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National Enquirer published story about P, an entertainer who lives in CA that alleged unseemly activities by P
U
pheld jdx b/c w/ libelous stories – it is reasonable that where the Π lives is where the impact of the case is
H - CA is focal point of THE ACT and THE HARM, jdx is proper b/c “effects” are felt in CA

Notes:
*With LIBEL CASES, court will typically look to where the P lives and is affected by the libel b/c most of the harm would impact the P…it is reasonable for the D to foresee that its libelous conduct would impact the P wherever they are**

Effects test controversial, not just limited to defamation