There was no evidence at trial that Auernheimerâ(TM)s actions evinced any contact with New Jersey, much less contact that was âoesubstantial.â The Government has not cited, and we have not found, any case where the locus of the effects, standing by itself, was sufficient to confer constitutionally sound venue./blockquote)
Spitler was in San Francisco, California and Auernheimer was in Fayetteville, Arkansas. The servers that they accessed were physically located in Dallas, Texas and Atlanta, Georgia. Although no evidence was presented regarding the location of the Gawker reporter, it is undisputed that he was not in New Jersey.
He was indicted and tried in NJ, despite none of the involved parties being located there.
If all else fails, lower your standards.