HUDDA, et al. vs WAHED

To afford general jurisdiction to a state’s courts, a defendant’s contacts with the state must be so systematic and extensive that the corporation is “fairly regarded as at home” in the state. 22CV016235: HUDDA, et al. vs WAHED 05/28/2026 Hearing on Motion to Quash NOTICE OF MOTION AND MOTION TO QUASH SERVICE OF SUMMONS AND COMPLAINT FOR LACK OF PERSONAL JURISDICTION; filed by Adient US, LLC, sued herein as Doe 103 (Defendant) CRS# 465997951808 in Department 512 (Daimler AG v. Bauman (2014) 571 U.S. 117, 137-139.) The paradigm examples of corporations at home in California include those which are incorporated here or have their principal place of business within the state. (Daimler AG, supra, 571 U.S. at p.137; Goodyear Dunlop Tires Ops., S.A. v. Brown (2011) 564 U.S. 915, 923-924.)

A state court can constitutionally exercise “specific” specific personal jurisdiction over an outof-state corporate defendant as to causes of action or claims when: (1) the defendant purposely established contacts with the forum state; (2) a plaintiff’s cause of action “arises out of” or is “related to” the defendant’s contacts with the forum state; and (3) the forum’s exercise of personal jurisdiction in the particular case comports with “fair play and substantial justice.” (Burger King Corp. v.

Rudzewicz (1985) 471 U.S. 462, 477-478.) “In order for a court to exercise specific jurisdiction over a claim, there must be an ‘affiliation between the forum and the underlying controversy, principally, [an] activity or an occurrence that takes place in the forum State.’” (Bristol-Meyers, supra, 582 U.S. at 264.) “When there is no such connection, specific jurisdiction is lacking regardless of the extent of a defendant’s unconnected activities in the State.” (Ibid.) Further, “specific jurisdiction is confined to adjudication of issues deriving from, or connected with, the very controversy that establishes jurisdiction.” (Bristol-Meyers, supra, 137 S.Ct. at p. 1780.)

Plaintiff has the burden of production of evidence on the first two elements of the specific personal jurisdiction analysis stated above. (LG Chem, Ltd. v. Sup.Ct. of San Diego County (2022) 80 Cal.App.5th 348, 361.) "It is [plaintiff's] burden to prove this second prong of the specific jurisdictional analysis, and he must do that with “‘competent evidence of jurisdictional facts.’” (80 Cal.App.5th at 365, quoting Rivelli v. Hemm (2021) 67 Cal.App.5th 380, 393.) “[T]he plaintiff must establish the purposeful availment and relatedness requirements by a preponderance of the evidence.” (L.W. v. Audi AG (2025) 108 Cal.App.5th 95, 108.) If that burden is met, “then the burden shifts to defendant to present a compelling case that the exercise of jurisdiction would be unreasonable because it fails to comport with “ ‘ “traditional notions of fair play and substantial justice.’ ” ” (Id.)

"In the sphere of specific jurisdiction, the phrase ‘relate to’ incorporates real limits, as it must to adequately protect defendants foreign to a forum.” (LG Chem, Ltd., supra, 80 Cal.App.5th at 367, quoting Ford Motor Co. v. Montana Eighth Judicial District Ct. (2021)592 U.S. 351, 361.) Merely selling a product that ends up being used in California is insufficient to create specific personal jurisdiction unless the sale was purposefully targeted to California. (Bombardier Recreational Prods., Inc. v. Dow Chem. Canada ULC (2013) 216 Cal.App.4th 591, 603-604; see also World-Wide Volkswagen Corp. (1980) 444 U.S. 286, 297 [presence of defendant’s product in forum state, even if foreseeable, is insufficient if the defendant did not direct it there].)

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

22CV016235: HUDDA, et al. vs WAHED 05/28/2026 Hearing on Motion to Quash NOTICE OF MOTION AND MOTION TO QUASH SERVICE OF SUMMONS AND COMPLAINT FOR LACK OF PERSONAL JURISDICTION; filed by Adient US, LLC, sued herein as Doe 103 (Defendant) CRS# 465997951808 in Department 512

ANALYSIS OF MOTIONS TO QUASH

At issue in this case are alleged defects in the front passenger seat of a 2015 Acura MDX (the “Vehicle”) in which plaintiff Alnoor Hudda was permanently injured in a rearend collision occurring in California on or about 4/22/2022. Plaintiffs present evidence that they purchased the Vehicle at an Acura dealership in Pleasanton, California in December 2016. (Pike Dec. Exh. A (“Hudda Decl.”) at ¶ 3. The Hudda Declaration does not state whether the Vehicle was purchased new and, if not, where the Vehicle was sold when new.

