Participated in an amicus brief (with other amici) filed with the U.S. Court of Appeals for the Sixth Circuit in Kent v. Hennelly. This case concerned whether, under the boundaries of constitutional due process, a federal court may exercise personal jurisdiction over a defamation defendant who merely posts speech online about a plaintiff who resides within the forum state. The brief urged the court to uphold the district court ruling that – contrary to Kent’s assertion – personal jurisdiction cannot be expanded in a manner that would allow a federal court to exercise jurisdiction over essentially any defendant who uses the Internet to discuss a resident of the forum state. [2018]