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Revell v. Lidov

United States Court of Appeals for the Fifth Circuit
317 F.3d 467 (5th Cir. 2002)


Lidov (defendant) wrote an article, which allegedly defamed Revell (plaintiff). At the time he wrote the article, Lidov did not know that Revell was a Texas resident. The majority of the article’s content was based on events that occurred outside of Texas, and Lidov did not use Texas-based sources. Lidov posted the article on a website maintained by Columbia University. The website served as a forum for subscribers to post articles and read materials posted by other subscribers. The website had no more than 20 subscribers from Texas. Revell sued Lidov and the Board of Trustees of Columbia University (Columbia) (defendant) in Texas federal court. Revell alleged the court had general and specific jurisdiction over Columbia and specific jurisdiction over Lidov. Lidov was a Massachusetts resident and Columbia’s principal place of business was in New York. Columbia did not maintain business operations in Texas. The district court dismissed the case for lack of personal jurisdiction.

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