E-Commerce Law:  “the United States District Court for the District of Arizona dismissed a defamation complaint for lack of personal jurisdiction where the defendant published on a website an allegedly defamatory article about the plaintiffs, who reside in Arizona. . . . the Arizona court was unable to exercise specific personal jurisdiction over the defendant because the allegedly defamatory act was not ‘expressly aimed’ at the state of Arizona.”  The case is  Xcentric Ventures LLC v. Bird.