In a recent legal malpractice case, the plaintiff sought services from the VA in Los Angeles. During those services, a VA social worker initiated a sexual relationship with her, which VA officials later deemed “profound patient abuse.” She filed an administrative claim under the Federal Tort Claims Act (FTCA) and the VA assigned a VA attorney in Arizona to handle the claim. Plaintiff found the Virginia law firm through its passive informational website, and retained firm to represent her in a potential claim for damages under the FTCA. Law firm was based in Virginia and, according to its website, had a nationwide practice involving FTCA claims. Lawyers at the firm had appeared in federal court in California a handful of times. From Virginia the firm negotiated a $200,000 settlement offer for the plaintiff, who was not in California at the time. Plaintiff met with the firm’s representatives in Virginia to sign the settlement agreement and later received the settlement check at a Virginia address. She later filed a malpractice action against law firm in California ; law firm filed a motion to quash based on lack of personal jurisdiction. The trial court granted the motion and the appellate court affirmed. California may exert “specific” personal jurisdiction over an out-of-state defendant with respect to a particular lawsuit only if (1) the defendant has purposefully availed itself of the benefits of California as a forum, (2) the controversy giving rise to the lawsuit is related to or arises out of the defendant’s contacts with California, and (3) the assertion of personal jurisdiction would comport with fair play and substantial justice. Whether specific jurisdiction exists is heavily dependent on the facts of each case. The court held that (1) the law firm and its lawyers did nothing to purposefully avail themselves of the benefits of doing business in California, and (2) the allegedly bad advice underlying the malpractice lawsuit was not sufficiently related to the firm’s and its lawyers’ contacts with California.