Ninth Circuit Relaxes Standard For Personal Jurisdiction Based On Internet Postings.

The Ninth Circuit, in opinions written by Judge William Fletcher, made it easier to subject defendants to local jurisdiction based on activities on the internet. In CollegeSource, Inc. v. AcademyOne, Inc. (Ninth Cir.; August 8, 2011) 653 F.3d 1066, [2011 DJDAR 11896], defendant, a Pennsylvania corporation posted material collected by plaintiff on its website. Defendant sought to serve a national market but targeted California students. This was sufficient for the California-based District Court to exercise in personam jurisdiction over defendant.  In Mavrix Photo, Inc. v. Brand Technologies, Inc. (Ninth Cir.; August 8, 2011) 647 F.3d 1218, [2011 DJDAR 11903], defendant, an Ohio corporation, posted photos on its website that were copyrighted by plaintiff. Defendant had agreements with California businesses relating to its website. This was also sufficient for the California-based District Court to exercise in personam jurisdiction over defendant.