1. Has Attaining Permeant Resident Status in Singapore Become Harder?
  2. The Next Trends in Internet Entertainment
  3. Current Scenario of Online Poker Gaming In India
  4. Shut down the lab or we’ll destroy the computer
  5. Disappointing examination results stay on Instagram
  6. What the Experts Are Saying About Moved Store Bought and What It Means For You
  7. What Business Goals Onpage Is – and What it Is Not
  8. Buyer Beware – A Guide to Buying Classic Video Games on eBay
  9. How To Wisely Buy A New Computer
  10. Beginner’s Guide to Computer Forensics
  11. Breaking the Computer Buying
  12. Computer Knowledge (Literacy)
  13. Evolution of Technology – The History of Computers
  14. Crunch Power And The Simulation Hypothesis
  15. Computer or Buy a New One?
  16. Online Computer Repair and Remote Virus Removal
  17. Are We Too Dependent on Computers?
  18. Cloud Computing – Is It Safe?
  19. Thirteen Steps to Successful Blogging
  20. 12 Things You Need to Know Before You Even Start a Blog
  21. Why I Love Blogging
  22. 7 Best Blogging Platforms to Start a Blog for Free
  23. 15 Reasons Why You Should Start a Blog Today
  24. Why You Should Blog To Make Money Online
  25. A Blog Marketing Plan – The Basics
  26. Why Most Bloggers Never See Their Blogs As a Business
  27. Use Blogging for Profit
  28. Five Smart Ways To Make Big Money From Blogging
  29. Arkansas Life Insurance Guide – How to Find Cheap Arkansas Term Life Insurance Rates
  30. Life Insurance Settlements Viewed Through the Eye of the NASD – A Study in Compliance
  31. It’s Ok to Say No to Technology for Your Kids and Why I Didn’t
  32. Tips to Secure Your Small Business Network
  33. New Business Startup Checklist
  34. Book Ghostwriter on Google
  35. 5 Steps on How to Start Affiliate Marketing for Beginners
  36. Shhh – Not In Front Of The Television
  37. What Every Investor Should Know About Options!
  38. Review: My Year With Microsoft Surface Pro
  39. Android 6.Zero Marshmallow: What’s on the Cards?
  40. Life Coaching – Past, Present, and Future
  41. Why Hire a Life Coach?
  42. The Condition For Man To Have Eternal Life
  43. Past Life – Wanting to Know Who I Was in My Past-Life
  44. Dividend Paying Whole Life Insurance – Understanding What Sets it Apart
  45. Step Up to a Better Life With the Help of a Good Coach
  46. 10 SEO Tips to Get Your WordPress Blog Ranking Highly in the Search Engines
  47. 4 Quick SEO Tips To Help You Make More Money From Home
  48. SEO Tips on Hiring an SEO Expert
  49. 9 Blog SEO Tips to Assist Your Blog Rankings
  50. Five SEO Tips: You Should Know
  51. Satellite Internet Access – No DSL Or Cable – No Problem
  52. Three Exchange Traded Funds to Invest in the Internet
  53. Large Companies Need Internet T3 Line
  54. Web Internet Marketing, Increase Income By Improving Sales Process In Any Business On The Internet
  55. The Key Role of InThe Key Role of Internet Service Providers To Their Subscribersternet Service Providers To Their Subscribers
  56. Satellite Internet: Getting Things Done Faster
  57. Learn More About Computer Internet Cable
  58. Wireless Internet for Laptops: The Norm Today
  59. Greater Opportunities for the Finer Salt Cave Here
  60. Internet Business Is a Pretty Big Place
  61. Should I Use The Internet for My Network Marketing Business?
  62. How Does Wireless Internet Work – Four Ways to Establish Wireless Connection to the Internet
  63. Speed Up Internet Windows 7
  64. Top Rural Area High Speed Internet Providers
  65. What Does Internet-Enabled Mean To The Average Construction Professional?What Does Internet-Enabled Mean To The Average Construction Professional?
  66. Back To School Internet Safety Tips For Parents
  67. 5 Great Uses of the Internet
  68. Comcast Internet Essentials Program – A Possible Solution To Help Bridge The US Digital Divide
  69. Kids Safety On The Internet – The Technology Blame Game?
  70. Internet Marketing Pt 1
  71. The Internet in Our Future
  72. What Is Broadband Internet? My Options
  73. How to Choose Your Internet Download Speed?
  74. Tips to Keep in Mind While Going for Internet Service
  75. What Can Broadband Internet Do For Me?
  76. The Growth of the Internet Economy
  77. What Are The Advantages Of Satellite Internet Over DSL Internet?
  78. The Most Interesting Facts About Broadband Internet
  79. Is a Wireless Internet Connection Right For You?
  80. Advantages of Getting Internet Connection From Broadband Internet Service Providers
  81. The Primary Duty of the Intermediary in Internet Oil Trading and Refined Petroleum Product Deals
  82. How Internet Brokers and Agents Kill Petroleum Deals and Oil Deals As Intermediaries in Trading
  83. Helpful Tips In Saving From Costs Of High Speed Internet
  84. 50 Amazing Facts About the Internet
  85. The Power of Internet: It’s Like a Magic!
  86. The Truth About Internet Money
  87. Effects of Internet in Today’s Lifestyles
  88. Selecting the Best Type of Internet Service Provider for Your Needs
