Going to California

Yue v. Yang, No. A159145 (D1d5 Mar. 25, 2021)

A Canadian made a bunch of highly inflammatory posts against a California resident on Chinese language Internet bulletin boards that were themselves located in California. Plaintiff Californian sued for defamation. The trial court quashed service for lack of personal jurisdiction.

Generally speaking, making postings on the Internet does not subject you to personal jurisdiction anywhere they might be read by somebody upset by them. But when your stay stuff like “I am going to come to California and bully you in your back yard,” and threaten to “go to California” and “destroy you the shyster in U.S. federal court,” the posts cross the line from generalized speech on the Internet to the kind of stuff that satisfies the Calder effects test. That is, when you deliberately aim harmful speech at someone, that is specifically directed to the jurisdiction they live in, you have purposefully availed yourself of the legal regime of that state and thus of its courts. 

Reversed.