electronic coupons contract

Response Reward Systems v. Meijer Inc. 189 F. Supp. 2d 1332 (M.D. Fla. 2002)
Response Reward, a Florida company, owns patents on issuing electronic coupons
Meijer, Inc. is a Michigan corporation that operates supermarkets
Meijer operated a website that offered electronic coupons
Response Reward alleged that Meijer was infringing its patents
Response Reward could have sued in Michigan, where Meijer was located. Instead, it sued in Florida
The Florida long-arm statute permits jurisdiction over a defendant who is “engaged in substantial and not isolated activity” within Florida
Meijer’s website was accessible from anywhere, but Meijer
was not licensed in Florida
had no offices, stores, employees or property in Florida
did not advertise in Florida
issued coupons which could not be used in Florida
BUT, some stores owned by others accepted the coupons in Florida
The Florida long-arm statute, as interpreted by the Florida courts, permits jurisdiction over a defendant who commits an act outside Florida that causes damage within Florida, e.g. patent infringement
Is it constitutional for Florida to exercise jurisdiction over Meijer?
No. Meijer did not have minimum contracts with Florida.
Think about it. Should there be jurisdiction just because the patent owner happens to be in Florida?
https://www.rfcexpress.com/lawsuit-related-cases.asp?ID=24641