  89. Boosting Internet Access Resilience, ISP Multihoming Explained
  90. How the Internet Is Structured
  91. Where Internet Jurisdiction Can Get Your Business Sued!
  92. Important Information About The Internet And Computers
  93. Rural Wireless Broadband Internet – How Does It Work And How Can I Get It?
  94. Flattening The American Internet
  95. Purchase Order Financing Tips and Secrets for Canadian Firms Seeking Trade Finance
  96. 7 Top-Rated Tourist Attractions in Palm Springs
  97. Are Inventory Financing Lenders and P O Factoring Solutions Your Best Business Financing Bet?
  98. Who’s Financing Inventory and Using Purchase Order Finance (P O Finance)? Your Competitors!
  99. Alternative Financing for Wholesale Produce Distributors
  100. Sources of Business Finance
  101. Alternative Sources of Business Growth Finance: There Is More Than One Way to Fund Growth
  102. Car Finance – What You Should Know About Dealer Finance
  103. Alternative Financing Vs. Venture Capital: Which Option Is Best for Boosting Working Capital?
  104. Best in Class Finance Functions For Police Forces
  105. Finance, Credit, Investments – Economical Categories
  106. Immortalizing Values Through Education for Sustainable Development
  107. Italy bridge: State of emergency follows Genoa catastrophe
  108. New Zealand bans sales of houses to foreigners
  109. Mystery Russian satellite’s behaviour increases alarm in US
  110. Face transplant: A ‘second risk’ for young suicide survivor
  111. Stocks in the news: Kotak Mahindra Bank, ONGC, Fortis Health, Khadim, UPL, Hathway Cable, MMTC
  112. Teacher Education and Teacher Quality
  113. Making Online Education Attractive
  114. Education Loans Can Augment The Boundaries Of What You Can Achieve
  115. Improving the Quality of Education: A 360 Degree Perspective on Education CSR in India
  116. Educational Problem Solving
  117. An Inside Look at the Special Education Profession
  118. 5 Best Layered Inverted Bob Haircuts You Should Try | Glaminati.Com
  119. Technology’s Effect on Commercial Real Estate in a Recession
  120. Trends in Technology
  121. Monitor Technology Explained
  122. Pros And Cons Of Online Education For The World Citizen
  123. Technology and Innovation Management
  124. Impact Of Technology In Banking
  125. Technology – Who Needs It?
  126. Implementing New Technology
  127. Automotive Advertising Agencies Must Use Yesterday’s Knowledge & Tomorrow’s Technology to Survive
  128. Cool Gadgets Shopper – Irresistible Gadgets Your Customers Will Love
  129. Do What You Do Best – Realistic Technology Tips For Paralegals
  130. Top 5 Twisted, Yet Fun Games of All Time
  131. Difference Between On-Campus Education and Online Education
  132. Electronics Gadgets Selling Tutorial: 15+ Wee Devices That Will Make Your Store a Big Hit On The Net
  133. Electronic Gadgets Sales For Morons: Ten+ Devices You Can Wear
  134. Self-Defense Gadgets And Gizmo’s – Should You Carry A Personal Safety Weapon?
  135. The Many Gadgets Available To Compliment Both Him And Her
  136. Kitchen Equipment And Gadgets For Your Raw Food Kitchen
  137. Buying a Clinical Information Technology System
  138. Cool Gadgets Shopper – Why You Need A Laser Light
  139. The Newest Home Electronics and the Latest Travel Gadgets
  140. Spy Gadgets Hints: Where to Use 17 Different Camouflaged Cameras
  141. Selling Automobile Dealerships to Public Companies – Effect of Framework Agreements
  142. Interview with Dr Renato C Nicolai, Author of “The Nightmare That Is Public Education”
  143. Millennium Education Development – Ways To Achieve
  144. Globalisation And Primary Education Development In Tanzania: Prospects And ChallengesGlobalisation And Primary Education Development In Tanzania: Prospects And Challenges
  145. Keep Your PC Healthy With Computer Tips & Tricks
  146. Use This Simple Computer Tip to Save Time Using the Internet
  147. 5 Stress Reducing Computer Tips
  148. Computer Tips From My Journal
  149. Speed Up Computer Tips
  150. Best Computer Tips to Help With Slowing Computer Problems
  151. Essential Computer Tips You Should Learn Right Now
  152. Home Computing Tips for Getting More From Your Technology
  153. Computer Tips that Help Small Businesses Operate Profitably
  154. Computer Tips – Some Useful Computer Tips For Average Computer User
  155. Spyware – Now a Problem for Mac Users as Well
  156. 15 Alluring Stacked Bob Haircuts to Brighten Your Day| Lovehairstyles.com
  157. The Non-Hostile Overview Of Choosing A PC Or Mac For Your Computing Needs
  158. What Went Wrong? When Relationships Go From Hot To Cold
  159. Malware on the Mac – Viruses, Spyware, Worms, and Other Digital Nasties Are Coming to the Mac
  160. How to Run Windows on a Mac
  161. Fixing a Slow Mac: Discover The Ultimate Solution
  162. Advantages and Features of Mac Computers
  163. Switching From PC to Mac
  164. Mac Mini User Guide
  165. The Short Awkward Life of Mac Remora
  166. Mac Media Center
  167. Software As a Service (SaaS) Software on Demand – Using SaaS the Smart Way
