepting a position as a director of a Massachusetts corporation alone does not establish that connection.

The American Freedom Train Foundation, Etc. v. Spurney · filed 1984-11-08(a), (c)

Plaintiff has not shown that his cause of action “arises from” any business, act, or omission which occurred in Massachusetts.

Section 3(a) permits personal jurisdiction based on business transacted in Massachusetts only when the claim arises from that business.

Buckeye Associates, Ltd. v. Fila Sports, Inc. · filed 1985-09-04(a)

Since none of those causes of action arise from any business transacted in Massachusetts by either Fila Italy or Fila USA, the Court cannot acquire jurisdiction under § 3(a).

Section 3 does not support personal jurisdiction over nonresident defendants on a conspiracy theory when the plaintiff offers only an information-and-belief assertion linking them to the alleged conspiracy.

Gilday v. Quinn · filed 1982-09-28

I rule that this assertion does not present the Court with facts sufficient to allow the Court to exert personal jurisdiction over Kelly and Webster under the conspiracy theory of personal jurisdiction.

Section 3(a) permits personal jurisdiction over a nonresident in a support modification action when the claim arises from marital acts in Massachusetts and there is a sufficient connection among the defendant, the forum, and the litigation.

Winternitz v. Winternitz · filed 1985-01-21(a)

Consequently, we think that Walter’s cause of action “arose from” acts which related to the marital conduct of the parties in Massachusetts. On the record before us, we conclude that there is a sufficient nexus among the defendant, the forum, and the litigation to provide a constitutionally acceptable basis for the trial court to assert jurisdiction under G. L. c. 223A, § 3(a).

Section 3 does not confer personal jurisdiction over a defendant whose Massachusetts contacts are insufficient to support jurisdiction over the claim.

Roy v. Roy · filed 1999-08-17

Such extraterritorial service was not effective to confer jurisdiction on the court, however, because nothing in Mueller’s conduct made him amenable to service under the Massachusetts long-arm statute, G. L. c. 223A, § 3, for want of the minimum contacts here that are required to establish personal jurisdiction.

Section 3(d) does not permit personal jurisdiction based on emails sent to Massachusetts advertisers on behalf of out-of-state publishers when those contacts are incidental to servicing the publishers.

MerlinOne, Inc. v. Shoom, Inc. · filed 2005-07-01(d)

Thus, the defendant’s contact with Massachusetts businesses is “incidental” to these business of servicing its clients, none of whom is located in Massachusetts. Accordingly, emailing Massachusetts businesses to verify the appearance of their advertisements in publications located throughout the United States does not warrant the extension of personal jurisdiction over the defendant.

Section 3(a) requires business transacted in Massachusetts, while § 3(d) requires an injury in Massachusetts and qualifying business activity or revenue there; forwarding invoices to Massachusetts and paying from there did not establish jurisdiction over work performed in Illinois.

Cambridge-Lee Industries, Inc. v. Acme Refining Co. · filed 2005-11-08(a), (d)

Therefore, this Court holds that Acme did not transact business in Massachusetts as contemplated by G.L.C. 223A, §3 (a). ... Therefore, this court holds that Cambridge-Lee has failed to establish that this court may exercise personal jurisdiction over Acme pursuant to G.L.c. 223A §3 (d).

Section 3(a) supports specific personal jurisdiction when the plaintiff shows that it reaches each defendant and that exercising jurisdiction satisfies due process.

Plunkett v. Valhalla Investment Services, Inc. · filed 2006-01-03(a)

In order to obtain specific personal jurisdiction in this case, the plaintiff must demonstrate 1) the Massachusetts long-arm statute (for purposes of this motion, M.G.L. c. 223A, § 3(a)) grants jurisdiction over each defendant and 2) the exercise of jurisdiction comports with Constitutional Due Process. ... The plaintiff has demonstrated both.

Section 3 requires a statutory ground for personal jurisdiction over a nonresident defendant; alleged abuse outside Massachusetts does not establish jurisdiction without a qualifying connection to the Commonwealth.

Lamarche v. Lussier · filed 2006-04-03

Nothing in the record before us suggests that any of the statutory grounds for the assertion of personal jurisdiction can be satisfied.

Section 3 reaches as far as the Constitution permits, so the court may resolve personal jurisdiction through the constitutional inquiry.

Platten v. HG Bermuda Exempted Ltd. · filed 2006-02-06

The Supreme Judicial Court of Massachusetts has interpreted the state's long-arm statute as coextensive with the outer limits of the Constitution, id. (citing "Automatic" Sprinkler Corp. of Am. v. Seneca Foods Corp., 280 N.E. 2d 423, 424 (Mass. 1972)); thus, the only inquiry that remains is the constitutional one, see Sawtelle v. Farrell, 70 F.3d 1381, 1388 (1st Cir. 1995).

Section 3 extends personal jurisdiction to the limits of constitutional due process, so a plaintiff’s failure to identify a particular subsection is not fatal.

Killion v. Commonwealth Yachts · filed 2006-02-16

His failure to do so is not fatal; the Supreme Judicial Court has interpreted the long-arm statute as extending as broadly as to the limits of constitutional due process.

Section 3(a) requires a claim arising from the defendant’s business activity in Massachusetts, while §3(c) requires tortious injury caused by an act or omission there.

Access TCA, Inc. v. Brand Architecture & Management, LLC · filed 2006-11-21(a), (c)

As this activity was not illegal, and as no other illegal “transaction of business” by Gillespie in Massachusetts is alleged, the Court concludes that plaintiffs cause of action “cannot arise from” the alleged above-described activities so as to confer jurisdiction under §3(a). ... In short, no substantive basis has been shown for jurisdiction under §3(c).

Section 3(a) permits jurisdiction when a defendant transacts business in Massachusetts and the claim arises from that business; section 3(d) also permits jurisdiction for tortious injury in Massachusetts caused by out-of-state conduct when the defendant regularly does business there.

Gray v. Michael Stapleton Associates, Ltd. · filed 2007-05-07(a), (d)

Gray has demonstrated that MSA was transacting business, and that Gray’s claim arose from MSA’s transaction of business within Massachusetts. As such, this Court can exercise personal jurisdiction over MSA pursuant to G.L.c. 223A, §3(a). ... The Court may also exercise personal jurisdiction over MSA pursuant to G.L.c. 223A, §3(d).

Section 3 authorizes personal jurisdiction to the limits allowed by the federal Constitution.

Massachusetts Institute of Technology v. Micron Technology, Inc. · filed 2007-08-23

The Massachusetts long-arm statute, Mass. Gen. Laws ch. 223A, § 3 (2000), authorizes jurisdiction over the person to the limits allowed by the federal Constitution.

Section 3(c) reaches as far as federal due process permits.

MHA Financial Corp. v. Varenko Investments Ltd. · filed 2008-09-26(c)

That statute has been interpreted to reach to the limits permitted by the Federal Constitution, effectively folding the two prongs of the jurisdictional inquiry into one.

Section 3 reaches the outer limits of constitutional due process for personal jurisdiction.

Barrett v. H & R BLOCK, INC. · filed 2009-02-06

The Massachusetts long-arm statute, Mass. Gen. Laws ch. 223A, § 3, has been interpreted to be coextensive with the outer limits of the Constitution.

Section 3(a) does not confer personal jurisdiction when the relevant business occurred outside Massachusetts, and §3(d) does not apply without alleged tortious injury in Massachusetts.

Zuraitis v. Kimberden, Inc. · filed 2008-01-02(a), (d)

Exercising jurisdiction under §3(a) is not appropriate in this case because Kimberden has not “transacted any business [in Massachusetts]All of the relevant business transacted in this case occurred in Florida. ... Likewise, jurisdiction under §3(d) is inappropriate because “tortious injury” is not alleged to have occurred.

