In Bird v. Parsons, 289 F.3d 865, 875 (6th Cir.2002), the court considered whether a plaintiff's cause of action arose in Ohio when the pro se plaintiff alleged the defendants - all of whom were non-Ohio residents - misappropriated his domain name in violation of copyright and trademark laws. Defendant Dotster was a registrar of internet domain names. After the district court dismissed the case for lack of jurisdiction, plaintiff appealed, and the court of appeals reversed. It noted that the "only factual allegations that connect the Dotster defendants in any way to Ohio" are as follows: the Dotster defendants admit they have sold approximately 233,333 internet domain names to United States customers, which, when divided by 50, means that on average they sold about 4,666 domain names to each state, including Ohio. Id. at 872. The court concluded that this satisfied the purposeful availment test. The court then considered whether plaintiff's claims arose out of the Dotster defendants' contacts with Ohio. The court held that the "arising out of" factor "requires only `that the cause of action, of whatever type, have a substantial connection with the defendant's in-state activities.'" Id. at 875 (quoting in part Third Nat'l Bank v. WEDGE Group, 882 F.2d 1087, 1091 (6th Cir.1989)). The court concluded that the actions of the Dotster defendants in registering a third party's domain name constituted sufficient connection with Ohio. The court held that "the operative facts are at least marginally related to the alleged contacts between the Dotster defendants and Ohio." Id.