structural:reformatting, structural:summarization, information:highlighting, information:filtering
Evolution of the case law

In the early 1990s, courts struggled with how to treat the Internet with regard to jurisdiction. One of the first noteworthy cases arising in this early stage was Inset Systems, Inc. v. Instruction Set, 937 F. Supp. 161 (D. Conn. 1996). The Inset court likened the company's use of the Internet to a continuous advertisement targeting customers in all states, and established an extraordinarily broad approach for Internet jurisdiction cases. Some early cases followed the Inset approach. For example, the Inset reasoning was cited by the court in Maritz, Inc. v. Cybergold, Inc. (1996) The court in Bensusan Restaurant Corp. v. King (1997), however, deviated from Inset, and established its own more tailored standard. Most notably, the court in Bensusan began looking into the nature of the website in question, holding that the website owned by the defendant was passive in nature. This launched a separate line of reasoning with regard to jurisdiction in Internet cases focused on the specific characteristics of the web, and was cited by Hearst Corp. v. Goldberger.