Specific Jurisdiction and Divergent Streams of Commerce: The Nevada Supreme Court Adopts an End‑Product / Derivative‑Product Framework in Franceschi v. LG Chem

I. Introduction

In Franceschi v. LG Chem, Ltd., 141 Nev., Adv. Op. 65 (Dec. 18, 2025), the Nevada Supreme Court addressed whether Nevada courts may exercise specific personal jurisdiction over a foreign battery manufacturer and its U.S. subsidiary when a Nevada resident is injured by a lithium‑ion cell purchased in the state.

The central innovation of the opinion lies in its treatment of the “stream of commerce” theory of specific jurisdiction. Adopting and endorsing a framework articulated by the Seventh Circuit in B.D. by and through Myers v. Samsung SDI Co., Ltd., 143 F.4th 757 (7th Cir. 2025), the court distinguished between:

• End‑product streams of commerce – where component parts are sold to sophisticated manufacturers for integration into finished products sold in the forum; and
• Derivative‑product streams of commerce – where discrete components are later diverted and sold directly to consumers through separate, often unauthorized channels.

The court held that specific jurisdiction requires a match between the stream of commerce the defendant purposefully engaged in and the stream through which the plaintiff’s injury arose. Because plaintiff Roberto Franceschi’s injuries stemmed from a standalone LG 18650 lithium‑ion cell sold through an unauthorized retail channel (a vape shop), and because LG did not serve or target that derivative consumer market in Nevada, the court found the “relatedness” prong of specific jurisdiction unsatisfied and affirmed dismissal for lack of personal jurisdiction.

This opinion significantly refines Nevada’s specific jurisdiction doctrine in products cases, especially for component‑part manufacturers and foreign entities whose products reach Nevada only indirectly.

II. Background and Procedural History

A. Factual Background

Roberto Franceschi, a Nevada resident, purchased individual LG‑branded 18650 lithium‑ion batteries from a Nevada vape shop. The batteries were sold:

• Individually (standalone cells, not in packs),
• Without packaging, and
• Without warnings or instructions.

While sitting at home with two such cells in his pants pocket, one battery ignited and exploded, causing severe second‑ and third‑degree burns to his leg, hand, and forearm. Franceschi asserted products liability and related claims against:

• LG Chem, Ltd. – a South Korean company that manufactures lithium‑ion cells, including model 18650, and operates on a business‑to‑business (B2B) model; and
• LG Chem America, Inc. (LGCAI) – a Delaware corporation based in Georgia, a subsidiary of LG Chem, that:
  • Primarily sells petrochemical products in the U.S., and
  • Assists with logistics and financial aspects of LG Chem’s 18650 sales to U.S. businesses.

LG Chem’s core position was that:

• Its 18650 cells are designed and sold as industrial component parts, intended to be assembled into battery packs by sophisticated manufacturers; and
• It does not sell 18650 cells as standalone, consumer‑replaceable batteries, nor does it authorize such sales, including in Nevada.

When LG learned that 18650 cells were being sold individually for use in e‑cigarettes:

• LG Chem notified its U.S. business customers that standalone use was improper,
• It sent cease‑and‑desist letters to retailers and vape shops across the U.S., including in Nevada, instructing them not to sell standalone 18650 cells for e‑cigarette use, and
• It placed warnings on its website discouraging standalone use.

LGCAI did not itself manufacture, distribute, or advertise 18650 cells for standalone use. Once LG Chem undertook remedial actions, LGCAI did not independently act further.

B. Procedural Posture

After jurisdictional discovery, both LG Chem and LGCAI moved to dismiss for lack of personal jurisdiction. The Eighth Judicial District Court (Clark County, Judge Maria Gall) granted the motions, concluding that:

• LG had purposefully availed itself of Nevada with respect to certain activities; but
• Franceschi failed to establish that his claims “arose out of or related to” LG’s Nevada‑directed contacts.

Because claims against other defendants remained, the orders dismissing LG were certified as final under NRCP 54(b), permitting an immediate appeal. The Nevada Supreme Court took the case and affirmed.

III. Summary of the Opinion

The Nevada Supreme Court applies the standard three‑part test for specific personal jurisdiction:

1. The defendant must have purposefully availed itself of the privilege of conducting activities in Nevada (or purposefully directed conduct toward Nevada);
2. The plaintiff’s claim must “arise out of or relate to” those contacts; and
3. The exercise of jurisdiction must comport with fair play and substantial justice.