  168. 10 Ways Baby Boomers Can Be Happier in 2018
  169. Predictive Dialer Software – Functions, Benefits and Features of This Tool
  170. Do You Have What It Takes?
  171. Is Technology a Bringer of Great Promise or Great Peril?
  172. What to Look for When Hiring an HVAC Professional
  173. Four Steps To Become Successful With Affiliate Marketing
  174. Eleven Minimalist Mindset Tips
  175. Miracles, The Power of the Web, Selfless Love and Acts of Kindness
  176. Top 10 Causes of Online Marketing Burnout
  177. Welfare of the Internet of Things
  178. Operational Route Accounting ERP Software: Benefits and Obstacles
  179. 3 Benefits to Using Cloud Yoga Business Software for Your Yoga Studio
  180. Software Engineering and the Intelligence Community – Setting Real Time Standards
  181. Importance of Software Testing in the IT Industry
  182. Death of an Automobile Dealership
  183. Electronics Gadgets – 13-Plus Disclaimers and Disclaimer Templates to Keep You Out of Trouble
  184. Automobile Accidents Are Easy to Prevent Using Modern Technology
  185. Compensation Caused via Automobile Accidents
  186. Site Control For Automobile Dealerships in the 21st Century
  187. The Automobile: Profit and Status, Waste and Pollution
  188. A Subjective Insight of the Future Automobile
  189. How to Save on Automobile Insurance
  190. Forty Years of Sheer Galveston Fascination
  191. Visit the Beautiful Places in Darjeeling, the Queen of the Himalayas
  192. Rhode Island Personal Injury Law FAQS and Automobile – Car Accidents – through a RI Lawyer – Attorney
  193. Buying and Selling Automobile Dealerships – Limitations When Negotiating the Contract
  194. Confused With All the Travel Information at the Internet?
  195. Friendly Places to Travel With Grand Children
  196. I’m Going to Cuba – And Other Adventures!
  197. The Trek to Upper Mustang – The Forbidden Kingdom
  198. Tazaungmon And The Tazaungdaing Light Festival
  199. Explore Antigua
  200. Cuba: Yesterday, Today and Tomorrow
  201. The South Shore Pub Tour Along Nova Scotia’s Fabulous South Shore Lighthouse Route
  202. How to Get Started With Sports Betting
  203. The National Service Factor in Sports Development
  204. Title IX – Sports
  205. A Brief Theology of Sports
  206. Youth Sports – The Role of Organized Sports in Your Child’s Life
  207. Sport and the Russian Revolution
  208. Modern Trends in Sports Administration and Management
  209. Which Software Testing Company?
  210. Accounting and Payroll Software – Industry Jargon Defined
  211. The Case for Flag Football As an Olympic Sport
  212. Peak Performance in Sports
  213. Sports Betting Champ, John Morrison Sports Betting Product Review!
  214. What Is iCloud, and Do I Need It?
  215. Is the iPhone 4S a Huge Waste of Money? Find Out Why You Should Keep Your iPhone four and Not Upgrade
  216. Should I Upgrade My iPad? What’s Inside Does Not Matter That Much
  217. How Is Apples IOS 6 Passbook App Going to Change the Electronic Wallet World?
  218. Ultima Forever: Quest for the Avatar iOS (Pre) Review
  219. Five Yes’ to the iPhone 5S!
  220. Areas That iPhone 4 Still Crumble to Android
  221. New Mobile Applications Stock Market
  222. ICloud – The Essential Guide
  223. An Introduction to Mobile Applications
  224. Apple’s IOS Vs Google’s Android OS Vs Blackberry’s Rim Vs Microsoft’s Windows Mobile
  225. Finding The Best Small Business Scheduling Software
  226. The Top Facebook Games of 2010
  227. Most Anticipated Video Games of 2010
  228. Different Types of Card Games
  229. Apple iOS five.0 Features: Notifications, iMessages and All Other Goodies You Need to Know
  230. 10 Ways to Market Your Mobile App
  231. Mobile Application Development – Current Technologies
  232. Understanding Mobile Phones
  233. Rapid Web-Based Desktop And Mobile Application Development
  234. Introduction to Designing Open Source Games for the Google Smart Phones
  235. History of Video Games – The First Video Game Ever Made?
  236. Mobile Sales Force Automation – How businesses doubled its income quantity with wi-fi technologies
  237. The Mobile Landscape – The Truth Behind the Hype
  238. Everything About Mobile Apps That You Want to Know!
  239. Considerations When Creating A Mobility Extension To The Corporate Network
  240. Tablet Wars! VHS or Betamax? Android, Apple, or Playbook?
  241. How to Select the Best Android Tablet
  242. Purchasing a Top Android Phone is a Good Decision
  243. An Introduction to Forensics Data Acquisition From Android Mobile Devices
  244. Comparing the Widows Mobile and Android Develpment Platform
  245. Every Man Is An Island: The Fragmentation of Android
  246. Google’s Android Phones Challenge Apple iPhone For Smartphone Market Share
  247. Android User Security
  248. 10 Free Android Apps That Will Actually Make You Money While Shopping!
  249. How to Pick Video Games Both Parents and Their Kids Will Love
  250. Exercise for the Brain
  251. How Prefabrication Is Helping the Hospitality Sector
  252. IPhone Vs Android Battle Royale
