Bridge Co., an architectural firm, designs and constructs bridges for major cities. Bridge Co. is incorporated and has its principal place of business in Washington D.C. Bridge Co. is famous for its unique bridge designs and was featured last year on Prime News, a nationally televised program.

Upon seeing the Prime News feature on Bridge Co., the Newport Beach City Council hired Bridge Co. to design and construct a bridge between Newport Beach, California and Catalina Island. With the news of the bridge being constructed, Len Thomas, corporate counsel for Bridge Co. received a letter stating:

I used to work for Bridge Co. and was one of the architects working on the design of the bridge between Newport Beach and Catalina Island. There is a serious question about the bridges design. California is known for earthquakes, and the design of the bridge will not withstand an earthquake.

/s/ Mr. Sears

Mr. Thomas destroyed the letter he received from Mr. Sears and immediately drafted a memorandum based on the contents of that letter and sent it to the president of Bridge Co. Five years after the bridge was completed, California experienced an earthquake causing a portion of the bridge built in the city of Newport Beach to collapse. Dave was injured and suffered major injuries when the bridge collapsed.

Dave filed an action in Federal District Court for $70,000 and an injunction to force Bridge Co. to tear down the remaining bridge rather than repair it since it is unsafe due to the poor design in earthquakes. A statute in California states, The courts may exercise personal jurisdiction to the fullest extent permitted by the United States Constitution.

Bridge Co. moved to dismiss the complaint alleging lack of jurisdiction. The court denied the motion. Dave then filed a timely motion for production of the memorandum prepared by Mr. Thomas. The court denied the motion.

Was the court correct in its rulings?