context: To establish purposeful availment, a plaintiff must show that "(1) it felt the injurious effects of a defendant's tortious act in the forum, and (2) that the defendant's act was calculated to cause injury to the plaintiff there."
citation_a.signal: see also
citation_a.identifier: 633 F.3d 1235, 1241
citation_a.parenthetical: "Posting allegedly defamatory comments or information on an internet site does not, without more, subject the poster to personal jurisdiction wherever the posting could be read (and the subject of the posting may reside
citation_a.sentence: Swiss Am Bank, Ltd., 274 F.3d at 632-33; see Sawtelle v. Farrell, 70 F.3d 1381, 1391 (1st Cir. 1995) (if defendant’s contact with jurisdiction was “voluntary” and was of such a nature so as to make state’s exercise of jurisdiction “foreseeable,” plaintiff has established purposeful availment); see also Noonan, 902 F.Sup. at 305 (defamatory “effect” within state by itself is not sufficient to confer jurisdiction over foreign defendant, defendant must also have intended their tortious act to be felt in forum state); Shrader v. Biddinger, 633 F.3d 1235, 1241 (10th Cir. 2011) (“Posting allegedly defamatory comments or information on an internet site does not, without more, subject the poster to personal jurisdiction wherever the posting could be read (and the subject of the posting may reside) . . . [I]n considering what ‘more’ could create personal jurisdiction for such activities, courts look to indications that a defendant deliberately directed its message at an audience in the forum state and intended harm to the plaintiff occurring primarily or particularly in the forum state”).
citation_b.signal: see
citation_b.identifier: 70 F.3d 1381, 1391
citation_b.parenthetical: if defendant's contact with jurisdiction was "voluntary" and was of such a nature so as to make state's exercise of jurisdiction "foreseeable," plaintiff has established purposeful availment
citation_b.sentence: Swiss Am Bank, Ltd., 274 F.3d at 632-33; see Sawtelle v. Farrell, 70 F.3d 1381, 1391 (1st Cir. 1995) (if defendant’s contact with jurisdiction was “voluntary” and was of such a nature so as to make state’s exercise of jurisdiction “foreseeable,” plaintiff has established purposeful availment); see also Noonan, 902 F.Sup. at 305 (defamatory “effect” within state by itself is not sufficient to confer jurisdiction over foreign defendant, defendant must also have intended their tortious act to be felt in forum state); Shrader v. Biddinger, 633 F.3d 1235, 1241 (10th Cir. 2011) (“Posting allegedly defamatory comments or information on an internet site does not, without more, subject the poster to personal jurisdiction wherever the posting could be read (and the subject of the posting may reside) . . . [I]n considering what ‘more’ could create personal jurisdiction for such activities, courts look to indications that a defendant deliberately directed its message at an audience in the forum state and intended harm to the plaintiff occurring primarily or particularly in the forum state”).