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![handle is hein.journals/jltp2026 and id is 1 raw text is:
PERSONAL JURISDICTION HAS BEEN ADDED TO YOUR
SHOPPING CART: WHEN CAN A BUSINESS'S SINGLE ONLINE
SALE ESTABLISH MINIMUM CONTACTS?
Kayla Beckley*
I. INTRODUCTION
Today, e-commerce is an integral part of daily life thanks to the rapid ex-
pansion of the Internet and technology during the twenty-first century.' Not only
is the market accessible from computers, but it can be reached from a laptop,
tablet, smart phone, and even a watch.2 For consumers, e-commerce makes
spending money easier and, with expedited shipping options, conveniently
quick.3 For businesses, it is also easier to sell to customers across a global mar-
ket.4 For those seeking to initiate their own small businesses, e-commerce and
online marketplaces have lowered the barriers to entering the market.5
E-commerce has less desirable effects as well.6 The growth of e-commerce
also allows counterfeiters and pirates to engage large platforms of potential cus-
tomers, increasing the number of counterfeit goods sold.7 Trademark infringe-
ment in e-commerce is a growing concern as more businesses move their
* J.D. Candidate, University of Illinois College of Law 2026; B.A., Social Work, Hope College 2021.
The Author thanks Professor Sean Anderson for his invaluable guidance and edits, and the Editors and Members
of JLTP for their contributions to this Note.
1. E.g., Madeleine Hillyer, How has technology changed - and changed us - in the past 20 years?,
WORLD ECON. F. (Nov. 18, 2020), https://www.weforum.org/stories/2020/11/heres-how-technology-has-
changed-and-changed-us-over-the-past-20-years/ [https://perma.cc/78LP-J7PL] ([I]n 2000, just half of Ameri-
cans had broadband access at home. Today, that number sits at more than 90%.).
2. E.g., Hoang Nguyen, Global: 45% ofglobal consumers use their phones to shop online at least once
a day, YouGov (May 30, 2022), https://business.yougov.com/content/42686-global-mobile-online-shopping-
survey [https://perma.cc/LTZ2-G7VJ].
3. Id.
4. See e.g., Michael Keenan, 22 Selling Sites and Marketplaces for Selling Things Online (2025),
SHOPIFY (Nov. 5,2024), https://www.shopify.com/blog/online-selling-sites [https:/perma.cc/HH9H-FF98] (de-
scribing the most popular online market platforms for readers to use to sell their products).
5. Id.; Yan Anderson, Peer-to-PeerMarketplaceMastery: A Comprehensive Guide to Building and Nav-
igating, CS CART (Jan. 16, 2026f), https://www.cs-cart.com/new-lease-of-life-peer-to-peer-marketplace-plat-
form.html [https://perma.cc/7KVD-ZYTX].
6. See, e.g., sources cited infra note 7 (discussing growth of counterfeit sales and trademark infringement
due to growth of e-commerce).
7. Secondary Trademark Infringement Liability in the E-Commerce Setting, U.S. PAT. & TRADEMARK
OFF. 1, 1 (2021), https://www.uspto.gov/sites/default/files/documents/Secondary-TM-Infringement-Liability-
Response.pdf [https://perma.cc/QY5D-YTA7]; Trademark Infringement in E-Commerce, TRADEMARK
FACTORY, https:/trademarkfactory.com/trademark-infringement-in-e-commerce [https:/perma.cc/6G5V-CK
NR] (last visited Feb. 28, 2025).
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