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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.

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