LG Chem, Ltd. v. Superior Court

California resident Ryan Lawhon purchased an unpackaged 18650 lithium-ion battery at Vapin’ the 619, a San Diego vape shop. One day, while the battery was in Lawhon’s pocket, it exploded, severely burning Lawhon’s leg and hand. Seeking damages, Lawhon filed a negligence and products-liability suit against multiple vape-shop-affiliated parties plus LG Chem Ltd. (LG) (plaintiff), the battery’s alleged manufacturer. LG was a South Korean company headquartered in Seoul, South Korea. It did not have any California offices or employees and did not market or sell any consumer products in California. LG’s only connection with California was its sale of 18650 batteries to three electric-vehicle manufacturers. LG had sold millions of batteries to those manufacturers, generating significant income. LG required the manufacturers to sign an agreement stating they would not sell the batteries individually but only as component parts in their vehicles. The agreement was consistent with LG’s broader policy that its 18650 batteries be sold only as component products to industrial equipment manufacturers. LG moved to quash Lawhon’s claims against it, arguing the California superior court (defendant) lacked personal jurisdiction over LG. Lawhon conceded that the court lacked general personal jurisdiction but argued that the court had specific personal jurisdiction because LG sold batteries into California and Lawhon was injured by a battery he purchased in California. The superior court agreed, denying LG’s motion. LG filed a petition against the superior court in the California Court of Appeal, seeking a writ of mandate requiring the superior court to grant the motion.