In Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017) (“BMS”), the United States Supreme Court concluded that specific jurisdiction must be premised on a defendant’s in-state conduct giving rise to a plaintiff’s alleged injury. The Court explained that plaintiffs therefore could not pursue their claims in a state in which they did not reside or in which they were not injured if a defendant conducted no activity in that state connected to the injury. That other in-state plaintiffs may be advancing similar claims as part of a coordinated proceeding did nothing to change this analysis.

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