Case Citator › FC Investment Group LC v. IFX Markets, Ltd.

FC Investment Group LC v. IFX Markets, Ltd.

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
D.C. Circuit
Citation
529 F.3d 1087
Decided
Confirmed treatments
2
Flagged citations read
28 of 28
Citing cases (total)
28
Treatment dates
2018–2021

Status

Overruled in part
A reviewed court has overruled part of this case’s holding. FC Investment Group LC v. IFX Markets, Ltd. was overruled in part on its standard for general personal jurisdiction based on online business. The D.C.
More on how this was screened

Circuit now requires corporate contacts that make the corporation essentially at home in the forum. The two confirmed treatments are listed below. All 28 flagged citations have been read; later courts continue to use the decision's separate rules on civil RICO jurisdiction, jurisdictional discovery, and the pleading of conspiracy jurisdiction.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

28 later cases cite FC Investment Group LC v. IFX Markets, Ltd.; 28 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on FC Investment Group LC v. IFX Markets, Ltd.?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The D.C. Circuit overruled FC Investment Group's lower standard for general jurisdiction based on a corporation's online business in the forum.

    Erwin-Simpson v. AirAsia Berhad · D.C. Circuit · filed

    Because Gorman and FC Investment Group set a lower bar, we overrule our precedent on that point as inconsistent with Daimler and Goodyear.
    Read the full opinion on CourtListener →

Limited

  • After Walden, the district court required a plaintiff invoking the conspiracy jurisdiction test associated with FC Investment Group to allege the defendant knew of the coconspirator's acts in the forum.

    Cockrum v. Donald J. Trump for President, Inc. · D.D.C. · filed

    Some cases in this Circuit, predating the Supreme Court’s 2014 decision in Walden v. Fiore, discussed a conspiracy theory of personal jurisdiction, and those cases required “a prima facie showing of (1) a conspiracy (2) in which the defendant participated and (3) a co-conspirator’s overt act within the forum, subject to the long-arm statute and in furtherance of the conspiracy.” Youming Jin v. Ministry of State Sec., 335 F. Supp. 2d 72, 78 (D.D.C. 2004) (footnote omitted); FC Inv. Grp. LC v. IFX Markets, Ltd., 529 F.3d 1087, 1096 (D.C. Cir. 2008); World Wide Minerals, Ltd. v. Republic of Kazakhstan, 296 F.3d 1154, 1168 (D.C. Cir. 2002). ... Adopting the approach taken by Judge Mehta, this Court concludes that if any conspiratorial jurisdiction survives Walden, a plaintiff pursuing such a theory must allege that the defendant knew of the co-conspirator’s acts in the forum.
    Read the full opinion on CourtListener →

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