MBL of America's reply brief in support of its motion to dismiss for lack of personal jurisdiction or, in the alternative, dismiss for improper venue, emphasizes that jurisdiction cannot be predicated on the fact that defendants' website can be seen by New York consumers, as the site has no shopping cart function.

The brief also points out the impropriety of a German plaintiff selecting New York as venue for suit against Arizona and California defendants merely because it is a reasonable mid-point between the two locales.