Adient is a Michigan corporate entity with principal place of business in Michigan and that Johnson Controls is a Wisconsin corporation with principal place of business in Wisconsin. Defendants admit in their moving MPAs that Johnson Controls designed, manufactured and supplied the seat adjustor, foam, trim, and headrest assembly pursuant to Honda’s seat performance specifications and subject to Honda’s design approval, but asserts that none of these components were manufactured in or supplied to California. (See Adient’s moving MPA at p. 7:2-15.)

Defendant also admits Johnson Controls is Adient’s predecessor in interest. (Ibid.) Johnson Controls apparently spun off its automotive seating business to Adient in 2016, and Adient assumed Johnson Controls’ existing automotive seat liabilities at the time of the spin off. (Pike Decl., Exh. C at p. 22:4-22.)

First Johnson Controls and later Adient were involved in the design, manufacture and supply of the front passenger seats for Acura MDX model vehicles between 2014 and 2020, including those for model year 2015; the seats were built to specifications of some Honda corporate entity not adequately identified in either Plaintiffs’ or Defendant’s record. The record contains no direct evidence that all 2015 Acura MDX vehicles were assembled in Alabama by Honda Manufacturing Alabama or that Johnson Controls assembled seats for the 2015 Acura MDX; instead, the evidence indicates that another entity, Bridgewater, assembled the seats. (Pike Dec.

Exh. C at p. 28:7-21.) However, the deposition testimony of Defendants’ person most qualified in this action supports a finding that Johnson Controls was responsible for designing and supplying at least some portions of the front passenger seats on all 2015 model Acura MDX vehicles old in the United States, including portions of the headrests, which Plaintiffs’ operative Fourth Amended Complaint alleges at ¶¶ 34-39 were defective and responsible for Alnoor Hudda’s injuries. (See Id. at at pp. 27:25-28:21, 33:19-37:10; Exh.

J at p. 9 of 36.)

Johnson Controls contracted with some Honda entity, most likely “Honda Manufacturing Alabama,” whose facility assembled the Acura MDX vehicles some or all of the 2015 Acura MDX sold in the United States, or possibly “Honda R&D,” but did not contract with defendant American Honda Motor Co., Inc. ("AHMC"), the Honda entity responsible for distribution and

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

22CV016235: HUDDA, et al. vs WAHED 05/28/2026 Hearing on Motion to Quash NOTICE OF MOTION AND MOTION TO QUASH SERVICE OF SUMMONS AND COMPLAINT FOR LACK OF PERSONAL JURISDICTION; filed by Adient US, LLC, sued herein as Doe 103 (Defendant) CRS# 465997951808 in Department 512 sale of finished 2015 Acura MDX vehicles in the United States. Johnson Controls understood it was to design and supply the above-listed seat parts for 72,164 units (seats) for each of the first three years of the seat program (2013-2015). (Pike Decl., Ex.

C, at pp. 33:19-37:10.) Although Johnson Controls lacked details regarding specific states where finished Acura MDX vehicles would be sold, it understood that AHMC was responsible for distributing the 2015 Acura MDX vehicles "to [AHMC's] network." (Id. at p. 45:2-24.)) Nevertheless, the Court can reasonably infer that Johnson Controls, as the designer and supplier of some parts for the seats for all Acura MDX, knew that AHMC would be distributing the vehicles in the United States, possibly including California.

Plaintiffs rely heavily on L.W. v. Audi AG (2025) 108 Cal.App.5th 95, a recent decision that arguably expanded the “stream of commerce” theory for establishing specific personal jurisdiction over defendants whose products are distributed nationally, including to the forum state California. Defendants rely heavily on a prior Motion to Quash ruling involving related defendant Bridgewater Interiors, LLC (“Bridgewater”); however, that motion was decided prior to L.W. v. Audi AG.

L.W. v. Audi AG states, in relevant part:

“J. McIntyre [Machinery, Ltd. v. Nicastro (2011) 564 U.S. 873] also confirms that, at a minimum, a plaintiff trying to establish personal jurisdiction over a foreign manufacturer must show a regular ... flow or regular course of sales in the forum state, and/or some additional efforts directed toward the forum state, such as special state-related design, advertising, advice, [or] marketing. Tellingly, J. McIntyre confirms that ‘additional efforts’ are required only if ‘regular flow’ or ‘regular course of sales’ in the forum state are not shown.” (L.W., supra, 108 Cal.App.5th at 114.)

