This past quarter, the U.S. District Court for the Western District of New York dismissed a case after a plaintiff’s failure to accept a settlement offer caused the court to lose subject matter jurisdiction. In another case, the court discussed the extent to which a website could be used to exercise personal jurisdiction over an out-of-state defendant based partially on a website that was incapable of completing an online sale. The court also ordered an in camera review of grand jury testimony as part of an ongoing inquiry into allegations of “outrageous government conduct.” The latest developments in the Facebook ownership lawsuit have the parties accusing each other of forgery and computer hacking.

Settlement Offer’s Effect

In Automobile Ins. Co. of Hartford Conn. v. Electrolux Home Products Inc., No. 08-CV-623A, 2011 WL 3295510 (WDNY Aug. 1, 2011), the defendant engaged in a noteworthy course of action to obtain dismissal of the case against it.

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