In Snowney v. Harrah's Entertainment, Inc. (2005) 35 Cal.4th 1054, a California resident filed a class action against a group of Nevada hotels for failing to provide notice of an energy surcharge imposed on hotel guests. (35 Cal.4th at p. 1059.) In concluding that the defendants' website established purposeful availment of the benefits of doing business in California, the court noted that the website specifically targeted California residents by touting the proximity of the hotels to California and providing driving directions from the state to the hotels. (Id. at p. 1064.) In addition, the defendants advertised extensively in California. (Id. at p. 1065.) Thus, they "purposefully and successfully solicited business from California residents. In doing so, defendants necessarily availed themselves of the benefits of doing business in California and could reasonably expect to be subject to the jurisdiction of courts in California." (Ibid.) The Court noted that interactive websites which sell goods or services, such as the one in question, fall within the middle ground of the Zippo Mfg. Co. v. Zippo Dot Com, Inc. (W.D.Pa. 1997) sliding scale. The court further observed that some courts have held that sufficient minimum contacts are established simply "where the defendant's website is capable of accepting and does accept purchase orders from residents of the forum state." (Snowney, supra, at p. 1064.) Other courts require "something more," such as conduct purposefully directed at residents of the forum state. (Ibid.) Because purposeful availment was established under either measure in Snowney, the court left open the proper approach to be applied in California.