A second approach is to view the Internet as a highway that allows users to travel from one place to another. This single point presence approach would closely mirror the current legal view of telephone communications. Personal jurisdiction generally is limited to the receiving end of a phone call, as the caller should know where he is calling, but the receiver cannot tell where the call is coming from. Thus, the caller purposefully avails her activity to the forum state. This approach would require courts to determine who initiated the conduct that gives rise to the suit.
Additional conduct is required.
A good example of the highway approach can be found in Zippo Manufacturing Co. v. Zippo Dot Com, Inc . One end of the scale is defined by situations where a defendant is clearly conducting business over the Internet. The case cited by Zippo as the example here is Compuserve, Inc. v. Patterson . The Texas defendant threatened to sue when Compuserve began marketing a similar product.