The court held:

• First prong – Purposeful availment: Satisfied. LG’s sales of certain batteries and petrochemical products into Nevada, and its sale of 18650 cells as components to national manufacturers whose end‑products were sold in Nevada, constituted purposeful availment.
• Second prong – “Arise out of or relate to”: Not satisfied. Franceschi’s injury did not arise from the same stream of commerce through which LG’s Nevada contacts occurred. LG participated in an end‑product stream of commerce (cells integrated into packs and end‑products), whereas Franceschi was injured by a cell that reached him via a separate, unauthorized derivative‑product stream (standalone retail sale in a vape shop).
• Third prong – Fair play and substantial justice: Not reached. Because relatedness failed, specific jurisdiction was foreclosed.

Doctrinally, the court:

• Explicitly endorses a dual “streams of commerce” framework (end‑product vs derivative‑product),
• Holds that courts may examine distinct streams of commerce within a single forum to assess relatedness, without violating the “sovereign‑by‑sovereign” focus of jurisdictional analysis, and
• Clarifies that purposeful availment via component‑part sales does not automatically confer jurisdiction over injuries caused by unauthorized consumer use of the same component when sold through a different, non‑targeted distribution stream.

IV. Analysis

A. Precedents and Framework

1. Nevada’s Long‑Arm Statute and General Jurisdictional Framework

The court reaffirms that Nevada’s long‑arm statute, NRS 14.065(1), is coextensive with the limits of federal due process. Accordingly, the inquiry collapses into a constitutional analysis. This is grounded in:

• Tricarichi v. Coöperatieve Rabobank, U.A., 135 Nev. 87, 440 P.3d 645 (2019); and
• Catholic Diocese of Green Bay, Inc. v. Doe 119, 131 Nev. 246, 349 P.3d 518 (2015).

Only specific (not general) jurisdiction is at issue, consistent with the dichotomy articulated in Ford Motor Co. v. Montana Eighth Judicial District Court, 592 U.S. 351 (2021).

The Nevada Supreme Court again applies the three‑prong specific jurisdiction test set out in In re Trust of Burgauer Revocable Living Trust, 138 Nev. 801, 521 P.3d 1160 (2022):

1. Purposeful availment / direction;
2. Arising out of or relatedness; and
3. Fair play and substantial justice.

On standard of review and evidentiary burdens, the court cites:

• Fulbright & Jaworski LLP v. Eighth Judicial District Court, 131 Nev. 30, 342 P.3d 997 (2015) – de novo review of personal jurisdiction determinations;
• Dogra v. Liles, 129 Nev. 932, 314 P.3d 952 (2013) – clear‑error review for factual findings underlying jurisdictional rulings;
• Trump v. Eighth Judicial District Court, 109 Nev. 687, 857 P.2d 740 (1993); and
• Levinson v. Second Judicial District Court, 103 Nev. 404, 742 P.2d 1024 (1987) – plaintiff must make a prima facie showing of jurisdiction, and factual disputes are resolved in the plaintiff’s favor at the jurisdictional stage.

2. Stream of Commerce Doctrine

The opinion draws on the U.S. Supreme Court’s foundational stream‑of‑commerce case:

• World‑Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) – A forum state may exercise jurisdiction over a corporation that delivers its products into the stream of commerce with the expectation that they will be purchased in the forum. Awareness of and participation in a distribution system that targets the forum can establish purposeful availment.

Nevada precedent applying this principle is Judas Priest v. Second Judicial District Court, 104 Nev. 424, 760 P.2d 137 (1988), holding that “[t]he creator of a product is subject to personal jurisdiction where his product is sold if he is aware of and uses a national distribution system to make the sale.”

3. United States Supreme Court: “Arise out of or Relate to”

The court heavily relies on Ford Motor Co. v. Montana Eighth Judicial District Court, 592 U.S. 351 (2021), which clarified:

• The phrase “arise out of or relate to” contains two distinct concepts:
  • “Arise out of” suggests a causal connection between the defendant’s contacts and the injury.
  • “Relate to” is broader; it does not require strict but‑for or proximate causation, but still demands a meaningful, non‑attenuated link between the forum contacts and the claims.
• In Ford, jurisdiction was proper in Montana and Minnesota because Ford systematically served a market in those states for the very models of vehicles that allegedly malfunctioned, even though the specific cars involved were initially sold elsewhere.

