Wurth Additive Group Inc V Paradigm Manufacturing

Key Facts

Transaction Type

Issues

• Whether the District Court has personal jurisdiction over Defendant Paradigm Manufacturing, considering the forum selection clauses in the Equipment Lease Agreements and the requirement for consent to jurisdiction
• Whether the District Court has subject matter jurisdiction based on diversity of citizenship between parties and the amount in controversy exceeding $75,000
• Whether Plaintiff's motion for default judgment against Defendant Paradigm Manufacturing should be granted given the lack of personal jurisdiction over the defendant

Holdings

Remedies

Legal Principles

• District courts have original jurisdiction over all civil actions in which the amount in controversy exceeds $75,000, exclusive of interest and costs, and that are between citizens of different States. A corporation is deemed a citizen of every State where it is incorporated and of the State of its principal place of business. A limited liability company maintains the citizenship of each of its members.
• Absent a forum selection clause that binds Paradigm, it is unclear how that entity might be subject to personal jurisdiction in New Jersey. The Court requires additional information from Würth and will file a letter advising how it intends to move forward in the action by making appropriate filings establishing an alternative basis for personal jurisdiction or by seeking transfer to the United States District Court for the District of Arizona.
• In default judgment proceedings, the Court takes the factual allegations of the complaint as true, except those relating to the amount of damages. The Court may conduct a hearing to determine damages, but a damages determination may be made without a hearing as long as there is a basis for the damages specified in the default judgment.
• Parties to a contract are free to consent in advance to personal jurisdiction in a foreign court through the use of consent-to-jurisdiction clauses, also known as forum-selection clauses. A forum selection clause may act as consent to personal jurisdiction, thus obviating the need for a personal jurisdiction analysis. The Court must enforce the provision as written, interpreting a forum selection clause in accordance with its plain meaning.

Precedent Name

• Harfouche v. Wehbe
• Days Inns Worldwide, Inc. v. Panchal
• Fischer v. Fed. Express Corp.
• Nationwide Mut. Ins. Co. v. Starlight Ballroom Dance Club, Inc.
• DIRECTV, Inc. v. Pepe
• M/S Bremen v. Zapata Off–Shore Co.
• In re McGraw-Hill Glob. Educ. Holdings LLC
• Danka Funding, L.L.C. v. Page, Scrantom, Sprouse, Tucker & Ford, P.C.
• Barrett v. Tri-Coast Pharmacy, Inc.
• Teamsters Health & Welfare Fund of Phila. & Vicinity v. Dubin Paper Co.
• Hritz v. Woma Corp.
• Prudential Ins. Co. of Am. v. Bramlett
• Comdyne I, Inc. v. Corbin
• Lampe v. Youth, Inc.

Key Disputed Contract Clauses

Cited Statute

• Federal Rule of Civil Procedure 55(b)(2)
• 28 U.S.C. § 1332(c) - Corporate Citizenship
• Federal Rule of Civil Procedure 78(b)
• 28 U.S.C. § 1332(a) - Diversity Jurisdiction

Judge Name

Passage Text

• The Court must enforce the provision as written. In re McGraw-Hill Glob. Educ. Holdings LLC, 909 F.3d 48, 67 (3d Cir. 2018) ("We interpret a forum selection clause in accordance with its plain meaning"). Thus, though the record reflects that Würth has consented to personal jurisdiction in this District, nothing suggests that Paradigm has done so.
• 2 As Würth has not identified any basis for personal jurisdiction over Paradigm outside of the Equipment Lease Agreements' respective forum selection clauses, it has not established its entitlement to default judgment. The Court need not, therefore, conduct the balance of the default judgment analysis (i.e., evaluating the sufficiency of service under the Federal Rules of Civil Procedure, examining whether Würth has established a sufficient cause of action, analyzing the propriety of a final judgment by default, and determining the proper measure of damages).
• Based on the foregoing, it is on this 30th day of December, 2025, ORDERED that Würth's motion for default judgment, (D.E. No. 13), is DENIED without prejudice; and it is further ORDERED that, on or before January 16, 2026, Würth shall file a letter advising how it intends to proceed in this action.

Damages / Relief Type