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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