The Court of Appeals for the Sixth Circuit issued an interesting decision, Bird v. Parsons.  The Court exercised personal jurisdiction over defendant Dotster, an ICANN-accredited registrar, based on the assumption that because Dotser sold 233,000 domain names in the U.S., 1/50 of those (4,666) were likely sold in Ohio, so Dotster had minimum contacts with Ohio.  Can this argument be made in Hawaii?  The decision is at  There is also a discussion as to whether registrars and name re-sellers (Afternic was another defendant), “traffic” in names.