Companhia Brasileira Carbureto, et al v. Applied Industrial Materials C, et al
Plaintiffs sued defendants alleging that defendants submitted fraudulent petitions to the U.S. International Trade Commission ("ITC") and thereby induced the ITC to impose unwarranted duties on plaintiffs' products. At issue was whether defendants' petitions to the ITC established personal jurisdiction in the District of Columbia when none of the defendants was located or incorporated in the District of Columbia. Also at issue was whether jurisdiction was proper where defendants had conspired with a trade association that was located within the District of Columbia. The court held that plaintiffs' allegation that defendants conspired with a trade association was insufficient to support personal jurisdiction. The court then certified the following question to the D.C. Court of Appeals, "Under District of Columbia law, does a petition sent to a federal government agency in the District provide a basis for establishing personal jurisdiction over the petitioner when the plaintiff has alleged that the petition fraudulently induced unwarranted government action against the plaintiff?"