Directory Assistants Inc. v. LK Jordan & Associates
Internet posts that specifically name a Connecticut resident can result in jurisdiction, pursuant to Connecticut General Statutes §52-59b(a)(2). The plaintiff, Directory Assistants Inc., is an advertising consulting company that helps businesses advertise efficiently in the Yellow Pages. Allegedly, a worker at LK Jordan posted negative comments online about Directory Assistants' vice president, Michael Cody, calling Cody a "Yellowpage Consultant Scam Artist," and claiming that Directory Assistants provided "no real service at very high cost," after Directory Assistants signed a contract with defendant LK Jordan & Associates. An Internet post requested that Directory Assistants' general manager "explain all the lawsuits that you have been involved in over the years in such a short amount of time." Directory Assistants sued LK Jordan and individual defendants, alleging that false statements posted on the Internet led to tortious interference with contractual relationships and business expectancies. Defendants LK Jordan, a Texas corporation, and Matt Opel, a resident of Texas, moved to dismiss, alleging lack of personal jurisdiction. The court rejected the defendants' claims that the Internet posts were not directed at Connecticut residents. The court found that the Internet posts named specific Connecticut citizens. "[T]his Court and state superior courts," wrote the District Court, "have held that internet postings that specifically target a Connecticut resident or audience are sufficient to afford the exercise of jurisdiction under Section 52-59b(a)(2)." The defendants reasonably could have anticipated being haled into Connecticut court, as a result of the allegedly false statements. The court denied the defense motion to dismiss for lack of personal jurisdiction.