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Personal Jurisdiction and the Internet

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Dailey v. Popma<br />

• COA Test: Whe<strong>the</strong>r D through his internet activities,<br />

manifested an intent to target <strong>and</strong> focus on North<br />

Carolina citizens<br />

• Not enough that some BB participants were North<br />

Carolinians.<br />

• Nor was it enough that D’s postings affected P in North<br />

Carolina.<br />

• Because P did not meet burden to show materials were<br />

posted with intent to direct content to NC, <strong>and</strong> presented<br />

no o<strong>the</strong>r evidence linking D to NC, dismissal was<br />

appropriate

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