Jim Mohr (defendant), the sports editor for the Inland Valley Daily Bulletin (Bulletin), attended a speech on the dangers of steroids in Riverside, California. Afterward, Mohr wrote an article claiming that the speaker had said that “Bo Jackson lost his hip because of anabolic abuse.” The article was published on the Bulletin’s website on March 24, 2005 and in the newspaper the following day. The Bulletin has 65,000 print subscribers; only one is located in Illinois. There are no internet subscribers in Illinois. The Bulletin’s website has almost no interactivity with individuals outside California: the information provided and the contact phone numbers are local. Vincent “Bo” Jackson (plaintiff) filed suit in Illinois state court against Mohr and the Bulletin’s owners and affiliates (defendants) for defamation, invasion of privacy, and intentional infliction of emotional distress. The defendants removed the case to the United States District Court for the Northern District of Illinois and moved to dismiss under Fed. R. Civ. P. 12(b)(2) for lack of personal jurisdiction.