A plaintiff has always been the “master” of a complaint, but such mastery is not unfettered. Principles of subject matter jurisdiction, proper venue, and personal jurisdiction restrict a plaintiff’s choice of forum. A trend of recent cases from the Supreme Court down through the lower courts continue to narrow that “mastery” that a plaintiff once laid claim to. A recent decision from the Central District of California, Oceanside Health Products LLC v. Instock Goodies Inc., 2023 WL 3781649 (C.D. Cal. May 2, 2023) once again confirms that for a court to retain specific personal jurisdiction over a defendant, that defendant must have expressly aimed the allegedly infringing behavior at the forum. For trademark cases, the Central District of California made clear that a test buy of an allegedly infringing product initiated by the plaintiff does not evince the necessary “purposeful direction and purposeful availment” of the forum to give rise to specific jurisdiction.