In a decision with implications for the free exchange of ideas on the Internet, a federal judge recently rejected an attempt by an author to obtain jurisdiction over an Amazon.com book reviewer in New York simply because the review could be viewed by New York Internet users. In Hammer v. Trendl, an individual living and working in Illinois posted several unflattering book reviews on the Amazon.com web site. The author of the books filed an action against the reviewer, alleging that the reviews violated federal copyright and state defamation laws. The United States District Court for the Eastern District of New York dismissed the action, finding that there was no personal jurisdiction over the reviewer. In its opinion, the court concluded that posting a book review on a website that could be viewed by New York Internet users does not demonstrate the type of purposeful activity in New York sufficient to support the exercise of personal jurisdiction.

Friedman Kaplan partner Robert D. Kaplan and associate Heather Windt represented the defendant in the action.