I. INTRODUCTION The unprecedented explosion of the Internet has singularly induced "the most profound transformation a technology has brought since the capture of fire."' A review of the exponential growth surrounding the Internet reveals some dizzying figures. In 1981 less than 300 computers were connected to the Internet.2 Eight years later the number had only grown to about 90,000.3 But by 1996 an estimated 9,000,000 computers worldwide were linked to the Internet.4 The most staggering figure of all, however, is the estimated 200,000,000 computers which will be tapped into this remarkable global mine of information by the year 1999.5 Recently, traffic on the Internet has been doubling every 100 days.'
Such expansive growth has created significant ramifications in the legal field. Among the hottest legal issues to roll off the information superhighway is the question of personal, or territorial, jurisdiction over Internet users. District courts across the country are being inundated with cases in which plaintiffs seek to use Internet-related activity as a basis for personal jurisdiction. Naturally, Internet users are "entitled to the [full] protection of the Due Process Clause, which mandates that potential defendants be able to `structure their primary conduct with some minimum assurance as to where the conduct will and will not render them liable to suit."'7
As recently observed in a Wall Street Journal article, however, Internet users are finding that this right is being trampled on. The article notes that several years ago "the Net's freewheeling, new-frontier style" made it "the kind of place where entrepreneurs could make deals, launch products and grow with a minimum of headaches."' But with the rise in litigation over cyberspace, "[t]he fear of lawsuits is turning the World Wide Web into a world of warnings."9 This problem highlights the vital need of Internet users to know when and where their Internet activities will render them liable to suit. Is merely placing an informational web page on the Internet sufficient to establish personal jurisdiction? What about creating a web site which solicits business and allows users interactively to exchange information? And how should the jurisdictional issue be resolved in the case of a person actively conducting business over the Internet?
Further complicating the answers to these questions is the fact that cyber-jurisdiction cases rarely involve Internet contacts alone. Typically in these cases the defendant commits acts and makes contacts in addition to those made via the Internet. How should these additional contacts be factored into the jurisdictional equation? Thus far, the "development of the law concerning the permissible scope of personal jurisdiction based on Internet use is in its infant stages."lo The decisions reached by the courts in response to such questions will thus have a profound impact on the continued development of the Internet-particularly the burgeoning financial activity being transacted there"1-either by impeding or by fostering it. A September 1997 decision of the United States District Court for the District of New Jersey, Weber v. Jolly Hotels, developed an analytical model for addressing cases involving cyber-jurisdiction.l2 It proposed a three-tiered classification based upon a qualitative analysis of a defendant's contacts made over the Internet. This Note examines Weber and concludes that for the most part the court correctly interpreted and applied International Shoe and its progeny in adopting the three-tiered model. However, the Weber scheme is an inadequate yardstick for determining personal jurisdiction in cyberspace. Although the Weber model provides some help in analyzing the jurisdictional question, by itself it is incomplete and fails to provide sufficiently detailed criteria to enable a court applying it to distinguish between the differing types and the varying degrees of cyber-contacts.