Since the dawning of the Internet age, or at least soon afterward, plaintiffs have claimed defendants were subject to personal jurisdiction in New York’s state or federal courts because the defendants operated Web sites that were accessible to New Yorkers. The law relating to that argument, which has frequently been characterized as the “spectrum of interactivity,”1 is relatively well known by now.
Generally speaking, when a plaintiff seeks to invoke New York’s long-arm statute over a non-domiciliary defendant based on its operation of a Web site, the jurisdictional inquiry requires considerations particular to that medium. Because sites are, for the most part, “equally accessible everywhere,”2 courts have not found the mere availability of a site to users in New York, standing alone, to amount to transacting business in the state for purposes of CPLR §302(a).3
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