That one donation could have spoiled the whole thing

In Carefree of Maryland, Inc. v. Carefree Pregnancy Centers, Inc., the Fourth Circuit in a published opinion by Judge King joined by Chief Judge Wilkins and Judge Motz answered "no" to the question of "whether an Illinois organization subjected itself to personal jurisdiction in Maryland by operating an Internet website that allegedly infringed the trademark rights of a Maryland insurance company," where 0.0174% of the Illinois company's donations came from Maryland, and "[a]part from a single online donation made by the lawyer for Carefirst in this proceeding, there is no evidence that the Maryland donations were made through the website."