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X. Kevin Zhao X. Kevin Zhao

In Calder v. Jones, a California plaintiff sued two Florida defendants for libel based on an article that they had written in Florida that was circulated in California, which caused her to suffer reputational harm. Applying what is now commonly referred to as the “effects test,” the Supreme Court held that “because California [was] the focal point both of the story and 8th Circuit Spotlightof the harm suffered,” “[j]urisdiction over [the defendants] [was] proper in California based on the ‘effects’ of their Florida conduct in California.” 465 U.S. 783, 789 (1984).

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