constitutionally mandated requirement in Florida

2017Importantly, the Supreme Court of Florida has held that “telephonic, electronic, or written communications into -Florida may form the basis for personal jurisdiction under section 48.193(1)(b) 6 if the alleged cause of action arises from the communications,” Wendt, 822 So.2d at 1260 , and that “[t]here is no question that physical ¡presence is not necessarily required to satisfy the constitutionally mandated requirement of minimum contacts,” Id. at 1257-58 .

2017Importantly, the Supreme Court of Florida has held that “telephonic, electronic, or written communications into -Florida may form the basis for personal jurisdiction under section 48.193(1)(b) 6 if the alleged cause of action arises from the communications,” Wendt, 822 So.2d at 1260 , and that “[t]here is no question that physical ¡presence is not necessarily required to satisfy the constitutionally mandated requirement of minimum contacts,” Id. at 1257-58 .

2007See In Interest of L.B.W., 863 So.2d 480, 483 (Fla. 2d DCA 2004) (citing Padgett v. Dep't of Health & Rehab.

2007See In Interest of L.B.W., 863 So.2d 480, 483 (Fla. 2d DCA 2004) (citing Padgett v. Dep’t of Health & Rehab.

2006Citing Burger King Corp. v. Rudzewicz, 471 U.S. 462, 476 , 105 S.Ct. 2174 , 85 L.Ed.2d 528 (1985), the court concluded that communications from outside the state will satisfy minimum contacts so long as the commercial actor's efforts were purposefully directed toward a resident of Florida. 822 So.2d at 1258 .

2006Citing Burger King Corp. v. Rudzewicz, 471 U.S. 462, 476 , 105 S.Ct. 2174 , 85 L.Ed.2d 528 (1985), the court concluded that communications from outside the state will satisfy minimum contacts so long as the commercial actor's efforts were purposefully directed toward a resident of Florida. 822 So.2d at 1258 .

2017In addressing allegations that a non-resident defendant committed a tort in Florida through acts and communications directed into the state from outside Florida, “[t]he appropriate inquiry is whether the tort as alleged occurred in Florida, and not whether the alleged tort actually, occurred.” Machtinger v. Inertial Airline Servs., Inc., 937 So.2d 730, 734 (Fla. 3d DCA 2006).

2013OSI Indus., Inc. v. Carter, 834 So.2d 362, 365 (Fla. 5th DCA 2003) (holding that minimum contacts existed to satisfy due process requirements because “by calling [pjlaintiff in Florida, [the non-resident defendant] knew that his alleged misrepresentations would impact [pjlaintiff in Florida. [The non-resident defendant] knew [pjlaintiff worked in Florida, and thus [non-resident defendant] should have realized that [pjlaintiffs reliance on alleged misrepresentations regarding retirement or pension plans would injure [pjlaintiff in Florida”); see also Wendt, 822 So.2d at 1257-58 (holding that “p

2002See Execu Tech, 752 So.2d at 586 ; see also Burger King Corp. v. Rudzewicz, 471 U.S. 462, 476 , 105 S.Ct. 2174 , 85 L.Ed.2d 528 (1985) ("[W]e have consistently rejected the notion that an absence of physical contacts can defeat personal jurisdiction there.").