The Supreme Court’s landmark 2014 decision in Daimler AG v. Bauman was a major victory for business organizations. No longer could they be haled into court in any state, regardless of the events alleged in the case, simply because they had continuous and systematic contacts in a state. The Court’s reframing of general personal jurisdiction has had positive aftershocks for businesses too, as they have begun persuading courts to rein in expansive and burdensome jurisdictional discovery in line with Bauman’s teaching. Yet, while Bauman provides helpful tools for companies resisting forum-shopping plaintiffs, state registration requirements for out-of-state businesses remain an obstacle and source of unpredictability.

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