In Yahoo! Inc. v. La Ligue Contre Le Racisme et l'antisemitisme (LICRA), the Ninth Circuit applied the Calder test to find that a California court could properly establish specific personal jurisdiction in a declaratory judgment action against two French civil rights organizations suing Yahoo! and Yahoo! France over the availability of Nazi content to French users of its services. Under the threat of substantial financial penalty, the French Court ordered Yahoo! in two interim orders to take "all necessary measures to dissuade and render impossible" access within France to sites displaying Nazi paraphernalia or other anti-Semitic content, and directed Yahoo! France to display an interstitial warning to users in France prior to enabling their access to Yahoo.com.French Court Order (Nov. 20, 2000). While Yahoo! France substantially complied with the orders, Yahoo! resisted the French court's efforts to dictate changes to its US-based services. (Yahoo! later adopted a policy change addressing many of the French complaints, allegedly for independent reasons.)
