On November 13, 2009, the United States District Court for the Eastern District of Michigan applied the Calder effects test in granting a defendant's motion to dismiss for lack of personal jurisdiction, pursuant to Fed. R. Civ. P. 12(b)(2), or, in the alternative, to transfer venue. Weather Underground, Inc. v. Navigation Catalyst Systems, Inc., 2009 WL 3818191 (E.D. Mich. Nov. 13, 2009).
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