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You are likely familiar with the children’s game, Connect 4, in which players drop red and black checker pieces into an upright rack trying to get four of their pieces in a row to win. Some of you may have even seen enlarged outdoor versions of the Connect 4 game at various venues. On August 24, 2022, the Ninth Circuit

In Lang Van, Inc. v. VNG Corporation (decided July 21, 2022), the Ninth Circuit addressed the issue of how to evaluate whether a U.S. District Court can exercise personal jurisdiction over a foreign defendant with regard to a copyright infringement suit. Lang Van is a California corporation that produces and distributes Vietnamese music and entertainment, owning the copyrights to thousands