This Note evaluates the difficulty in deciding what type of internet activity will support the exercise of personal jurisdiction over a foreign defendant. There are some discrepancies among the federal court decision as courts have been left to their own devices to decide there issues without guidance form the Supreme Court. As declared by on commentator, and expressed by the United States District Court for the district of Oregon in Millennium Enterprises, Inc. v. Millennium Music, LP, “the case law dealing with the exercise of personal jurisdiction based on an Interactive Website is a ‘current hodgepodge of case law [which] is inconsistent, irrational, and irreconcilable.

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