Oregon Court Finds Personal Jurisdiction Over Georgia Canine Semen Bank Using 'Effects Test'

U.S. District Judge Adrienne Nelson denied a motion to dismiss for lack of personal jurisdiction in a trademark infringement suit, holding that Savants Canine Services LLC purposefully directed activities toward Oregon by conflating its identity with the Oregon-based plaintiff, International Animal Semen Bank (ICSB).

ICSB sued Kathryn Roberts, Atlanta Canine Reproduction LLC, and Savants Canine Services LLC. Savants, a Georgia company created in June 2025 at Roberts’s direction, moved to dismiss the trademark and unfair competition claims against it.

The dispute stems from a licensing relationship. Roberts previously operated a licensed ICSB center in Georgia under the name ICSB–Atlanta. After ICSB terminated the license in June 2025, Roberts and her husband, John Heltzel, created Savants.

Savants argued it had no contacts with Oregon. It does not maintain an office, bank account, or property in the state, and it has not attended dog shows in Oregon.

Judge Nelson rejected that argument, focusing on Savants’ website. The site is moderately interactive, allowing users to log in, submit stud request forms, and purchase products.

More critically, the judge found the website expressly aimed at Oregon by blurring the line between Savants and ICSB. The Terms of Use state that “ICSB guarantees live semen only,” and an “About Us” section claims Roberts started the business in 2010, ignoring Savants’ 2025 founding date.

The website also references “our long-term commitment to our clients and their studs’ semen stored at ICSB Oregon Main Office.”

“Boasting of a long-term commitment to clients’ products stored in Oregon is a purposeful, direct targeting towards Oregon,” Nelson wrote.

The judge applied the “effects test” from Calder v. Jones, finding that Savants committed an intentional act by creating the website, expressly aimed it at Oregon by using the trademark of a known Oregon resident, and caused harm likely to be suffered state.

Nelson also found the exercise of jurisdiction reasonable. She noted that litigation against Roberts and Atlanta Canine will continue in Oregon, making it the most efficient forum.

“Litigation will continue in this Court against Roberts and Atlanta Canine, regardless of the outcome of this motion, and it is not unreasonable for Savants to defend itself forum given its close ties with the other defendants,” Nelson wrote.

Savants’ motion is denied.