AMA v. Wanat

AMA Multimedia, a long-established producer of high-quality adult entertainment, filed suit against Marcin Wanat, an individual residing in Poland operating the ePorner website, which unlawfully displayed the content of numerous adult entertainment producers, including AMA. Wanat filed a motion to dismiss, contending that, as a non-resident of the U.S., he was not subject to personal jurisdiction in any U.S. court. The District Court agreed with Wanat, and AMA appealed its decision to the U.S. Court of Appeals for the Ninth Circuit.

In 2019, the Ninth Circuit also agreed with Wanat in a published opinion, holding that Wanat never expressly aimed his conduct at the United States, allowing him to continue infringing the intellectual property of American content producers and leaving those content producers with no recourse in American courts. Judge Gould of the Ninth Circuit issued a strongly-worded dissent in favor of AMA’s position. AMA asked the Supreme Court to grant certiorari, but the Supreme Court declined.

Several years later, AMA and Randazza Legal Group were vindicated. In Briskin v. Shopify, Inc., issued on April 21, 2025, the Ninth Circuit expressly overruled its decision in AMA v. Wanat. The court stated that the reasoning it employed in AMA v. Wanat, requiring a “forum-specific focus” or “differential targeting,” was incorrect and adopted the position that AMA and Randazza Legal Group argued for six years earlier.