In Rotblut v. Terrapinn, C.A. No. N15C-12-024-AML (Del. Super. Sept. 30, 2016), Judge Abigail LeGrow confronted the following question: When an allegedly defamatory article caused injury to a Delaware corporation, but the article was posted solely on a website with no connection to Delaware, while the author was outside Delaware, and without any nexus between either the author, the website’s host and Delaware, can jurisdiction be maintained against the author of the article and the host of the website? Her answer: no. Although the opinion makes passing references to federal constitutional due process concerns, LeGrow’s analysis rests squarely on Delaware’s long-arm statute.
The case was brought by Jeffrey Rotblut, the CEO of UBO Proprietary Trading, and UBO, an alternative asset manager, research firm and system developer for institutions and high-net worth individuals. UBO was a Delaware corporation. The defendants were Terrapinn Inc., a business media company organized in Delaware that promotes and conducts trade exhibitions, conferences, training solutions and electronic and print publications worldwide; its parent company, Terrapinn Holdings, a U.K. company; and Lewis Wilkins, an individual and citizen of the District of Columbia.
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