Rao v. ERA Alaska Airlines
United States District Court for the District of Maryland
22 F.Supp.3d 529 (2014)
Maryland residents (plaintiffs) bought tickets through Expedia for an intrastate flight within Alaska on ERA Alaska Airlines (defendant), traveled to Alaska, and after landing discovered a case of valuables was missing; they sued ERA and other Alaska-based defendants in Maryland federal court, and after limited jurisdictional discovery, the defendants argued personal jurisdiction was improper because ERA had not purposefully engaged in business in Maryland, having simply allowed a travel website to list its flight information for anyone to access.
Whether a state may exercise personal jurisdiction over a party who purposefully directs internet activity into the forum state with the manifest intent of engaging in business there.