Rethinking “Express Aiming”: The Ninth Circuit’s Briskin v. Shopify Decision Shakes Up Personal Jurisdiction for Online Defendants

The Ninth Circuit, sitting en banc, has significantly altered the landscape for establishing specific personal jurisdiction over out-of-state defendants operating online. In its April 21, 2025, decision in Briskin v. Shopify, Inc., 2025 U.S. App. LEXIS 9410, 135 F.4th 739, 2025 WL 1154075 (9th Cir. 2025), the court overruled a key aspect of its prior jurisprudence, making it potentially easier for plaintiffs to sue online businesses in their home forums.