Courts have been struggling with the issue of personal jurisdiction based on Internet activity since the mid-1990s. For some reason, courts were either reluctant or technologically ill-equipped to apply long-standing principles of personal jurisdiction to Internet-based causes of action. Courts initially deemed the Internet too unique and complex to fit squarely within the ambit of traditional personal jurisdiction analysis. Therefore, courts all over the United States began crafting new tests of Internet-based personal jurisdiction from scratch.

This paper argues that a separate legal doctrine for Internet-based personal jurisdiction is unnecessary. Traditional personal jurisdiction analysis is flexible enough to accommodate changes in technology and Internet-based activities can be analyzed under these existing requirements. Witnessing the courts spin their wheels while trying to come to a consensus on a new legal doctrine is proof that a specific test for Internet-based personal jurisdiction is inappropriate and gratuitous.