  253. Eight Ways To Awaken Your Greatness And Affirm Your True Power
  254. Why You’re So Damn Ugly And How To Become Beautiful Or Handsome
  255. The Power Of Awareness: How To Cultivate Mindfulness In Your Everyday Life
  256. IRR Transfer for Dependency or Hardship
  257. The Cure To Loneliness
  258. Top Ways to Prevent Data Loss
  259. Five Ways to Build Enterprise Mobile Apps “The Right Way”
  260. 6 Website Must-Have’s for Small Businesses
  261. Top 5 Most Important Aspects of Your Game
  262. How To Not Fail With Your New Year’s Resolutions
  263. Extreme Celestial Magnifying Glass Detects Dim Galaxies In The Primeval Universe
  264. How to Worship God According to Jesus
  265. Particles Born In A Black Hole’s Hostile Winds
  266. Hot Jupiter Planets: Any Way The Wind Blows
  267. Project-Based Teaching Methods
  268. Can Chia Seeds Reverse Diabetes?
  269. Mezcal in Oaxaca: State, National and Global Significance of Mexico’s Iconic Spirit
  270. The Magic Power of Perception
  271. Seven Chakras and Seven Colors Interconnected
  272. How to Control Stress Eating
  273. Killer Foods
  274. Stop Body Hate: Seven Mindset Qualities to Love Your Body
  275. What Is Calcium And What Does It Do?
  276. Calcium Needs At All Life Stages
  277. How to Achieve Health and Fitness
  278. 7 Main Reasons to Drink More Water
  279. 15 Amazing Healthcare Technology Innovations
  280. Earth’s Moon Has A Soggy Secret
  281. Messages From the Grave – Hit Over the Head With a Double Boiler
  282. Poetry and the Muses
  283. Cancer Antidote three-D
  284. A Fond Farewell To A Misty Moon
  285. What Makes a Good Game, and Where Will it Lead Us From Here?
  286. Not Even Jealousy Can Stop God
  287. The Mysterious Magnetic Personality Of Our Star
  288. Some Anti-Theist Religious Bits & Pieces: Round Sixteen
  289. Your Thoughts Determine Your Life
  290. What Are the Causes of PMS?
  291. 20 Exhilarating Destinations To Explore In India With Your Girl-Gang
  292. Psychology in China – Fairy Tales For Therapy
  293. 9 Tested search engine marketing Tips
  294. A Shaman Shares Knowledge
  295. Online Dating one hundred and one – Online Dating Basics
  296. Top 10 Doris Day Movies
  297. Creating A Life You Love
  298. How to Clean-up Your Allergies with 2 Easy Home Tips
  299. Vanity Killed My Car
  300. SEO Tips for Lawyers – Five Crucial Keys to Organic Search Engine Optimization
  301. 10 search engine marketing Tips to Be #1 on Search Engines
  302. Top five SEO Tips For WordPress
  303. How To Make More Money
  304. 25 search engine marketing Tips for Visitors and Search Engines Using Newswire Techniques
  305. The Growing Popularity of Free & Casual Games
  306. Top 10 SEO Tips That Will Get Your Site Ranked Higher in Google
  307. 6 search engine optimization Tips for Better Search Engine Rankings
  308. Five Ways To Make Money With Your Website
  309. Importance of Social Proof for the Hospitality Industry
  310. Five Important On Page search engine marketing Tips
  311. An Ounce of Prevention – 16 search engine marketing Tips
  312. 38+ Quick SEO Tips for E-Commerce Websites
  313. Avoiding Website Headaches
  314. RIP-OFFS: Online Computer Repair and Remote Virus Removal
  315. Should I Fix My Computer or Buy a New One?
  316. Computing Crunch Power And The Simulation Hypothesis
  317. The Evolution of Technology – The History of Computers
  318. Scope of Online Degrees in Computer Sciences
  319. Breaking the Computer Buying Cycle
  320. The Best Computer Equipment for Day Trading E-Mini Futures
  321. What Does Office 2016 Mean to a Small to Medium Business?
  322. 5 High Demand Technology Skills for 2016
  323. 10 Health Problems Caused by Computer Use and How to Win Them
  324. 4 Content Marketing Mistakes You Should Avoid in 2016
  325. Content Marketing Trends In 2016
  326. Driving Free Website Traffic in 2016
  327. 5 Tips To Do Social Media Marketing In 2016
  328. Working With Fashion Bloggers for Product Promotion and Purchasing Decisions Is Smart
  329. The Spectrum of Death: Perspective on News Coverage
  330. Book Trailers: Compiling & Arranging Elements for Effective Results
  331. Japanese Guys Think Europeans Girls Are Not Into Them – They Are So Wrong!
  332. How to Prevent Pre-Diabetes From Getting Worse
  333. Top three Books for Inspiration on How To Work Smarter, Not Harder
  334. The Walrus and the Honeybee: Remembering Buckfast
  335. Bloggers’ Parties For Product Promotion
  336. Blogger Tricks – Simple Blogger Tricks And Tips For New Bloggers
  337. How a blogger went from sharing stock picks to building his own version of the hottest investment product around
  338. Nigerian blogger detained for criticising governor in prison 10 days after
  339. Why a massive DDoS attack on a blogger has internet experts worried
  340. Saudi Arabian teen arrested for online videos with American blogger
  341. Should Australians Still Invest Properties in the United States?
  342. Financial Modeling: Investment Property Model
  343. What Constitutes Separate Property in Virginia?
