4. In KEETON v. HUSTLER MAGAZINE, INC., 465 U.S. 770, 104 S.Ct. 1473, 79 L.Ed.2d 790 (1984), Kathy Keeton, a resident of New York, brought a libel suit in federal district court in New Hampshire against Hustler Magazine, an Ohio corporation. The jurisdictional reach of the federal court was limited to that of the state in which it sat, so the district court could serve process only under the authority of the New Hampshire long-arm statute. See Fed. R.

Civ. P. 4(k)(1)(A), discussed at p. 197, infra. Keeton chose to sue in New Hampshire because it was the only state where the statute of limitations did not time-bar the action at the time of filing. She argued that jurisdiction existed because Hustler sold ten to fifteen thousand magazines a month in the state. Keeton herself had only one connection to New Hampshire:

a magazine that she helped to produce was circulated there.

The District Court dismissed Keeton’s suit for lack of jurisdiction, and the First Circuit affirmed, holding that Keeton’s lack of contacts with New Hampshire rendered the state’s interest in redressing the libel, in a suit seeking nationwide damages, was too attenuated to support jurisdiction. The Supreme Court unanimously reversed, saying: