The plaintiff in this case is Best Van Lines, Inc., (“BVL”), a New York based moving company, which claims to have been defamed by Tim Walker (“Walker”), a resident of Iowa, who runs a website that is exclusively meant to provide information and opinions about household movers. Walker allegedly posted statements on his website claiming that BVL had just received its license and it should not be used for moving purposes. These postings were made from Iowa and, of course, were viewable by people around the world including in New York, where the company is based.

BVL filed suit against Walker in the United States District Court for the Southern District of New York. The action was dismissed because of lack of personal jurisdiction. Decide whether or not jurisdiction is proper based on purposeful availment in the forum state and whether the court of appeals should affirm or reverse the district court’s ruling.