United States Court of Appeals 

For the First Circuit 

Nos. 18-1550 

 18-1551 

STEPHEN D. KNOX; JEAN KNOX, 

Plaintiffs, Appellants, 

v. 

METALFORMING, INC., 

Defendant, Appellant, 

SCHECHTL MASCHINENBAU GMBH, 

Defendant, Appellee. 

APPEALS FROM THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF MASSACHUSETTS 

[Hon. George A. O'Toole, Jr., U.S. District Judge] 

Before 

Lynch, Stahl, and Barron, 

Circuit Judges. 

Benjamin R. Zimmermann, with whom Stacey L. Pietrowicz and 

Sugarman and Sugarman, P.C. were on brief, for Stephen and Jean 

Knox. 

Javier F. Flores, with whom Eric V. Skelly, Thaddeus M. 

Lenkiewicz, and Manning Gross & Massenburg LLP, were on brief, for 

MetalForming, Inc. 

Frederick W. Reif, with whom Marie E. Chafe, Cornell & Gollub, 

Debra Tama, and Wilson Elser Moskowitz Edelman & Dicker, LLP, were 

on brief, for Schechtl Maschinenbau GmbH. 
January 30, 2019 
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LYNCH, Circuit Judge. Stephen Knox's hand was badly 

injured at his work at Cape Cod Copper (CCC) in October 2016 when 

he operated a machine that was manufactured by defendant Schechtl 

Maschinenbau GmbH, a German company. The machine had been sold to 

CCC by defendant MetalForming, Inc., an American company located 

in Georgia and Schechtl's U.S. distributor. 

The question on appeal is whether there is personal 

jurisdiction over Schechtl, named as a defendant by Knox and as a 

cross-claim defendant by MetalForming. The district court 

dismissed the claims against Schechtl, finding that Schechtl had 

not purposefully availed itself of the privilege of doing business 

in Massachusetts. Knox v. MetalForming, Inc., 303 F. Supp. 3d 

179, 184 (D. Mass. 2018). 

We reverse. 

I. 

A. Background 

The district court did not permit jurisdictional 

discovery. Id. at 187. The following facts are undisputed. 

In October 2016, Stephen D. Knox, plaintiff here along 

with his wife, Jean, was injured while using a Schechtl MAX 310,1

a motor-driven metal-bending machine. The injury occurred at CCC, 

 1 Although some materials refer to the machine as a 

"MAX3100 FOLDER," the parties refer to it as a "MAX 310," and we 

will do the same. 
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Knox's place of employment, located in Lakeville, Massachusetts. 

When Knox inadvertently hit the foot pedal of CCC's MAX 310, the 

machine activated, crushing his left hand. 

Schechtl, the manufacturer of the MAX 310, is 

headquartered in Edling, Germany and maintains no operations in 

the United States. The company's marketing materials say that 

Schechtl manufactures the "most popular architectural sheet metal 

folders in the world." 

Schechtl sells its machines to United States customers 

through MetalForming, a separate and independently owned U.S. 

distribution company. Schechtl's distribution agreement ("the 

agreement") with MetalForming gives MetalForming the exclusive 

right to distribute Schechtl's products in the "Contract 

Territory," which comprises Canada, the United States, and Mexico. 

The agreement outlines the procedure for selling 

Schechtl's machinery. The purchasing end user ("the purchaser") 

places an order with MetalForming, which in turn acquires the 

machine from Schechtl. MetalForming then sends a purchase order, 

naming the purchaser, to Schechtl in Germany. Under the agreement, 

MetalForming must include "technical and other data" in the 

purchase order, because that information is "of importance for the 

ordered product, the supply contract, and its performance." 

Schechtl then chooses whether to accept the purchase 

order. If it does accept, it issues a written order confirmation, 
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which "govern[s] the product to be delivered, its technical 

qualities, the delivery price, the place of delivery, the time of 

delivery as well as all other relevant contractual provisions." 

Schechtl then manufactures the machine to the 

purchaser's specifications. The agreement provides that Schechtl 

"reserves the right, in the exercise of its sole discretion, to 

discontinue the manufacture or distribution of any Product without 

incurring any obligation to [MetalForming]." 

When the machine is ready, Schechtl delivers it to a 

"freight forwarder or other transport agency" in Germany, at which 

point ownership passes to MetalForming. The record does not detail 

the ordinary shipment process after that point, but, as we describe 

below, it does show how the MAX 310 that injured Knox came to CCC. 