  344. How to Rent My Property
  345. 5 Reasons Why Investing in Property in Hull Will Create Wealth
  346. Yours, Mine and Ours: How Spouses Share and Transfer Property
  347. Ten Tips for Comparing Health Care Policies
  348. Beauty Spells Really Make You Beautiful
  349. Patient Abandonment – Home Health Care
  350. What is Taught in Beauty Schools?
  351. The Simulation Hypothesis: Even More Evidence From Physics
  352. How To Make Money Online Today – The Basic Process
  353. Career Change At 50 – Start Working From Home
  354. Even More Religious Shorts
  355. Sample Counseling Statement, IRR Transfer
  356. Writing Website Content – Who Are You Writing To?
  357. 12 Great Reasons To Have A Niche Website
  358. Why Your Metabolic Age Matters
  359. Alternative Sources of Business Growth Finance
  360. Best in Class Finance Functions
  361. What You Should Know About Dealer Finance
  362. Safe Driving Through Mexico’s Yucatan From Oaxaca: Archaeology Agave Crafts Wildlife Nature & More
  363. Boosting Your Audience Engagement to the Max
  364. Revenue-Based Financing for Technology Companies With No Hard Assets
  365. The New Rule For Buying a Home – Using Owner Financing
  366. Learning a Language In the Throes of the Perfectionist Syndrome
  367. Accounts Receivable Financing – Don’t Worry, Be Happy
  368. What Does the Bible Say About Beauty?
  369. Where within the World Is Your Finance Penetration?
  370. The Best Car Deals – Low Finance Rates Vs Rebates – Which Should You Choose?
  371. Real True Beauty
  372. What the Heck is Owner Financing?
  373. Finance, Credit, Investments
  374. Debunking 3 Common WordPress Myths
  375. WordPress Banned The Website Of The Fascist Group Linked To The Alleged Charlottesville Killer
  376. WordPress Migrations Made Easy
  377. Comparison Between Open Source CMS Systems and Commercial Open Source Systems
  378. Inner Beauty – Beauty Goes Beyond What the Eye Can See
  379. Simple Homemade Beauty Tips To Implement For Natural Beauty
  380. Beauty – An Essential Ingredient For Choosing A Spouse
  381. What Does Really Beauty Means?
  382. How to Feel Beautiful: Feel Beautiful and Celebrate Ourselves
  383. What Do I Do: WordPress or HTML?
  384. Taking Your WordPress Website To The Next Level
  385. How to Use Cpanel
  386. Benefits of College Education
  387. Basic Building Block of Starting a Profitable Blog
  388. Why is Education So Important? Something We Don’t Think of But Should
  389. Real Beauty – Bliss!
  390. The Real Reasons for Society’s Immense Influence on Education
  391. Your Network Marketing Business Blog – 5 Good Reasons To Use WordPress
  392. WordPress search engine marketing
  393. The Numerous and Useful Advantages of the Internet in Education
  394. Unexpectedly Brilliant Uses of Computers in Education
  395. Beliefs About the Purpose of Education You Probably Didn’t Know
  396. Oldest University within the World
  397. GRE Scores Scale
  398. Outlining the Difference Between a College And a University
  399. Ethical Issues in Education We Can’t Afford to Ignore
  400. A Beginner’s Guide To Setting Up A Successful Online Store
  401. The Nikon D3400 Picture Controls and Effects – How to Use Them on the Nikon D3400 DSLR Camera
  402. Retail Design for Vehicle Showrooms
  403. How to Secure Your Small Business with a PIX Firewall
  404. The Due Diligence Concept: A Six Month Journey To High Rankings On The Internet
  405. Perception: Learned Or Innate? A Debate
  406. Best Practices for 21st Century Boards
  407. Why Boko Haram Became Violent
  408. Should You Use Revit Server or Collaboration For Revit (C4R)?
  409. Managing Fixed Asset As a Corporate Financial Strategy – The Accountants’ Perspective
  410. Beauty – Is It Physical Appearances or Self-Esteem?
  411. The 10+1 Paths To Vibrant Healthy Skin At Any Age – How To Make 2013 Your Best Year For Beauty Ever
  412. How Does a Whole Life Insurance Policy Work?
  413. What is Permanent Life Insurance? Should I Choose Permanent Life Insurance Or Term Life Insurance?
  414. I Danced With Christ In Bali
  415. Five Positive Tips for Baby Boomers: Retirement & Panic
  416. Hurricane Erma A Floridian’s Story
  417. The Hidden Hazards of Digital Devices and Blue Light on Kid’s Eyes.
  418. Teaching Data Entry to New Hires
  419. Trauma Aftershocks
  420. I Still Haven’t Started With Live Trading Yet, Because I Am Afraid to “Click”
  421. E-Commerce: B2B Vs B2C
  422. The Simulation Hypothesis: Evidence From Physics
  423. The Best Consumer Electonics Reviews and Deals
  424. Reasons to Not Have a Cellphone
  425. Top Ten PC Games In The World
  426. Video Games and the Law: Sex, Violence and Addiction
  427. Tichu Card Game Review
  428. Should Students Learn A Musical Instrument Or Play Educational Video Games?
  429. Game Ideation For The Everyman
  430. MMO Games for Kids and Teens – Harmless Fun?
  431. What It’s Like Being a Game Maker
  432. Family Gaming – 10 Best Xbox 360 Family Games
  433. Top 10 Cool Online Physics Games

