Personal Jurisdiction Found Where Website Harms

Addressing issues of personal jurisdiction regarding copyright infringement on the internet, the U.S. Court of Appeals for the Eleventh Circuit reversed a lower court's ruling and found that a Tennessee website operator was subject to jurisdiction for copyright infringement of a Florida resident's works. Licciardello v. Lovelady, 2008 U.S. App. LEXIS 21376 (11^th Cir., Oct. 10, 2008) (Hill, J.).

Plaintiff Carman Licciardello (Licciardello) has been a nationally-known Christian musician and entertainer for more than 25 years. From 2000 to 2001, Rendy Lovelady ("Lovelady") was employed by Licciardello as his personal manager; Lovelady also managed Licciardello's concert tour during that year. Licciardello alleges that in early 2006, Lovelady posted a website on the internet that was accessible to the public in Florida that promoted Lovelady as a personal manager for music artists. The website used Licciardello's trademarked name and his picture, implying that