Chancery: UCC Filing Serves as Partial Basis to Impose Personal Jurisdiction

Lake Treasure Holdings, LLC v. Foundry Hill GP, LLC, C.A. No. 6546-VCL (Del. Ch. Nov. 21, 2013)

This Chancery decision determined that the filing of a UCC statement may serve to satisfy two elements of the 5-part test to establish personal jurisdiction in Delaware based on the well-settled “conspiracy basis of personal jurisdiction”, and in light of Section 3104 which refers to a specific act related to imposing jurisdiction as compared to a “general basis”.