Under the agreement, MetalForming is responsible for 

installation at the purchaser's site and for training the 

purchaser's personnel in the proper use of the machine. The 

agreement does, however, provide that it may "become necessary 

that installation work be conducted under the direction of a" 

Schechtl technician. And there is somewhat different information 

as to training contained in the information manual, as noted below. 

The agreement also requires that MetalForming "provide 

any and all warranty services for the" Schechtl products. Schechtl 

provides a one-year warranty "to the end users for all of its 

machines, machine parts, tools, spare parts, and accessories." 
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MetalForming must also, under the agreement, "pass along 

to customers information received from [Schechtl]" regarding the 

products and their proper use. This information is packaged in 

with each machine when it is delivered to the purchaser. The 

enclosed material includes a declaration that the machine had been 

"developed, designed and manufactured in compliance with" 

applicable European safety directives. It also includes 

instruction manuals and safety instructions for each machine. 

The instruction manual includes an "Instruction for 

Inquiries and Spare Part Orders," which directs purchasers to 

contact Schechtl (and not MetalForming) for inquiries and for 

additional machine parts. A later troubleshooting section of that 

manual also instructs that operators experiencing a problem 

should, "[i]f it is not possible to correct the malfunction with 

the aid of the following tables, contact the Schechtl Maschinenbau 

GmbH Service department." It does not instruct the 

operator/purchaser to contact MetalForming. The manual also 

offers that "[t]he operating company may receive extensive machine 

training by Schechtl Maschinenbau GmbH upon request . . . at 

[Schechtl's] facilities or at the operating company's facilities." 

There is no evidence as to whether any Massachusetts purchaser 

made such a request. 

The materials provided to the purchasers of Schechtl 

machines contain Schechtl's direct contact information, including 
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its phone and fax numbers and its mail and email addresses. 

Schechtl also operates a website that instructs purchasers of its 

machines to contact Schechtl directly for frequently asked 

questions, sales, parts, and other information relating to its 

machines. See Schechtl, http://www.schechtl.biz/index_e.htm (last 

visited Jan. 24, 2019). 

Schechtl has provided MetalForming with advertising 

materials to market Schechtl products in the United States. 

MetalForming has promoted Schechtl machines in national trade 

publications and at industry trade shows. There is no record 

evidence as to the Massachusetts recipients of those trade 

publications. And while the record shows that Schechtl 

representatives attended several trade shows in the United States 

with MetalForming, there is no evidence that any of those shows 

were in Massachusetts. 

Between 2000 and September 2017, MetalForming sold 2,639 

Schechtl sheet metal machines throughout the United States, at a 

value of just over $97 million. Between July 2001 and September 

2017, MetalForming sold to purchasers in Massachusetts forty-five 

Schechtl machines and 234 Schechtl parts, at a value of nearly 

$1.5 million (about $1.3 million for the machines and $176,752 for 

the parts). Schechtl's Massachusetts machine sales appear to 

constitute 1.35% of its United States machine sales. The record 

does not reveal Schechtl's total parts sales in the U.S. 
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Schechtl sold the MAX 310 which injured Knox to 

MetalForming in April 2001. MetalForming took delivery in Georgia. 

In August, four months after the initial sale, MetalForming shipped 

the machine to CCC, with CCC taking ownership of the machine in 

Georgia. The respective purchase orders show that MetalForming 

purchased the machine from Schechtl for $25,830 and sold it to CCC 

for $38,950. The purchase order from MetalForming to Schechtl 

identified the purchaser as CCC but did not give CCC's location. 

The purchase order from MetalForming to CCC shows that the machine 

came with a one-year Schechtl warranty and that the price included 

a "Schechtl Installation Charge" and a "Schechtl Freight Charge" 

to the purchaser, but no party explains what these last two terms 

mean or who receives the payment. 

