In Jardim v Overley, the Appellate Division held that a one time transaction involving the sale of a “vintage car” arising from an internet posting by a California seller did not constitute “minimum contacts” providing jurisdiction in New Jersey when the buyer discovered the car to be in poor condition upon arrival. Plaintiff had an e-mail exchange with the seller making a counter offer to buy the convertible, and plaintiff and a business associate each had a telephone discussion with the seller before the transaction was completed. Plaintiff sent the deposit through PayPal.com.

Plaintiff or his associate also arranged for shipping the car to New Jersey and for financing by a New Jersey credit union which paid for the car after receiving title, which was transferred in California.

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