By Timothy S. Donahue

Top Takeaways:

• The Samsung SDI Co., Ltd. will face litigation in Minnesota after the state Court of Appeals found it had “sufficient minimum contacts” with the forum through sales of 18650 lithium-ion batteries.
• Between 2017-2022, Samsung SDI shipped roughly 2.9 million 18650 cells via three Minnesota manufacturers, and internal records show it knew the batteries were being resold for e-cigarette use.
• The decision signals heightened liability exposure for battery component suppliers and vape-device manufacturers, particularly as circuits across the U.S. reject “different market” defenses in e-cig battery cases.

Minnesota’s Court of Appeal affirmed that the South Korean corporation Samsung SDI Co., Ltd. is subject to personal jurisdiction in Minnesota state courts, paving the way for a products-liability trial after an e-cigarette battery explosion caused severe injuries.

In the case of Shawn Peters v. Samsung SDI Co., Ltd., the court determined that SDI’s business activities in Minnesota—including the sale and shipment of millions of 18650 lithium-ion cells to Minnesota-based manufacturers under contracts governed by Minnesota law—meet the threshold for “minimum contacts” and purposeful availment .

According to court records, Samsung SDI shipped approximately 2.9 million individual 18650 cells to three Minnesota manufacturers between 2017 and 2022, inside “sealed battery packs.” Although Samsung argued that the packs were designed for equipment such as floor cleaners and were never intended for consumer use, the appellate opinion noted that internal investigations as early as 2016 confirmed that the same 18650 cells were being sold through U.S. vape stores and online retailers for vaping products.

The contract records included Minnesota choice-of-law and venue provisions, as well as a resale clause acknowledging that goods “may be resold, either directly or indirectly, for personal, family, or household use.”

In its analysis, the court applied the five-factor test under Minnesota’s long-arm statute and due-process jurisprudence. The first factor—the quantity of contacts—was strongly in favor of jurisdiction: the court found that the shipment volume and supplier contracts establish Samsung’s deliberate entry into the Minnesota market.

The second factor—the nature and quality of contacts—also supported jurisdiction, including Minnesota law in contracts, and recognizing potential resale demonstrated purposeful availment. The third factor—the link between the cause of action and the conduct—was also satisfied because Peters alleges he purchased a Samsung 18650 cell from a Minnesota vape store, it exploded in his pocket in Minnesota, and the injury occurred in Minnesota.

Factor four—Minnesota’s strong interest in providing a forum for injured residents—was acknowledged by the court. Factor five—the convenience factor—was considered neutral because Samsung, based in South Korea, would need international travel for witnesses, but the plaintiff would face the same if forced to litigate elsewhere.

Samsung argued that it only supplied sealed battery packs to industrial customers and not to e-cigarette users. It also claimed it did not market or sell these cells directly to consumers in Minnesota. The court rejected this “different market” defense, citing precedents from the U.S. Supreme Court’s Ford Motor Co. v. Montana Eighth Judicial District Court (2021) and the Fifth and Sixth Circuits in similar 18650 battery explosion cases.

The appellate panel stated that “a manufacturer who places its product into the stream of commerce in an effort to serve, directly or indirectly, markets in a jurisdiction is subject to suit in one of those jurisdictions if its product there caused injury.”

From an industry perspective, the ruling increases risks for global battery and vaping product manufacturers. The appellate opinion highlights direct and indirect supply chain connections to the e-cigarette market, aligning with recent decisions in Ethridge v. Samsung SDI Co. (5th Cir. 2025) and Sullivan v. LG Chem, Ltd. (6th Cir. 2023), where similar “different market” defenses were rejected by appellate courts.

For the vaping industry, including e-cigarette and heated-tobacco device manufacturers, this decision means that component suppliers—even those originally intended for industrial uses—could face liability if their products are used in consumer applications like e-cigarettes.

As one legal expert pointed out: “This ruling underscores that manufacturers cannot outsource risk by claiming they only sell to industrial customers when their products can reasonably be expected to enter the e-cigarette market.” The example mentioned in the opinion—Samsung’s internal investigation confirming use in vape stores—illustrates this point.

The case now returns to the Hennepin County District Court in Minnesota to proceed on the merits of the product-liability claims. The Court of Appeals explicitly upheld the denial of Samsung’s motion to dismiss for lack of jurisdiction, but “express[ed] no opinion on the merits of Peters’s products‐liability claims in the underlying dispute.”

The ruling may prompt vape shop owners and product suppliers—including device manufacturers, battery suppliers, importers, and other retailers—to re-evaluate indemnity agreements, supply-chain documentation, and foreseeability risks under state law.

In June, a Georgia appeals court reinstated a $10.9 million judgment against Samsung Electronics America Inc. in a case involving a man who suffered severe injuries when an e-cigarette battery allegedly exploded in his pocket.

In July, Samsung SDI was cleared of responsibility in a lawsuit over a vape battery explosion that injured a teenager in Indiana. In a unanimous decision, the Seventh Circuit Court of Appeals ruled that the battery manufacturer could not be held liable because it had no direct connection to the state’s vape market and did not intend its batteries to be sold for individual use in vaping devices.