The concept of Internet jurisdiction can be complicated and unclear. What happens when a dispute arises over an item or service purchased from your business through the internet? If that dispute turns into a lawsuit, it could be with an individual residing across the country from your business. What happens then? If you live in California, could your business actually be dragged into a state court in Maine?

Any business with an Internet presence should understand how courts gain authority to hear claims made against out-of-state businesses. The bottom line is that establishing Internet jurisdiction over your business can potentially end up being very costly!

Establishing Internet Jurisdiction Over Your Business

No matter what the subject of the dispute is about, a court must have what is known as “personal jurisdiction” over all the parties involved. This applies to all courts, including state and federal district courts. Establishing personal jurisdiction means that the court has the legal power to make a binding decision over the plaintiff and the defendant in a given dispute. State and federal courts always have personal jurisdiction over state residents. But, when the defendant’s principal residence or place of business is not in the state where the lawsuit is filed (often called the “forum state”), matters are much more complex. This is often the case with suits involving e-commerce.

(Note: A corporation is treated as a citizen of the state in which it is incorporated and the state in which its principal place of business is located. A partnership or limited liability company is considered to assume the citizenship of each jurisdiction of its partners/members. If you understand the nature of how a court can gain jurisdiction to hear a claim filed against your business, you can avoid certain practices that may expose you to out-of-state claims.)

The Concept of Minimum Contacts

One way a foreign court can claim personal jurisdiction over your business is by establishing that some sort of meaningful connection exists with the state in question and your business. States can exercise jurisdiction over your business through their “long-arm statutes” (which I discuss separately). However, the Due Process Clause of the U.S. Constitution mandates that certain “minimum contacts” must exist between the forum state and the defendant in order for a state to assert jurisdiction over the defendant. This basically means that activities which are deemed to establish substantially sufficient contacts with the residents or businesses of a particular state can be used by its courts to establish jurisdiction over your business. For example, you are not subject to the personal jurisdiction of an out-of-state court simply because you are involved in an automobile accident with a resident of that state where you live. All the events necessary to give rise to the claim occur outside the state of the other resident.

Activities establishing minimum contacts with another state are not always clear, but usually any substantial presence in the state will justify personal jurisdiction. Regularly soliciting business in that state, deriving substantial revenue from goods or services sold in that state, or engaging in some other persistent and continuous course of business conduct in the state are all examples of activities that would establish minimum contacts with that state.

Minimum Contacts Define Internet Jurisdiction

As stated, the concept of minimum contacts becomes more complicated when it involves the Internet. The courts have recognized that exposing the owners of a website to personal jurisdiction simply because the website can be viewed nationally is not enough to establish minimum contacts in a given state. Personal jurisdiction is “directly proportionate to the nature and quality of commercial activity that a business conducts over the Internet.” Businesses that enter into contracts or subscriptions with residents of another state that involve the “knowing and repeated transmission of computer files over the Internet will be subject to the jurisdiction of out-of-state courts. But, websites that only post information without making active sales are unlikely to establish personal jurisdiction in a foreign state (except in the state where the owner(s) resides or conducts other business).

