The district court properly dismissed this abuse of process and malicious prosecution action for lack of personal jurisdiction.  This action was filed in Arizona where the plaintiff lived.  Defendants were Nevada citizens who had sued plaintiff in Nevada, though they succeeded in taking plaintiff’s deposition in Arizona as part of the Nevada litigation.  When considering specific personal jurisdiction in tort cases, the court looks to whether the defendant purposefully directed his activities toward the forum state (here, Arizona).  Purposeful direction requires that the defendant commit an intentional act expressly aimed at the forum state causing harm that the defendant knows is likely to be suffered in the forum state.  It is not enough that the plaintiff is a resident of the forum state and thus likely to suffer any injury in the forum where he resides.  Instead, the defendant must create contacts with the forum state and not just with persons who reside there.  Here, defendants did not establish such contacts but instead sued in Nevada.  The ancillary service of process and taking of a deposition in Arizona as part of the Nevada litigation were insufficient to create minimum contacts with Arizona.

Ninth Circuit Court of Appeal (Kronstadt, J., sitting by designation); October 23, 2017; 2017 WL 4766888.