Bookmark and Share



» Access to Courts and Court Remedies

» Campaign Finance and Election Laws

» Constitutional Rights and Requirements

» Health, Safety, and Environment

» Open Government and Open Courts

» Representing Consumers

» Workers' Rights

Currently Featured Topics

Government Transparency
Consumer Justice
First Amendment
Health, Safety and the Environment


Read about our work helping lawyers
with cases in the Supreme Court.


  Public Citizen | Litigation Cases ***Search other cases***

Internet Solutions Corporation v. Marshall

Topic(s): Court Procedure, Federal Jurisdiction, and Appellate Jurisdiction
Internet Free Speech - Miscellaneous



A company called Internet Solutions Corporation (ILC) sued Tabatha Marshall, a website owner located in the state of Washington, over allegedly defamatory statements about ILC made on Marshall’s website. ILC, whose principal place of business is in Florida, filed the suit in federal district court in Florida. Marshall moved to dismiss for lack of personal jurisdiction, and ILC appealed. The Eleventh Circuit then asked the Florida Supreme Court to address the question whether the allegedly defamatory posts on the website subjected the owner to personal jurisdiction in Florida under Florida’s long-arm statute. Public Citizen filed a brief arguing that someone who refers to a company on a website that is accessible in all states cannot reasonably expect to face jurisdiction in every state where that website can be viewed. Accordingly, in determining whether jurisdiction is proper, courts should look to whether a website specifically targets forum residents and whether the site is commercially interactive. Because here, defendant Marshall posted the allegedly defamatory statements on a noncommercial, minimally interactive website that did not specifically target Florida residents, she should not be subjected to jurisdiction in Florida. The Florida Supreme Court, however, held that jurisdiction was proper under Florida’s long-arm statute because the website was accessible and accessed in Florida.

Copyright © 2017 Public Citizen. Some rights reserved. Non-commercial use of text and images in which Public Citizen holds the copyright is permitted, with attribution, under the terms and conditions of a Creative Commons License. This Web site is shared by Public Citizen Inc. and Public Citizen Foundation. Learn More about the distinction between these two components of Public Citizen.

Public Citizen, Inc. and Public Citizen Foundation


Together, two separate corporate entities called Public Citizen, Inc. and Public Citizen Foundation, Inc., form Public Citizen. Both entities are part of the same overall organization, and this Web site refers to the two organizations collectively as Public Citizen.

Although the work of the two components overlaps, some activities are done by one component and not the other. The primary distinction is with respect to lobbying activity. Public Citizen, Inc., an IRS § 501(c)(4) entity, lobbies Congress to advance Public Citizen’s mission of protecting public health and safety, advancing government transparency, and urging corporate accountability. Public Citizen Foundation, however, is an IRS § 501(c)(3) organization. Accordingly, its ability to engage in lobbying is limited by federal law, but it may receive donations that are tax-deductible by the contributor. Public Citizen Inc. does most of the lobbying activity discussed on the Public Citizen Web site. Public Citizen Foundation performs most of the litigation and education activities discussed on the Web site.

You may make a contribution to Public Citizen, Inc., Public Citizen Foundation, or both. Contributions to both organizations are used to support our public interest work. However, each Public Citizen component will use only the funds contributed directly to it to carry out the activities it conducts as part of Public Citizen’s mission. Only gifts to the Foundation are tax-deductible. Individuals who want to join Public Citizen should make a contribution to Public Citizen, Inc., which will not be tax deductible.


To become a member of Public Citizen, click here.
To become a member and make an additional tax-deductible donation to Public Citizen Foundation, click here.