B. Procedural History 

The Knoxes sued both Schechtl and MetalForming in 

Massachusetts state court. They alleged negligence, breach of 

warranty, loss of consortium, and violation of the Massachusetts 

consumer protection statute, Mass. Gen. Laws ch. 93A. MetalForming 

removed the case to Massachusetts federal district court and filed 

crossclaims against Schechtl for indemnification, contribution, 

and breach of contract. Schechtl moved to dismiss the claims 

against it for lack of personal jurisdiction. Both the Knoxes and 

MetalForming opposed Schechtl's motion.
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The district court, after finding that the terms of 

Massachusetts's long-arm statute were "easily . . . satisfied," 

Knox, 303 F. Supp. 3d at 183, nonetheless granted Schechtl's motion 

to dismiss, id. at 188. The court reasoned that, even though 

"Schechtl ha[d] derived . . . 'substantial revenue' from 

MetalForming's sales of Schechtl equipment to Massachusetts 

customers," id. at 186, Schechtl had not purposefully availed 

itself of the privilege of doing business in Massachusetts, id. at 

187. The court added that there was "[n]o Massachusetts-specific 

'plus' factor," like "'special state-related design, advertising, 

advice, marketing,' etc." Id. at 186 (quoting J. McIntyre Mach., 

Ltd. v. Nicastro, 564 U.S. 873, 889 (2011) (Breyer, J., 

concurring)). The court did not mention either the instructions 

or the warranties that Schechtl provided to the purchasers in 

Massachusetts. 

This appeal followed. 

II. 

The district court held that MetalForming had not made 

a prima facie showing of personal jurisdiction. See id. at 184. 

On prima facie review, the plaintiffs' burden is to proffer 

evidence "sufficient to support findings of all facts essential to 

personal jurisdiction" without relying on unsupported allegations. 

A Corp. v. All Am. Plumbing, Inc., 812 F.3d 54, 58 (1st Cir. 2016). 

We construe these facts "in the light most congenial to the 
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plaintiff's jurisdictional claim." Mass. Sch. of Law at Andover, 

Inc. v. Am. Bar Ass'n, 142 F.3d 26, 34 (1st Cir. 1998). "Our 

review is de novo." LP Sols. LLC v. Duchossois, 907 F.3d 95, 102 

(1st Cir. 2018). 

In a diversity jurisdiction case like this one, "a 

plaintiff must satisfy both the forum state's long-arm statute and 

the Due Process Clause of the Fourteenth Amendment." C.W. Downer 

& Co. v. Bioriginal Food & Sci. Corp., 771 F.3d 59, 65 (1st Cir. 

2014). Compliance with the terms of the Massachusetts long-arm 

statute is not contested here. Schechtl proceeds directly to the 

federal constitutional analysis; we will do so as well. 

For the exercise of personal jurisdiction to be 

constitutional, a defendant must have "certain minimum contacts 

with [the forum state] such that the maintenance of the suit does 

not offend 'traditional notions of fair play and substantial 

justice.'" Int'l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945) 

(quoting Milliken v. Meyer, 311 U.S. 457, 463 (1940)). The 

constitutional "inquiry is highly 'fact-specific.'" PREP Tours, 

Inc. v. Am. Youth Soccer Org., No. 17-1223, 2019 WL 126221, at *4 

(1st Cir. Jan. 8, 2019) (quoting United Elec., Radio & Mach. 

Workers of Am. v. 163 Pleasant St. Corp., 960 F.2d 1080, 1089 (1st 

Cir. 1992)). Importantly, the "test is 'not susceptible of 

mechanical application; rather, the facts of each case must be 
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weighed.'" Id. (quoting Kulko v. Superior Ct. of Cal., 436 U.S. 

84, 92 (1978)). 

The Knoxes and MetalForming have asserted specific 

personal jurisdiction over Schechtl, so the constitutional 

analysis here has three components: relatedness, purposeful 

availment, and reasonableness. Plixer Int'l, Inc. v. Scrutinizer 

GmbH, 905 F.3d 1, 7 (1st Cir. 2018). That is, the plaintiffs must 

show that (1) their claims directly arise out of or relate to the 

defendant's forum activities; (2) the defendant's forum contacts 

represent a purposeful availment of the privilege of conducting 

activities in that forum, thus invoking the benefits and 

protections of the forum's laws and rendering the defendant's 

involuntary presence in the forum's courts foreseeable; and 

(3) the exercise of jurisdiction is reasonable. Id. The Knoxes 

and MetalForming must meet all three requirements to establish 

personal jurisdiction. Id. We hold that they have. 

The district court reached only the issue of purposeful 

availment. But at oral argument Schechtl's counsel conceded that 

the other two requirements are met. We briefly explain below why 

we agree and address the main issue of purposeful availment. 

