Plaintiffs initially filed this putative class action against State Farm in the United States District Court for the District of Arizona on November 6, 2018. See Chee Vang et al, v. State Farm Mutual Automobile Insurance Company, No. CV-18-03870-PHX-DWL, 2019 WL 1676150 (D. Ariz. Apr. 17, 2019). On December 18, 2018, Defendant filed a motion to dismiss for lack of personal jurisdiction and for failure to state a claim.

A fair reading of Delphix is that jurisdiction is assessed based on a lengthy look back at the defendant's presence in the forum state, not just on the defendant's citizenship at the moment the case was commenced. Alternatively, one might, as does Chee Vang v. State Farm Mut. Auto Ins. Co., 2019 WL 1676150 at *3 (D.Ariz. Apr. 17, 2019), read Delphix as applying the "exceptional case" caveat of Daimler AG v. Bauman, 517 U.S. 117, 139 n .19 (2014), which posits that in certain exceptional circumstances, "a corporation's operations in a forum other than its formal place of incorporation or principal place of business may be so substantial and of such a nature as to render the corporation at home in that state" as well. Either reading suffices to resolve Craftworks' jurisdictional challenge here.