Section 3 authorizes personal jurisdiction to the full extent permitted by the Constitution.

Momenta Pharmaceuticals, Inc. v. Amphastar Pharmaceuticals, Inc. · filed 2012-01-19

Because the Massachusetts long-arm statute, M.G.L. c. 223A, § 3, reaches to the full extent that the Constitution allows, the Court may proceed directly to the constitutional analysis.

Section 3 requires a basis for personal jurisdiction over a nonresident defendant tied to the conduct or property it covers.

I.S.H. v. M.D.B. · filed 2013-05-01

The mother has not identified in the record before us any applicable basis for personal jurisdiction in the traditional long-arm statute, G. L. c. 223A, § 3. She has not suggested, for example, that the father, a nonresident, has ever been domiciled in, transacted business in, engaged in a persistent course of conduct in, or held property in the Commonwealth.

Section 3 permits personal jurisdiction when a defendant’s conduct falls within one of its listed categories and exercising jurisdiction satisfies due process.

Lothrop v. North American Air Charter, Inc. · filed 2015-03-26

If a defendant’s conduct falls within one of the subsections of the Massachusetts long-arm statute, then I may exercise jurisdiction over the defendant unless doing so would be inconsistent with the Due Process Clause of the United States Constitution.

Section 3 does not authorize specific personal jurisdiction when the complaint alleges no qualifying conduct or business ties in Massachusetts.

Carl R. Reetz & Gurry Investments v. Bio-Fertilis · filed 2011-04-06

No specific personal jurisdiction exists because none of the required elements under the Massachusetts long-arm statute are present in the Amended Complaint.

Section 3 does not permit personal jurisdiction over a defendant whose alleged contacts with Massachusetts are insufficient.

Lynch v. Stop & Shop Companies · filed 2013-02-21

However, on the facts alleged in the amended complaint, Horizon’s contacts with Massachusetts are insufficient under G.L.c. 223A, §3.

Section 3(a) requires Massachusetts contacts associated with the transaction giving rise to the claim; unrelated contacts do not establish specific jurisdiction.

Fletcher Fixed Income Alpha Fund, Ltd. v. Grant Thornton LLP · filed 2016-07-14(a)

The cases do not hold that unrelated contacts with the forum are relevant for specific jurisdiction under G. L. c. 223A, § 3(a), as the plaintiffs insist.

Section 3 reaches as far as the Constitution permits, so a court may proceed directly to the constitutional analysis of personal jurisdiction.

Rodriguez v. SAMSUNG ELECTRONICS CO., LTD. · filed 2011-11-07

Because the Massachusetts long-arm statute reaches to the full extent that the Constitution allows, the Court may proceed directly to the constitutional analysis.

Section 3 provides no basis for personal jurisdiction over a nonresident doctor for claims arising from medical treatment at an out-of-state hospital.

Lyons v. Duncan · filed 2012-05-23

The plaintiffs’ 2007 claims arise from medical treatment provided by a nonresident ... at a hospital outside the Commonwealth, and we discern no basis for personal jurisdiction in relation to these claims.

Section 3 authorizes personal jurisdiction to the limits allowed by the federal Constitution.

TomTom, Inc. v. Norman IP Holdings, LLC · filed 2012-09-04

The Massachusetts long-arm statute, Mass. Gen. Laws ch. 223A, § 3 (2000), authorizes jurisdiction over the person to the limits allowed by the federal Constitution.

Section 3 permits personal jurisdiction over an out-of-state defendant to the limits allowed by the Constitution.

Acushnet Co. v. Zimventures, LLC · filed 2015-12-23

The Massachusetts long-arm statute permits “an assertion of jurisdiction over [an out-of-state defendant] to the limits ’ allowed by the Constitution of the United States.” “Automatic” Sprinkler Corp. of Am. v. Seneca Foods Corp., 361 Mass. 441, 443, 280 N.E.2d 423 (1972). Accordingly, the Court need only analyze the Due Process component.

Section 3 extends to the limits of constitutional due process, so the due process inquiry determines whether it permits personal jurisdiction.

Hilsinger Co. v. FBW Investments, LLC · filed 2015-06-17

The Supreme Judicial Court has interpreted the long-arm statute as extending as broadly as to the limits of constitutional due process. Daynard, 290 F.3d at 52; “Automatic” Sprinkler Corp. of America v. Seneca Foods Corp., 361 Mass. 441, 443, 280 N.E.2d 423 (1972). Therefore, the relevant inquiry is the constitutional one.

Section 3 extends personal jurisdiction to the limits of the United States Constitution.

Malden Transp., Inc. v. Uber Techs., Inc. · filed 2017-12-29

The Massachusetts long-arm statute, M.G.L. c. 223A, § 3, extends jurisdiction to the limits of the United States Constitution.

Section 3 extends Massachusetts personal jurisdiction to the limits of the United States Constitution.

Malden Transportation, Inc. v. Uber Technologies, Inc. · filed 2017-12-29

The Massachusetts long-arm statute, M.G.L. c. 223A, § 3, extends jurisdiction to the limits of the United States Constitution.

Section 3 requires an enumerated basis for personal jurisdiction before a court considers constitutional limits.

Filmore v. VSP North America LLC · filed 2019-01-14

Given the inapplicability of the pertinent provisions of chapter 223A, § 3, in conferring personal jurisdiction over defendants, this court need not discuss the constitutional constraints on the exercise of jurisdiction under the statute.

Section 3 does not permit personal jurisdiction over defendants for an out-of-state accident merely because the plaintiff received treatment or felt its effects in Massachusetts.

Tomas v. Buckley · filed 2020-05-22

Plaintiff has failed to provide any evidence that the accident or any actions taken by Buckley and Hodson had any connection to Massachusetts. ... Although Plaintiff may have sought treatment and experienced the effects of the accident in Massachusetts, that is insufficient for the Court to exercise personal jurisdiction over Buckley and Hodson.

Section 3 does not confer personal jurisdiction when the defendant lacks qualifying business or contractual contacts with Massachusetts, the plaintiff cannot connect it to the alleged tort, and no agent’s contacts can be imputed to it.

Ferris v. Pound Hounds Res-Q · filed 2020-07-31

As to subsections (a) and (b), ACCNYC did not itself transact any business or make any contracts connected to Massachusetts. ... Ms. Ferris has failed to show how subsections (c) and (d) of the long-arm statute apply to ACCNYC. ... Because the SAC does not allege sufficient facts to support the contention that Pound Hounds was ACCNYC’s agent, I do not need to assess whether Pound Hounds is bound by the long-arm statute for the purposes of ACCNYC’s motion to dismiss.

Section 3 does not permit personal jurisdiction when the defendant’s conduct and the accident occurred outside Massachusetts and only the plaintiff’s residence, treatment, and injuries connect the case to Massachusetts.

Lifchits v. Integon National Insurance Co. · filed 2020-08-17

Section 3 of the Massachusetts long-arm statute allows for the exercise of “personal jurisdiction over a person, who acts directly or by an agent, as to a cause of action in law or equity arising from” various activities within or outside of the Commonwealth. ... Although Plaintiff resides, sought treatment, and experienced the effects of the accident in Massachusetts, that is insufficient for the Court to exercise personal jurisdiction over Key 4U.

Section 3 does not permit personal jurisdiction based solely on a plaintiff’s Massachusetts residence, treatment, and injuries when the defendant’s conduct and the accident have no connection to Massachusetts.

Lifchits v. Key 4U Transporation Corp. Bus · filed 2020-08-17

Although Plaintiff resides, sought treatment, and experienced the effects of the accident in Massachusetts, that is insufficient for the Court to exercise personal jurisdiction over Key 4U.

Section 3(a) requires deliberate business contacts with Massachusetts, and § 3(c) requires conduct intended to cause harm there; communications with an out-of-state company’s employee working remotely in Massachusetts did not satisfy either provision.