4. Seventh Circuit’s Samsung SDI Decision – Adopted by Nevada

The Nevada Supreme Court explicitly adopts the analytical framework from:

• B.D. by and through Myers v. Samsung SDI Co., Ltd., 143 F.4th 757 (7th Cir. 2025) – another 18650 lithium‑ion battery explosion case.

The Seventh Circuit distinguished:

• End‑product stream of commerce: The manufacturer sells components (like 18650 cells) to sophisticated entities that integrate them into battery packs and then into consumer products (e.g., laptops, power tools). The manufacturer knows these end products are sold nationally, including in the forum state.
• Derivative‑product stream of commerce: A separate channel in which the same or similar components are repackaged and sold as discrete items directly to consumers (e.g., individual 18650 cells sold in vape shops), typically by third parties and often for uses the manufacturer did not intend or authorize.

The key doctrinal move in Samsung was the conclusion that:

• Specific jurisdiction requires a match between:
  • The stream of commerce the defendant purposefully engaged in, and
  • The stream of commerce through which the plaintiff’s injury arose.
• If there is a mismatch (for example, defendant targeted only end‑product integration, but the injury arose from a separate consumer market for standalone cells cultivated by third parties), jurisdiction is improper.

Nevada expressly “finds this method for analyzing relatedness persuasive” and imports it into its own due‑process analysis.

5. Other Cited Authorities

The court also addresses or distinguishes several other decisions:

• J. McIntyre Machinery, Ltd. v. Nicastro, 564 U.S. 873 (2011) (plurality) – Emphasizes that jurisdictional analysis must be sovereign‑by‑sovereign (state‑by‑state), not merely national. The plaintiff cited this to argue against segmenting the Nevada market into distinct streams of commerce. The Nevada Supreme Court holds that differentiating streams of commerce is not the same as subdividing the sovereign itself.
• Yamashita v. LG Chem, Ltd., 62 F.4th 496 (9th Cir. 2023) – A factually similar LG Chem 18650 case in which the Ninth Circuit found no specific jurisdiction where LG did not target the forum market for standalone 18650 cells.
• LG Chem America, Inc. v. Morgan, 670 S.W.3d 341 (Tex. 2023) – The Texas Supreme Court upheld specific jurisdiction over LG for injuries from standalone 18650 cells, but there was evidence that LG directly shipped thousands of 18650 cells into Texas. Nevada distinguishes this core factual point; here, Franceschi produced no evidence of any such Nevada shipments.
• Rockwell International Corp. v. Costruzioni Aeronautiche Giovanni Agusta, 553 F. Supp. 328 (E.D. Pa. 1982) – An early stream‑of‑commerce case involving helicopter ball bearings. The manufacturer knew its bearings would be integrated into helicopters marketed nationally, including in the forum. Nevada aligns Rockwell with the Samsung “hypothetical laptop” scenario: injuries from components integrated into a final product that the defendant intentionally placed into the end‑product stream of commerce.

B. The Court’s Legal Reasoning

1. Purposeful Availment: LG’s Contacts with Nevada

The court quickly resolves the first prong in Franceschi’s favor. LG’s Nevada contacts are not “random, isolated, or fortuitous” (to use Ford’s terminology), but deliberate:

• LG sells non‑18650 batteries to electric vehicle manufacturers that operate in Nevada;
• LG sells petrochemical products in Nevada through LGCAI; and
• LG manufacturers 18650 cells and sells them to sophisticated OEMs (original equipment manufacturers) to be integrated into devices (e.g., power tools, phones, e‑cigarettes) that it knows will be sold nationwide, including Nevada.

Those activities constitute classic purposeful availment under Ford and Nevada precedents: LG “exploits a market” and is part of distribution systems that predictably reach Nevada consumers. Thus, the first prong is satisfied.

2. The Relatedness Requirement and Franceschi’s “Stream of Commerce” Theory

The contested issue is the second prong—whether the claims “arise out of or relate to” LG’s Nevada‑connected activities. Franceschi conceded that he could not establish a strict causal “arise out of” link, but he argued relatedness under the broader half of the Ford standard.

His argument, distilled, was:

• LG systematically collects technical specifications from its national manufacturing partners;
• It sells 18650 cells for integration into products that are sold in Nevada;
• He, a Nevada resident, was injured in Nevada by an LG 18650 cell purchased in Nevada; therefore,
• The injury “relates to” LG’s Nevada‑oriented activities involving the same model of battery.

The court categorizes this as a stream‑of‑commerce relatedness theory. That framing sets up the move to Samsung’s dual‑stream concept.

