A registered dietician presented a speech on diet, exercise, and the dangers of steroid use, in Riverside, California. A sports editor for the Inland Valley Daily Bulletin, attended the forum and wrote an article entitled, 'Forum tackles the dangers of steroid use.' The article referenced Bo Jackson who lost his hip because of anabolic abuse. The presenter cited Bo as an example of how she personally witnessed damage on someone's life.' The article was posted on the internet website www.dailybulletin.com and published in the Inland Valley Daily Bulletin newspaper. The presenter said she never mentioned 'Bo' Jackson in her speech or conversation with D, nor made the statement attributed to her in the aforementioned article. P sued for damages. Ds move to dismiss for want of personal jurisdiction under 12(b)(2).