Collision Communications, Inc. v. Nokia Corporation · filed 2020-09-02(a), (c)

Plaintiff therefore fails to demonstrate that Defendant’s contacts with Massachusetts were deliberate, rather than fortuitous, under Section 3(a). ... The Court finds that Defendant’s alleged actions were not intended to cause harm within the Commonwealth as required by Section 3(c).

Section 3 extends personal jurisdiction to the limits of the Constitution.

The D.S. Brown Company v. White-Schiavone, JV · filed 2020-11-05

Because the Massachusetts long-arm statute, M.G.L. c. 223A, § 3, extends jurisdiction to the limits of the Constitution, the Court proceeds directly to the constitutional analysis.

Section 3(a) requires deliberate business contacts with Massachusetts, and Section 3(c) requires conduct intended to cause harm there.

Collision Communications, Inc. v. Nokia Corporation · filed 2020-11-23(a), (c)

Plaintiff therefore fails to demonstrate that Defendant’s contacts with Massachusetts were deliberate, rather than fortuitous, under Section 3(a). ... The Court finds that Defendant’s alleged actions were not intended to cause harm within the Commonwealth as required by Section 3(c).

Section 3(a) supports personal jurisdiction over a Delaware company with sufficient Massachusetts contacts, including a Massachusetts bank account and a contract with a Massachusetts resident for services.

The PATRIOT GROUP, LLC v. STEVEN C. FUSTOLO & Others. · filed 2024-05-28(a)

To the contrary, there are sufficient contacts between Fustolo CPE and Massachusetts to satisfy both the long-arm statute, G. L. c. 223A, § 3 (a), and due process.

Section 3 does not permit personal jurisdiction based on limited phone and email contacts with a Massachusetts company when the defendant’s alleged acts occurred outside Massachusetts and the additional contacts required by subsection (d) are absent.

AIG Specialty Insurance Company, As Assignee and Subrogee v. McColgan · filed 2023-08-14(a), (c), (d)

Such limited connections cannot afford jurisdiction. ... As discussed above, Machado was physically present in Connecticut during the entire relevant period. ... Again, the amended complaint fails to allege that Machado engaged in regular business or any conduct in Massachusetts at all, nor that he derived substantial revenue from goods used or consumed in Massachusetts. In sum, the Massachusetts long-arm statute does not permit the exercise of personal jurisdiction over Machado.

Section 3(a) requires a Massachusetts business transaction giving rise to the claim, while § 3(d) requires regular business, persistent conduct, or substantial revenue in Massachusetts when an out-of-state act causes injury there.

Jorge v. Adler · filed 2024-01-10(a), (d)

Thus, Plaintiff has not established that § 3(a) of the Massachusetts long-arm statute supplies a basis for the court’s jurisdiction over Defendant for infringing Plaintiff’s copyright. ... Thus, Plaintiff has not established that § 3(d) of the Massachusetts long-arm statute supplies a basis for the court’s jurisdiction over Defendant for infringing Plaintiff’s copyright.

Section 3(a) and (c) require a claim to arise from business transacted in Massachusetts or an in-state act causing tortious injury; calls continuing an earlier out-of-state scheme did not satisfy that requirement.

Rao v. Vanaja A. Sudhakar. · filed 2025-04-10(a), (c)

The Massachusetts long-arm statute requires that the plaintiff's cause of action "aris[e] from" the defendant's transaction of business, or act or omission, in Massachusetts. The defendant's conduct in Massachusetts must be a "but for" cause, i.e., "the first step in the train" that led to the cause of action. ... In those circumstances, the defendant's alleged statements in telephone calls to the mother in Massachusetts did not give rise to the plaintiff's cause of action.

Section 3 requires the cause of action to arise from the defendant’s Massachusetts transactions or acts.

CHWASTIAK v. LEAH GOUGH-COOPER & Another. · filed 2026-01-21

In any event, however one were to characterize these minimal contacts with the Commonwealth, to whatever extent they can be properly characterized as contacts, the complaint makes clear that the cause of action in this case does not "arise from" any of these alleged transactions or acts.

Section 3 does not authorize personal jurisdiction based on unrelated Massachusetts business, an alleged tortious act committed outside Massachusetts, and limited in-state business activity.

Old Republic National Title Insurance Company v. Simmons Bank · filed 2025-06-23

Accordingly, § 3(a) does not apply. ... Thus, § 3(c) is inapplicable. ... Thus, even assuming arguendo that Old Republic suffered a tortious injury in Massachusetts, Simmons’ limited and indirect economic activity in the Commonwealth does not satisfy § 3(d).

A claim that a defendant impaired a plaintiff’s Massachusetts business sufficiently asserts tortious injury in Massachusetts under § 3(d).

Engine Specialties, Inc. v. Bombardier Limited · filed 1972-01-20(d)

In our opinion the claim of impairment of ESI’s Massachusetts business is a sufficient assertion of tortious injury in the commonwealth.

Section 3(c) permits personal jurisdiction over a person when a claim arises from tortious injury caused by that person’s act in Massachusetts, including wrongful taking or damage to property there.

Wood v. Wood · filed 1976-02-03(c)

The cause of action in equity alleged here arises out of the defendant’s wrongful taking, detention, disposition and damaging of property of the plaintiff. Injury resulting from such acts is tortious, and the acts took place in the Commonwealth. Thus the case falls squarely within § 3 (c).

Section 3(a) reaches business communications directed into Massachusetts that give rise to a claim, while § 3(c) reaches tortious injury caused there by alleged nondisclosures during those communications.

North American Video Corp. v. Leon · filed 1979-11-19(a), (c)

A defendant’s initiation of telephone communications from outside the state to employees of a plaintiff in the state and the mailing of reports into the state are activities pointing to the conclusion that the defendant transacted business in Massachusetts, within the meaning of Mass.Gen.Laws c. 223A, § 3(a). ... Plaintiff has alleged and tendered affidavits supporting the conclusion that each of the defendants made telephone calls to NAVCO employees in Massachusetts in which the operations of the New York office were discussed and that defendants violated their duties of disclosure with respect to the truth or falsity of such reports. This fact pattern fulfills the literal requirements of c. 223A, § 3(c).

Section 3(d) requires tortious injury in Massachusetts; discovering an alleged misrepresentation there does not move the place of injury from where the purchase occurred.

Petricca Construction Co. v. A.C. De Soto Equipment Co. · filed 1981-02-24(d)

The tort was complete upon the transfer of the purchase price (in Tioga, Pennsylvania) and Petricca’s cause of action accrued at that time. The fact that the alleged misrepresentation was not discovered until the crusher was used in Massachusetts does not thereby make Massachusetts the place of injury.

Section 3(c) permits personal jurisdiction over a person who causes tortious injury in Massachusetts through an agent’s allegedly deceptive calls into the state.

Freimarck v. First National Monetary Corp. · filed 1982-01-14(c)

They are sufficient to bring Vitters under the terms of § 3(c) as construed by the Court in Murphy v. Erwin-Wasey, Inc. They are also sufficient to bring FNMC under, its tferms since Vitters was acting on FNMC’s behalf.

Section 3(d) requires tortious injury in Massachusetts; treatment and recovery there do not change where an injury occurred.

Mello v. K-Mart Corp. · filed 1985-03-18(d)

Because the Mellos, like the Walshes, have experienced no tortious injury in Massachusetts, I rule that § 3(d) of the state long-arm statute provides no basis for this Court’s exercise of jurisdiction over Shinn Fu Auto.

Section 3(c) requires an act or omission in Massachusetts that causes injury there; negligent treatment and discharge in Puerto Rico do not qualify merely because the patient later suffers injury in Massachusetts.

