Case Explained: SHENZHEN ZEHUIJIN INVESTMENT CENTER V. YINGKUI, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-08-03 Docket: 3:24-cv-00372- The ninth-circuit affirmed the district court’s judgment confirming a foreign arbitral award against Liu Yingkui, holding that the district court had general personal jurisdiction over him because he was physically present in California. The panel ruled that the Due Process Clause of the Fourteenth Amendment does not require service of process directly on the defendant’s person to establish presence-based personal jurisdiction; rather, jurisdiction is satisfied when a voluntarily present defendant receives notice through alternative means reasonably calculated to provide actual notice. The court rejected Yingkui’s Federal Rule of Civil Procedure 12(b)(2) defense of lack of personal jurisdiction under this standard. Additionally, the panel held that Yingkui waived his separate argument challenging the sufficiency of service of process under Rule 12(b)(5) because he failed to raise it in his motion to dismiss. Consequently, the confirmation of the arbitral award stands. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.