I know it when I see it.

—Supreme Court Justice Potter Stewart

The Internet hosts millions of websites and, unfortunately, a substantial number offer videos or images relating to pornography hosted from locations around the world. Since the inception of the Internet, legal disputes relating to the copying and distribution of pornography have been a driving force in the application of traditional legal concepts in the electronic era. When a foreign actor violates U.S. copyright law using the Internet, the injured party may have difficulty in securing jurisdiction in a local court to bring a lawsuit. In an otherwise routine copyright case, the U.S. Court of Appeals for the Ninth Circuit addressed whether a foreign actor whose adult content website is accessed by users in the United States can be sued in Arizona. The Ninth Circuit's decision also questioned the standards recently applied by the Fourth Circuit in a very similar case.