Charles Gendler & Co., Inc. Plaintiff-Respondent v. Telecom Equipment Corporation, Defendant, and Nippon Electric…

Summary

The Supreme Court of New Jersey reversed the Appellate Division and remanded for further fact‑finding, holding that the record does not show that Nippon Electric Co. knowingly participated in a distribution system targeting New Jersey, and therefore personal jurisdiction under the stream‑of‑commerce theory was not established. The Court adopted the stream‑of‑commerce approach for foreign manufacturers but required proof of the manufacturer’s awareness of the forum market.