Express aiming

The second part of the effects test requires that the defendant's conduct be expressly aimed at the forum. "'[S]omething more' than mere foreseeability [is required] in order to justify the assertion of personal jurisdiction," and that “something more” means conduct expressly aimed at the forum.

The maintenance of a passive website alone cannot satisfy the express aiming prong. It is equally clear, however, that “operating even a passive website in conjunction with ‘something more’ &mdash; conduct directly targeting the forum &mdash; is sufficient to confer personal jurisdiction.” Regardless of whether a case involves the Internet, the question remains whether the defendant's conduct was expressly aimed at the forum.

"Express aiming is a concept that in the jurisdictional context hardly defines itself." This much, however, is clear: “the [express aiming] requirement is satisfied when the defendant is alleged to have engaged in wrongful conduct targeted at a plaintiff whom the defendant knows to be a resident of the forum state.”