3. Adoption of the End‑Product / Derivative‑Product Distinction

Using Samsung as its primary doctrinal guide, the court defines:

• End‑product stream of commerce:
  • The path by which LG sells 18650 cells to vetted, sophisticated entities;
  • Those entities integrate the cells into battery packs;
  • The battery packs in turn are integrated into final consumer products (e.g., power tools) sold nationwide, including in Nevada.
• Derivative‑product stream of commerce:
  • A separate path, in which individual 18650 cells, removed from their intended industrial context or supplied by unauthorized distributors, are sold directly to end users—such as vape shops selling loose cells for e‑cigarettes.

The Nevada Supreme Court embraces Samsung’s conclusion that:

“For a defendant’s contacts to relate to a plaintiff’s injuries, there must be a connection between the stream of commerce a defendant manipulated and the stream of commerce through which a plaintiff’s injuries arose. When there is a mismatch, the exercise of personal jurisdiction is foreclosed.”

Importantly, the court squarely rejects Franceschi’s contention—drawn from Nicastro—that examining multiple streams of commerce within one state impermissibly “granulates” the forum. The court, aligning with Samsung, states that:

• Distinguishing between markets or distribution channels does not “divide” the forum sovereign (Nevada) into sub‑sovereigns; it is simply a way of accurately describing the nature and scope of the defendant’s targeted activities within that single sovereign.

4. Application: The Mismatch Between LG’s Contacts and Franceschi’s Injury

Applying this framework, the court finds:

• Franceschi successfully shows that LG participates in an end‑product stream of commerce that reaches Nevada:
  • LG cooperates with “nationally recognized businesses,”
  • Produces 18650 cells to be integrated into packs and end products,
  • And knows those end products are sold nationwide, including Nevada.
• However, Franceschi fails to show that LG:
  • Directly ships individual 18650 cells into Nevada; or
  • Serves a consumer market in Nevada for standalone 18650 cells.

Indeed, Franceschi’s own counsel conceded at oral argument that “LG never shipped 18650s directly to Nevada,” a concession consistent with LG’s deposition testimony. This evidentiary posture is critical.

Thus, the injury arose through:

• A standalone 18650 cell purchased in a Nevada vape shop,
• Supplied by an unknown third‑party distributor,
• Operating independently of LG’s authorized distribution scheme.

The court characterizes this as:

• An “alternative stream of commerce” manipulated by others.

In addition, LG presented substantial evidence that it acted affirmatively to prevent the formation of a consumer market for standalone 18650 cells:

• Contractual and technical limitations to prevent cells from being removed from packs;
• Cease‑and‑desist letters to retailers and vape shops, including those in Nevada;
• Website warnings against standalone consumer use.

Citing the Supreme Court’s admonition that defendants may structure their primary conduct to minimize exposure to distant forums, the Nevada Supreme Court treats these measures as:

• Evidence that LG did not purposely avail itself of Nevada’s derivative consumer market for loose cells; and
• Support for the conclusion that the derivative‑product stream was forged by others, not by LG’s forum‑directed conduct.

As in Samsung, the court concludes there is a disconnect—or mismatch—between:

• LG’s purposeful end‑product‑stream contacts with Nevada, and
• The specific harm alleged by Franceschi, which arose solely through the derivative‑product stream.

That mismatch is fatal to the relatedness inquiry.

5. Distinguishing Ford, Morgan, and Rockwell

a. Ford Motor Co. v. Montana Eighth Judicial District Court

In Ford, the manufacturer argued there was no jurisdiction because the specific vehicles involved in the accidents had neither been designed nor sold by Ford in the forum states. The U.S. Supreme Court rejected that narrow causation test because Ford:

• “Systematically served a market” in the forum states for the very models of vehicles that allegedly malfunctioned; and
• Had continuous and deliberate contact with the forum markets for those models (advertising, sales, service, etc.).

The Nevada Supreme Court sees no inconsistency between Ford and Samsung (and thus its own approach):

• In Ford, there was no mismatch—Ford was actively and directly serving a market in the forum for the very class of products (the same car models) that caused the harm.
• Here, by contrast, LG did not serve a Nevada market for the class of products at issue: standalone 18650 cells sold directly to consumers.

The fact that LG serves a Nevada market for components integrated into finished goods (end‑product stream) does not automatically carry over to injuries caused by standalone components sold through a separate derivative stream.

b. LG Chem America, Inc. v. Morgan (Texas)

In Morgan, the Texas Supreme Court held Texas could exercise specific jurisdiction over LG for injuries from standalone 18650 batteries purchased in Texas. Crucially, however, the record there showed:

• LG had sold and shipped thousands of 18650 cells directly into Texas.

