Delaware's long-arm statute provides jurisdiction over
defendants who are not residents of the State of Delaware.
Rather, the statute provides the courts of this State with
jurisdiction over a defendant who "in person or through an
agent . . . [t]ransacts any business or performs any character of
work or service in the State . . . [or c]auses tortious injury in
the State by an act or omission in this State." 10 Del. C. §
3104(c). Jurisdiction of this nature may also include
co-conspirators, who are treated as agents of a conspirator. The
agency and co-conspirator theory of jurisdiction may even apply to
conspiracy with an entity.
As artfully stated in the recent decision of Reid v. Siniscalchi, a
"conspiracy theory is . . . not an independent jurisdictional
basis, but a way to impute a conspirator's conduct to a
co-conspirator not otherwise subject to the Court's
jurisdiction." To determine whether jurisdiction over a
co-conspirator exists, the Court utilizes a
