On-line auction seller is subject to personal jurisdiction in a distant state, court holds

Can an eBay seller be hauled into court in a distant state by a disappointed buyer?  The answer is yes, at least if defendant uses the on-line auction site as his primary commercial marketing method.  That was the conclusion reached recently by a federal district court judge in the Eastern District of Michigan.  The Michigan plaintiff was the successful bidder on two paintings defendant offered for sale.  Defendant accepted the purchase price but never shipped the paintings, and later offered a refund.  Plaintiff demanded the paintings or their fair market value.  Even though the seller conducted no business operations in Michigan, the court held he was subject to suit there.  Relevant contacts with Michigan included a series of emails and phone calls between the parties, and defendant's acceptance of payment from Michigan.  But most significantly, the seller's extensive use of the internet as his sole marketing channel meant that he should have expected to be subject to suit outside of his home state.
Dedvukaj v. Maloney, 2006 WL 2520347 (ED Mich 2006).