A. Relatedness 

To show relatedness, the Knoxes and MetalForming must 

demonstrate that their "cause of action either arises directly out 

of, or is related to, the defendant's forum-based contacts." 
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Harlow v. Children's Hosp., 432 F.3d 50, 61 (1st Cir. 2005) (citing 

163 Pleasant St., 960 F.2d at 1088-89). This "flexible, relaxed 

standard," N. Laminate Sales, Inc. v. Davis, 403 F.3d 14, 25 (1st 

Cir. 2005) (quoting Pritzker v. Yari, 42 F.3d 53, 61 (1st Cir. 

1994)), requires only that the claim have a "demonstrable nexus" 

to the defendant's forum contacts, Mass. Sch. of Law, 142 F.3d at 

34. This requirement is easily met here. 

B. Purposeful Availment 

The case turns on the purposeful availment prong. To 

meet this requirement, the Knoxes and MetalForming bear the burden 

of demonstrating that Schechtl has "purposefully avail[ed] itself 

of the privilege of conducting activities within the forum State, 

thus invoking the benefits and protections of its laws." Hanson 

v. Denckla, 357 U.S. 235, 253 (1958). 

The purposeful availment requirement ensures that the 

exercise of jurisdiction is essentially voluntary and foreseeable, 

C.W. Downer, 771 F.3d at 66, and is not premised on a defendant's 

"random, fortuitous, or attenuated contacts," Carreras v. PMG 

Collins, LLC, 660 F.3d 549, 555 (1st Cir. 2011) (quoting Burger 

King Corp. v. Rudzewicz, 471 U.S. 462, 475 (1985)). "[T]he Supreme 

Court has explained that 'the foreseeability that is critical to 

due process analysis . . . is that the defendant's conduct and 

connection with the forum State are such that he should reasonably 

anticipate being haled into court there.'" PREP Tours, 2019 WL 
- 13 - 

126221, at *6 (quoting Burger King, 471 U.S. at 474). This 

requirement applies equally to foreign defendants. Plixer, 905 

F.3d at 7. 

Each side asserts that the Supreme Court's decision in 

J. McIntyre Machinery, Limited v. Nicastro supports its view. Like 

other circuits, we have held that the narrowest, and thus binding, 

opinion from the "fragmented Court" in that case was Justice 

Breyer's. Plixer, 905 F.3d at 10 (quoting Marks v. United States, 

430 U.S. 188, 193 (1977)); accord Williams v. Romarm, SA, 756 F.3d 

777, 784 (D.C. Cir. 2014) (finding Justice Breyer's concurring 

opinion controlling under Marks); Ainsworth v. Moffett Eng'g, 

Ltd., 716 F.3d 174, 178 & n.14 (5th Cir. 2013) (same); AFTG-TG, 

LLC v. Nuvoton Tech. Corp., 689 F.3d 1358, 1363 (Fed. Cir. 2012) 

(same). In the end we do not think that this case, on the facts 

here, fails the personal jurisdiction tests articulated by either 

Justice Breyer's concurring opinion or the plurality opinion in 

Nicastro. 

The district court found that Schechtl had not 

designated Massachusetts "for special attention" and had not 

"target[ed] buyers within" Massachusetts. Knox, 303 F. Supp. 3d 

at 186. Using those tests, the district court held that Schechtl 

had not purposefully availed itself of the privilege of conducting 
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business in the Commonwealth. Id.2 Those, as our Plixer decision 

later made explicit, are not the exclusive tests to establish 

purposeful availment. 

In Plixer we concluded that "Supreme Court precedent 

does not establish specific targeting of a forum as the only means 

of showing that the purposeful availment test has been met." 905 

F.3d at 9 (emphasis added). Depending on the facts, a defendant's 

"'regular flow or regular course of sale' in the [forum]" could 

make the exercise of jurisdiction foreseeable to the defendant. 

Id. at 10. And, again depending on the facts, jurisdiction could 

be foreseeable based on "something more" than this, evidencing an 

intent to serve the forum. Id. (citing Asahi Metal Indus. Co., 

Ltd. v. Superior Court of Cal., 480 U.S. 102, 111-12 (1987) 

(opinion of O'Connor, J.)). Justice O'Connor's plurality opinion 

in Asahi, endorsed by the plurality opinion in Nicastro, see 564 

U.S. at 885 (plurality opinion), says that "something more" may 

include, "for example, designing the product for the market in the 

forum State, advertising in the forum State, establishing channels 

for providing regular advice to customers in the forum State, or 

marketing the product through a distributor who has agreed to serve 

 2 To be clear, there is no argument that a producer like 

Schechtl is subject to jurisdiction solely because it knows that 

its products might be sold in Massachusetts. See Nicastro, 564 

U.S. at 891 (Breyer, J., concurring) (rejecting such a standard). 
- 15 - 

as the sales agent in the forum State." Asahi, 480 U.S. at 112 

(opinion of O'Connor, J.). 

