In a declaratory judgment action involving alleged patent infringement, U.S. District Court Judge Paul W. Grimm held that the Court lacked personal jurisdiction under Maryland’s long-arm statute over a patent owner that sent a letter offering a patent license to an accused infringer. According to the Court, a non-Maryland defendant does not “transact business” within the meaning of the long-arm statute by sending written communications, including a cease-and-desist letter, to a purported infringer located in Maryland. The Court thus dismissed the case. Government Employees Ins. Co.