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).