Specific jurisdiction must rest on a defendant's 

voluntary contact with the forum and not on "the 'unilateral 

activity of another party or a third person.'" Burger King, 471 

U.S. at 475 (quoting Helicopteros Nacionales de Colombia, S.A. v. 

Hall, 466 U.S. 408, 417 (1984)). The argument for jurisdiction 

here does not rest on MetalForming's Massachusetts activities. It 

rests instead on the totality of Schechtl's activities, 

voluntarily undertaken, that connect the German company to 

Massachusetts. 

These voluntary acts on Schechtl's part led to a "regular 

flow or regular course of sales," and more than that, in the 

Commonwealth. Over sixteen years, Schechtl, through MetalForming, 

sold forty-five machines (an average of close to three machines in 

each of those sixteen years). It also provided 234 parts to 

purchasers in Massachusetts. Those parts and machines led to 

nearly $1.5 million of Massachusetts sales for Schechtl. 

We compare this case to Plixer, in which we upheld the 

exercise of jurisdiction over a defendant who, over three-and-ahalf years, served 156 forum customers, generating about $200,000 

in business. See 905 F.3d at 4-5; see also id. at 11 (describing 

post-Nicastro rulings upholding the exercise of jurisdiction based 

on "a regular course of sales"). And we compare Schechtl to the 
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defendant in Nicastro, who Justice Breyer described as having made 

"a single isolated sale" into the forum. 564 U.S. at 888 (Breyer, 

J., concurring). Schechtl certainly does not fall into the 

category of manufacturer, "small" in "shape[] and size[]," 

described by Justice Breyer in Nicastro. Id. at 892 (Breyer, J., 

concurring). 

Schechtl argues that we should discount its 

Massachusetts sales because those sales were part of a nationwide 

sales effort. But the question is not whether a defendant sells 

its product across the U.S.; it is instead whether a defendant's 

forum connection is such "that the exercise of jurisdiction is 

essentially voluntary and foreseeable." Plixer, 905 F.3d at 7 

(citing C.W. Downer, 771 F.3d at 66); see Ainsworth, 716 F.3d at 

179 (upholding the exercise of jurisdiction based on substantial 

in-forum sales, even though the defendant's forum sales 

represented only 1.55% of its nationwide sales during the relevant 

period). And we note that the use of a nationwide distributor 

does not automatically preclude the exercise of jurisdiction. See 

Ainsworth, 716 F.3d at 179 (upholding the exercise of jurisdiction 

over a manufacturer even though the manufacturer employed a 

nationwide distributor). 

To be clear, we do not hold that the mere volume of 

Schechtl's sales in Massachusetts over sixteen years standing 
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alone would suffice (a hypothetical situation we need not address). 

There is more here. 

Schechtl individually approved and manufactured 

according to purchaser-provided specifications each of the nearly 

fifty machines it sent to Massachusetts purchasers. See In re 

Chinese-Manufactured Drywall Prods. Liab. Litig., 742 F.3d 576, 

589 (5th Cir. 2014) (upholding the exercise of personal 

jurisdiction based in part on the defendant's fulfilling product 

orders on a "made-to-order basis"); cf. Asahi, 480 U.S. at 112 

(opinion of O'Connor, J.) (adding that "designing the product for 

the market in the forum State" may be "additional conduct" 

necessary to make the exercise of jurisdiction constitutional). 

Schechtl's relationship with purchasers in Massachusetts 

did not end when Schechtl accepted the purchase order and 

manufactured the machine. Schechtl required that MetalForming 

include, with each machine, materials that instructed that 

purchaser to contact Schechtl directly, whether to purchase 

replacement parts or to obtain assistance with troubleshooting and 

fixing problems. From the fact that hundreds of Schechtl parts 

were delivered to Massachusetts, the inference is entirely 

plausible that Massachusetts purchasers did use the channels 

Schechtl established both as to spare parts and as to 

troubleshooting. 
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Schechtl's channels to Massachusetts purchasers 

constitute efforts to continue -- and perhaps to expand -- its 

relationship with Massachusetts purchasers. Those deliberately 

opened channels, kept open over many years and presumably used, 

are relevant to the jurisdictional analysis. See Asahi, 480 U.S. 

at 112 (opinion of O'Connor, J.) (noting that "establishing 

channels for providing regular advice to customers in the forum 

State" may be "something more" in support of jurisdiction). Those 

channels established a direct link between Schechtl and its 

purchasers. Here that means that Schechtl voluntarily opened at 

least forty-five such direct links with Massachusetts purchasers. 

