Revell v. Lidov
Fifth Circuit
317 F.3d 467 (5th Cir. 2002)
Lidov (defendant) wrote an article, allegedly defamatory of Revell (plaintiff), without knowing Revell lived in Texas; the article's content was based on events outside Texas and used no Texas sources. Lidov posted the article on a Columbia University (defendant) message board with no more than 20 Texas-based subscribers and no Texas business operations. Revell sued Lidov and Columbia in Texas federal court, alleging general and specific jurisdiction over Columbia and specific jurisdiction over Lidov; the district court dismissed for lack of personal jurisdiction.
Whether a court has personal jurisdiction when the cause of action arises from posting or maintaining information on a website, where the information is neither directed toward nor based on events or sources related to the forum state.