In Maritz, Inc v Cybergold, Inc 947 F Supp 1328 (ED Mo, 1996), there was not only the potential for contact, but 131 instances in which the defendant succeeded in contacting Missouri residents. Id. Interestingly, the court refused to consider the 180 instances in which plaintiff accessed the defendant's website, noting that "if such contacts were to be considered, a plaintiff could always try to create personal jurisdiction." Id., 1333, n 4. The court thus implicitly suggested that the potential for contact does not by itself create jurisdiction, and that the plaintiff must show actual contact. The nature of the Maritz plaintiff's cause of action also forms a salient factual distinction. The plaintiff alleged that it was injured by the defendant's trademark violation every time an Internet user accessed the site. The court was thus able to conclude that the defendant's conduct caused a tortious effect in Missouri. Id., 1331. The Court found jurisdiction where the defendant maintained a website that was "continually accessible to every Internet-connected computer in Missouri and the world." Id., 1330. Emphasizing the newness of Internet technology and the unique marketing opportunities offered by the Internet, the Court contrasted the Internet from older forms of communication and concluded that the ease and rapidity of Internet communications justified personal jurisdiction based on the website: A company's establishment of a telephone number, such as an 800 number, is not as efficient, quick, or easy way to reach the global audience that the internet has the capability of reaching. While the internet does operate via telephone communications, and requires users to place a "call" to a website via the user's computer, a telephone number still requires a print media to advertise that telephone number. Such media would likely require the employment of phone books, newspapers, magazines, and television. Even then, an 800 number provides a less rapid and more limited means of information exchange than a computer with information downloading and printing capabilities. With a website, one need only post information at the website. Any internet user can perform a search for selected terms or words and obtain a list of website addresses that contain such terms or words. The user can then access any of those websites. [Id., 1332-1333.] The court further commented that the defendant had deliberately used the Internet to reach potential customers and that 131 Missouri residents used the website to contact the defendant for more information. Id., 1333.