With the rise of the Internet age, the need for a brick and mortar physical presence within a state to facilitate business transactions has been largely obviated. As millions of individuals engage in internet commerce, the courts have reached inconsistent and conflicting conclusions concerning the permissible scope of personal jurisdiction based on such commerce.
The U.S. District Court for the Southern District of New York recently addressed the issue of whether personal jurisdiction can be exercised in New York on the basis of a defendant’s Web site. In Chloe v. Queen Bee, the defendant operated a Web site from which users could view products and place orders, including products described as Chloe handbags.1 A paralegal employed by plaintiff’s counsel ordered one of these bags from counsel’s New York office for delivery to that office.
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