2. One of the first cases to deal with the question of personal jurisdiction and the Internet was INSET SYSTEMS, INC. v. INSTRUCTION SET, INC., 937 F.Supp. 161 (D. Conn. 1996), which concerned a trademark infringement action by a Connecticut corporation against a Massachusetts corporation. The District Court found that defendant’s advertising on its website, although not directed at any state in particular, was sufficient to support personal jurisdiction in Connecticut under the purposeful availment test. Many courts have disagreed with the Inset Systems test for personal jurisdiction when defendant’s contacts with the forum are mostly through the Internet. In CYBERSELL, INC. v. CYBERSELL, INC., 130 F.3d 414, 418 (9th Cir. 1997), the court held that “something more” than the mere maintenance of a website is required to show that the defendant purposefully directed its activities at the forum.