Stokinger v. Armslist — First Circuit Holds Years of In-State Firearm Listings, Combined With Site Design and Ad Revenue, Show Purposeful Availment
Reviving claims against the online firearms marketplace Armslist, the First Circuit held that 16,000 New Hampshire firearm listings per year — viewed together with the site’s geographic-listing design and the advertising revenue those listings generated — were enough to make a prima facie case of purposeful availment. Section 230 was raised but not decided and remains open on remand.