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Question
On a warm afternoon in Miami Florida, Salinda was scrolling through Facebook. An ad popped up for low rates on term life insurance policies. Salinda clicked on the ad and then purchased a term policy with Green Life Insurance Co. The life insurance policy stated that it would be automatically renewed each year so long as the insured (Salinda) continued paying the policy premiums. For the next 20 years, Salinda made payments to the company via the mail, and the company sent her statements and policy updates. Salinda decided that she wanted to be closer to her sister, and moved to Georgia. Salinda wrote to Green Life with her updated contact information. Green Life continued to bill her in Florida. After Salinda passed away at the age of 90, the Green Life refused to provide insurance coverage, arguing that Salinda had made a material misstatement on her original application. Green Life has its headquarters in Los Angeles and is incorporated in Delaware.
Salinda's beneficiary, her nephew Carlos, wants to file suit against Green Life Insurance Co. in Florida. Green Life has never had any customers in Florida besides Salinda.
Assume the following:
Salinda received a letter from Green Life after she moved to Georgia. The letter offered to boost her coverage on her term life policy. She accepted the offer. Green Life has had a few customers (perhaps 10) in Georgia over the past 20 years besides Hanna for various term and whole life policies. Will Carlos succeed in asserting personal jurisdiction against Green Life in Georgia? Explain.
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