Gail Lindgren is an entrepreneur who runs a small business called Moonbeams based in West Des Moines, Iowa. In 1997, Ms. Lindgren designed and began selling JeanJangles ®, jewelry that hangs from the belt loops on jeans. Ms. Lindgren obtained a patent for the trinkets in 2000. JeanJangles ® are made from sterling silver or gold-filled wire, with pieces incorporating such items as gold nuggets, glass, and abalone. JeanJangles ® may be purchased from Ms. Lindgren’s website, www. jeanjangle.com, or from Teacups & Tiaras in West Des Moines, Iowa, and its online store. A California company, GDT, began selling “Jeans for the Hip,” also called Jean Jewel. GDT filed a trademark application for Jean Jewel on May 21, 2002. GDT maintains a website, www.jeanjewel.com, which began selling Jean Jewel merchandise in June 2003. Jean Jewel merchandise is also available at foreign and domestic retail outlets, although not in Iowa. GDT’s principal place of business is Pacific Palisades, California.
Ms. Lindgren became aware of GDT, its website, and its product when People magazine did a feature story on the jean trinkets and friends called to congratulate her on her national success. Ms. Lindgren filed suit in federal district court in Iowa against GDT for infringement. GDT filed a motion to dismiss the case for lack of in personam jurisdiction. Should the suit be dismissed for lack of jurisdiction by the Iowa courts? [Lindgren v. GDT, LLC, 312 F. Supp. 2d 1125 ( S. D. Iowa 2004).]