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OOMA, INC. v. DEPT. OF REVENUE

(SC S067581).

501 P.3d 520 (2021)

369 Or. 95

OOMA, INC., a foreign corporation, Plaintiff-Appellant, v. DEPARTMENT OF REVENUE, State of Oregon, Defendant-Respondent.

Supreme Court of Oregon, En Banc.

December 23, 2021.

Attorney(s) appearing for the Case

Michael J. Bowen, Akerman, LLP, Jacksonville, Florida, argued the cause for appellant. Casey M. Nokes, Cable Huston LLP, Portland, filed the briefs.

Darren Weirnick, Assistant Attorney General, Salem, argued the cause and filed the brief for respondent. Also on the brief were Ellen F. Rosenblum, Attorney General, and Benjamin Gutman, Solicitor General.

The Due Process Clause and the Commerce Clause of the United States Constitution limit the authority of states to impose tax obligations on out-of-state residents. U.S. Const., Amend. XIV (Due Process Clause); US Const. Art. I, § 8, cl 3 (Commerce Clause). This case requires us to determine whether taxpayer, Ooma, Inc., a California...

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