Bradley v. Cheleuitte · filed 1974-11-25(c)

Thus, personal jurisdiction over these defendants hinges upon whether the defendants committed any act or omission in Massachusetts which caused injury to the plaintiff in Massachusetts. ... The medical treatment occurred solely in Puerto Rico, and any effort by this Court to characterize it differently cannot be properly rationalized. Therefore, this Court lacks personal jurisdiction in this matter and defendants’ motions to dismiss are allowed.

Section 3(c) does not confer personal jurisdiction based on a failure to warn a person in Massachusetts when the defendant had no contact with the state.

Rose Chlebda, Administratrix of the Estate of Joseph Chlebda v. H. E. Fortna and Brother, Inc. · filed 1979-11-29(c)

It seems clear that it could not be. The whole thrust of plaintiff’s claim is that there was no contact at all.

Section 3(d) permits jurisdiction for tortious injury in Massachusetts when the defendant regularly does or solicits business there or derives substantial revenue from goods used there.

Kolikof v. Samuelson · filed 1980-05-19(d)

On the basis of the foregoing, I rule that because Permaform regularly does nor solicits business in Massachusetts and derives substantial revenue from goods used in Massachusetts, this Court has personal jurisdiction over Permaform pursuant to Mass. Gen.Laws ch. 223A § 3(d).

Section 3(c) allows personal jurisdiction over a person for a claim arising from tortious injury caused by acts in Massachusetts, including acts committed through an agent.

Cooper v. Church of Scientology of Boston, Inc. · filed 1982-01-27(c)

Plaintiff’s allegations regarding Hubbard sufficiently state claims of tortious acts committed by Church-Boston and others at the direction of Hubbard to allow this court to assert its jurisdiction over him and to permit service on him outside of Massachusetts.

Section 3(d) permits personal jurisdiction for tortious injury in Massachusetts caused by an out-of-state act when the defendant regularly does business or engages in persistent conduct in Massachusetts; the alleged contacts were sufficient at the pleading stage.

Table Talk, Inc. v. Table Talk Pie Distributors of Poughkeepsie, Inc. (In Re Table Talk, Inc.) · filed 1985-05-16(d)

Table Talk relies upon M.G.L. c. 223A, § 3(d). ... These allegations are sufficient to meet the requirements of the Massachusetts Long-Arm statute for the purposes of ruling that the complaint is not subject to dismissal on its face.

Section 3(c) permits personal jurisdiction when an intentional misrepresentation sent from outside Massachusetts causes reliance within the Commonwealth.

Burtner v. Burnham · filed 1982-02-05(c)

We are of opinion that Burnham’s acts (as described in the complaint and the Burtner affidavits) may be found to have been sufficiently intentional and to have caused sufficient reliance by the Burtners within Massachusetts, to give the Massachusetts courts jurisdiction under c. 223A, § 3(c).

Section 3(c) permits personal jurisdiction when the plaintiff proves the defendant’s tortious conduct in Massachusetts.

Salvador v. Meese · filed 1986-08-19(c)

Consequently we find that plaintiffs have provided sufficient proof of Propper’s tortious activity in Massachusetts to support the exercise of personal jurisdiction over the Propper defendants pursuant to § 3(c) of the Massachusetts long-arm statute.

Section 3(d) does not treat the effects of an out-of-state lawsuit as tortious injury when the suit is neither malicious prosecution nor abuse of process.

Whistler Corp. v. Solar Electronics, Inc. · filed 1988-04-25(d)

Absent malicious prosecution and abuse of process, filing a lawsuit cannot be described as "wrongful" or as "of the nature of a tort." ... The Court thus concludes that Whistler has not suffered any “tortious injury” in Massachusetts within the meaning of subsection 3(d) as a result of Solar’s actions.

Section 3(a) does not reach a California hotel based on its toll-free number, magazine advertising, and a reservation call from Massachusetts; § 3(c) reaches alleged intentional deceit communicated into Massachusetts and relied on there.

Rye v. Atlas Hotels, Inc. · filed 1991-02-12(a), (c)

It is clear to us that the defendant transacted no business in Massachusetts. ... Here, as in Burtner, the defendant’s conduct is alleged to have been intentional, not merely negligent, and to have caused sufficient reliance of the plaintiff in Massachusetts to bring the defendant within the reach of c. 223A, § 3(c).

Section 3(d) locates a tortious injury where the underlying injury occurred, not where its later effects are felt.

Kimberly Crocker and Julian H. Crocker v. The Hilton International Barbados, Ltd. · filed 1992-10-08(d)

Furthermore, the injury to which Section 3(d) refers is the sexual assault itself, not the manifestations or effects of that injury as claimed by appellants.

Section 3(c) permits Massachusetts courts to exercise personal jurisdiction over a person for a claim arising from tortious injury caused by that person’s act in Massachusetts.

Legaski v. Melanson · filed 1994-10-05(c)

Melanson, a resident of Florida, is thus subject to the jurisdiction of the courts of Massachusetts through the “long arm” of G.L.c. 223A §3 ... After determining that the defendant’s conduct satisfies one of the statutory bases of jurisdiction under the Massachusetts longarm statute, however, the court must also decide whether the exercise of jurisdiction would satisfy the Fourteenth Amendment due process test of minimum contacts.

Section 3(c) requires facts showing a tortious act or omission in Massachusetts; purchases of materials and services in Massachusetts alone do not satisfy § 3(d)’s business-contact requirement.

Russo v. Material Handling Specialties Co. · filed 1995-08-29(c), (d)

In sum, this court concludes that plaintiff fails to meet his burden of showing facts sufficient to satisfy G.L.c. 223A, §§3(c) or 3(d). Accordingly, this court lacks personal jurisdiction over defendants McPaul and Magee.

Section 3(d) requires a plaintiff to identify an out-of-state act by the defendant related to the injury in Massachusetts, even when the defendant has extensive unrelated contacts with the state.

Noonan v. Winston Co. · filed 1995-09-25(d)

While section 3(d) asserts general jurisdiction over defendants (like RJRTC) who have extensive unrelated contacts with Massachusetts, the plaintiff must still specify some act committed by the defendant outside the forum that relates to the in-state cause of action.

Section 3(c) permits personal jurisdiction over claims arising from tortious injury caused by a defendant’s acts in Massachusetts.

Milford Power Ltd. Partnership v. New England Power Co. · filed 1996-03-14(c)

Given the requirement that this Court accept NEP’s proferred evidence as true, the Court concludes that NEP has satisfied its ... burden of establishing the jurisdiction of this Court over the moving parties under § 3(c) of the Massachusetts long-arm statute, at least with respect to the claims of civil conspiracy, violation of Chapter 93A, defamation and abuse of process, based on the alleged in-forum October Meeting alone.

Section 3(d) allows jurisdiction for an injury in Massachusetts caused by an out-of-state act when the defendant regularly solicits business in Massachusetts; the solicitations need not succeed.

George F. Noonan and Ann Marie Noonan v. The Winston Company · filed 1998-03-09(d)

While the parties energetically debate the success of CLB’s Massachusetts solicitations, we measure only the solicitations themselves.

Section 3(c) permits personal jurisdiction when a nonresident intentionally directs conduct at a Massachusetts resident and causes injury there, even without physically entering the state.

Liu v. DeFelice · filed 1998-07-15(c)

DeFelice’s acts subject him to personal jurisdiction under the Massachusetts long-arm statute M.G.L. ch. 223A § 3(c). His actions, although performed without physical entrance into the Commonwealth, were intentionally directed at, and caused injury to, a Massachusetts resident.

Section 3(d) requires an injury in Massachusetts from an out-of-state tort; a depositor’s Massachusetts residence does not make banking services performed in Antigua services rendered in Massachusetts.

