This note discusses the procedural history of Panavision. Part III surveys the evolving application of personal jurisdiction in the various courts as applied to the Internet through minimum contacts and the Calder "effects test." Part IV outlines the Ninth Circuit's analysis of personal jurisdiction in Panavision. Part V critiques the Ninth Circuit's analysis, focusing particularly on several flaws in the court's reasoning. Part VI summarizes the effect that the decision in Panavision will have on future suits involving the Internet.
Scott D. Sanford,
Nowhere to Run ... Nowhere to Hide: Trademark Holders Reign Supreme in Panavision lnt'l, L.P. v. Toeppen., 29 Golden Gate U. L. Rev.