Personal Jurisdiction, the Internet and the Marx Brothers: Is There Life After <i>Zippo</i>?

Despite some suggestions to the contrary, the rise of the Internet as a business tool does not portend the end of limits on personal jurisdiction. The cyber-sky is not falling. Rather, the courts are finding that the Internet merely provides another vehicle (albeit an electronic one) through which a party may purposely avail itself of the privilege of conducting business in a foreign state and thus subject itself to jurisdiction in that state. In some recent cases, the federal courts have analyzed the characteristics of this relatively new and expanding technology under the Supreme Court's existing personal jurisdiction precedent. Instead of changing the personal jurisdiction standard, which is grounded in the Constitution, the courts have applied the existing personal jurisdiction standards to Internet activities.