The establishment of a website through which Pennsylvania customers can order products does not, on its own, suffice to establish general jurisdiction in Pennsylvania. This according to U.S. Senior Judge Marvin Katz in the recently decided case of Molnycke Health Care v. Dumex Medical Surgical Products , 1999 WL 695579 (E.D.Pa.) 1-7, 3. According to the court, "to hold that the possibility of ordering products from a website establishes general jurisdiction would effectively hold that any corporation with such a website is subject to general jurisdiction in every state." The court was unwilling to take such a step.

Pennsylvania law permits the exercise of general jurisdiction over a corporate defendant when the corporation carries on a continuous and systematic part of its general business within the state. In order to exercise such jurisdiction, a plaintiff must show that a defendant has maintained continuous and substantial affiliations with the forum.

In Molnyce, the defendant maintained two websites, which the plaintiff argued established general jurisdiction. One of the websites permitted users to place their names and addresses on a mailing list to receive product information. Both websites advertised the defendant's products generally. Further, products could be ordered directly from the websites.

The court states that the growing case law in the Third Circuit addressing the relationship between personal jurisdiction and internet sites established a sliding scale of jurisdiction based largely on the degree and type of interactivity on the website in question. Defendant's affidavit stated that it has never sold the product in question in Pennsylvania, and that less than one percent of its total sales are in Pennsylvania. The court held that the websites in question did not rise to the level of establishing jurisdiction.

The court concluded by stating that "[f]or the court to hold that general personal jurisdiction could be established solely by the existence of websites such as those at issue here would deal a serious blow to the concept of personal jurisdiction. Virtually every corporation, domestic and foreign, would be subject to the general personal jurisdiction of every state. While personal jurisdiction and other legal doctrines must obviously evolve in light of new technologies, the court does not believe the time has yet come to abandon personal jurisdiction altogether."