United States v. Swiss American Bank, Ltd. · filed 1998-09-30(d)

Furthermore, subsection (d) requires, in addition to purposeful availment and injury within the state, that the defendant derive substantial revenues from “goods used or consumed or services rendered in the commonwealth.” All of the services provided by the defendant banks were provided in Antigua. The fact that the depositor Fitzgerald was a Massachusetts resident, even if the shell corporations that controlled the accounts are ignored, does not resurrect the government’s argument, because whatever revenue the banks derived was not from services rendered in Massachusetts.

Section 3(d) requires tortious injury in Massachusetts caused by an act or omission outside Massachusetts; an injury occurring in Connecticut does not satisfy that requirement.

Princeton Capitol Finance Co. v. Marketechs, Inc. · filed 1999-02-12(d)

Therefore, it was in Connecticut that Princeton suffered injury. See id. The first prong of G.L. 223A, §3(d), specifically that Webster caused tortious injury in Massachusetts by an act or omission outside Massachusetts has not been met by Princeton. This court cannot exercise personal jurisdiction over Webster under this statutory provision on the conversion claim and it must therefore be dismissed.

Section 3(d) permits personal jurisdiction for an injury in Massachusetts caused by an out-of-state act when the defendant regularly does or solicits business there, engages in persistent conduct there, or derives substantial revenue from goods or services there.

Bartow v. Extec Screens and Crushers, Ltd. · filed 1999-06-09(d)

Consequently, the Court concludes that for the purposes of the Massachusetts long-arm statute, Extec “regularly does or solicits business, or engages in any other persistent course of conduct, or derives substantial revenue from goods used or consumed or services rendered, in this commonwealth.”

Section 3(d) permits personal jurisdiction over a defendant whose persistent course of conduct in Massachusetts is connected to a tortious injury there.

Turpin v. Mori Seiki Co., Ltd. · filed 1999-07-12(d)

In any event, MS Ltd. has certainly engaged in a “persistent course of conduct” in Massachusetts by publicly acknowledging that it has its own overseas office in Boston. Consequently, this Court can exercise personal jurisdiction consistent with the state long-arm statute and the United States Constitution.

Section 3(d) permits personal jurisdiction for tortious injury in Massachusetts caused by conduct outside the state when the defendant regularly solicits business, engages in persistent conduct, or derives substantial revenue in Massachusetts.

Snyder v. ADS Aviation Maintenance · filed 2000-01-10(d)

Despite Superior’s assertions to the contrary, I conclude that Superior both regularly solicits business and engages in a persistent course of conduct in Massachusetts within the meaning of the statute. ... The plaintiffs thus have satisfied their burden under §3(d).

Section 3(a) does not reach an isolated mailing and telephone call responding to Massachusetts residents’ inquiries; §3(d) requires the tortious injury itself to occur in Massachusetts.

Shannon M. v. Clark · filed 2000-09-28(a), (d)

In the instant case, plaintiff has alleged even fewer contacts with the forum state and thus, under the holding in Droukas, this Court finds as a matter of law that defendants did not “transact business” under §3(a) of the Massachusetts longarm statute. ... While manifestations, effects, and consequences of an out-of-state injury may be experienced in Massachusetts, they do not constitute “injury in this commonwealth” within the meaning of §3(d).

Section 3(c) covers a consumer protection claim based on misrepresentation that causes tortious injury, although an injury under the Consumer Protection Act is not necessarily tortious.

Christian Book Distributors, Inc. v. Great Christian Books, Inc. · filed 2001-03-08(c)

The parties do not raise the question whether a Consumer Protection Act claim is "tortious” within the meaning of ch. 223A, § 3(c). ... We conclude that while an injury compensable under the act is not necessarily tortious, it was in this instance.

Section 3(d) permits jurisdiction for tortious injury in Massachusetts caused by out-of-state conduct only when the defendant has the required business, conduct, or revenue ties to Massachusetts.

Bearse v. Main Street Investments · filed 2001-10-25(d)

The only prong of the Long Arm Statute that arguably could apply to Norman is prong (d) — that he caused tor-tious injury in Massachusetts by an act or omission outside of Massachusetts. However, this prong also requires that a defendant either regularly did business or solicited business in Massachusetts or engaged in a persistent course of conduct in Massachusetts or derived substantial revenue from goods or services used in Massachusetts. There is no evidence or even a single allegation that Norman did business or derived any revenue from goods or services used in Massachusetts.

Section 3(a) reaches a nonresident seller who advertises in Massachusetts and comes there to complete a sale; section 3(c) reaches tortious injury caused by the seller’s conduct in Massachusetts.

Carlson v. Petroske · filed 2002-09-13(a), (c)

We hold that he was transacting business in Massachusetts. More importantly, however, even if he was not transacting business per §3(a), he caused tortious injury by an act or omission in Massachusetts per §3(c).

Section 3(d) does not permit jurisdiction over a parent corporation based on its subsidiary’s Massachusetts activity and the parent’s indirect revenue without evidence that the parent itself acted in the Massachusetts market.

In Re Lupron Marketing and Sales Practices Litigation · filed 2003-02-19(d)

Assuming that Heins is correctly decided (the Appeals Court seems to have confused specific and general jurisdiction in its analysis of § 3(d)), ... plaintiffs have failed to offer any facts showing that Takeda, as opposed to TAP, actively inserted itself as an actor in the Massachusetts market in the same fashion as did the German defendant in Heins.

Section 3(d) permits personal jurisdiction when out-of-state trademark infringement injures a Massachusetts trademark owner and the defendant regularly solicits business in Massachusetts through a continuously available interactive website.

Venture Tape Corp. v. McGills Glass Warehouse · filed 2003-10-20(d)

Here, the first element (causing injury by an act elsewhere) is met because in trademark infringement cases, the injury is said to have occurred where the trademark owner is located. ... The second element (regular solicitation of business in Massachusetts) is met by McGills’ maintaining an interactive website that is continuously available to Massachusetts residents.

Section 3(c) permits personal jurisdiction when a defendant’s tortious act or omission occurs in Massachusetts and causes injury there; misrepresentations sent into the Commonwealth can satisfy that rule.

Roberts v. Legendary Marine Sales · filed 2005-11-29(c)

General Laws c. 223A, § 3(c), requires two elements for the assertion of long-arm jurisdiction: (1) a tortious injury by the act or omission of the defendant; and (2) that the tortious act or omission occur in the Commonwealth. ... The plaintiffs’ allegations here satisfy § 3(c).

Section 3(c) does not treat monetary damages grounded in breach of contract as tortious injury, even when the plaintiff alleges misrepresentations.

Roberts v. Legendary Marine Sales · filed 2006-12-12(c)

The substance of the plaintiffs’ complaint is contractual. The damages sought are grounded in breach of contract and do not constitute “tortious injury” as contemplated under § 3 (c).

Section 3(d) requires a claim of tortious injury in Massachusetts caused by an act or omission outside the state; a breach of contract claim alone does not qualify.

Builder's Resource, Inc. v. Coreslab Structures (Conn), Inc. · filed 2008-01-23(d)

Plaintiffs claims are based entirely on breach of contract; there is no claim of tortious injury in the complaint. Accordingly, this claim does not meet the threshold requirement of “tortious injury in this commonwealth by an act or omission outside this commonwealth.”

Section 3(c) does not authorize personal jurisdiction for a tort claim based on a negligent act or failure to act outside Massachusetts.

Fiske v. Sandvik Mining · filed 2008-02-04(c)

The injury is thus clearly not the result of an “act or omission in this commonwealth” within the meaning of § 3(c).

Section 3 permits personal jurisdiction at the pleading stage when allegations sufficiently show that defendants caused tortious injury through acts or omissions in Massachusetts.

Basore v. Ayvazian · filed 2008-12-11

Similarly, plaintiffs allegations that personal jurisdiction exists over these defendants under M.G.L.c. 223A, §3 as a result of defendants “causing tortious injury by acts or omissions in the Commonwealth of Massachusetts . . .” appears, at least at this stage before any substantial discovery has been made of these defendants, to be sufficient.

