• Digital Control Inc. v. Boretronics, 161 F. Supp. 2d 1183 (W.D. Wash. 2001) (holding that an advertiser has not "purposely directed" its activities at a particular forum until it "is actually faced with and makes the choice to dive into a particular forum")

• American Information Corp. v. American Infometrics Inc., 139 F. Supp. 2d 696 (D. Md. 2001) (although defendant"s site provided "interactivity" in the form of links to search engines, price lists, and contact information, and the site generally was directed at finding customers in the United States, no jurisdiction in Maryland court because there was no evidence that the defendant had ever targeted Maryland in particular and or actually fielded any queries from Maryland prospective customers)