International Association of Certified Home Inspectors v. Lesh, 1:18-cv-00454

InterNACHI, a national home-inspector trade association headquartered in Colorado, sued Frank Lesh (former ASHI executive) for defamation, commercial disparagement, tortious interference, and deceptive trade practices based on an article Lesh wrote, "The Badges We Earn," published in ASHI Reporter (print and on ASHI’s website).
The article criticized "purchased designations" and was understood by InterNACHI to refer to its nationwide certification programs; InterNACHI alleged reputational and business harm (memberships, referrals) felt in Colorado.
ASHI distributed the issue nationwide, including to Colorado residents; the article was also posted on ASHI’s website (accessible in Colorado).
Lesh is an Illinois resident with no meaningful contacts with Colorado (no residence, property, or work there; last in Colorado around 2000/2001); he moved to dismiss for lack of personal jurisdiction.
InterNACHI conceded lack of general jurisdiction and relied on specific jurisdiction theory, arguing Lesh purposefully directed his conduct at Colorado because InterNACHI’s principal place of business is in Colorado and the injury was felt there.
The district court accepted InterNACHI’s pleadings as true for the prima facie inquiry but held InterNACHI failed to show Lesh expressly aimed his conduct at Colorado and dismissed the case without prejudice for lack of personal jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has specific personal jurisdiction over Lesh for claims arising from the article	Lesh knew InterNACHI is based in Colorado and targeted InterNACHI; the injury was felt primarily in Colorado, so Lesh should reasonably anticipate being haled into court there	Lesh is an Illinois resident whose publication was national (print + web) and he did not purposefully direct activities at Colorado; mere foreseeability or harm in Colorado is insufficient	Court: No specific jurisdiction. InterNACHI failed to show Lesh expressly aimed his conduct at Colorado; dismissal without prejudice for lack of personal jurisdiction
Whether internet and nationwide print publication alone satisfy the "expressly aimed" / purposeful-direction test	Nationwide publication that injures a Colorado-based plaintiff suffices because the plaintiff’s principal place of business is in Colorado	Internet availability and national distribution, standing alone, do not make Colorado the focal point; must show the defendant targeted Colorado specifically	Court: Publication on the internet and national distribution without additional Colorado-focused conduct is insufficient (citing Calder/Walden/Dudnikov/Shrader); jurisdiction not established

Behagen v. Amateur Basketball Ass’n, 744 F.2d 731 (10th Cir.) (plaintiff bears burden to establish personal jurisdiction and prima facie standard where no evidentiary hearing)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (minimum contacts and foreseeability principles in due-process jurisdiction analysis)
Dudnikov v. Chalk & Vermillion Fine Arts, Inc., 514 F.3d 1063 (10th Cir.) (purposeful direction test for torts; plaintiff’s injury must arise from forum-directed conduct)
Calder v. Jones, 465 U.S. 783 (U.S. 1984) (defendant’s conduct expressly aimed at forum where focal point of story and injury occurred)
Walden v. Fiore, 571 U.S. 277 (U.S. 2014) (jurisdictional contacts must be with the forum state itself, not just with forum residents)
Shrader v. Biddinger, 633 F.3d 1235 (10th Cir.) (Internet postings not enough without deliberate targeting of forum; forum must be focal point of message)
Silver v. Brown, [citation="382 F. App'x 723"] (10th Cir.) (distinguishing targeted regional conduct that supports jurisdiction from merely accessible publications)