Section 3(c) permits personal jurisdiction when a defendant’s intentional misrepresentation causes tortious injury in Massachusetts.

Krishelle, Ltd. v. Detroit Diesel Corp. · filed 2005-07-06(c)

MDS’s intentional misrepresentation and subsequent failure to compensate Krishelle to Krishelle’s detriment satisfies the requirements of both G.L.c. 223A, §3(c) and constitutional due process.

Section 3(d) does not permit personal jurisdiction based on alleged out-of-state tortious conduct unless the defendant regularly does or solicits business in Massachusetts, engages in a persistent course of conduct there, or derives substantial revenue from goods or services there.

Saint-Gobain Ceramics & Plastics, Inc. v. Hewes · filed 2006-05-26(d)

Even if St. Gobain can establish that such a breach has occurred, it must still show that Hewes regularly does or solicits business or engages in any other persistent course of conduct or derives substantial revenue from goods used or consumed or services rendered in the Commonwealth. It has not shown that with respect to Hewes.

Section 3(d) permits personal jurisdiction when a defendant’s out-of-state conduct causes tortious injury in Massachusetts and the defendant engages in a persistent course of conduct there.

Rosenthal v. MPC COMPUTERS, LLC · filed 2007-07-02(d)

Moreover, the several contacts reviewed by the Magistrate Judge at 20-21 of the Report and Recommendation (Dkt. No. 19) demonstrate, at least at this stage, that Defendant has at a minimum engaged “in a persistent course of conduct” in the Commonwealth.

Section 3 allows Massachusetts courts to exercise personal jurisdiction over claims involving torts allegedly committed in Massachusetts.

Mahoney v. Eli Lilly & Co. · filed 2008-04-22

Because complete diversity exists, 28 U.S.C. § 1332; because Massachusetts's long-arm statute extends to torts allegedly committed in Massachusetts, Mass. Gen. Laws ch. 223A, § 3; and because a substantial part of the events occurred in Massachusetts, 28 U.S.C. § 1391(a)(2), the court recognizes that this case could have been brought in the District of Massachusetts.

Section 3(c) permits personal jurisdiction when the defendant or an agent commits a tort in Massachusetts, but speculation about that conduct is insufficient.

City Sanitation LLC v. Beck · filed 2010-03-30(c)

For the court to assert jurisdiction over either Christopher or EZ, the commission of a tort, i.e., conversion of the engine, must have been committed by one of them, or their agent, in the Commonwealth.

Section 3(c) does not confer jurisdiction over alleged out-of-state wrongdoing based on an in-state act that is not pleaded to be wrongful.

Dew ex rel. Yates v. Skevington · filed 2010-05-26(c)

This act, would not however, by itself, confer Massachusetts jurisdiction over Skevington for all of her alleged New Jersey actions. Moreover there are no facts pleaded which would lead one to conclude, even accepting the averments as being true, that Skevington’s removal of the large plastic bag and television is wrongful.

Section 3(c) and (d) permit personal jurisdiction based on a tortious act in Massachusetts or an out-of-state act causing injury in Massachusetts when the defendant has the specified additional contacts with the state.

Harrell v. Repp · filed 2010-12-29(c), (d)

It is clear, despite Plaintiffs’ contention to the contrary, that none of Defendant Sansone's conduct satisfies Massachusetts’ long-arm statute. Plaintiffs allege no facts on which the court could find that Defendant Sansone engaged in any persistent course of conduct in Massachusetts, that Plaintiffs suffered any injury in Massachusetts, or that Defendant Sansone committed a tortious act in Massachusetts.

Section 3(c) permits jurisdiction over a nonresident whose conduct in Massachusetts causes tortious injury, subject to due process limits.

Edozien v. XS Micro, LLC · filed 2014-03-07(c)

The Massachusetts Long-Arm statute authorizes courts to exercise jurisdiction over non-resident defendants when the defendants have caused “tortious injury by an act of omission in this commonwealth.” G.L.c. 223A, §3(c). ... Since the Supreme Judicial Court has consistently held that the Massachusetts Long-Arm statute extends to the limits allowed by the Constitution, the court may proceed directly to the due process analysis and assume that if due process is satisfied, so too, is the Long-Arm Statute.

Section 3(d) requires services to be rendered in Massachusetts; treating Massachusetts residents at a Rhode Island facility does not satisfy that requirement.

Jones v. Brody · filed 2011-07-15(d)

Indeed, the record before the court shows that non-residents come to Rhode Island for treatment and that MRI/CT does not provide services anywhere except in Rhode Island, thus, not fulfilling the plain language of the statute that the services must be rendered in the Commonwealth.

Section 3(d) requires ongoing Massachusetts business, conduct, or substantial revenue to support jurisdiction for an out-of-state act causing injury in Massachusetts.

American International Insurance v. Ziabicki Import Co. · filed 2012-07-05(d)

Seuffer has also negated the other potential basis for jurisdiction, G.L.c. 223A, §3(d). It never subjected itself to personal jurisdiction in the Commonwealth for causing tortious injury in Massachusetts by actions outside the state “if [it] regularly does or solicits business, or engages in any other persistent course of conduct, or derives substantial revenue from goods used or consumed or services rendered” in Massachusetts.

Section 3(d) permits jurisdiction for tortious injury in Massachusetts caused by conduct outside the state when the defendant has sufficient Massachusetts business contacts.

Anaqua, Inc. v. Bullard · filed 2014-07-24(d)

The literal requirements of subsection 3(d) of the longarm statute, therefore, are satisfied as to Lecorpio.

Section 3(d) permits personal jurisdiction for an out-of-state act causing injury in Massachusetts when the defendant engages in a persistent course of conduct in the Commonwealth.

Arthur v. Doe · filed 2014-07-31(d)

Viewing the facts in a light most favorable to Arthur, the threshold requirement of§3(d), thatArthur’s in-state harm was caused by Burkle’s out-of-state act, is met. ... Finally, the court concludes that Arthur has sufficiently alleged that Burkle has engaged in a persistent course of conduct with Massachusetts through his affiliation with Harvard.

Section 3(c) supports personal jurisdiction when an out-of-state defendant mails an allegedly misleading demand letter into Massachusetts that causes tortious injury there.

Larson v. Perry · filed 2020-03-27(c)

Here the Massachusetts long-arm statute is satisfied where the complaint alleges that Plaintiff “caus[ed] tortious injury by an act or omission in this commonwealth” by mailing a demand letter into the Commonwealth where that demand letter is alleged to misrepresent the applicable law so as to cause tortious injury.

Section 3(c) permits personal jurisdiction when a defendant’s act or omission in Massachusetts causes tortious injury in Massachusetts.

O'Grady v. Safety-Kleen Systems, Inc. · filed 2020-03-30(c)

Plaintiffs must therefore allege that defendants took some action in Massachusetts that caused the plaintiffs to be injured in Massachusetts. ... Accordingly, O’Grady has failed to establish that this Court has jurisdiction under Massachusetts General Laws ch. 223A, § 3(c).

Section 3(c) permits personal jurisdiction over defendants who intentionally cause documents to be delivered into Massachusetts to garnish property there, even when they use an intermediary to deliver them.

NRO Boston, LLC v. Arch Capital Funding · filed 2020-09-28(c)

Here, where the LLC Defendants intended that the documents reach Massachusetts to garnish property in Massachusetts, it therefore makes little difference, for the purposes of § 3(c), that they intentionally caused the documents to be delivered to Massachusetts via Barbarovich and a registered agent, as opposed to via the postal service. The former meets the § 3(c) standard.

Section 3(c) does not require the defendant’s physical presence in Massachusetts, but the act causing the injury must be purposefully directed at the plaintiff there.

