JPMorgan Chase Bank, N.A. v. Neovi, Inc., 2006 WL 3803152 (S.D. Ohio Nov. 14, 2006)
In this case involving UCC claims stemming from defendant’s internet-based check service, defendant disputed that it did sufficient business with Ohio residents to subject it to the court’s jurisdiction. The court allowed limited discovery on the issue, and plaintiff propounded a number of interrogatories concerning any business contacts between the defendant and the state of Ohio or Ohio residents. Defendant replied “unknown” to the interrogatories, and stated that its customers were not required to provide address information; however, it failed to state whether any customers, despite not being required to provide their addresses’ or their payees’ addresses, had actually done so, or whether customer or payee addresses were available to defendant in its customer database.