Promotion of Accused Product on Home Shopping Network Insufficient to Exercise Personal Jurisdiction

Defendant did not purposefully direct its activities at the forum state for purposes of personal jurisdiction. "Although the availability of the [accused product] for purchase on the HSN [Home Shopping Network] website could be a basis for personal jurisdiction, here HSN ran the website and all sales through it and [defendant] had no control." "Courts have consistently held . . . that there must be a 'sustained promotion campaign directed at' the forum state when a plaintiff seeks to establish personal jurisdiction based on a national promotion."

Pearson v. Mangano, 2-08-cv-02504 (TNWD January 26, 2009, Order).