CompuServe v. Patterson

Citation: CompuServe, Inc. v. Patterson, 89 F.3d 1257, 39 U.S.P.Q.2d (BNA) 1502 (6th Cir. 1996).

Factual Background
Patterson sold shareware on CompuServe under a Shareware Registration Agreement with CompuServe, which stated that Ohio law governed the relationship. The trial court held that Patterson's connection with Ohio was insufficient to support the exercise of personal jurisdiction over him under Ohio's long arm statute.

Trial Court Decision
The trial court held that the electronic “link” between the defendant in Texas and CompuServe in Ohio were “too tenuous to support the exercise of personal jurisdiction” in a lawsuit by CompuServe against a Texas subscriber.

Appellate Court Decision
The appellate court stated that “merely entering into a contract with CompuServe would not, without more, establish that Patterson had minimum contacts with Ohio. By the same token, Patterson's injection of his software product into the stream of commerce, without more, would be at best a dubious ground for jurisdiction. Because Patterson deliberately did both of those things, however,. . . we believe that ample contacts exist to support the assertion of jurisdiction in this case. . . .”