Website – Availment ≠ Jurisdiction.

“Louisiana residents can access Eastrock’s website, no less than residents of other states. But as our cases suggest, and as we now expressly hold, a defendant does not have sufficient minimum contacts with a forum state just because its website is accessible there. The defendant must also target the forum state by purposefully availing itself of the opportunity to do business in that state. And here, there is no evidence that Eastrock targets Louisiana: Eastrock has not sold a single accused product to a Louisiana resident, and it solicits no business there through targeted advertising. That ends this case.” Admar Int’l Inc. v. Eastrock LLC, No. 21-30098-CV (Nov. 19, 2021). (For reference, I think this is the current version of the website in question; the litigation involved the defendant’s alleged misuse of product images.)