8.2.3.3 Geographic Territory Limitation

• Jurisdiction: Arizona

The traditional CGL coverage form contains a provision governing the territorial scope of coverage. The Internet, and business liability based upon information published on the Internet, is global. For example, Yahoo!, Inc. v. La Ligue Contre Le Racisme et L'Antisemitisme,^[219] a California Internet service provider (ISP) sued French associations who had obtained order from French court requiring ISP to block French citizens' access to Nazi material displayed or offered for sale on ISP's United States site, seeking declaration that order was unenforceable in the United States. The court held that associations were not subject, under the specific jurisdiction doctrine, to personal jurisdiction in ISP's action seeking a declaration that the French court's order violated ISP's First Amendment rights; associations did not expressly aim at California inasmuch as they did not engage in any wrongful conduct by taking action to enforce their legal rights under French law. It demonstrates the perils and...