Arista Records, Inc. v. Sakfield Holding Co.

General Jurisdiction Over Defendant Established by Using Computer Forensic Evidence

314 F. Supp 2d. 27. (D.D.C., 2004)

The plaintiff record company brought suit against the defendant website for allowing people to download the record company’s music. The defendant claimed that the District Court for the District of Columbia did not have jurisdiction over it. The court stated that there was enough evidence to show specific jurisdiction because the case was based on the declaration of a man who lived in the District of Columbia, and said that he had downloaded music files from the defendant’s website.

During jurisdictional discovery, the plaintiff’s computer expert was able to uncover evidence that the defendant had deleted a log that listed all of the people who had downloaded music from its website. From the information that he was able to recover, the expert determined that 241 of the people who had downloaded music from the defendant’s website were in fact from the District of Columbia.

The court found these contacts with people in the District of Columbia to be sufficient to establish the continuous and systematic contacts, which are necessary to establish general jurisdiction over the defendant.