In Trimble v. PerDiemCo, the Fed. Cir. found personal jurisdiction over a patentee based on multiple letters to plaintiffs, concluding that their holding in Red Wing Shoe did not preclude personal jurisdiction.  PerDiemCo, is owned by a Washington DC resident, which rents office space in Marshall, Texas.  The owner had never visited Marshall and there were no employees in Marshall.  PerDiemCo’s 11 patents were related to electronic logging devices and/or geofencing.  PerDiemCo sent a warning letter to ISE, headquartered and having a principal place of business in Coralville, Iowa, which was forwarded to parent company Trimble, incorporated in DE and headquartered in Sunnyvale, CA.  At least 22 times, PerDiemCo communicated with Trimble, threatening to sue in ND Iowa and ED Texas.  Trimble and ISE, asserting a specific jurisdictional theory, filed a DJ action in the ND California, which was dismissed by the district court, citing Red Wing Shoe Co. v. Hockerson-Halberstadt, Inc.  Noting CA’s long-arm statute, the question was reduced to whether exercise of jurisdiction over PerDiemCo. would be consistent with due process and focused on the nature and extent of the defendant’s relationship with the forum state.  Citing three, post Red Wing Shoe SCOTUS opinions rejecting special rules for patent litigation, examining the nature and scope of communications into a state as creating specific personal jurisdiction and the relevance of the breadth of defendant’s contacts with the forum, the Fed. Cir. found that PerDiemCo’s actions satisfied the minimum contacts or purposeful availment test.  The Fed. Cir. found the more than 22 communications over three months, to far exceed the contacts in Red Wing Shoe.  PerDiemCo’s actions went beyond “solely … informing a party who happens to be located [in California] of suspected infringement and was more akin to “an arms-length negotiation in anticipation of a long-term continuing business relationship.