Law360, New York ( October 19, 2015, 10:36 AM EDT) -- The 2014 U.S. Supreme Court decision in Daimler AG v. Bauman[1] has increased challenges for establishing personal jurisdiction in Hatch-Waxman infringement actions against foreign entities. Daimler makes it significantly more difficult to establish general jurisdiction over foreign entities lacking a place of business in the United States. In addition, the implications of Daimler call into question the viability of consent jurisdiction based on a foreign entity's compliance with state business statutes requiring the designation of a registered agent within the state for service. Adding to the problem, the proper location of specific jurisdiction based on the "artificial" act of infringement under 35 U.S.C. §271(e)(2) has been (and remains) far from clear. As discussed here, however, in the face of shrinking and uncertain jurisdictional options, a reliable hook remains for Hatch-Waxman actions against foreign entities....