That evidence established:

• LG’s purposeful availment of the Texas market for standalone 18650 cells, and
• A direct relationship between those contacts and the plaintiff’s injuries.

Nevada distinguishes Morgan on this factual ground:

• Franceschi presented no evidence that LG shipped standalone 18650 cells into Nevada or otherwise targeted a Nevada consumer market for such cells.

c. Rockwell v. Costruzioni Aeronautiche Giovanni Agusta

In Rockwell, a component manufacturer produced ball bearings for a specific helicopter model, knowing the helicopters would be marketed throughout the United States. When a helicopter crash allegedly caused by defective bearings occurred, the court sustained jurisdiction.

Nevada analogizes Rockwell to Samsung’s hypothetical scenario where an integrated battery pack in a laptop explodes:

• In both examples, the component reaches the forum through the end‑product stream of commerce that the defendant itself set in motion and reasonably anticipated (and intended) would reach the forum.
• There is no stream‑mismatch; the injuries occur along the very distribution path the defendant used to serve the forum market.

That is not what happened to Franceschi; his injury came from a derivative resale channel outside LG’s targeted distribution chain.

6. Disposition on the Third Prong (Fair Play and Substantial Justice)

Because the court found the second prong unsatisfied, it expressly declined to analyze whether asserting jurisdiction over LG would offend “traditional notions of fair play and substantial justice.” This preserves doctrinal clarity: all three prongs must be met, and a failure on relatedness ends the inquiry.

C. Impact and Implications

1. A New Nevada Rule on “Divergent Streams of Commerce”

The most significant doctrinal contribution is Nevada’s explicit authorization for courts to:

• Differentially analyze distinct streams of commerce within the same forum state, and
• Require that the plaintiff’s injury arise from or relate to the same stream in which the defendant purposefully availed itself of the forum’s benefits.

The rule can be restated as:

When a defendant places products into an end‑product stream of commerce reaching Nevada, but a plaintiff’s injury arises solely from an unauthorized derivative‑product stream (e.g., gray‑market, aftermarket, or misused components sold as standalone items), Nevada courts lack specific jurisdiction absent evidence that the defendant purposefully served the forum market for that derivative‑product stream.

This refines Nevada’s earlier, more generalized reference to national distribution systems in Judas Priest and aligns Nevada with the more structured analysis emerging in federal appellate courts.

2. Consequences for Products Liability and Component Manufacturers

For manufacturers of components, especially foreign corporations:

• The opinion limits exposure in Nevada for injuries caused by unauthorized uses or gray‑market distribution of their products, so long as:
  • They do not themselves target or serve the forum market for those unauthorized channels; and
  • They take reasonable structural steps (warnings, contractual controls, cease‑and‑desist letters) to prevent such distribution.
• At the same time, it implies that jurisdiction might be appropriate if the injury stemmed from:
  • An end product (e.g., a power tool, laptop) in which their components were integrated, and
  • The manufacturer had deliberately used an end‑product stream of commerce anticipating sales in Nevada.

For plaintiffs, the opinion:

• Makes it more challenging to sue foreign component manufacturers in Nevada when injuries arise from standalone or repurposed components sold by third‑party retailers,
• Increases the importance of jurisdictional discovery that can show direct shipments or targeted marketing of the specific product stream into Nevada, and
• Encourages plaintiffs to focus on:
  • Downstream sellers (retailers, distributors) in Nevada, and/or
  • Filing suit in forums where the manufacturer more clearly served the relevant derivative‑product market.

3. Incentives for Corporate “Structuring of Primary Conduct”

By favorably citing Supreme Court language that defendants may structure their conduct to avoid or minimize jurisdiction in particular states, the opinion:

• Validates compliance strategies such as:
  • B2B‑only models,
  • Contractual and technical restrictions on downstream redistribution,
  • Active enforcement (e.g., cease‑and‑desist letters) against unauthorized resellers, and
  • Clear public warnings against certain uses.
• Signals that such actions may be probative not only on the merits (e.g., negligence, failure to warn) but also on the jurisdictional question of whether the manufacturer has purposefully availed itself of a particular derivative consumer market.

