Outside of the federal circuits that have expressly adopted the closely related
doctrine, district courts in the following federal districts have also applied the doctrine in
reported opinions. Deese-Laurent v. Real Liquidity, Inc., ___ F. Supp. 3d ___, ___, No.
CV 17-10867-RWZ, 2018 WL 1610540, at *5 (D. Mass. Mar. 30, 2018); Sagittarius
Sporting Goods Co., Ltd v. LG Sourcing, Inc., 162 F. Supp. 3d 531, 538 (D.S.C. 2016);
Sabre Int’l Sec. v. Torres Advanced Enter. Sols., 60 F. Supp. 3d 21, 33-34 (D.D.C. 2014);
Harland Clarke Holdings Corp. v. Milken, 997 F. Supp. 2d 561, 585 (W.D. Tex. 2014);
Medtronic, Inc. v. Endologiz, Inc., 530 F. Supp. 2d 1054, 1056 (D. Minn. 2008); D.I.P.R.
Mfg., Inc. v. Perry Ellis Int'l, Inc., 472 F. Supp. 2d 151, 154 (D.P.R. 2007); Allianz Ins. Co.
of Can. v. Cho Yang Shipping Co., 131 F. Supp. 2d 787, 791 (E.D. Va. 2000). But cf.
Presbyterian Healthcare Servs. v. Goldman, Sachs & Co., 122 F. Supp. 3d 1157, 1212
(D.N.M. 2015) (declining, on the facts of the case, to apply the closely related doctrine to
bind a state-created instrumentality by a forum-selection clause in a contract it did not
sign); Quicksilver Res., Inc. v. Eagle Drilling, LLC, 792 F. Supp. 2d 948, 954 (S.D. Tex.
2011) (holding that the closely related cases were inapposite based on the facts of the case
at issue); Trans. All. Bank, Inc. v. Arrow Trucking Co., 766 F. Supp. 2d 1188, 1198 (N.D.
Okla. 2011) (same); Millennium Petrochemicals, Inc. v. C.G. Jago, 50 F. Supp. 2d 654,
658 (W.D. Ky. 1999) (same). Cf. Dos Santos v. Bell Helicopter Textron, Inc. Dist., 651 F.
Supp. 2d 550, 556-57 (N.D. Tex. 2009) (rejecting the closely related test to apply a “more
strict” third-party beneficiary doctrine but ultimately holding that the non-signatory
defendant consented to jurisdiction because he was the agreement’s intended beneficiary).
In state courts, California, Illinois, Minnesota, New York, Ohio, and West Virginia
have adopted the closely related doctrine. Lu v. Dryclean-U.S.A. of Cal., Inc., 11 Cal. App.
4th 1490, 1494 (1992) (enforcing a forum-selection clause against a closely related non-
signatory because “[t]o hold otherwise would be to permit a plaintiff to sidestep a valid
forum selection clause simply by naming a closely related party who did not sign the clause
a defendant”); Solargenix Energy, LLC v. Acciona, S.A., 17 N.E.3d 171, 185-86 (Ill. App.
Ct. 2014) (“A nonsignatory impliedly consents to the forum selection clause via its
connections with [the] dispute, the parties, and the contract or contracts at issue.”); C.H.
Robinson Worldwide, Inc. v. FLS Transp., Inc., 772 N.W.2d 528, 536 (Minn. Ct. App.
2009) (applying the closely related doctrine to find personal jurisdiction over non-
signatories that “[we]re ‘closely related to the dispute such that it becomes foreseeable’
that they would be bound by the clauses” (citation omitted)); Univ. Inv. Adv. SA v. Bakrie
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