L.W. v. Audi AG concluded: “If, as here, Audi is marketing a product through a distributor who has agreed to serve as the sales agent in the United States, including California, and the evidence shows a regular flow of that product into the state, jurisdiction is properly found.” (108 Cal.App.5th at p. 114 [holding that where defendant Audi’s expert implicitly acknowledged regular sales of its vehicles, through a distribution company, in California, and where Audi’s counsel acknowledged that the distribution company had extensive dealings with California, “including delivery of hundreds of thousands of Audi vehicles to the United States and national advertising that includes California, and that there are a large number of Audi dealerships (and at least some customers requiring product support) in California,” Audi “intentionally and purposefully engaged a national distributor (Volkswagen Group of American (“VWGoA”)) to targe and exploit the automobile market in California” for its own benefit through a “regular flow” of vehicles to the forum state, subjecting it to specific jurisdiction].)

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

22CV016235: HUDDA, et al. vs WAHED 05/28/2026 Hearing on Motion to Quash NOTICE OF MOTION AND MOTION TO QUASH SERVICE OF SUMMONS AND COMPLAINT FOR LACK OF PERSONAL JURISDICTION; filed by Adient US, LLC, sued herein as Doe 103 (Defendant) CRS# 465997951808 in Department 512 Under L.W., then, if Plaintiffs adduce evidence showing Defendants were aware that AHMC was distributing the 2015 Acura MDX (including their front passenger seats) throughout its U.S. "network," and AHMC's network included the “regular flow” or a “regular course of sales” of the 2015 Acura MDX in California, then there would be a sufficient basis under L.W. v. Audi AG to find that this Court has specific personal jurisdiction over moving Defendants in this action.

Defendants’ argument on Reply that their seating components or the seats they designed “were” not sold to consumers in California (or elsewhere)” (Reply at p. 5:18-19) does not shed any light on whether the product they designed was sold in California.

That said, Plaintiffs bear the burden to demonstrate specific jurisdiction, and here, the only evidence in the record related to any regular flow of sales in California is Plaintiffs’ purchase of the Vehicle in California one or two years after the vehicle would likely have first come on the market. This does not suffice.

Plaintiffs have not met their evidentiary urden, and Defendants here have not made the kind of implied admissions and express concessions that permitted the court of appeal, in L.G. v. Audi AG, to reasonably infer the existence of a “regular course of sales” of Audi’s product in the forum state. (See 108 Cal.App.5th at p. 114, as discussed supra.)

ORDER

Wherefore, the Court GRANTS Defendants’ Motions to Quash.

The Court OVERRULES Defendants’ Reply Objections.

Plaintiffs’ counsel are again admonished to ensure that all future courtesy copies of documents pursuant to Local Rule 3.30(c) must comply with the California Rules of Court, including those provisions specifically identified in the Court’s 5/14/2026 regarding the present motions. Unredacted courtesy copies of evidentiary submissions shall consist of a single document containing only unredacted exhibits. The Court has no need for courtesy copies of redacted documents, in addition to the confidential unredacted ones (and submitting a mix of both unduly burdens the undersigned and court staff).

Further, and particularly when citing to voluminous exhibits, Plaintiffs’ memoranda must cite to specific pages of those exhibits, so that the court can quickly locate and review the relevant portions. Further failures to comply with applicable rules of court will result in the imposition of sanctions.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

22CV016235: HUDDA, et al. vs WAHED 05/28/2026 Hearing on Motion to Quash NOTICE OF MOTION AND MOTION TO QUASH SERVICE OF SUMMONS AND COMPLAINT FOR LACK OF PERSONAL JURISDICTION; filed by Adient US, LLC, sued herein as Doe 103 (Defendant) CRS# 465997951808 in Department 512 CONTESTING TENTATIVE RULINGS

PLEASE NOTE: If any party contests the tentative ruling, the hearing on the motion will occur remotely via the court’s own video-conferencing system.

In light of the timing of posting, any party contesting shall do so by 10:00 a.m. on 5/28/2026.

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First, the party must notify Department 512, by email at Dept512@alameda.courts.ca.gov and copy all counsel of record and self-represented parties. The contesting party must state in the subject line of the email the case name, case number and motion.

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