A sample of personal jurisdiction cases decided after Young v. New Haven Advocate

5th Cir. 2002
“We find several distinctions between this case and Calder -- insurmountable hurdles to the exercise of personal jurisdiction by Texas courts. First, the article written by Lidov about Revell contains no reference to Texas, nor does it refer to the Texas activities of Revell, and it was not directed at Texas readers as distinguished from readers in other states. Texas was not the focal point of the article or the harm suffered, unlike Calder, in which the article contained descriptions of the California activities of the plaintiff, drew upon California sources, and found its largest audience in California. This conclusion fits well with our decisions in other intentional tort cases where the plaintiff relied upon Calder. In those cases we stated that the plaintiff's residence in the forum, and suffering of harm there, will not alone support jurisdiction under Calder. We also find instructive the defamation decisions of the Sixth, Third, and Fourth Circuits in Reynolds v. International Amateur Athletic Federation, Remick v. Manfredy, and Young v. New Haven Advocate, respectively.”

W.D. Tex. 2007
“While the Court agrees that Defendant Benn's phone conversation with Plaintiff, the broadcast, and the website alone may  not establish personal jurisdiction over Benn, the Court focuses on the direct aim of the harm to distinguish this case from Young. Unlike Young, wherein the only contacts evaluated in the personal jurisdiction analysis stemmed from Internet-based activities, Defendant Benn interacted with the State of Texas in a more direct manner: Defendant Benn actually sent the allegedly defamatory videotapes and scripts to a television station in San Antonio. In doing so, Benn effectively distributed an arguably libelous publication in Texas. Although San Antonio did not air the tapes, with her distribution, Benn directly planted the seed for harm to Plaintiff in Texas. This fact, considered in conjunction with Benn's other contacts with Texas during the investigation, convinces this Court that it may properly assert jurisdiction over Defendant Benn.”

11th Cir. 2008
Suit claimed intentional trademark infringement by defendant posting plaintiff’s trademark on his website and falsely inferring that plaintiff endorsed defendant’s business.  The suit was filed in Florida where the plaintiff resided.  The defendant resided in Tennessee and the website was created in Tennessee, but the 11th Circuit found that Florida could exercise personal jurisdiction under its long arm statute without violating the Due Process Clause relying on the Caldor decision.  The court concluded that the website was accessible in Florida and that the tort was committed in Florida because that was where the trademark holder resided, where the trademark was “passed off,” and where the plaintiff was injured.  This decision was reached even though the website did not target Florida in any specific way or include Florida-related content.

S.D. Ind. 2008
Plaintiff filed a trademark infringement suit in Indiana against a defendant who did business only in California. The defendant’s website was accessible in Indiana, but the court found there was no personal jurisdiction over the defendant.  The website contained a home page listing services provided and a toll free telephone number. There was a link for online support that included a series of frequently asked questions. The site included  a "request service" page that required a telephone number with a preset list of area codes that are found only in California. Finally, the site had a "contact us" page that listed the addresses of various stores, all located in California, as well as the toll free telephone number. A customer could not enter into a contract for service solely through the website.  Based on these facts the court concluded that the website was aimed at California residents only and did not target Indiana.  It also rejected the argument that trademark infringement is always directed at the residence of the trademark holder.