Red Oak Apartment Homes, LLC v. Strategis Floor & Décor, Inc. & a.

Summary

The Supreme Court of New Hampshire affirmed the trial court’s dismissal of Red Oak Apartment Homes’ claims against Strategis Floor & Décor for lack of specific personal jurisdiction. The Court held that Strategis’ contacts with New Hampshire did not satisfy the purposeful availment prong of the stream‑of‑commerce‑plus test, because the defendant neither designed its product for the New Hampshire market nor engaged in targeted advertising or other voluntary conduct directed at the forum state.