Rashid Kambarov sued Quality Counts, Inc. under the Fair Credit Reporting Act after the company completed an employment report about him, sold it to Elwood Staffing, and — according to the complaint — published inaccurate information about him. The report addressed whether an Oregon state court had validly convicted Kambarov of a felony, and it allegedly undermined his eligibility for employment at an Oregon branch office of Elwood Staffing. The District of Oregon dismissed the case for lack of personal jurisdiction. The Ninth Circuit, in a memorandum disposition filed April 17, 2026, vacated that dismissal.
The panel walked through all three prongs of the Calder effects test. On the first prong — intentional act — the court held that Quality Counts's completion of the report, its sale to Elwood Staffing, and its publication of the allegedly inaccurate information satisfied the requirement of an intent to perform an actual, physical act in the real world.
On the second prong — express aiming — the panel held that Quality Counts directed the report at Oregon because the report's contents concerned an Oregon resident's Oregon state-court conviction, the report was drawn from Oregon court records, it was requested by and made accessible to an Oregon branch office of Elwood Staffing through Quality Counts's own portal, and the only harm Kambarov allegedly suffered — loss of employment and related emotional harm — occurred in Oregon. The panel rejected the district court's conclusion that the report was directed toward Indiana, where Elwood Staffing is headquartered, noting that the Oregon office had direct portal access to the report.
On the third prong — foreseeable harm in the forum — the panel found that the record showed Quality Counts knew Kambarov lived in Oregon and had applied for a job in Oregon, and therefore knew or should have known that publishing a false report would cause him reputational harm there.
Because the district court had not addressed the second and third factors of the broader specific-jurisdiction test drawn from Briskin v. Shopify, Inc., the panel vacated the dismissal and remanded for the district court to complete the jurisdictional analysis. Costs were taxed against the appellee.
The disposition is unpublished and is not precedent except as provided by Ninth Circuit Rule 36-3.