The ‘Zippo’ Sliding Scale Guide

Generally speaking, minimum contacts for Internet retailers and marketers are directly related to the nature and quality of electronic contacts they establish with residents of another state. In other words, mere advertising alone is not enough to establish jurisdiction. Most courts across the nation have adopted the “sliding scale” approach used in Zippo Manufacturing Co. v. Zippo Dot Com, Inc. (1997). The court in Zippo determined that the act of processing the applications from Pennsylvania residents and assigning passwords was sufficient to demonstrate sufficient minimum contacts with the state. But, the Court held that jurisdiction is not proper when a website passively posts information on the Internet which may or may not be viewed by residents of that particular jurisdiction.

In the Zippo case, the district court described a spectrum consisting of three categories websites fall under. This spectrum ranges from: 1) businesses clearly conducting commercial activities over the Internet by entering into contracts with residents of the forum state; 2) interactive web sites with which a user in the forum state can exchange information and jurisdiction is proper if the level of interactivity is sufficient and there is a commercial component to the web site and 3) web sites which are “passive” by merely allowing users to post information accessible nationwide or globally that do not target a particular plaintiff in a particular forum (i.e. by intentional trademark or copyright infringement or in cases of defamation). Basically, under the Zippo sliding scale jurisdiction is more likely to be established when your Internet business engages in commercial activities directed at residents of a given state.

Of course, many cases fall in the middle of the Zippo sliding scale. In these instances, the courts generally have determined that “the exercise of jurisdiction is determined by examining the level of interactivity and commercial nature of the exchange of information that occurs on the website.” Making multiple sales to state residents is likely to expose an Internet-based business to personal jurisdiction in that state. A single sale may also be enough, provided it is accompanied by numerous intentional communications with a resident customers so that the transaction can be said to be purposefully aimed at the residents (or businesses) of that state.

Typically, the courts require “something more” than passive Internet advertising or more than just a single sale for jurisdiction to exist over a non-resident Internet business. Jurisdiction is often triggered by repeated or commercially significant sales to out-of-state residents, deliberate target marketing to out-of-state residents or significant non-Internet based contacts with the state Unique Press.

State Long Arm Statutes

All states have enacted “long-arm statutes” setting forth what will be considered sufficient contacts with that state. In a nutshell, the long-arm statute allows that state’s courts to gain personal jurisdiction over Internet businesses. These statutes form the legal basis allowing the courts to exercise personal jurisdiction over your business. Under these statutes, service of process outside the state on nonresident individuals and businesses is allowed for claims generally arising out of: (1) the transaction of any business in the state; (2) the commission of a tortious act within the state; (3) the ownership, use, or possession of real estate in the state; or (4) contracting to supply goods or services to any person or business in the state; or 5) causing injury or damage in this state to any person by breach of warranty expressly or impliedly made in the sale of goods; 6) contracting to insure any person, property, or risk located within this state at the time of contracting; 7) an act or omission outside the state causing injury in the state.

State courts typically exercise personal jurisdiction over Internet businesses under the “transacting business” provision of the long-arm statute. Like the Zippo court, state courts will look at jurisdiction in an Internet setting by looking at the “nature and quality” of the contacts with the state. Some Long-arm statutes set forth factual situations likely to satisfy the minimum-contacts test. Others contain much broader provisions not inconsistent with constitutional restrictions.

Helpful Case Summaries

Here is a summary of some decisions that have helped shape the law regarding internet jurisdiction. Hopefully, these summaries can provide some guidance.

Thompson v. Handa-Lopez, Inc. (1998): A Texas court gained personal jurisdiction over an out-of-state online gambling enterprise because the gambling operation entered into contracts with Texas residents to play online gambling games, sent emails to the Texas residents, and sent winnings to Texas residents;
ChloƩ NA v Queen Bee of Beverly Hills LLC (2010): The US Second Circuit Court of Appeals held that specific personal jurisdiction over an out-of-state website operator located in California may exist based on a single act of shipping a handbag into New York, along with other substantial business activity in the state. The single act of shipping an infringing handbag to New York combined with other substantial contacts, such as the shipment of several other items in-state and operating a commercial interactive website available to New York residents was sufficient to obtain specific personal jurisdiction;
Verizon Online Services, Inc. v. Ralksky (2002): The court held that nonresident defendants’ transmission of spam emails through plaintiff’s servers, located in Virginia, to nonresident Internet subscribers created a substantial connection to forum sufficient for exercise of personal jurisdiction on a claim of trespass to chattel;
Gates v. Royal Palace Hotel (1998): The court decided that the combination of a concentrated advertising effort within the state of Connecticut, active booking of reservations for Connecticut citizens through state travel agents, and an invitation to Connecticut citizens to make reservations through the Internet, constituted the transaction of business within the state such that exercise of personal jurisdiction was proper.
Causing an Injury within a State

Your Internet business can also be subject to jurisdiction in another state for purposefully causing a physical or economic injury (i.e. a “tort”) to a business or resident of that state. This is a separate avenue of liability outside of a breach of contract claim where your business is dragged into court by one of your unhappy customers. If you use the Internet to cause an injury in one state, you or your business may be brought into court in the state where the injury occurred. For example, under state long arm statutes, committing a tortious act within the state is a basis of jurisdiction.

