In J. McIntyre Machinery Ltd. v. Nicastro, 564 U.S. 873, 131 S. Ct. 2780 (2011), the Supreme Court held that a court in New Jersey could not exercise personal jurisdiction over a foreign defendant whose product, distributed through an American company whose charge was to target the U.S. market as a whole, caused a severe injury in New Jersey. The result reflects a restrictive view of personal jurisdiction. At the same time, the absence of a majority opinion leaves the message of Nicastro uncertain. Does Nicastro herald a new approach to personal jurisdiction in which plaintiffs will find it increasingly difficult to establish jurisdiction over out-of-state and foreign defendants? Or does it leave the law largely unchanged? With two years of judicial decisions interpreting Nicastro now on the books, a substantial body of law exists from which to draw tentative conclusions.