In Zippo Manufacturing Co. v. Zippo Dot Com, Inc., 952 F. Supp. 1119 (W.D. Pa. 1997), the Zippo Manufacturing Company sued a website with the address " for various causes of action related to trademark infringement. 952 F. Supp. at 1121. The court began with the proposition that "the likelihood that personal jurisdiction can be constitutionally exercised is directly proportionate to the nature and quality of commercial activity that an entity conducts over the Internet." Id. at 1124. From there it posited a "sliding scale" that places websites on a continuum from the active solicitation and doing of business to the passive conveyance of information. Id. On an active website, users may "enter into contracts with residents of a foreign jurisdiction that involve the knowing and repeated transmission of computer files." Id. On a passive website, information is merely made available for those who are interested. Id. Between these two ends of the spectrum lie websites where "a user can exchange information with the host computer and the exercise of jurisdiction is determined by examining the level of interactivity and commercial nature of the exchange of information that occurs on the Web site." Id.