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Internet Trademark Case Summaries

CompuServe, Inc. v. Patterson

89 F.3d 1257 (6th Cir. 1996)

The court held that an Ohio court could exercise jurisdiction over a Texas defendant whose contacts with the forum occurred almost exclusively through computer transmissions to CompuServe’s system in Ohio.  Based on defendant’s choice to subscribe to Ohio-based CompuServe and to enter into a software distribution arrangement with CompuServe, the court determined that defendant had “reached out” to Ohio.  Defendant had derived benefits from his advertising on CompuServe and had transacted business in the state by selling his software that was stored on CompuServe’s system.  The court further noted that defendant had electronically agreed to the provisions of the shareware-distribution agreement, one of which designated Ohio law as the law governing the contract.