Compuserve, Inc. v. Patterson case brief summary

Compuserve, Inc. v. Patterson 

Facts: CompuServe provided computer information services to individual subscribers, including access to computer software products and information resources through the Internet. Patterson was a subscriber to CompuServe. He developed a shareware software product to help people navigate through the Internet. The shareware was advertised on CompuServe’s system. Patterson’s agreement with CompuServe specifically chose OH law to control the agreement and disputes between the parties regarding the agreement. Are contacts, almost entirely electronic, sufficient to establish the minimum contacts needed for long-arm jurisdiction?

                                                                                                                           

Holding: Patterson’s combined contacts with OH and the quality of such contacts reached the level 

necessary to demonstrate purposeful availment of the benefits and protections of Ohio law.
 

1. The court determined that he had reached out to OH to subscribe to CompuServe, entered into a 

contract with CompuServe to market his shareware product over the Internet, repeatedly interacted 

with CompuServe via file transfers, e-mail, and other communications, and prompted the filing of 

this law suit through his own threat to sue CompuServe.
 

2. Patterson, acting as a software entrepreneur, chose to market his software product exclusively 

through CompuServe.
 

3. The relationship between Patterson and CompuServe was found to be important to the case.
 

4. Since Patterson’s common law trademarks were effectively established through activities in OH 

under a contract governed by OH law, it was reasonable to assert personal jurisdiction over him in 

this matter.