Internet Doorway, a Mississippi-based ISP, took action against Texas resident Connie Davis and others, who were sending spam e-mails which contained a forged return address, suggesting that they came from the ISPs system, a practice known as spoofing. Internet Doorway’s claim was based on trade mark infringement and trespass.
The court rejected Ms Davis’ claim that it lacked jurisdiction over her, ruling that she was “doing business” in the state of Mississippi by sending the e-mail advertisement to a Mississippi resident, the crucial act being the recipient's opening of the e-mail, not the sending. It also ruled that a single contact with a Mississippi resident was sufficient. The judge concluded,
"By sending an e-mail solicitation to the far reaches of the earth for pecuniary gain, one does so at her own peril, and cannot then claim that it is not reasonably foreseeable that she will be hauled into court in a distant jurisdiction to answer for the ramifications of that solicitation."