The Second Circuit ruled, in today’s decision in Best Van Lines, Inc. v. Walker, that making statements on an Iowa-based website about a New York-based moving company, responding to a question from a reader in New York, and accepting donations from New York readers does not subject the proprietor to jurisdiction in the New York courts under New York law. The court did not reach the issue of constitutional due process limitations on personal jurisdiction, and noted the limited scope of jurisdiction for defamation claims in the New York statute (a view influenced by the New York Times v. Sullivan case, which I have long cited as a significant horizontal-federalism case). For those who follow this issue closely, the court’s skeptical treatment of the Zippo standard for jurisdiction will be interesting.