Schechtl's long service of purchasers in Massachusetts through at 

least its spare parts sales bolsters our conclusion that the 

exercise of jurisdiction here is foreseeable.3

Purposeful availment analysis "'will vary with the 

quality and the nature of the defendant's activity.'" PREP Tours, 

2019 WL 126221, at *6 (quoting Burger King, 471 U.S. at 474-75). 

This case involves a manufacturer which can direct where its 

products go, which sold dozens of expensive products into the forum 

 3 Schechtl argues that it did not know that CCC was located 

in Massachusetts. Even if that contention were correct, we would 

not consider it dispositive given all the other facts here. We do 

not comment on MetalForming's argument that Schechtl should have 

known CCC's location. 

We also do not rest on, or even reach, the argument that 

Schechtl made no effort to exclude Massachusetts purchasers from 

its American market. Cf. Ainsworth, 716 F.3d at 179. 
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over nearly two decades, and which initiated an ongoing 

relationship with its in-forum purchasers. Nicastro, by contrast, 

involved a manufacturer which lacked any similar ability to control 

the end location of its products, see 564 U.S. at 878 (plurality 

opinion) (noting that there was "no allegation that the distributor 

was under [the defendant's] control"), and which had no other 

relationship with the forum, see id. at 886. The defendant there 

knew only "that its products are distributed through a nationwide 

distribution system that might lead to those products being sold 

in any of the fifty states." Id. at 879 (internal quotation marks 

omitted). None of the opinions from Nicastro require that we 

accept Schechtl's arguments on appeal. 

Schechtl's only remaining argument is that MetalForming 

takes title to the Schechtl products in Germany. First Circuit 

law has long found this argument irrelevant to the jurisdictional 

analysis. See Benitez-Allende v. Alcan Aluminio do Brasil, S.A., 

857 F.2d 26, 30 (1st Cir. 1988) (Breyer, J.) ("The fact that title 

to the [products] passed in [a foreign country] is beside the 

point, for '[i]f International Shoe stands for anything, however, 

it is that a truly interstate business may not shield itself from 

suit by a careful but formalistic structuring of its business 

dealings.'" (quoting Vencedor Mfg. Co., Inc. v. Gougler Indus., 

Inc., 557 F.2d 886, 891 (1st Cir. 1977))). The same is true for 

an international business. 
- 20 - 

C. Reasonableness 

We explain briefly why we consider the exercise of 

jurisdiction to be reasonable under the five "gestalt" factors: 

(1) the defendant's burden of appearing [in 

the forum], (2) the forum state's interest in 

adjudicating the dispute, (3) the plaintiff's 

interest in obtaining convenient and effective 

relief, (4) the judicial system's interest in 

obtaining the most effective resolution of the 

controversy, and (5) the common interests of 

all sovereigns in promoting substantive social 

policies. 

Ticketmaster-N.Y., Inc. v. Alioto, 26 F.3d 201, 209 (1st Cir. 1994) 

(citing Burger King, 471 U.S. at 477). Schechtl in its briefs, 

but not at oral argument, argues that Massachusetts litigation 

would be burdensome because it is a German company with German 

employees, and that cross-Atlantic travel and communications would 

impose burdens on its employees. That there is some burden on 

Schechtl (which can be mitigated) is not enough on the facts here 

to make the exercise of jurisdiction unreasonable. See Plixer, 

905 F.3d at 13 (noting that "'[w]hen minimum contacts have been 

established, often the interests of the plaintiff and the forum in 

the exercise of jurisdiction will justify even the serious burdens 

placed on the alien defendant'" (quoting Asahi, 480 U.S. at 114 

(opinion of O'Connor, J.)); see also C.W. Downer, 771 F.3d at 70 

(noting that many of the case's logistical challenges "can be 

resolved through the use of affidavits and video devices"). 
- 21 - 

III. 

We conclude that the exercise of personal jurisdiction 

over Schechtl comports with due process. We reverse and remand 

for further proceedings consistent with this opinion.