Yes. The Nevada hotels can be sued in California. The court looked at three things to decide. First, did the hotels choose to do business with California? Yes, they spent a lot of money on ads and a website to attract Californians. Second, is the lawsuit about what the hotels did in California? Yes, the lawsuit is about a surprise fee that wasn't mentioned during the booking process that started in California. Third, is it fair to make the hotels come to California for court? Yes, because they make so much money from Californians, they should expect to have to answer for their actions in a California court.

Yes, California can make decisions about these hotels. The hotels did a lot of business with Californians on purpose. They put up ads in California and made it easy for Californians to book rooms on their website. They got a lot of their business from California. The problem the Californian is suing about is related to how the hotels advertised in California. It's fair for California courts to decide this case because the hotels chose to do so much business with Californians.

Yes. California courts may exercise specific personal jurisdiction over the out-of-state hotels. Specific jurisdiction is proper under a three-part test: purposeful availment, relatedness, and fairness. First, the defendants purposefully availed themselves of the benefits of doing business in California through extensive and targeted advertising, direct mailings, a toll-free number, and an interactive website that successfully solicited a significant amount of business from California residents. These actions were not 'random' or 'fortuitous' but were deliberately directed at the forum. Second, the plaintiff's claims—based on the failure to disclose the surcharge during the reservation process and in advertising—are substantially connected to and arise from the defendants' forum-related activities. The harm alleged relates directly to the content of defendants' promotional activities in California. Third, the exercise of jurisdiction is fair and reasonable; defendants, having purposefully directed their activities at California, failed to present a compelling case that jurisdiction would be unreasonable.

Yes. The defendants have purposefully availed themselves of the privilege of conducting activities within California, and thus should reasonably anticipate being haled into court there. I base this conclusion on their extensive advertising targeted at California residents, their interactive website that facilitates business transactions with California residents, and the significant portion of their business derived from California. The controversy is related to defendants' contacts with California because the alleged harm relates directly to the content of defendants' promotional activities in the state. The exercise of jurisdiction is fair and reasonable given the defendants' purposeful direction of activities at forum residents. Because of these activities, California courts may exercise specific jurisdiction over the defendants.

Snowney v. Harrah's Entertainment, Inc.

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