Law360, New York ( August 25, 2011, 3:18 PM EDT) -- In a pair of recent Ninth Circuit cases decided by the same panel on the same day, the court clarified the circumstances whereby an out-of-state company operating a website may be subject to personal jurisdiction in California in intellectual property cases. In CollegeSource Inc. v. AcademyOne Inc. (9th Cir.; Aug. 8, 2011) and Mavrix Photo Inc. v. Brand Technologies Inc. (9th Cir.; August 8, 2011), the court held that the defendants were subject to the jurisdiction of the California federal courts, notwithstanding that they had no continuous and systematic contacts with the state, because each had engaged in conduct for commercial gain through its website that was "expressly aimed" at California....