No Minimum Contacts.

Plaintiff alleged he tried to start a personal watercraft manufactured by defendant, and the watercraft caught fire, causing him serious injuries.  He claimed the manufacturer was negligent for failing to inform him of a recall of the watercraft for a defective fuel tank. The manufacturer cross-complained against the successor-in-interest of the manufacturer of the fuel tank, a Canadian company. The Canadian company never had a registered agent in California, never qualified to do business in California, never manufactured any products in California, never had any employees, offices, or facilities in California, and never advertised or sold any personal watercraft fuel tanks or fuel tank filler necks in California. The watercraft manufacturer argued the Canadian company had sufficient minimum contacts with California because it knew its fuel tanks would be used on the watercrafts and would be sold in the U.S., including California, and had agreed to produce its fuel tanks in accordance with regulatory standards promulgated by the U.S. Coast Guard. The trial court quashed service of summons for lack of personal jurisdiction. The appellate court affirmed, stating the Canadian company and its successor “did not purposefully direct their activities toward the residents of California. They created no substantial connection with California or continuing obligations between them and California. They did not deliberately engage in any significant activities within California. Because of their lack of minimum contacts with California, they could not reasonably expect to be subject to California’s jurisdiction.”  Bombardier Recreational Products, Inc. v. Dow Chemical Canada ULC  (Cal. App. Third Dist.; May 17, 2013) 216 Cal.App.4th 591.