In MacDermid, Inc. v. Deiter, the Second Circuit held that a Connecticut court may exercise personal jurisdiction over a defendant who allegedly used a computer in Canada to remotely access a computer server located in Connecticut in order to misappropriate proprietary, confidential electronic information belonging to a Connecticut corporation. This Note argues that, given the factual elements before the court, MacDermid was an unsurprising, orthodox, and proper holding in the context of personal jurisdiction jurisprudence. However, the facts in MacDermid, and the corresponding limits inherent in the Second Circuit’s holding, reveal potentially gaping holes in our modern personal jurisdiction framework and its ability to respond to the realities of modern commerce and technology.

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