“Two Streams of Commerce” — One Legal, One Rogue
The ruling hinges on the legal concept of “streams of commerce.” While Samsung SDI does sell battery cells into the U.S. market, it does so exclusively for integration into larger, pre-approved devices. The company actively prohibits the sale of individual batteries to retail customers. Buyers must go through an application process, specify their intended use, and acknowledge that loose batteries should not be sold separately.
“This isn’t splitting hairs,” the panel wrote. “A single forum can implicate two streams of commerce — one the defendant navigates deliberately, and one it avoids.”
In other words, the vape shop’s decision to stock the battery was a “unilateral action by an unknown third party”, and Samsung SDI could not be held accountable in Indiana simply because its batteries ended up there through unauthorized channels.
A Warning Shot on Jurisdiction
B.D.’s legal team argued that Samsung’s national distribution was enough to create jurisdiction anywhere its products surface. But the judges disagreed, warning that such logic would blur the critical line between general jurisdiction (being sued anywhere) and specific jurisdiction (being sued where the company directly operates).
“Accepting this theory,” the court said, “would effectively erase the limits on jurisdiction that the Supreme Court has emphasized.”
