In Young v. New Haven Advocate, 315 F.3d 256 (4th Cir. 2002), cert. denied, 538 U.S. 1035, 155 L. Ed. 2d 1065, 123 S. Ct. 2092 (2003), the warden of a Virginia prison brought a libel suit in the United States District Court for the Western District of Virginia against Connecticut newspapers based on articles criticizing harsh conditions at the prison -- which by contract with Connecticut housed Connecticut prisoners to alleviate overcrowding in Connecticut prisons. The warden relied upon the following contacts with Virginia in asserting specific personal jurisdiction over the newspapers: (1) the newspapers, knowing that Young was a Virginia resident, intentionally discussed and defamed him in their articles; (2) the newspapers posted the articles on their websites, which were accessible in Virginia; (3) the primary effects of the defamatory statements on Young's reputation were felt in Virginia. Young emphasizes that he is not arguing that jurisdiction is proper in any location where defamatory Internet content can be accessed, which would be anywhere in the world. Rather, Young argues that personal jurisdiction is proper in Virginia because the newspapers understood that their defamatory articles, which were available to Virginia residents on the Internet, would expose Young to public hatred, contempt, and ridicule in Virginia, where he lived and worked. Id. at 261-62. In addressing the Young plaintiff's contentions, the Fourth Circuit pointed out that "the fact that the newspapers' websites could be accessed anywhere, including Virginia, does not by itself demonstrate that the newspapers were intentionally directing their website content to a Virginia audience." Id. at 263. The court believed that "something more than posting and accessibility" in the forum state was needed in order for the newspapers to have purposefully -- through electronic means -- directed their activity in a substantial way to the forum state. Id. The court determined that the dispositive question in such cases should be whether the defendant "through the Internet postings, manifested an intent to target and focus on the forum state's readers." Id. The court, after reviewing the newspapers' website and the actual articles, concluded that no basis for jurisdiction existed. Id.