No Personal Jurisdiction Based on Kickstarter Advertisement “Equally Accessible in All States”

The court granted two individual defendants' motion to dismiss plaintiff's infringement action for lack of personal jurisdiction. "Plaintiff highlights the personal nature of [defendants'] advertisement on their Kickstarter page, and notes that the only means of contacting the Defendants in connection with that solicitation was through [an individual defendant's] Facebook account. . . . Kickstarter.com, due to its online nature, is equally accessible in all states. Thus, even without considering the fiduciary shield, the Defendants’ advertising campaign on Kickstarter.com cannot, by itself, be the basis for this Court to exercise personal jurisdiction over the individual Defendants.

Robinson v. Bartlow, et. al., 3-12-cv-00024 (VAWD March 22, 2013, Order) (Moon, J.).