Of course, in cases where the connection between the activity and the injury is not clear, courts have looked for evidence that the activity was “purposefully directed” at the resident(s) of the forum state, or that the person causing the injury had substantial contacts with the state. Most courts are less inclined to exercise personal jurisdiction over non-residents in cases involving tort claims arising from Internet use. Generally speaking, an Internet business must direct its activities at an in-state resident, or have a continuing obligation with that resident, in order reasonably to anticipate being hauled into court in the state.

But, not all torts or injuries will expose your business to the personal jurisdiction of another state. Even if a plaintiff claims to feel the effects of the harm caused by an act causing injury in his or her forum state, there must still be “something more” than mere Internet use to satisfy due process under the Constitution. Purposeful conduct may still be insufficient in jurisdictions where the activity must be directed at the plaintiff in his or her capacity as a resident of that particular state.

More case examples:

EDIAS Software International v. BASIS International Ltd. (1996): A New Mexico company was sued for sending defamatory email and making defamatory postings about an Arizona business. The court claimed personal jurisdiction because the defamatory statements intentionally targeted the Arizona business and actually caused an injury (defamation) within the state.
Pavlovich v. Superior Court (Cal. 2002): Under the “effects test”, the trial court did not have jurisdiction over a foreign resident in a corporation’s suit alleging the resident misappropriated its trade secrets by posting the corporation’s program’s source code on his website. The website was accessible to any person with Internet access and the resident merely posted information and had no interactive features. The court determined that the resident could not have known that his tortious conduct would hurt the corporation in California when the misappropriated code was first posted and this did not establish express targeting of California residents.
Blumenthal v. Drudge (1998): In another early decision, Matt Drudge of The Drudge Report made alleged defamatory statements about a Washington, D.C. resident on his website and the resident filed suit in the District of Columbia. Although Matt Drudge lived and worked in California at the time of the suit, a court ruled that he was subject to personal jurisdiction in the District because the injury occurred in the District. The court also determined that the Drudge Report had substantial contacts in D. C. since Drudge personally emailed his column to a list of emails belonging to D.C. residents, solicited contributions and collected money from D. C. residents and he traveled to D. C. on two occasions to promote his column. All of this was enough for the court in that case to determine that Matt Drudge had substantial contacts with the District;
Cybersell, Inc. v. Cybersell, Inc. (1997): An Arizona plaintiff suing for trademark infringement argued that a Florida defendant’s mere use of the same trademark in its home page was sufficient for personal jurisdiction. The Florida defendant had “no contacts with Arizona other than maintaining a home page that was accessible to anyone over the Internet.” The court declined to exercise jurisdiction, noting the Florida defendant “did nothing to encourage residents of Arizona to access its site, and there [was] no evidence that any part of its business (let alone a continuous part of its business) was sought or achieved in Arizona.” The circumstances lacked the “something more” necessary “to indicate that the defendant purposefully… directed his activity in a substantial way to the forum state.”
Consenting to Jurisdiction over Your Business

A court can obtain personal jurisdiction if both parties consent to such jurisdiction. The most common type of consent is where a company is required to consent, in advance, to personal jurisdiction in a state for incorporating or organizing a business under the laws of that state. State business organization statutes require that a business provide the secretary of state with an agent to accept service of process. An Internet business can also consent to the court’s jurisdiction by filing a response to a lawsuit filed with that court.

Similarly, you may grant consent by signing a contract that has a provision requiring you agree in advance to be subject to the personal jurisdiction of a state. For example, a California website developer may sign an agreement with an Illinois service provider containing a clause stating: “The parties consent to the exclusive jurisdiction of the federal and state courts located in Cook County, Illinois, in any action arising out of or relating to this agreement. The parties waive any other venue to which either party might be entitled by domicile or otherwise.” (However, the States of Montana and Idaho do refuse to recognize such clauses).

You have now been introduced to the catch 22 of e-commerce! The Internet provides a great way for small businesses to operate and achieve massive growth. Unfortunately, such growth will inevitably expose your business to foreign jurisdiction and the ability to be hauled into court in some distant State. If you want to guarantee that you will avoid this risk and you plan on operating a commercial website, you will surely sacrifice sales and growth.

This article was written by Philip A. Nicolosi, J.D. Mr. Nicolosi provides legal services through his law firm, Phil Nicolosi Law, P.C., focusing on startup and small business law, Internet & technology law and commercial transactions.

Mr. Nicolosi serves as a trusted advisor to numerous startups and small to medium sized businesses. This includes representation for a wide range of business law matters including business organization, corporate/LLC governance, regulatory law, contracts and transactions and most other matters outside of litigation. Mr. Nicolosi provides guidance with e-commerce, Internet and mobile marketing and technology-related legal matters to many of his business clients. He also assists startups with seed funding and venture capital law.

This is a Sidebar position. Add your widgets in this position using Default Sidebar or a custom sidebar.