Bay Promo, LLC v. Alaniz · filed 2021-04-28(c)

While Moncada is correct that § 3(c) does not require that a defendant be physically present in Massachusetts at the time that a plaintiff is injured, the act that is the “but for” cause of the injury must have been purposefully directed at the plaintiff in Massachusetts.

Section 3(c) covers alleged tortious injury caused by a ship crew’s negligent conduct in Massachusetts.

American Home Assurance Company v. M/V One Helsinki · filed 2021-07-01(c)

I conclude that § 3(c) applies to KLSM because Plaintiff alleges that the KLSM crew was negligent in their use of the Conley Terminal and that they failed to adequately secure the ship in its berth and take adequate precautions in preparation for the wind conditions.

Section 3(c) does not authorize personal jurisdiction for an injury in Massachusetts caused by an allegedly defective product manufactured outside the state.

Whitley v. Linde Heavy Truck · filed 2018-06-01(c)

Therefore, Mr. Whitley’s injury is “clearly not the result of an ‘act or omission in this commonwealth’ within the meaning of § 3(c).”

Section 3(c) permits personal jurisdiction when threatening communications sent from outside Massachusetts cause fear and tortious injury within the Commonwealth.

N.C. v. M.O. · filed 2019-03-28(c)

As pertinent here, our long-arm statute authorizes personal jurisdiction "as to a cause of action in law or equity arising from [a] person's ... causing tortious injury by an act or omission in this commonwealth." G. L. c. 223A, § 3 (c ). The Supreme Judicial Court has held that communications originating from outside Massachusetts create tortious injury within Massachusetts if they "include threats or harassing statements" or "placed the plaintiff in fear." ... The defendant's e-mails in this case, for all the reasons we have set out above, meet these criteria.

Section 3(c) treats online defamatory material allegedly accessed in Massachusetts as an act of defamation committed in the Commonwealth.

Lin v. TipRanks, Ltd. · filed 2019-11-21(c)

Here, because the defamatory material on TipRanks’ website was allegedly accessed or “circulated” in Massachusetts, the act of defamation was committed in Massachusetts within the meaning of section 3(c) of the long-arm statute.

Section 3(d) requires specific facts showing regular or persistent business in Massachusetts or substantial revenue from goods used there; unsupported assertions and inferences are insufficient.

Ericson v. Conagra Foods, Inc. · filed 2020-11-24(d)

First, Plaintiff does not allege that Defendants “regularly [do] or [solicit] business” or engage in another “persistent course of conduct” in Massachusetts. See Mass. Gen. Laws ch. 223A, § 3(d). Nor does she adequately assert that Defendants derive substantial revenue from goods sold in the Commonwealth; she makes no allegations regarding how Defendants derive revenue, how much revenue they derive, and from where they derive that revenue.

Section 3(c) permits jurisdiction based on an agent’s tortious conduct in Massachusetts only when an agency relationship is shown.

Driscoll v. McCann · filed 2020-11-30(c)

This conduct did not create an agency relationship for purposes of satisfying § 3(c) of the Massachusetts long-arm statute.

Section 3(c) permits personal jurisdiction when a defendant, directly or through an agent, sends misleading statements into Massachusetts that cause tortious injury there.

iNebular, Inc. v. Deutsche Bank Trust Company Americas · filed 2023-01-17(c)

Because iNebular has alleged specific facts in support of the existence of an agency relationship between Deutsche Bank and Navitec, the Court finds there are grounds for personal jurisdiction in this matter under M.G.L. c. 223A § 3(c).

Section 3(c) requires facts showing that the defendant committed an act causing tortious injury in Massachusetts.

Komarovskiy v. Celsius Network LLC · filed 2024-03-31(c)

Simply stated, Plaintiff has failed to show the applicability of Section 3(c) to these causes of action since there are no facts before the Court that Mashinsky committed any of these alleged torts within Massachusetts specifically.

Section 3(c) does not reach alleged tortious conduct outside Massachusetts that was not directed into the state, and § 3(d) does not treat emotional effects felt in Massachusetts as an in-state injury when the alleged assault occurred elsewhere.

Frederick v. United States Olympic Committee · filed 2022-09-20(c), (d)

As discussed above, Frederick has not pleaded facts that Carlson’s tortious conduct was directed into the forum or involved fraudulent conduct. ... That Frederick alleges a separate claim for negligent infliction of emotional distress does not alter the analysis where the alleged conduct giving rise to the emotional distress is the out-of-state sexual assault. ... Accordingly, the court finds that personal jurisdiction under § 3(c) or § 3(d) of the Massachusetts long-arm statute does not exist as to Carlson.

Section 3(c) does not establish personal jurisdiction based on communications directed to an out-of-state proceeding when the plaintiff alleges non-intentional torts rather than fraudulent misrepresentation.

Frederick v. United States Olympic Committee · filed 2023-03-02(c)

The court’s reasoning in Murphy to find that personal jurisdiction exists under § 3(c) is not applicable here where Frederick does not bring a claim of fraudulent misrepresentation against Carlson in her second amended complaint but rather maintains two non-intentional tort claims.

Section 3(d) can establish specific personal jurisdiction when an out-of-state act causes injury in Massachusetts and the defendant meets one of the subsection’s business or revenue requirements.

Barnes v. Merck & Co., Inc. · filed 2023-01-04(d)

Given that duty and the precedent concluding that § 3(d) embraces the theory of specific jurisdiction, this Court concludes, as it has previously, that § 3(d) can be used to establish specific jurisdiction over a defendant.

Section 3(c) permits jurisdiction over an out-of-state defamatory statement purposefully directed at a Massachusetts resident and intended to cause harm there; unsupported allegations of targeting do not suffice.

Beck, M.D. v. Fradette · filed 2023-03-31(c)

As noted above and in the Memorandum and Order [Doc. No. 32], in the context of defamatory statements courts have found that the requirements of § 3(c) are met when an out of state statement is purposefully directed towards a Massachusetts resident and intended to cause harm in Massachusetts. ... Accordingly, the court finds that personal jurisdiction does not exist over Defendants under subsection (c) of the Massachusetts long-arm statute.

Section 3(c) does not permit a court to attribute a person’s conduct to a company for personal jurisdiction without facts establishing an agency relationship.

Huang v. Liu · filed 2024-07-17(c)

Thus, because Huang does not assert facts sufficient to establish an agency relationship “[she] has failed to establish personal jurisdiction [over Fluor] under § 3(c) of the Massachusetts Long Arm Statute.” Bud’s Goods, 2023 WL 2696587, at *3.

Section 3(c) permits personal jurisdiction when a person’s intentional conduct targets Massachusetts and begins a chain of events causing injury there.

Doane · filed 2025-12-04(c)

At this stage, Doane’s proffered evidence is sufficient to bring Levine within the scope of Section 3(c) of the long-arm statute. The record adequately supports Doane’s position that Levine personally participated in, and benefited from, Python’s call centers that targeted Massachusetts consumers like Doane. And the long-arm statute’s causation standard is met here: Levine’s conduct, including allegedly developing Python’s call scripts, started a “train of events” that led Python’s callers to repeatedly contact Doane without his permission and cause him harm in Massachusetts.

Section 3(c) requires the act causing a tortious injury to occur in Massachusetts; fabricating evidence there did not establish jurisdiction when its use in Florida caused the injury.

Gaikwad · filed 2026-04-06(c)

But this alleged fabrication alone does not suffice to demonstrate that Plaintiff’s injury was “caus[ed] . . . by an act” in Massachusetts. Cf. Mass. Gen. Laws ch. 223A, § 3(c).

Section 3(c) requires an act or omission in Massachusetts that causes tortious injury; section 3(d) requires additional Massachusetts business activity, persistent conduct, or substantial revenue when the act occurs outside the state.

