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Zippo-Ing The Wrong Way: How The Internet Has Misdirected The Federal Courts In Their Personal Jurisdiction Analysis, Catherine Ross Dunham
Zippo-Ing The Wrong Way: How The Internet Has Misdirected The Federal Courts In Their Personal Jurisdiction Analysis, Catherine Ross Dunham
Catherine Ross Dunham
ZIPPO-ING THE WRONG WAY: HOW THE INTERNET HAS MISDIRECTED THE FEDERAL COURTS IN THEIR PERSONAL JURISDICTION ANALYSIS
ABSTRACT
In 1997, the Federal District Court for the Western District of Pennsylvania evaluated one in a line of emerging personal jurisdiction cases that raised the question of whether Internet-based contacts with citizens of the forum state can alone establish the defendant purposefully established contacts with the forum state. In this unlikely watershed case, Zippo Mfg. Co. v. Zippo Dot Com, the District Court wrangled with the new concept of purposeful availment through electronic contact with the forum state. The court viewed Zippo …