Goldberg Segalla’s Alex P. Blair authored a column for Illinois Defense Quarterly that examines a decision by the United States Court of Appeals for the Seventh Circuit in a complex product liability case.

Alex, a partner in the firm’s Chicago office, represents a variety of manufacturers in complex product liability and toxic tort matters. He also serves as the Product Liability columnist for Illinois Defense Quarterly.

The column, “Seventh Circuit Affirms Indiana District Court’s Dismissal of Foreign Corporation for Lack of Personal Jurisdiction Where Plaintiff’s Injuries Did Not Relate to Defendant’s In-Forum Contacts,” analyzes the Seventh Circuit’s July 2025 decision in B.D. v. Samsung SDI Co., affirming the dismissal of a foreign battery manufacturer for lack of personal jurisdiction.

The case involved a minor who was severely burned when a Samsung lithium‑ion battery, purchased individually and through an unauthorized retail transaction, exploded in his pocket. Although Samsung’s batteries reach Indiana consumers when incorporated into battery packs within finished products, the company intentionally prevents the sale of individual, unpackaged batteries to ordinary consumers, requiring corporate purchasers to apply, disclose intended uses, and avoid e‑cigarette applications.

Alex then explains the Seventh Circuit’s three‑pronged specific jurisdiction test, acknowledging that Samsung had purposefully availed itself of Indiana under the end‑product stream of commerce (batteries incorporated into consumer goods). However, the court found a disconnect between those deliberate contacts and the plaintiff’s claim, which arose from the derivative‑product stream – the sale of a loose battery through unilateral actions of third parties. Because the injury did not “arise out of or relate to” Samsung’s purposeful forum contacts, specific jurisdiction was improper.

READ THE FULL ARTICLE HERE

MORE ABOUT GOLDBERG SEGALLA’S Alex P. Blair:

Alex is an experienced defense attorney who represents manufacturers of a variety of products and owners of food, beverage, and refining facilities in complex product liability and toxic tort matters. In addition to defending clients in Illinois, Indiana, and Texas, Alex has handled depositions on behalf of clients in Pennsylvania, New Jersey, and New York and analyzed relevant statutes and case law in defense of lawsuits filed in jurisdictions across the country.

Alex has managed cases as local counsel from initial filing through final disposition and collaborated with national coordinating counsel to formulate strategy and report litigation developments. Before joining Goldberg Segalla, his practice included litigating premises liability, commercial, real estate, employment and labor, construction, professional liability, and insurance coverage disputes.