In Knapp v. Sage Payment Solutions, Inc., 2018 WL 659016, at *7 (N.D.Cal., 2018), Judge Chesney employed a lengthy analysis too long to repeat here to find in a blast-fax case that, because plaintiff could demonstrate no agency facts on which to pin liability to the alleged principal, the Court lacked personal jurisdiction over the alleged principal/defendant.
For the reasons set forth above, the Court finds it lacks personal jurisdiction over Sage. See Williams v. Yamaha Motor Co., 851 F.3d 1015, 1024 (9th Cir. 2017) (holding district court lacked specific personal jurisdiction premised on agency theory where appellants “failed to make out a prima facie case for any such agency relationship”).
The case demonstrates how, in a proper case, a jurisdictional challenge might short-cut lengthy litigation required before summary judgment could be reached.