Law360 (April 3, 2018, 8:31 PM EDT) -- The First Circuit on Tuesday said a New Hampshire district court got it right when it dismissed a defamation lawsuit between an Arizona-based broker-dealer and a New York-based financial news site for lack of jurisdiction, finding there was no evidence anyone in the state read the site’s allegedly defamatory articles.

The appellate panel said the delivery of email newsletters to two people at Dartmouth College in New Hampshire was not enough to revive Scottsdale Capital Advisors Corp.’s claim that The Deal published libelous statements in late 2013 and early 2014, because just as the lower court found, evidence in the case suggests that no one at Dartmouth ever accessed or read the articles.

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