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Unformatted text preview: a Florida venue selection clause, the defendant has given
implied consent to personal jurisdiction in the forum State and has, in essence, conceded
 As stated above, Hatfield appears to have been engaged in continuous and
systematic general business contact with Florida, and the underlying contract contains a 243 clause selecting Florida as the forum to resolve any action arising out of the relationship
between Hatfield and AutoNation. Thus, Hatfield's conduct and connection with Florida
are such that he should reasonably have anticipated being haled into court in Florida for
The factors present here appear very similar to two cases in which other courts have
found that an out-of-state agent had minimum contacts with Florida sufficient to support
personal jurisdiction. In Nordmark Presentations, Inc. v. Harman, 557 So.2d 649 (Fla. 2d
DCA 1990), an events promotion company known as Events International hired Harman
to arrange events throughout the United States. The parties' contract provided that, if the
contract terminated, Harman, for three years, would not conduct any promotions in
metropolitan areas where he previously had conducted promotions for Events. At the
time of his hire, Harman resided in Iowa. After Harman completed a training seminar in
Ohio, Events assigned Harman briefly to Alabama, and then to Michigan, where he
resided and performed his duties for three years before he terminated the contract.
According to the unrefuted allegations of the complaint, Events' Sarasota office provided
Harman with proprietary information, trade secrets, managerial training and assistance,
and regularly directed and supervised Harman's day-to-day activities. In addition, Events
assisted Harman in carrying out his assigned duties, in solving problems, and in
providing technical and practical assistance and support. While working for Events,
Harman attended three business meetings in Florida, each of which lasted no more than
one-and-a-half days. H...
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This note was uploaded on 09/30/2012 for the course ENC 102 taught by Professor Deria during the Spring '08 term at FIU.
- Spring '08