Garagesocial, Inc. v. The Hagerty Group, LLC · filed 2025-06-13(c), (d)

Accordingly, subsection (d) is not applicable. ... Plaintiff has adduced no facts suggesting that the alleged infringement occurred in Massachusetts, and subsection (c) therefore does not apply.

Section 3(c) permits personal jurisdiction when a defendant intentionally sends fraudulent misrepresentations into Massachusetts that injure Massachusetts residents.

Aquidneck Trucking, LLC v. Lightspeed Trucking, LLC · filed 2025-07-31(c)

The Court finds jurisdiction proper under at least subsection (c), which authorizes courts to hear causes of action arising from “tortious injury [caused] by an act or omission in this commonwealth.” Mass. Gen. Laws c. 223A, § 3(c). Massachusetts courts have long held that subsection (c) is satisfied where, as alleged here, a claim arises out of a defendant’s intentionally “sen[ding] or caus[ing] to be sent into Massachusetts fraudulent misrepresentations which caused injury to Massachusetts residents.” Commonwealth v. Purdue Pharma, L.P., 2019 WL 5617817, at *5 (Mass. Super. Oct. 8, 2019) (collecting cases); see also Compl. ¶¶ 84, 99. Plaintiffs have therefore satisfied the long-arm statute.

Section 3(a) does not confer personal jurisdiction over an out-of-state buyer whose Massachusetts contacts consist of mailing a purchase order and payments to a Massachusetts seller.

"Automatic" Sprinkler Corp. of America v. Seneca Foods Corp. · filed 1972-03-16(a)

We conclude that there were insufficient contacts here to make the defendant subject to our long arm statute.

Section 3(a) does not treat a defendant as transacting business in Massachusetts merely because the plaintiff performs some contracted work there and the defendant occasionally sends an employee there to collect plans.

Nichols Associates, Inc. v. Starr · filed 1976-02-19(a)

We hold that on this record the defendant was not “transacting any business” in Massachusetts within the meaning of G. L. c. 223A, § 3 (o).

Section 3(a) treats purposeful personal acts as transacting business; commercial activity is not required.

Ross v. Ross · filed 1976-12-08(a)

The statute’s reference to “transacting any business” does not require that the defendant have engaged in commercial activity. That language is general and applies to any purposeful acts by an individual, whether personal, private, or commercial.

Section 3(a) permits personal jurisdiction over a nonresident when claims arise from its business dealings in Massachusetts.

Marketing & Distribution Resources, Inc. v. Paccar, Inc. · filed 1978-11-03(a)

Paccar is therefore amenable to suit in this Court under § 3(a) of the Massachusetts long-arm statute.

Section 3(a) permits personal jurisdiction when a claim arises from a defendant’s business activities in Massachusetts, including activities conducted through an agent.

Sahatjian v. Woodlets, Inc. · filed 1979-03-16(a)

Some of the obligations of the parties under the employment agreement required performance in Massachusetts. It is those activities of defendant in Massachusetts that plaintiff claims violated defendant’s obligation under that contract. The contentions raised in plaintiff’s complaint bring into question issues of fact and law pertaining to the dealings of Woodlets in Massachusetts. Accordingly, the contract sued upon was sufficiently connected with the forum to permit the exercise of jurisdiction over the defendant. ... Because I find jurisdiction over Woodlets under Mass.Gen.Laws ch. 223A, § 3(a), it is unnecessary to consider plaintiff’s contention that Woodlets is subject to suit under Mass.Gen.Laws ch. 223A, § 3(b).

Section 3(a) permits personal jurisdiction over a seller whose sustained sales to a Massachusetts distributor and frequent communications with it constitute transacting business in the Commonwealth.

Boston Super Tools, Inc. v. RW Technologies, Inc. · filed 1979-03-28(a)

Accordingly, I rule that Rotorway was transacting sufficient business in Massachusetts to supply a basis for jurisdiction under the Massachusetts long-arm statute, Mass. Gen.Laws ch. 223A, § 3(a), and, thus, its motion to dismiss should be denied.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the claim arises from that business; sustained reports, calls, and billing into the state can satisfy that requirement without physical presence.

Good Hope Industries, Inc. v. Ryder Scott Co. · filed 1979-05-04(a)

General Laws c. 223A, § 3 (a), gives rise to jurisdiction if the defendant either directly or through an agent transacted any business in the Commonwealth, and if the alleged cause of action arose from such transaction of business. ... The literal requirements of G. L. c. 223A, § 3 (a), are satisfied.

Section 3(a) does not confer jurisdiction when defendants’ contacts do not substantially involve them in or affect the Massachusetts economy.

Backman v. Schiff · filed 1979-10-31(a)

Their relationship with plaintiff did not substantially involve defendants in, nor did their activities have a substantial impact on, the Massachusetts economy so as to subject them to jurisdiction under Section 3(a).

Section 3(a) treats physically signing a contract in Massachusetts as transacting business there when the claim arises from that contract.

Carlson Corp. v. University of Vermont · filed 1980-03-06(a)

There can be no doubt that physically signing a contract in Massachusetts is, in literal terms, transacting business in Massachusetts, if the cause of action arises from that contract.

Section 3(a) permits personal jurisdiction when a claim arises from a defendant’s sustained business dealings in Massachusetts, even if the defendant was never physically present there during those dealings.

Little, Brown and Co.,(Inc.) v. Bourne · filed 1980-07-23(a)

Thus, by looking at the whole of defendant’s relationship with the plaintiff publisher, and for purposes of literal fidelity to Section 3(a) of the long arm statute, we may conclude that even though defendant was physically absent, he can be held to have transacted business in Massachusetts.

Section 3(a) treats mailed patent infringement threats as transacting business in Massachusetts when the patentee receives royalties from activity there involving the patent and the recipient competes there.

Nova Biomedical Corporation v. Willi Moller, D/b/a/ Gebruder Moller Glasblaserei · filed 1980-08-08(a)

In light of the facts described — and with particular reference to Moller’s receipt of royalties from Orion’s use of the patent in suit and the competitive positions of Nova and Orion — we conclude that Moller’s threatening infringement notices to Nova constituted a transaction of business under, section 3(a) giving rise to the present cause of action.

Section 3(a)'s transaction-of-business requirement is satisfied when a defendant's agents execute the contract underlying the claim in Massachusetts.

Space Building Corp. v. Envirodyne Engineers, Inc. · filed 1981-03-10(a)

The physical presence of Agrostruct’s agents in Massachusetts to execute the contract was sufficient to satisfy the literal requirements of § 3(a).

Section 3(a) permits personal jurisdiction over those who administer a retirement plan for employees at a Massachusetts plant.

Comstock v. Pfizer Retirement Annuity Plan · filed 1981-09-23(a)

Because the Pfizer Plan provided coverage for the employees at a Massachusetts plant, those in charge of the plan necessarily had to administer its provisions to some extent in Massachusetts. In my opinion, such activity constitutes doing the business of the trust and warrants “long-arm” jurisdiction under M.G.L. c. 223A, § 3(a).

Section 3(a)’s transacting-business ground does not cover an isolated hotel promotion by someone who is not the hotel owner’s agent.

Brandi v. National Bulk Carriers, Inc. · filed 1982-06-15(a)

Magnifico was not an agent for the purposes of G. L. c. 223, §§ 37 & 38, nor did Westend transact business in the Commonwealth. G. L. c. 223A, § 3(a). Magnifieo’s involvement in a bank promotion whereby he furnished information on the hotel was an “isolated transaction.”

Section 3(a) permits personal jurisdiction over a nonresident whose deliberate, sustained contacts amount to transacting business in Massachusetts and satisfy due process.

C. H. Babb Co. v. A. M. Manufacturing Co. · filed 1982-08-04(a)

Since we conclude that Babb has presented jurisdictional facts sufficient to survive due process scrutiny and to satisfy § 3(a), we need not consider whether jurisdiction could also be found under § 3(b).