4. Harmonization and Tension with Other Jurisdictions

The decision:

• Aligns Nevada with the Ninth Circuit’s reasoning in Yamashita v. LG Chem and the Seventh Circuit in Samsung SDI, forming a growing multi‑jurisdictional consensus regarding 18650 cells and similar component‑part distributions; but
• May produce divergent outcomes compared to states like Texas (Morgan), where fact patterns show direct shipments and targeting of the forum for standalone cells.

Thus, the decision underscores that jurisdictional outcomes in 18650‑related cases are highly fact‑sensitive, turning on the evidence of how, and into which stream, the manufacturer actually placed its products.

V. Complex Concepts Simplified

1. Personal Jurisdiction: General vs. Specific

• General jurisdiction: The defendant can be sued in the forum for any claim, even unrelated to its forum activities. For corporations, this usually exists only where they are “at home” (place of incorporation or principal place of business).
• Specific jurisdiction: The defendant can be sued in the forum only for claims that arise out of or relate to its contacts with the forum. This is the type at issue here.

2. Purposeful Availment / Direction

A nonresident defendant is subject to specific jurisdiction only if it has deliberately engaged with the forum state:

• Purposeful availment focuses on the defendant’s voluntary use of the forum’s laws and markets (e.g., selling products in the state, entering contracts centered there).
• Purposeful direction often concerns intentional torts where conduct elsewhere is aimed at causing harm in the forum.

Here, LG purposefully availed itself of Nevada via its B2B distribution of batteries and petrochemicals and by participating in end‑product distribution channels that reach Nevada.

3. “Arise Out of” vs. “Relate To”

• “Arise out of” implies that the plaintiff’s claims would not exist but for the defendant’s forum contacts—essentially, a causal relationship.
• “Relate to” is broader: the claims need not be strictly caused by the forum contacts but must still have a close, relevant connection to them. Ford makes clear this is not a limitless concept; mere similarity is not enough.

In Franceschi, the court accepted that “relate to” could, in theory, be broader than strict causation, but it still required the particular stream of commerce connecting LG and Nevada to be the one that generated Franceschi’s injury—which it was not.

4. Stream of Commerce: End‑Product vs. Derivative‑Product

• Stream of commerce refers to the path a product takes from manufacturer to consumer, including all intermediate distributors and retailers.
• End‑product stream:
  • The manufacturer sells components to other businesses,
  • Those businesses integrate them into final products,
  • The final products are marketed and sold to consumers (e.g., a laptop with a battery pack inside).
• Derivative‑product stream:
  • A breakaway path where components are sold individually, often for uses the manufacturer did not intend (e.g., loose 18650 cells sold in vape shops).

The Nevada Supreme Court’s key point is that injury in the forum must travel along a stream the defendant knowingly and purposefully used to reach the forum—not some different stream constructed by others.

5. NRCP 54(b) Certification

NRCP 54(b) allows a district court to direct entry of final judgment as to fewer than all claims or parties if there is “no just reason for delay.” Here:

• Claims against LG were dismissed for lack of jurisdiction,
• Other defendants remained in the lawsuit,
• The court certified those orders as final, allowing Franceschi to immediately appeal the jurisdictional dismissal as to LG, rather than waiting for the entire case to conclude against all parties.

VI. Conclusion

Franceschi v. LG Chem is a significant Nevada precedent on personal jurisdiction in products liability and component‑part cases. It confirms that:

• Specific jurisdiction remains a two‑stage inquiry of contact and relatedness, enhanced by a third fairness prong.
• While LG had unquestionably purposefully availed itself of Nevada’s markets through B2B sales and participation in end‑product distribution chains, those contacts did not suffice to hale it into Nevada courts for injuries from standalone 18650 cells sold by unauthorized third‑party retailers.
• Nevada courts may distinguish between end‑product and derivative‑product streams of commerce and require a match between:
  • The stream of commerce the defendant purposely manipulated, and
  • The stream that produced the injury in the forum.
• If the plaintiff’s harm arises solely from a derivative stream the defendant did not serve or target—and arguably attempted to forestall—specific jurisdiction is lacking, even if the defendant’s product also reaches the forum through other, authorized channels.

In the broader constitutional landscape, the decision harmonizes Nevada law with Ford, World‑Wide Volkswagen, and emerging federal appellate authority (Samsung, Yamashita), while articulating a clear, structured approach to stream‑of‑commerce jurisdiction in the age of complex global supply chains. For practitioners, Franceschi underscores that the precise distribution path of the product that caused injury—and the defendant’s role, if any, in targeting that path within the forum—is now central to specific jurisdiction analysis in Nevada.