Well said, I agree with your logic. The dissent had a much stronger argument here. The author of this article had a well thought out, but ultimately incorrect interpretation of this ruling. Johnson clearly had standing to bring this case in Texas, and I believe this case will be overturned in time.

Libel of an individual – In this case, it appears that the individual, Mr. Johnson, was named specifically in the libel. His physical location is definite – Texas. HuffPost, on the other hand, is a “virtual” entity, which has effectively no location. As such, jurisdiction should be in the location of the target of the libel, not some undefined location that may never be narrowed to a specific jurisdiction.

Maui to Maine – The libel was against an individual. General jurisdiction would not open the libel case to any and all jurisdictions on the map. Instead, there would only be 2 potential jurisdictions… The location of the person libeled (Texas), or the location of the publication (uncertain, as it is a website with multiple contributors in potentially any jurisdiction). As such, it would be appropriate to file suit in Texas, where the libel “victim” resides.

As the plaintiff is a resident of Texas, the location of events in the article is moot. If an article is written in New York, the subject is in Texas, the recounted events are in Las Vegas, and the distribution is universal; the only two locations that are relevant to jurisdiction are the place of publication and the place the libel has “effect”. As the effect was on a man in Texas, filing suit in Texas should be appropriate.

Gunshot in Oklahoma, victim in Texas – If a gun is fired in Oklahoma, the bullet travels across the border, and strikes a man in Texas, where is the jurisdiction? Would the victim’s location, Texas, have jurisdiction? When there is a specific target of libel (an individual in a definite location), hasn’t the offense occured in the victim’s location? The effect of the libel (damage to reputation, loss of job, and other negative effects of libel) is felt where the victim resides, not where the article was written. Therefore, with the results of the libel taking affect in Texas, Texas would be the correct jurisdiction.