Billion Law is pleased to report a favorable outcome for our client, Lucy Caldwell, in a federal trademark lawsuit filed in the United States District Court for the District of Delaware. On January 7, 2026, United States District Judge Gregory B. Williams granted Ms. Caldwell's Motion to Dismiss, concluding that the Court lacked personal jurisdiction over her.

Background

The case arose from allegations by No Labels — a Washington, D.C.-based nonprofit organization — that a group of defendants collectively operated a copycat website at the domain nolabels.com, which was allegedly designed to imitate No Labels' legitimate website at nolabels.org. No Labels claimed that the infringing website contained content intentionally crafted to portray the organization in a false and damaging light. The lawsuit asserted numerous claims, including trademark infringement, cybersquatting, trademark dilution, and civil conspiracy, among others.

Ms. Caldwell was named as one of several individual defendants alleged to have participated in the creation and operation of the infringing website. Billion Law's Mark M. Billion and Peter K. Schaeffer represented Ms. Caldwell throughout the proceedings.

The Legal Issue: Personal Jurisdiction

The central issue with respect to Ms. Caldwell was whether the Federal District Court in Delaware had personal jurisdiction over her. Plaintiff argued that Ms. Caldwell was subject to jurisdiction in Delaware because she had allegedly served as an agent of NoLabels.com Inc. — a Delaware corporation — and had provided services directed toward Delaware in connection with the infringing website.

Billion Law argued successfully that Plaintiff's allegations fell short of the legal standard required to establish personal jurisdiction. Specifically, the Court found that No Labels failed to allege that Ms. Caldwell's relevant activities actually took place in Delaware, as required under Delaware's long-arm statute. The Court further rejected Plaintiff's conspiracy theory of jurisdiction, finding that No Labels had not sufficiently alleged that any substantial act in furtherance of the purported conspiracy actually occurred within the State of Delaware.

The Outcome

The Court granted Ms. Caldwell's Motion to Dismiss in its entirety, finding that Plaintiff had failed to make even a prima facie case of personal jurisdiction. Ms. Caldwell was dismissed from the federal action as a result.

What This Case Illustrates

This outcome underscores the importance of rigorously challenging the threshold question of personal jurisdiction at the outset of litigation. Courts cannot exercise authority over individuals simply because a co-defendant may have connections to a forum state — plaintiffs must allege specific acts by each defendant that are tied to the jurisdiction in question. Billion Law's early and effective motion practice on this issue resulted in our client's complete dismissal from a complex, multi-defendant federal lawsuit.

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