MacDermid, Inc. v. Deiter No. 11-5388 (2d Cir. Dec. 26, 2012)
Employee in Canada accesses email from USA employer.
Employer sues in Connecticut alleging misappropriation of confidential information.
“From one computer in Canada to another computer in Canada.” District Court: No personal jurisdiction. (reversed)
Jurisdiction is appropriate. Defendant intentionally accessed servers known to be in Connecticut. Second Circuit holds: