Under the U.S. Constitution, courts may not exercise specific personal jurisdiction unless the plaintiff's alleged injury "arise s out of or relate s to" the defendant's forum contacts. In Ford Motor Co mpany v. Mont ana Eighth Judicial District Court , this Court clarified that this standard does not always require proof of a "strict causal relationship" between injury and forum contacts. 141 S. Ct. 1017, 1026 (2021). But causation was not irrelevant. Rather, the Court explained that in "some" cases, a defendant's "raft of … in -state activities" may be an "except for" cause of the plaintiff's injury even if that cannot be definitively "pro[ved]." Id. at 1026, 1029. Concurring, Justice Alito called this "rough causation." Id. at 1034.

In this declaratory -judgment action for trademark noninfringement, the court below read Ford as creating a categorical rule that no form of causation is ever required in any context . The court below held that Impossible X, a single -member LLC, is subject to California's specific jurisdiction based on general business activities that took place years before the controversy arose , even though Impossible X has never sought to enforce its trademarks in California. The questions presented are:

1. Does Ford create a categorical rule that specific jurisdiction does not require any link between the defendant's forum contacts and the plaintiff's injury, even when the defendant has no presence in the forum state ?

2. Are the relevant forum contacts in a declaratory noninfringement action only those that relate to the defendant's enforcement -related conduct , or can they also include general business activities?

Does Ford create a categorical rule that specific jurisdiction does not require any link between the defendant's forum contacts and the plaintiff's injury, even when the defendant has no presence in the forum state?