ePlus Technology, Inc. v. Aboud’s Empirical Analysis
313 F.3d 166 · 2002
Citation profile
10 federal appellate · 8 district · 3 state decisions
How this case has been cited
Cited by 64 later decisions — most recently May 2025 · most notably American Chiropractic Association Incorporated Dc, New Wellington Financial Corp. v. Flagship Resort Development Corp. (2005)
10 federal appellate · 8 district · 3 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on International Shoe Co. v. Washington · Burger King Corporation v. Rudzewicz · World-Wide Volkswagen Corp. v. Woodson · McGee v. International Life Insurance · Asahi Metal Industry Co. v. Superior Court of Cal., Solano Cty.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A]cts of corporate agents are acts of the corporation itself, and corporate employees cannot conspire with each other or with the corporation.”
5 later decisions quote this exact passage · from the majority“While a minimum of two predicate acts is required, two acts alone do not necessarily establish a pattern. To establish a pattern of racketeering activity, the plaintiff must show that the predicate acts are related and that they amount to or pose a threat of continued criminal activity.... Continuity refers either to a closed period of repeated conduct, or to past conduct that by its nature projects into the future with a threat of repetition. Closed-ended continuity may be established by a series of related predicates extending over a substantial period of time. Predicate acts extending over a few weeks or months and threatening no future criminal conduct do not satisfy this requirement. Open-ended continuity may be established where, for example, the related predicates themselves involve a distinct threat of long-term racketeering activity, or where the predicate acts are part of an ongoing entity’s regular way of doing business ... or of conducting or participating in an ongoing and legitimate RICO enterprise. [The Fourth Circuit is] cautious about basing a RICO claim on predicate acts of mail and wire fraud because it will be the unusual fraud that does not enlist the mails and wires in its services at least twice. RICO liability is reserved for ongoing unlawful activities whose scope and persistence pose a special threat to social well-being.”
1 later decision quote this exact passage · from the majority“In the typical case, the contacts of a company are not attributed to a corporate agent for jurisdictional purposes. See Calder v. Jones, 465 U.S. 783, 790 , 104 S.Ct. 1482 , 79 L.Ed.2d 804 (1984) (holding that employees’ ‘contacts with [the forum] are not to be judged according to their employer’s activities there’). On the other hand, [a defendant] is not immune from jurisdiction in Virginia merely because her contacts with the Commonwealth were made ostensibly on behalf of [the corporation]. Id. (noting that employees’ ‘status as employees does not somehow insulate them from jurisdiction’). Therefore, the court’s exercise of jurisdiction was proper if [the defendant] had sufficient contacts with Virginia, even if those contacts were made ostensibly on behalf of [the corporation].”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.