The Oregon courts have personal jurisdiction over parties in any action arising under the Oregon Securities Law against an applicant for registration or a registrant, and any person who offers or sells a security in Oregon, unless the security or the sale is exempt from ORS 59.055. Under this rule, the Oregon courts also have personal jurisdiction over any person, whether or not a resident of Oregon, who has engaged in conduct prohibited or made actionable under the Oregon Securities Law.
Minimum contacts with Oregon are, however, still required. In the absence of evidence of purposeful availment, the signing of an exchange agreement was insufficient for personal jurisdiction in Mann v. St. Laurent, 2002 WL 31972161, *3 (D.Or. 2002) (unreported). Similarly, attorneys who had a three month e-mail correspondence with the plaintiffs’ representative in Oregon were not subject to personal jurisdiction after the court’s review of the content of those e-mails showed that the correspondence was about administrative issues such as mailing addresses and fax numbers for the purchasers, acknowledgments of information received, and brief status reports answering plaintiffs’ inquiries. “This can hardly be said to alert a reasonable person to the possibility of being haled into court in Oregon.” Mann v. St. Laurent, 229 FSupp2d 1133, 1137 (D.Or. 2002).