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Sukumar v. Health Tech Resources
Ponani Sukumar and his physical rehabilitation clinic, Southern California Stroke Rehabilitation Associates (together Sukumar), appeal orders dismissing Panatta Sport SRL (Panatta) and Air Machine Com SRL (COM) from the action for lack of personal jurisdiction. Sukumar contends the trial court erred when it granted the separate motions to quash of Panatta and COM after ruling neither was subject to jurisdiction in California under a successor liability theory, based on the minimum contacts of their alleged predecessor defendant Air Machine SRL (SRL). Sukumar also maintains both Panatta and COM are subject to specific jurisdiction in California based on each party's own activities/contacts (as opposed to those of SRL) in the forum.
Because we affirm an order granting SRL's motion to quash service for lack of jurisdiction in a separate opinion,[1] we conclude here that Sukumar failed to satisfy his burden to establish jurisdiction over Panatta and COM as successors of SRL. In addition, we also determine Sukumar did not carry his burden to prove either Panatta or COM is subject to specific jurisdiction based on each party's contacts with California. Therefore, we affirm the orders.

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