A corporation or other entity’s mere appointment of an in-state agent for service of process, in a state where the entity has not otherwise established a business operation and other direct contacts in the state, does not operate as consent, or otherwise satisfy the constitutional standard for “minimum contacts” with the state sufficient to confer personal jurisdiction.  (King v. American Family Mutual Insurance Co., Ninth Circuit No. 08-35988, January 31, 2011)  Thus it should be not assumed, for example, that a parent-level holding company’s mere qualification in a foreign state, when its actual operations are conducted by operating subsidiaries which themselves are duly qualified in-state, is sufficient to confer personal jurisdiction on the upper-level entity solely because an agent for service of process shows up on state records.

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