The Judge has denied both David Linhardt's and e360's attempt to dismiss the case on jurisdictional grounds.
I think that this ruling is a bit shaky. I say that because the judge here seems to contemplate that the sending of email is an invitation to be sued in any jurisdiction:
"Under these circumstances, defendants knew or reasonably should have known that their emails would reach individuals located in other states through servers located in other states. It is therefore reasonable to conclude that defendants purposefully availed themselves of the privilege of conducting activities in those other states." (pg. 5)
Usually there is something stronger than "if you send email out on the internet it can go somewhere else" that links the ability of the defendant to ascertain the destination (say, a webpage or a whois record). I'm not sure that this is what normal jurisdictional analysis has in mind.
That's not to say that I don't think that the Court may not be correct in its ruling. Especially if Ferron's assertion that e360 had state codes associated with addresses is correct, then there would be some form of notice that mail was flowing to Ohio. But, this bit of the judge's ruling doesn't address that.